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Drinking Water Regulations and Radiological Testing. Bahman Parsa NJ Department of Health and Senior Services Public Health and Environmental Laboratories Radioanalytical Services. Current Federal Regulations .
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Drinking Water Regulations and Radiological Testing Bahman Parsa NJ Department of Health and Senior Services Public Health and Environmental Laboratories Radioanalytical Services
Current Federal Regulations • Current Regulations were Promulgated in 1976. These are known as National Interim Primary Drinking Water Regulations. • These regulations set a maximum contaminant level (MCL) for gross alpha-particle activity, excluding radon and uranium, of 15 pCi/L in public drinking water supplies.
Current Federal Regulations (continued) • Radium-226 measurement is required when gross alpha-particle activity exceeds 5 pCi/L. • Radium-228 measurement is required when 226Ra concentration exceeds 3 pCi/L. • The MCL for combined 226Ra and 228Ra is 5 pCi/L.
Current New Jersey Regulations • Require gross alpha testing within 48 hours from sample collection to include α-particle emissions due to the presence of224Ra, • Recount samples with gross α over 5 pCi/L 24 hours later to eliminate 222Rn and 220Rn progeny contributions to the gross α-particle assay, • Require both 226Ra and228Ra testing when gross Follow the current Federal regulations, plus: • α-particle activity exceeds 5 pCi/L.
Background Proposed Rules • EPA published a “proposed Rule” in 1991. • In April 21, 2000, EPA published a ‘Notice of Data Availability’ (NODA) Document. • The NODA reiterates EPA recommendation to States and utilities that the gross alpha-particle analysis be performed within 48 to 72 hours after sample collection to capture the contribution of α particles from 224Ra.
New Federal Regulations • The Final Rule for radionuclides came out December 7, 2000 (Federal Register Vol. 65, No. 236, pp 76708-76753) and will be effective from December 8, 2003. • Rules apply to Community Water Systems. • Non-Community Systems (Transient and Non-Transient) are not effected by this Rule.
Summary of the Final Rule • Set a maximum contaminant level goal (MCLG) of zero for all radionuclides. • No change to the gross alpha MCL. This limit is retained at 15 pCi/L, excluding radon and uranium. • Combined 226Ra & 228Ra MCL is retained at 5 pCi/L. • Uranium is regulated for the first time. The MCL is set at 30 μg/L.
Summary (continued) • Monitoring Criteria: Point of Entry (POE), not the Point of Distribution any longer • During 2004-2007, Initial Compliance Monitoring cycle, 4 consecutive quarterly testing for gross α, Ra-226, Ra-228 and uranium is required. • In certain cases, gross α results can be substituted for the required Ra-226 and uranium analyses. • Mandatory 228Ra testing • Sample holding time 6 months unchanged • Radium-224 is a local issue and more occurrence data is needed.
Implementation Guidance for Radionuclides • USEPA draft paper, January 2002, EPA 816-D-00-002 • Allows use of gross alpha measurements for Ra-226 and uranium assessments. • If the gross alpha activity result is less than detection limit, one half of detection limit (i.e., 1.5 pCi/L) is used for Ra-226 and is added to Ra-228 activity to determine radium compliance.
Implementation Guidance for Radionuclides (Cont.) • If the gross α activity is above detection limit, compliance and future monitoring frequency is determined using the whole gross alpha results. • A gross α activity measurement may be substituted for the required uranium testing if the gross α activity is less than or equal to 15 pCi/L. States should assume all the gross α activity is due to uranium. Samples must be tested for U if the gross α activity is greater than 15 pCi/L.
226Ra and 228Ra Measurements • Radium-228 carries a higher health risk. • No correlation with 226Ra as previously thought, and hence... • Measure 228Ra separately. • Combined MCL of 5 pCi/L is still valid.
224Ra • EPA believes that 224Ra is a health concern and is a greater risk factor than previously thought. • Studies in New Jersey indicate a variable 224Ra/228Ra activity ratio, with a maximum of 3 and an average of 1.6. • 224Ra is 8 times less toxic than 228Ra. (It would take 40 pCi/L of 224Ra to equal the health risk of 5 pCi/L of 228Ra).
224Ra (Continued) • The same mitigation strategies would remove all Radium isotopes. • EPA plans to collect additional national occurrence information for 224Ra. • Based on national occurrence data, EPA may need to issue a proposed amendment to the Rule. • No EPA-approved 224Ra procedure as yet • New Jersey method for 224Ra testing
URANIUM • Uranium is regulated for the first time. • Uranium MCL: 30 μg/L, based on kidney toxicity/cancer risk studies and cost benefit studies (cost of regulating vs lowered health risks). • To determine compliance, both uranium mass and activity must be quantified.
Uranium (continued) • If 238U activity is measured isotopically, use its specific activity of 0.3365 pCi/µg to determine the uranium mass. Otherwise, • An appropriate conversion factor should be used. • EPA has recommended different numbers during various times. • Suggest using the more conservative 0.67 pCi/µg ratio
222Rn • Radon is not currently regulated. • EPA has proposed Rule for Radon and published in the Federal Register in 1999. • Proposed 222Rn MCL: 300 pCi/L or alternate MCL of 4,000 pCi/L (Multi-Media Approach). • A separate Radon Rule was anticipated as early as the summer 2001.
Beta Particle & Photon Emitters • CWS designated by States as ‘vulnerable or contaminated’ are only required to comply. • Current MCL of 4 mrem/year, based on the new risk reported in 1991 proposal, is retained. • CWS near nuclear facilities have additional rules to comply.
New Testing Procedures in Progress • Concurrent Determination of 224Ra, 226Ra, and 228Ra by Gamma-ray Spectroscopy (NJDHSS & Georgia Institute of Technology, in EPA approval process as an Alternate Test Procedure) • Simultaneous Determination of Gross Alpha, 224Ra, 226Ra, and 228Ra activities in Water Using a Single Sample Preparation Procedure