TENORM frequently asked questions | Department of Public Health & Environment

General

Where can I find health physics professionals to assist my facility in addressing Part 20 TENORM compliance tasks including TENORM characterization, non-routine maintenance or equipment changeouts, dose assessments, etc.?

Facilities or individuals who are looking for assistance with health physics may contact the Central Rocky Mountain Chapter of the Health Physics society to connect with local health physicists. You may prepare a request for assistance and forward that to the current chapter email account, crmchps@gmail.com and your request will be forwarded to their membership.

Where can I find a copy of Part 20 and its Basis and Purpose document?

Has Addendum A been developed?

Addendum A is now available.

Will you be identifying acceptable protocols to be used for conducting exposure rate and contamination (total and removable) surveys including appropriate instruments and survey methods in the guidance?

Yes, the guidance will provide a general guideline on types of acceptable survey instruments and survey protocols.

What are the environmental regulations that apply to exempt TENORM?

Exempt TENORM means the materials that are exempt from the requirements in Part 20. Such materials are still subject to other applicable Federal, State, or local regulations such as water quality control regulations, mining regulations, Colorado oil and gas conservation commission regulations, solid waste regulations, or hazardous waste regulations.

Does Part 20 apply to septic tanks?

Port-a-potty (e.g., in parks, construction sites, public areas) or grease from the restaurants are not TENORM and not subject to Part 20.
Septic systems associated with households are considered household wastes and exempted from Part 20. Part 20 defines households as single and multiple residences, motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, day use recreation areas.
The department is still evaluating how Part 20 applies to other septic systems for domestic or non-domestic wastewater treatment.

Rule 20.5.2.I states that “[w]hen activities involving such TENORM are permanently ceased at any site, if evidence of residual TENORM is identified, the registrant shall notify the department about such material and may consult with the department as to the appropriateness of sampling and restoration activities to ensure that any contamination or residual TENORM remaining at the site where registered TENORM was used does not exceed the limits in Table 20-1 or is not likely to result in exposures that exceed the limits in Section 4.61.2 of 6 CCR 1007-1 Part 4. Institutional controls may be required if compliance with Table 20-1 or the limits in Section 4.61.2 of 6 CCR 1007-1 Part 4 is not feasible.” What does “residual TENORM” mean?

Residual TENORM means any materials subject to registration.
Residual TENORM does not include those materials that have been land applied in accordance with Part 20 or land disposed of once a disposal facility has completed the closure and termination process.

Registration

How do I register for my TENORM?

Existing TENORM subject to registration should be registered by July 14, 2022.
To register, email all of the information required by Section 20.5.1.B of Part 20 to joel.doebele@state.co.us, along with the department’s SW-846 spreadsheet listing all of the characterization results.

Can I register both water treatment and wastewater treatment under one registration?

Registration will be done by facility/location. If you operate both types of treatment and generate both drinking water residual and wastewater treatment residual in the same facility/location, then both types of operations/materials will be covered under one single registration.

Is a fee required for each location?

Yes, initial registration and annual fees should be paid for each individual facility or location.
For those registrants who have multiple facilities or locations within a single Township, as designated by the United States Bureau of Land Management Public Land Survey System, only one fee for each Township in which registered facilities or locations are located shall be paid.

What is the definition of a “facility”?

Facility is defined in Part 1 of 6 CCR 1007-1 as the location within one building (or vehicle, or under one roof, or at one address) and under the same administrative control (multiple locations or addresses at a site or part of a site are considered together if so approved by the department) at which: (1) the possession, use, processing or storage of radioactive material is or was authorized; (2) a radiation machine is or was installed, operated, repaired and/or stored; and/or (3) a source of radiation is located.

If a facility is required to be registered, when can the facility resample to see if they still need to be registered?

We expect annual verification sample to be taken with the following procedures:
- Take one random sample (either grab or composite) from the material for the laboratory analysis.
- Add the sample result to the SW-846 spreadsheet along with the existing data for data evaluation.

TENORM characterization

How do I report my TENORM data?

For exempt TENORM, characterization data reporting is not required. However, we recommend keeping the characterization results and lab reports in your record.
For registered TENORM, characterization results should be provided to the department as part of the registration.

What field screening technologies and methods can be appropriately used and endorsed by CDPHE for TENORM characterization?

Any field screening methods should be provided to the department for approval.

Where can one find the information related to the background determination?

You may use either the department approved background values or determine site-specific background values.
Department approved background values are:
- Ra-226: 1.4 pCi/g
- Ra-228: 1.3 pCi/g
- Pb-210: 1.4 pCi/g
- Po-210: 1.4 pCi/g
Site-specific background values can be determined by initially taking 6-10 samples from the surface soil, either at the treatment site or the disposal site, and then using the department’s site specific background determination calculator to determine how many more background samples are needed and to calculate the final background value for each isotope.

What do you recommend for seasonal variations in radioactive concentrations in waste material production?

For a waste that has been accumulated over time, the seasonal variation contributes to the natural inhomogeneity in the waste material. The SW-846 method takes this natural inhomogeneity into account when determining the number of samples needed and the upper limit of confidence interval for the radionuclide concentration.
For a waste stream that continues being discharged to the sewer, one could characterize the waste in the season when the radionuclide concentration is at its highest, if there is a significant seasonal variation in the concentration.

We operate hundreds of oil and gas production locations across 10 plus townships. Do I need to sample every location in our operating field by taking 3 to 6 samples at each location? Or, do I make a composite sample for each township of collected sites?

Initial TENORM characterization should be made for each type of materials at each facility/location that might be subject to Part 20, unless a multi-location profiling is approved by the department.
TENORM characterization should start with 3-6 preliminary samples with the sampling results evaluated using the department’s SW-846 calculator.
Township only applies to the registration fee calculation. It does not apply to TENORM characterization.

What would be your guidance for setting up a profile for produced water disposal?

Any proposal of formation-based or multi-location profiling methods for produced water should be provided to the department for approval. Once approved, it will be documented in the guidance.

The guidance talks about re-characterization due to changes in materials accepted or a change in the water treatment process. What would be considered a change?

Re-characterization might be needed when there are changes that might result in change of TENORM classification (e.g., exemption, registration, specific licensing).
For water treatment, potential changes include:
- Change of raw water source with known different TENORM characteristics or unknown TENORM characteristics.
- Changes in the raw water that might result in different TENORM characteristics.
- Changes in the treatment process such as treatment technology, treatment efficiency, or treatment media.
- Changes in waste handling methods such drying of treatment residual prior to disposal.
- Identification of decreasing or increasing trends or outliers in the dataset.

For wastes that are generated periodically, less than one event per year, can historical data be used in the calculator, or would a minimum of 3 samples be required during each event?

If there is a consistent frequency of generation and the materials are expected to be essentially the same, you may use the historical data to make the initial TENORM determination and then collect data on this new "batch" when it is generated to verify that the materials are the same. If that data suggests that the materials are not consistent then you would have to sample completely each time.

Should wastewater treatment facilities characterize their bar screens, grit, or intermediate process solids?

The wastewater treatment facility does not need to characterize bar screens for TENORM. The department has determined that bar screens are not TENORM and not subject to Part 20.
No characterization is required for grit if the wastewater treatment facility does not accept any non-exempt TENORM.
Characterization is needed for grit if the wastewater treatment facility does accept non-exempt TENORM. Characterization may be done by any of the following methods:
- The standard SW-846 method (i.e., 3 – 6 preliminary samples and use the department’s SW-846 calculator), or
- Calculate the radium concentration in the grit based on the amount of non-exempt TENORM accepted, characterization data of radium provided by the generators, and the amount of grit generated at the wastewater treatment facility.
Intermediate process solids from cleaning out of tanks, basins, ditches, equipment, etc., should be characterized for TENORM. The characterization should be done when cleanouts are collected for disposal. The facility may combine all cleanouts from the different tank/basin/ditch/equipment within the sample facility prior to characterization.

We have a reclaim water facility used to treat some of the wastewater for irrigation purposes and the reclaim water facility is just an extension of the wastewater plant. The backwash from the reclaim water facility is piped back to the headworks of our own wastewater treatment plant. Do we need to characterize the backwash for TENORM?

No, if the backwash is piped back to the same wastewater treatment plant.
Characterization is needed when the backwash waste is collected for disposal or beneficial use off-site.

If we have scrap metal that does not have scale or any indication of the presence of TENORM, can we
recycle it without sampling?

No, visual observation may not be effective.
Oil and gas waste pipes should be characterized by measuring the radiation dose rate on contact with both the exterior surface accessible interior surface of the pipes. For natural gas pipes, one also needs to measure the level of non-fixed alpha contamination of the accessible interior surface in addition to radiation dose rate measurements.
The department is developing a guidance for pipe characterization.

There are requirements in Part 20 for oil piping and additional (internal wipe test) for gas piping. Some operator lines are oil and gas. Is the expectation that we conduct both external and internal screening for our pipe?

No, surface contamination surveys described in 20.4.5.C are required for those pipes exclusively used for natural gas transfer and processing.

Laboratory analysis

Is there a list of approved methods for analysis?

See Table A.1.2 of Addendum A of the guidance for the current listing of recognized laboratory methods for TENORM samples by the department.
Gamma spectroscopy for direct Ra-226 should not be used for the material with both uranium and radium present.
Please email the list of other methods to shiya.wang@state.co.us for approval.

Does CDPHE have a preference on how a non-detect (ND) result should be reported?

If the laboratory reports a value less than the detection limit, use the reported value.
If the laboratory reports “ND” without any numerical value, use one of the following options but the select option needs to be used consistently across the dataset:
- Option 1: do not use this data point.
- Option 2: use half of the detection limit as the reported value.

The guidance talks about re-characterization due to changes in materials accepted or a change in the water treatment process. What would be considered a change?

Re-characterization might be needed when there are changes that might result in change of TENORM classification (e.g., exemption, registration, specific licensing).
For water treatment, potential changes include:
- Change of raw water source with known different TENORM characteristics or unknown TENORM characteristics
- Changes in the raw water that might result in different TENORM characteristics
- Changes in the treatment process such as treatment technology, treatment efficiency, or treatment media
- Changes in waste handling methods such drying of treatment residual prior to disposal
- Identification of decreasing or increasing trends or outliers in the dataset

For wastes that are generated periodically, less than one event per year, can historical data be used in the calculator, or would a minimum of 3 samples be required during each event?

If there is a consistent frequency of generation and the materials are expected to be essentially the same, you may use the historical data to make the initial TENORM determination and then collect data on this new "batch" when it is generated to verify that the materials are the same. If that data suggests that the materials are not consistent then you would have to sample completely each time.

Do we need to analyze our samples for all four TENORM radionuclides?

Not necessarily. For the purpose of making TENORM determination and demonstrating compliance with Part 20, you may only analyze your material based on the following industry-specific radionuclide list:
- Drinking water treatment, mine water treatment: Ra-226, Ra-228.
- Wastewater treatment, land application, composting: Ra-226, Ra-228. If accepting any materials with known Pb-210 or Po-210 exceeding Ra-226, then also test for Pb-210 or Po-210.
- Other industrial wastewater treatment: Ra-226, Ra-228, Pb-210, Po-210. Depending on the process knowledge, one or more radionuclides may be eliminated from testing after consulting with the department.
- Oil and gas operation – pigging wastes or other natural gas processing or handling wastes: Pb-210, Po-210.
- Oil and gas operation – produced water, tank bottoms, filter socks, or others: Ra-226, Ra-228.
- Other TENORM: Ra-226, Ra-228, Pb-210, Po-210. Depending on the process knowledge, one or more radionuclides may be eliminated from testing after consulting with the department.

How should I convert the liquid sample results to the dry weight concentration?

One should first make sure that the laboratory does not filter or remove any solids from the sample during the analytical process.
Get the following results from the laboratory report of the liquid sample: radionuclide concentration (pCi/L), TDS (g/L), and TSS (g/L)
Use the following equation to convert the concentration in pCi/L to the dry weight concentration in pCi/g:

Concentration (pCi/g) = Concentration (pCi/L) / (TDS + TSS, in g/L).

For a gamma spec analysis (method 901.1) what ingrowth time is required? The interim guidance indicated lab results could take a month, which implied 21-day (equilibrium) ingrowth was expected. Is that still the case? And, does that vary based on matrix? For example, one lab says they can only do instantaneous 901.1 (less than a day ingrowth) for wastewater samples. Is that acceptable or do wastewater samples need 21-day (equilibrium) ingrowth also? If required ingrowth based on matrix varies, please provide us with info relating matrix to required ingrowth time.

We still expect people to follow the standard ingrowth time required for each method such as the 21-day ingrowth for Ra-226 using EPA 901.1, which would include wastewater samples. I think for any variation to this, we would treat it as a case-by-case determination. When you talk to the lab and if they suggest a different ingrowth time for certain matrix, certain situations, or certain samples, we can take a look if you and/or the lab can provide more information on the situations or reasoning. We have also heard that 5-day ingrowth might be good enough based on certain large data set some stakeholder had. I think we would have to look at the specific data set and determine whether it's acceptable case-by-case.

The regulation recommends that we use certain methods to run the analysis for TENORM analytes, but does the lab who runs the analysis have to be certified for that method in order for the results to be approved? Lots of labs run methods that are certified methods but the lab isn't certified to run all the methods they run.

Choose a lab with National Environmental Laboratory Accreditation Program (NELAP) certification or equivalent.
Use the methods recognized in Table A.1.2 of Addendum A of our guidance.
See Chapter A.1.5.1 of Addendum A for additional guidance on selecting labs.

Sampling

Will there be guidance on the type of sampling (grab/composite) for initial characterization and on-going analysis?

TENORM characterization should start with 3-6 preliminary samples, which could be either 3-6 grab samples or 3-6 composite samples.
The key is that the SW-846 calculator needs multiple data points to evaluate the variation between the data points. One single composite sample (regardless how many individual samples are combined into a composite sample) is not enough for the SW-846 calculation.
The guidance will include the above information.

Do the 3-6 samples need to be taken in a certain time period? Can we use historical data?

There is no particular time period required for sampling. However, existing TENORM should be properly characterized for compliance with Part 20 by July 14, 2022.
Historical data may be used if there has not been changes in the process or material.

All sample results can come back < 5 pCi/g but the variance between them may be large enough to trigger the requirement of more samples. How do I handle this situation?

One should use the department’s SW-846 calculator to determine how many samples are needed to adequately characterize a material.
If the number of samples determined by the SW-846 calculator is unreasonably high, contact shiya.wang@state.co.us for a case-by-case evaluation.

Do I need to sample my material for gross alpha and gross beta?

Not for the purpose of complying with Part 20. You may need to sample your material for gross alpha or gross beta if required by other regulations.

When we perform a separator or tank bottom clean out, there is generally relatively little waste that is extracted. Is it ok to combine the waste from several separator clean outs or several tank bottom clean outs into one composite sample for TENORM testing and subsequent disposal?

Cleanouts within the same facility/location may be combined into one waste for TENORM characterization. TENORM characterization should start with 3-6 preliminary samples, which could be either 3-6 grab samples or 3-6 composite samples.

Does Part 20 require the generators submit the sampling plans for approval?

Our site uses providers' wastewater biosolids to make compost. The providers will be needing to do the sampling before shipment to our site, will we also need to be doing the sampling again before we land apply?

You may use the generators’ characterization data for acceptance of TENORM. However, if your facility further processes the material, additional samplings may be required. For example, Section 20.7.3.D requires final composts to be characterized for TENORM prior to sale or distribution. Section 20.7.1.D or 20.7.2.D also requires biosolids or water treatment residuals to be characterized for TENORM after treatment or prior to land application.

Can injection wells rely on customer data for produced water characterization?

Yes, you may use the generators’ characterization data for acceptance of TENORM. However, if your facility further processes the material prior to disposal, additional samplings may be required.

Exemption

It states in the guidance that you only need to analyze for radionuclides specific to operation generating TENORM. However, this is not explicitly stated in the rule. For waste water and biosolid application, can we only analyze for Radium 226 and 228 and still be in compliance? Or do we need to do initial characterization to show exemption from Lead-210 and Polonium-210?

You only need to analyze for Ra-226 and Ra-228. You do not need to test your material for Pb-210 and Po-210 to demonstrate exemption. One exception is that if you accept a material for treatment from a generator and that material has known Pb-210 and Po-210 concentrations exceeding the Ra-226 concentration, then you will need to test your material for Pb-210 and Po-210.

For land application of biosolids, there is no requirement to sample the fields for TENORM, right?

Correct.

If a material has been determined to be exempt, is there a required sampling frequency to maintain this exemption?

No periodic verification sampling is required for exempt TENORM, unless there is or might be a change in the material or process that will result in change of TENORM classification (e.g., exemption, registration, specific licensing).

Training

For biosolids land application, will we have to conduct training for the land owners/farmers who have access to fields where biosolids are applied?

No, you are not required to provide trainings to land owners/farmers.

Do we need to provide training to our water plant staff if they are not the workers handling the materials, but are on site during the handling?

A basic radiation awareness training should be provided for the water plant staff who will be working in the general vicinity of the registered TENORM.

What will be the minimum training requirements e.g., subjects to be covered, minimum time allotment (hrs) for (a) general TENORM awareness training for workers who handle and/or otherwise work around non-exempt TENORM impacted materials and (2) workers assigned with responsibilities to conduct radiological surveys, interpret results and initiate actions accordingly?

All persons subject to registration should meet the training requirements in Section 20.5.3 of Part 20, including the topics to be covered in the training and the training frequency. The extent of the training should be commensurate with potential radiological health effects associated with job duties.
General TENORM awareness trainings normally include the following topics:
- Radiation
- Definition and description of NORM and TENORM
- Biological effects due to radiation
- Basic safety
- Applicable rules and regulations
- Site, industry or job specific hazards and incident response information
Additional trainings should be provided to those workers assigned with responsibilities to conduct radiological surveys or interpret results, with the following topics:
- Radiation detection
- Equipment operation
- Mathematics related to units and conversions
Training provided in other states will be acceptable only for general radiation safety topics.

Disposal

What steps must be followed if TENORM materials need to be disposed, prior to the January 14, 2022 effective date?

Generators should continue the same disposal methods until a TENORM determination is made in accordance with Part 20.
Once a TENORM determination is made,
- Part 20 allows all landfills to accept exempted TENORM.
- If the material is subject to registration, it should be registered by July 14, 2022. It should be disposed at a facility that is permitted to accept such material. See a list of Colorado disposal facilities currently approved to accept TENORM for disposal.

If a private party land-applies drinking water treatment residuals containing non-exempt concentrations of TENORM (between 5 – 25 pCi/) on its own land (which is not a sanitary landfill or municipal solid waste landfill) pursuant to the “one’s own waste on one’s own property” exemption, will the Division regulate the facility as an “other” facility under Regulation 20.9? Can the Division confirm that such land application would not be regulated under Rule 20.8?

Yes and yes.

Our understanding of Section 20.5.2 (P) of Part 20 is that it requires radionuclide monitoring only if monitoring is required by the Solid Waste Regulations. Since Section 9 of the Solid Waste Regulations does not require groundwater monitoring of water treatment plant coagulant sludge impoundments (Type A impoundments), such groundwater monitoring is also not required by the TENORM regulations. Is this understanding correct?

Yes. However, if there was cause for concern regarding mobility of TENORM in the environment as a result of the registrant activities, we could require monitoring as per Section 20.3.4 of Part 20. Again, this would only be in the case that the department made a decision that there was a radiological danger to public health and safety, workers, or property.

Beneficial Use

Can the Division confirm that land application of water treatment residuals is not subject to the final closure requirements for composting facilities (Rule 20.7.3)? Rule 20.7.2.D.4 requires registrants to only provide notice to the department 60 days prior to ceasing land application activities at the site; if a party provides such notice and terminates registration, but undertakes no other closure activity, the Division would not consider the TENORM to have been “abandoned” (as prohibited under Rule 20.5.2), correct?

Yes and correct. Land application is an authorized method of beneficial use and is not considered abandonment of material when performed in accord with 20.7.2.

TENORM regulations state that any person subject to registration “[s]hall secure registered materials from unauthorized removal or access, with the exception of those materials land applied for beneficial use in accordance with this Part.“ Rule 20.5.2.B. Can the Division expand upon the intent of this provision, and can the Division confirm that this would apply to beneficial uses of water treatment residuals?

The intent of 20.5.2.B is to prevent people from knowingly or unknowingly acquiring possession of registered TENORM that could lead to hazards to members of the pubic.
The exception in 20.5.2.B applies to land application of both biosolids and water treatment residuals.

Can the Division confirm that drinking water treatment residuals land applied and regulated under Rule 20.7 would not be subject to an environmental use restriction/covenant on the basis of TENORM?

Yes, this is correct.

Rules 20.7.1.C.2 and 20.7.2.C.2 set forth two restrictions on beneficial uses: (1) concentrations cannot exceed 25 pCi/g (for Ra-226, Ra-228, Pb-210, Po-210), and (2) biosolids and WTP residuals cannot be land-applied for more than 20 years/20 crop cycles. Can the Division confirm that these are two conjunctive restrictions (i.e., residuals must be 5-25 pCi/g, and such residuals can’t be land-applied for more than 20 years)?

Yes, both conditions have to be met.

Under Rules 20.7.1.C.2 and 20.7.2.C.2, can the Division confirm that there could be multiple beneficial use “sites” on a property – so, for example, a party could divide land into 4 “sites” and conduct beneficial use for 80 years?

Yes. If a site is subdivided to multiple subsections for land application, information regarding each subsection and the number of applications on each subsection should be provided as part of the annual reporting per 20.7.1.E or 20.7.2.E.

Rule 20.7.2 state that beneficial use activities “shall be in accord with a Beneficial Use Certification or Beneficial Use Determination issued by the [Division],” but it doesn’t indicate whether the Division will attach new conditions to the beneficial use certification/determination solely based on the residuals containing TENORM. Will non-exempt TENORM concentrations between 5 – 25 pCi/g be subject to any additional conditions or restrictions?

Additional conditions or restrictions may be added to the beneficial use certification or beneficial use determination to reference the applicable requirements in Part 20.

Is road spreading of oil and gas waste product, for example for dust suppression or de-icing, subject to 20.7.2 (beneficial use)?

Road spreading of E&P wastes: subject to Section 20.9.2 of Part 20.
Road spreading of solid wastes: subject to Section 20.7.4 of Part 20 and approved by both Radiation Control Program (dose assessment) and Solid Waste Program (beneficial use certification or beneficial use determination) of the department.