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Colorado Radionuclide Abatement and Disposal Strategy
(CO-RADS)

Compliance Options
and
Technical Guidance

The purpose of this page is to provide an accessible electronic library of all guidance and reference documents developed through the CO-RADS project. As new material and information becomes available, this page will be updated to provide the most current information on compliance options and other technical issues associated with radionuclides in drinking water.

Compliance Options Guidance

There are a number of options available to resolve radionuclide violations, however there are many considerations associated with each of these options.  Ultimately, identifying a viable option for a system can be an extreme challenge.

The U.S. Environmental Protection Agency has a number of documents available online that will offer general guidance on various compliance options.

Colorado specific guidance on many issues of concern can be found below.

CO-RADS Phase 3 Treatment and Disposal Evaluations

The Phase 3 summary report developed by Malcolm Pirnie, Inc. shows that traditional treatment and disposal methods for radionuclide compliance can be extremely costly.  Readers should be aware that there were limitations in  certain areas of these evaluations, such as non-treatment options like blending or consolidation, or certain waste handling options such as discharges to wastewater treatment facilities – for additional information on these impacts, please see the presentation materials for the first Phase 4 regional meeting.

Phase 3 Treatment and Disposal Evaluation Summary Report

• Executive Summary 
• Phase 3 Summary Report 
• Appendix A CO-RADS System Information 
• Appendix B Radionuclide Risk Assessment and Analysis 
• Appendix C Interim Measures and Point of Use 
• Appendix D Water Sampling and Travel Plan 
• Appendix E Feasible Technology Memo 
• Appendix F Worker Exposure Modeling Memo 
• Appendix G Bench and Pilot Testing Plan 
• Appendix H POU Workshop Slide 
• Appendix I Draft Non-Treatment Options Matrix 
• Appendix J Final Bench and Pilot Testing Report  
• Appendix K Additional Info Provided in CORADS Reports 
• Appendix L EPA Cost Estimates 
• Appendix M CORADS Impact on Rates Analysis 
• Appendix N Evaporation Basin and Labor Costs 
• Appendix O Updated Liquid Residuals Flowchart 
• Appendix P Final Residuals Sampling Results 

Additional Guidance for Treatment, Disposal, and Alternative Compliance Approaches

In light of the high costs for traditional approaches identified in Phase 3, the Water Quality Control Division will continue to work with systems and waste handling agencies in Phase 4 to develop more cost effective alternatives.

• Guidelines for preliminary engineering report or request for extension 
• Other treatment/compliance options to consider 
• Example alternative evaluations  
• Point-of-Use Treatment 
• How to hire an engineer  

Waste Management and Disposal

Waste streams generated by radionuclide removal processes may fall under the regulatory jurisdiction of multiple program areas within the department, including the Solid Waste, Radiation Management, and Wastewater Permitting Programs.  EPA and local health departments may also have jurisdiction over certain waste handling practices.  On average, 60 percent of the capital costs estimated in Phase 3 were associated with waste handling basins.  For some systems, these basins made up more than 80 percent of estimated capital costs.  Alternative disposal options or basin design could provide significant savings.  However, it is challenging to identify and address all associated waste handling requirements.  The following documents should provide further guidance on this issue.
 

• Interim policy and guidance pending rulemaking for control and disposition of technologically-enhanced naturally occurring radioactive materials in Colorado  
• Waste disposal options flowchart  
• Waste disposal contact information  

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Compliance Options Guidance

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