TENORM frequently asked questions

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 shiya.wang@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.

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. 

Is there a list of approved methods for analysis?

  • Current list of the approved laboratory methods:
    • Ra-226: EPA 901.1M, EPA 903.1.
    • Ra-228: EPA 901.1M, EPA 904.0M, EPA 9320.
    • Po-210: HASL 300.
    • Pb-210: EPA 901.1M, GFPC Enrichom Pb.
  • See Slide #43 of our Nov. 4, 2020 stakeholder meeting presentation for more information on these methods including sample size, typical turnaround time, and minimum detection limits. 
  • 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. 

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.

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. 

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. 

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

  • Correct. 

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.

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.

Has Addendum A been developed?

  • The department continues developing the guidance including the Addendum A.
  • Draft guidance will be posted on the guidance development webpage once available.