ORIGINAL

BEFORE THE POLLUTION CONTROL BOARD

OF THE STATE OF ILLiNOIS

DEC 08 2004

IN THE MATTER OF:

)

POUUt~~?~d

REVISIONS TO RADIUM WATER

)

QUALITY STANDARDS: PROPOSED

)

R04-21

(‘~ ~

NEW

35

ILL. ADM1N. CODE 302.307

)

Rulemaking

-

Water

AND AMENDMENTS TO

35

ILL. ADMIN.

)

CODE 302.207 AND

302.525

)

NOTICE OF FILING

To:

See Attached Service List

Please take notice that on December 8, 2004, we filed with the Office ofthe Clerk ofthe

Illinois Pollution Control Board an original and ten copies of the attached

COMMENTS

SUBMITTED BY

THEODORE ADAMS, BRL4NANDERSONAND CHARLES WILLIAMS,

a copy ofwhich is served upon you.

Respectfully submitted,

WATER

DIATION TECHNOLOGY, LLC

By:

One

C7j

i Attorneys

Jeffrey C. Fort

Letissa Carver Reid

Sonnenschein Nath & Rosenthal LLP

8000 Sears Tower

Chicago, Illinois 60606

(312) 876-8000

THIS FILING IS BEING SUBMITTED ON RECYCLED PAPER

---

R04-21

Dorothy Gunn

Clerk ofthe Board

Illinois Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago, IL 60601

Amy Antoniolli

Hearing Officer

Illinois Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago, IL 60601

Deborah J. Williams

Stefanie N. Diers

Illinois Environmental ProtectiOnAgency

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

Joel J. Stemstein, Assistant Attorney General

Matthew J. Dunn, Division Chief

Office ofthe Illinois Attorney General

Environmental Bureau

188 West Randolph

20th

Floor

Chicago, IL 60601

Stanley Yonkauski

Acting General Counsel

Illinois Department ofNatural Resources

One Natural Resources Way

Springfield, IL 62701

Richard Lanyon

Metropolitan Water Reclamation District

100 East Erie Street

Chicago, IL 60611

Roy M. Harsch

Sasha M. Engle

Gardner Carton & Douglas

191 North Wacker Drive

Suite 3700

Chicago, IL 60606-1698

Claire A. Manning

Posegate & Denes

111 North Sixth Street

Springfield, IL 62701

Lisa Frede

CICI

2250 East Devon Avenue

Suite 239

Des Plaines, IL 60018

William Seith

Total Environmental Solutions

631 East Butterfield Road

Suite 315

Lombard, IL 60148

Albert F. Ettinger

Environmental Law and Policy Center

35 East Wacker Drive

Suite 1300

Chicago, IL 60601

John McMahon

Wilkie & McMahon

8 East Main Street

Champaign, IL 61820

Dennis L. Duffield

CityofJoliet

Department ofPublic Works and Utilities

921 East Washington Street

Joliet, IL 60431

Abdul Khalique

Metropolitan Water Reclamation District of

Greater Chicago

6001 West Pershing Road

Cicero, IL 60804

---

ORIGINAL

CLERK’S OFRCE

T. G. ADAMS and ASSOCIATES, INC.

DEC 0

11

West Main

Street

2004

Springville, NY 14141

~Sf~TE

00F

ILLINOIS

(716) 592-3431 FAX (716)

592-3439

0 U

~Ofl ontrol Board

December

7,

2004

A. Antoniolli

Illinois Pollution Control Board

State ofIllinois

Suite 11-500

100 W.Randolph

Chicago, IL 60601

Dear Hearing Officer Antoniolli,

I have been in attendance at the hearings on August 24, and October 21 and 22. Ihave also

reviewedthe prior testimony and the documents submitted by the Agency, the City ofJoliet and

the Metropolitan water reclamation District of Greater Chicago. Based on that review, I believe

that there are several misunderstandings about radiation generally, and particularly the potential

effects and exposure ofradium in sludge.

The potency of radium particles and their behavior in POTWs

There appears to be a general lack ofunderstanding about the toxicity ofradium particles that are

formed from the treatment ofnaturally occurring radium materials. These materials

--

known as

Technically Enhanced Naturally Occurring Radioactive Materials orTENORM

-

are not the

same as they occur naturally. When the NORM are treated, such as with the HMO process, they

become concentrated radiumparticles. These are the kind ofparticles that led to the clean-up

costs in Ohio and Pennsylvaniathat I discussed in my August testimony. These are the kind of

particles that the NRC and subsequently the NRC-agreement states such as Illinois banned

from being placed into POTWs through the investigations and rulemaking activities Ihave

discussed in my testimony and exhibits.

As an example, the concentration ofradium on a particle from an HMO process likely is in the

range of 10,000 pCi/g, to 70,000 pCi/g. These particulates will be in the sludge that is placed on

the farm field, the parks and other public area where the sludge is used as a fertilizer. A small

amount ofthese particles on a chikfs face or arm could produce as much as 320 mRem dose to

that area in a 6-hour period. Every time the child goes out to play in the yard/field he/she is able

to pick up these high activity radium particulates and be exposed to unnecessary and unwanted

risks to skin cancer and lesions.

The exposure would be greater if the particle were ingested or inhaled. Ifa child ingested 2

grams ofthese particles he/she could be exposed to 350 mRem, which is

3.5

times the NRC

allowable exposure to the public (100 mRemlyr), but obtained in Only one exposure event. See

Attachment 1 to this comment.

---

Comments on the supplemental documentation submitted

by

the City of Joliet

These documents maybe the reports relied upon by Dennis Duffield during his testimony on

October 22. However, the reports are very fragmentary and do not appear to match, in at least

one instance, the reports that he promised to provide. We have numerous questions about these

documents, both as to their bases, their scientific acceptability and their completeness. The

document appearing at Tab 3 regarding the Westside Treatment Plant does not appear to be the

report on worker safety Mr. Duffleld described in his testimony; it appears to relate to surveys

and sampling ofthe WRT pilot plant and the Westside Treatment Plant. The report at Tab 4

ostensibly dealing with risks from exposure to soils that had been land-applied has several

inaccuracies, and it does not disclose the basis for the input assumptions. Those inputs are quite

different from those used by ISCORS analysis. And the analysis is cut offafter 7 years

-

ostensibly because the resident will move in that period oftime. But dermal exposure to high

activity radium particles, such as digging in a garden orplaying in a sludge augmented

field/yard, as well as ingestion exposures, do not appear to have been taken into account.

My comments on the 4 documents are presented in Attachment 2. The relevance ofthese

documents to this matter would have been much more clear had theybeen produced during the

October hearings, allowing questions to be asked. Nothing in them causes me to believe that my

prior testimony was not accurate for the issues addressed. And none ofthese documents address

the effects ofTENORM and exposures to particles ofhigh radium activity.

Inaccuracies and observations relating to the documents-submitted-by Illinois EPA

At the August 24 hearing, IEPA presented three documents that were marked as exhibits. No

one from the Agency testified in support ofthose documents. I was expecting an opportunity to

explore those documents since theyincluded some clear errors in calculations~Instead, we found

that the one conclusion potentially relating to water quality was done by someone no longer with

the Agency and no one at the Agency could vouch for his calculations calculations which during

the August hearing I stated my disagreement.

With respect to the issues raised by Tab 4 submitted by Joliet, and the assertions included in the

Agency’s document Exhibit 11, Ihave noted several inconsistencies that are troubling.

First, I was surprised to find that therewas a substantial amount ofradiation unaccounted for

between the total levels documented by IEPA’s Exhibit 11, and the calculations done by Dr Port

Joliet, Tab 4. Approximately .2 Curie per year is missing. That is a very large amount of

radiation, about half ofthe level that created a major problem in the North-East Ohio Regional

Sanitary District POTW. See Attachment 3 to this comment

Second, it appears that the Agency’s calculations on the amount of acreage that Joliet should use

to apply its sludge is 3 times greater than represented by the Agency.

Those calculations and their bases are in Attachment 4 to this comment.

Third, it appears that with the actual sludge levels sampled by the City ofJoljet, that the

Westside plant does not meet the 0.1 pCi/g standard contained in the IDNS/IEPA memorandum

ofagreement. Instead it appears that the sludge levels require twice as much land to meet the

IDNS standard. Interestingly, the East Side plant

-

which has sludge levels ofless 18 pCi/g does

2

---

meet the IDNS standard; it maybe that at the current application rates allowed by JEPA that any

sludge with levels over about 25 pCilgwill exceed the 0.lpCiIg standard. See calculations in

Attachment

5

to this comment.

Finally, I examined the effect on sludge levels ofa

5

pCi/l concentration in the wastewater

entering the Joliet treatment plants. Those calculations indicate that if the ONLY material

incoming is compliant with the drinking water standard of

5

pCi/I, that the sludge will barely

meet the 0.1 pCi/g limit in the IDNS-IEPA agreement. See Attachment 6. This would confirm

that the filtrate from treating the groundwater for Joliet should not be discharged into the POTW,

and certainly could not if the watertreatment plant were licensed. Obviously, I believe that is

the prudent engineering choice to make, forreasons completely apart from the relationship

between the maximum allowable federal drinking water level, and the IDNS-IEPA soil

application rule.

Further

comments on the BDAC approach

There was not time to respond to the comments at the last hearing about the alleged conservatism

ofthe BDAC approach. Dr Anderson has explained why the approach is not conservative from

an ecological perspective. I have used the BDAC approach to give an example ofwhat a water

quality standard might be based on the formulas included there.

Since that last hearing I did one further calculation that I wanted to share. I applied the BDAC

formula to the conditions at the lakes in Florida to see how it worked. I found that the Florida

situation passed the BDAC screening criteria. Then I calculated the actual radioactive dose, and

found that the actual radioactive dose in that situation exceeded the 1.0 Rad/day dose required by

the DOE order. From this I must conclude that the BDAC methodology is not perfect in

equating environmental conditions to the DOE standard, and that it may give a false sense of re-

assurance. These calculations are included as Attachment 7.

Feedback from NEORSD and KJSKJ POTW Representatives

As part ofmy evaluation ofthe impacts to POTWs from insoluble radioactive particulates

discharged to the sewers/drains, I contacted two ofmy clients who have been the recipients of

‘htdioactive solid~’placedinto theirsewers. I contacted Mr. Robert Kossack; Directorofthe

KISKI Valley Water Pollution Control Authority (KVWPCA) on what was his opinion of

allowing radioactive particles to be released to the sanitary sewer/drains. His response was an

emphatic’NOT A GOOD IDEA!’ (Approximately 10 years ago, the KWVPCA ended up with a

lagoon full ofuranium contaminated ash as a result of an NRC licensee discharging allowable

quantities ofinsoluble uranium down the sewer and into the POTW. The issue has still not been

resolved).

Mr. Kossack then went on to say that following his experience with the contaminated ash, the

KVWPCA took immediate action under their Pretreatment Permit Program and instituted a’No

Radioactive Solids Down the Sewe~’requirementon the NRC licensee. Rather thancomply with

the permit condition, the licensee disposed oftheir uranium material offsite.

3

---

I also contacted Mr. Thomas Lenhart from the Northeast Ohio Regional Sewer District

(NEORSD). In 1991 the NEORSD discovered cobalt-60 contaminated ash on their Easterly

Plant property and their Southerly Plant Property and dewatering lagoons. Remediation costs

have exceeded $2M to date and the NEORSD is now required to be an Ohio Radioactive

Materials Licensee.

Mr. Lenhart responded to my question by stating”llie total amount ofCo-60 in terms ofphysical

quantity was a tiny fraction of an ounce, only a gram ortwo. This gram or two ofmaterial was

mixed in hundreds oftons ofash and yet still posed a regulatory issue due to hot spots resulting

from the cobalt high activity.. NEORSD has to date spent approximately $2M addressing the

resulting issues~’

He continued by stating,’The studies (ISCORS) suggest that while neither man-made

radionuclides norNORM are usually a problem for the POTWs, in certain circumstances levels

ofactivity can be ofregulatory concern, as happened at NEORSD. Furthermore, the cost of

contaminating a POTW, even at extremely low levels, can be well into the millions~’

Regarding watertreatment technologies, Mr. Lenhart stated,’1 do not endorse any particular

technology or process. However, where there are inexpensive and effective processes available

to avoid the disposal ofradioactive materials into sanitary sewers, these processes or

technologies should be considered~’

Based on the responses from these POTWrepresentatives who have experienced the financial

impacts, potential liabilities, and concern over worker and public safety, the allowing ofthe

discharge ofradioactive particulates down the sewers by the JEPA/IBMA is inappropriate.

Conclusion

It appears that the IEPA is not conversant with the kinds ofissues raised by control ofradiation.

Moreover, the NRC and the agreement states have had experience with the very issue that

Illinois is confronting in this proceeding. I believe that what is done with the radium AFTER it

is removed from the drinking water supply is very important and should not be trivialized. I urge

Illinois to learn from what the NRC and other POTWs have learned. I urge Illinois to keep

radioactive solids out of sanitary sewers and to not dispose ofradium filtrate by putting it back

into the environment.

Sincerely,

c

Theodore G. Adams

4

---

CALCULATION OF DOSE TO

SKIN

ATTACHMENT 1: DOSE FROM DISCRETE RADIUM PARTICULATES

There are a number ofbest available and small system compliance treatment technologies

available for removal ofradionuclides (radium in our case) from drinking water. These

technologies include, but are not limited to:

Ion Exchange (IX)

Reverse Osmosis (RO)

Lime Softening

Hydrous Manganese Oxide (HMO)

Some ofthe treatment technologies produce a relatively soluble radium effluent, while others

like HMO produce a solid radium (i.e., spent resin) or particulate residual.

The Hydrous Manganese Oxide (HMO) treatment process produces two types of residuals:

Liquid

-

spent filter backwash water (contains high activity radium particulates and

co-occurring contaminants)

Solid

-

spent filter media (contains radium and co-occurring contaminants and

sludge)

It is the generation ofthe high activity radium particulates in the HMO spent filter backwash, the

JEPA approved release oftheir particulates into the sanitarysewer/POTW plants, and the

ultimate further concentration of high activity in the POTW sludge which is subsequently

applied to local farmland as fertilization that is the greatest concern. Based on available process

information, radium particles from the HMO process can range from 16,000

-

70,000 pCi/g (see

attached memo from John Litz to Charles Williams)

Discrete radium particulates of this kind, with radium levels on solids of 1 0,000pCi/g to 70,000

pCilg

present a unique concern when they are part ofsludge applied to a local farm, park,

playground as fertilizer/soil augmentation.

Discrete Radioactive Particles (DRPs) orhot particles are a major concern in nuclear power

plants. Radiation protection procedures/programs have been-developed-to-address DRPs. A

large amount of effort by both the National Council on Radiation Protection and Measurement

(NCRP), the Nuclear Regulatory Commission (NRC), and other independent researchers have

been expended in evaluating the overall human health effects (i.e., skin cancers) due to the

exposure to these hot particles.

To gain an understanding ofthe potential dose impacts to individuals (i.e., children playing in

fields, parks where sludge containing high activity radium particulates was applied) who might

obtain several ofradium particulates on their skin, a dose calculation was performed.

Details of the input, assumptions, and results ofthe calculation is presented in Calculation #6.

WRTOO9.wpd

IT. G.

ADAMS AND ASSOCIATES, INC.,

12)07104

-

Page 1

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CALCULATION OF DOSE TO

SKIN

FROM DISCRETE RADIUM PARTICULATES

The methodology for calculating the skin dose to the individual is provided.

WRTOO9.wpd IT. G. ADAMS AND ASSOCIATES, INC., 12107104

Page 2

---

Given:

Particle Activity:

Exposure Area:

Skin Thickness:

Skin Dose Rate Factor* for Radium-226:

Exposure Time:

Activity:

Distribution:

70,000 pCi/g

410mg/cmcm2 2 (child’s neck, arm, face)

or

5.9

6 Hours0.25x

10~RemlhrSv/yrperper

jtCi/cmBq/cm22

Child playing in soil augmented with

radium particulates containing 70,000 pCi/g

3 grams ofsoil containing 70,000 pCi/g

or 210,000 pCi or 0.21 ~tCion skin

=

Hot Particle Skin Dose (Rem)

=

Particle activity (~iCi)

=

Skin Dose Factor (Rem/hrper j.tCi/cm2)

=

Residence Time on Skin (hr)

=

Area over which the dose is averaged (cm2)

D

=

ADFt/s

==

0.03

0.21

Rem

jiCi xO.25Rem/hr4tCi/cm

or 30 mRem per occurrence/event

2 x 6hrs/lOcm2

Where:

D

A

DF

t

5

*

Health Physics, 53 Pages, 138-141, Kocher & Eckerman, 1987, Pergamon Journals,

Limited

WRTOO9.wpd

IT. G.

ADAMS ANDASSOCIATES, INC., 12)07/04

Page 3

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(continued)

Prior to April

5,

2002, the hot particle skin exposure was averaged over 1 cm2 of the skin. Prior

to this date, the NRC requested the NCRP evaluate this approach. NCRP issued Report No. 130

(NCRP 1999) and Statement No. 9 on March 30, 2001, which supported among other

recommendations that the hot particle dose be averaged at 10 cm2 rather than 1 cm2. On April

5,

2002, the NRC revised the area to be averaged from 1 cm2 to 10 cm2.

Ifthe pre-2002 NRC rule was still in effect, the skin dose to the child would be 0.32 Rem or 320

mRem! This dose would be forjust one exposure event. Whether it is 30 or 300 mRem, every

time the child goes out to play in the yard, he/she is able to pick up these high activity radium

particulates and be exposed to unnecessary and unwanted radiation and unnecessary risk to skin

cancer and lesions.

Dose Due to Ingestion of Radium Particulates

If a gram or two ofthese were ingested by a young child, which is not unreasonable, the results

would be:

Given:

2 grams (140,000 pCi or 0.14 p~Ci)ofRadium-226 was ingested.

All radium was retained in body (i.e., body burden of0.14 ~tCi)

ALl for radium is 2 p~Ci(NRC 10 CFR 20, Appendix B)

Use internal dose methodology used for radiation worker.

CEDE

=

5

Rem x I (~iCi)/ALI(~tCi)

=

5

Rem x 0.14 p.Ci/2 p~Ci

=

0.35 Rem or 350 mRem

Where:

CEDE

=

Committed Effective Dose Equivalent (Rem)

I

=

Activity ofIngested Radionuclide (jiCi)

ALl

=

Annual Limit on Intake (~tCi)

The 350 mRem is 3.5 times the NRC allowable exposure to the public (100 mRem/yr), but

obtained in only one exposure event.

WRTOO9,wpdlT. G. ADAMSAND ASSOCIATES, INC., 12/07/04

Page 4

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DATED NOVEMBER 24, 2004

Based on our review ofthe following calculations/reports (provided as Tabs 1, 2, 3 and 4 of the

City of Joliet supplemental documents) the following comments/questions are offered:

Calculations/Reports

Calculation ofthe Benefit to Public Costs in Dollars per Person-Rem for Land Application

ofBiosolids (Author Unknown, Tab 1)

Evaluation ofRadium Removal Impacts to Sludge Handling at the Eastside and Westside

Wastewater Treatment Facilities (Clark Dietz, Inc., August 2004, Tab 2)

Report of Survey at Westside Wastewater Treatment Plant in City of Joliet, Illinois (RSSI,

November 15, 2004, Tab 3)

Report ofRESRAD Dose Modeling for Wastewater Treatment Plant Sludge Applied to

Land Currently Used for Agriculture (RSSI, October 18, 2004, Tab 4)

WRTOO8.wpd/T, 0. ADAMSAND ASSOCIATES, INC., 12/06/04

Page

1

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Specific

5.

Paragraph

5:

The paragraph should clarify that the 25 years doses are from the Eastside and Westside

“Model 2 Applications.”

6.

The basis for three homes per acre is not given.

7.

8.

It is not clear how the information in the first table, which shows capital and operating costs

for the Eastside and Westside POTWs, relates to the “savings associated with land

applications” in the Clark Dietz, Inc. report. There appears to be no existing operating or

capital costs presented in the subject report.

9.

The calculation ofthe cost of person-rem is incomplete. Please clarify/show costs per

person-rem using the 2,500 per person-rem costs.

10. It is not evident how the number ofpersons was determined?

WRT008.wpd IT. G. ADAMS ANDASSOCIATES, INC., 12)06/04

Page 2

---

Specific

1.

Page 3, Section 2.1, Paragraph 1, Section 1:

The daily flow of 14 mgd presented here conflicts with the 7.628 mgd presented by IEPA

from the 2002 data from the DWPC database.

2.

Page 3, Section 2.2, Paragraph 3, Section 1:

“Westside” should be “Eastside.” The “2,217.3 dry tons” presented here does not agree

with the IEPA’s 2,400 dry tons presented in the September 2003 Engineering Evaluation

Report.

3.

Page

5,

Section 3.3, Paragraph 1:

Sentence 1

But the proposed water treatment technology (HMO) will produce concentrated radium

particles in the sludge which will contain radium concentrations up to 70,000 pCi/g. (See

attached memo from John Litz to Charles Williams).

Section 2

The test results of the sludge and farmer’s field were not referenced. References and/or test

results should be provided.

However, the need for more drinking water due to population growth will require more

water be pumped from deeper wells with higher concentrations ofradium. This event

cause increases in radium concentrations to occur in the sludge.

4.

Page 6, Title: Analysis of Landfill ofAlternative:

Delete second “of.”

WRTOO8wpd/T. G. ADAMS AND ASSOCIATES, INC., 12)06/04

Page 3

---

5.

Page 7, Section 4

General:

Dewatering thç sludge will increase the radium concentration in the sludge. Care will need

to be taken to maintain sludge concentrations within acceptable IEPAJIEMA and landfill

operator limits.

Not all of the sludge will need to be disposed ofin a landfill, only the radium contaminted

water treatment residuals. The POTW sludge can be applied to the farmer’s field, as is

currently done.

WRTOO8.wpd/T. 0. ADAMS AND ASSOCIATES, INC., 12/06/04

Page 4

---

General

1.

No page numbers are provided.

2.

There were no purposes or objectives given for the survey and sludge sampling efforts.

Please clarify.

3.

No references are provided for fieldprocedures used to perform the surface scan, exposure

rate measurements, dose rate measurements, orthe laboratory gamma spectroscopy

analysis. Please provide copies ofthe procedures used to perform the three types of surveys

and the gamma spec analysis of the sludge sample.

4.

No mention was made ofthe use of a chain of custody procedure/form to control/maintain

custody ofthe sludge samples.

5.

No mention was made ofthe calibration status of the survey instrumentation used to

perform the survey.

10. Testimony was provided by Mr. Duffield during the October 21-22, 2004 hearings that

RSSI evaluated the production ofradon within the Joliet Westside POTW. However, there

is no description or discussion ofthis sampling effort or related results. This report does not

appear to be the same equipment.

Specific

1.

Page 1, Methodology, Paragraph 1:

Please clarify that this survey was a “scan survey” as opposed to a “static survey” (i.e., one

minute count in a particular location/spot).

2.

Page 1, Methodology, Paragraph 1:

“Surface ofthe surface.” Suggest deleting “surface and.”

3.

How much ofthe surface area tank(s) were scanned?

WRTOO8.wpd

IT. 0.

ADAMS AND ASSOCIATES, NC., 12/06/04

Page

5

---

4.

Page 1, Methodology. Paragraph 2, Sentence 5:

“Located” should be “locate.”

5.

Page 1, Methodology. Paragraph 2, Sentence 6:

Do not understand the relevance ofthis statement and the overall objective of the survey.

Please see General Comment 2.

6.

Page 1, Paragraphs 2 and 3:

How many exposure rate measurements were obtained?

7.

Page 1, Paragraph 4:

How many dose rate measurements were obtained?

8.

Page 2, Bulk High Resolution, Gamma Spectroscopy, Paragraph 1, Sentence 1:

Marinelli beakers are not typically used for sampling purposes due to th econcern of

contamination ofthe outside of the container and the counting system. They are usually

used for counting purposes. Please clarify.

Please clarify who counted the sludge samples and at what location/facility.

Was the sample counted utilizing an approved field/lab procedure, trained lab technician,

and under an approved Quality Assurance Plan? Please provide documentation.

9.

Page 2, Results, Paragraph 1, Sentence 1:

Where were the background level determinations made for each instrument? Were they

performed in accordance with an approved and documented field procedure? Please

provide documentation.

10. Page 2, Results, Paragraph 1. Sentence 2:

The survey described in the Methodology, Direct Reading section was a scanning survey.

Therefore, one would expect a range ofreadings/results for the surface scan screening

survey (i.e., 40-80 cpm with a high of80 cpm, a low of 40 cpm, and an average of60 cpm).

The section states, “the surface tanks were 40 cpm approximately. Please clarify.

WRTOO8.wpd

IT. G.

ADAMS AND ASSOCIATES, INC., 12)06/04

Page 6

---

11. Typically, drawings ofthe item(s) surveyed (i.e., tank, vehicle, floor) are provided with

locations ofeach survey point shown on the drawing. Completed survey

measurements/results can then be correlated with the location of the item where the

measurement/reading was taken. It is recommended that a drawing ofthe tank(s) be shown

and a table with the specific survey results (i.e., exposure rates, dose rates, and scan results)

be provided to correlate these results.

12. Page 3, Bulk High Resolution Gamma Spectroscopy, Paragraph 1. Sentence 1:

It is not clear based on statements made on page 2 whether the sludge sample was dried

first and then counted, orthe sample counted as soon as it was collected with no drying.

Was the 17 gram, which resulted after drying, counted in the Marinelli container or the

gamma spec system? How was counting geometry controlled?

13. Page 3, Bulk High Resolution Gamma Spectroscopy:

Typically, an analytical result for a sample is reportedwith its standard error (i.e.,

95).

The results reported in the RSSI report are shown without their associated standards errors.

Please clarify.

14. Page 3, Conclusions, Bullet 7:

What is the relevancy ofthe second sentence in the first bullet, the second bullet, and the

third bullet to the objectives (or lack thereof) of the survey?

WRTOO8.wpd /

T. G.

ADAMS AND ASSOCIATES, INC., 12)06/04

Page 7

---

REPORT OF RESRAD DOSE MODELING FOR WASTEWATER TREATMENT

General

There are no page numbers.

Specific

Page

1, Paragraph 1, Sentence 5:

Ra-228 is not an alpha emitter, it is a beta emitter.

2.

Page 1, Paragraph 2, Sentence 1:

“Usuallyhas” run on.

3.

Page .1. Paragraph 4, Sentence 2 and Paragraph 5, Sentence 3:

Statements are not true.

“Drinking water studies in Ontario, Canada, Illinois/Iowa, and in Wisconsin previously

havefound the association between osteosarcoma and elevated radium levels in drinking

water.

“

(NDHSS News Release, 9/19/03.)

“When exposure estimates were categorized in terms of total radium cancerpotency,

expressed as equivalents ofRadium-228, the resulting incidence rate among those

exposed at ?4pCi/L was 90°/shigher than those whose tap water had less than 0.5

pCi/L. The elevated incidence ofosteosarcoma was entirely associated with males.

For males in areas receiving water with ~?4pCi/L and 2.0- 3.9pCi/L, compared to those

receiving 0.5pCi/L, the rate ratios were 3.4 (95 CI 1.5, 6.7), and 3.1 (95 CI 1.3,

6.0), respectively. For males 25 and over, rate ratios were 6.2 (95 C12.0, 14) and 5.5

(95 CI 1.8, 1.3), respectively. (“Radium in Drinking Water and the Incidence of

Osteosarcoma, “DHSS, 9/19/03.)

In other words, even at the 2

-

3.9 pCi/L Ra-228 equivalent, the rate of osteosarcoma was

3.4 (3.4 times higher) for ?4 pCi/L and 3.1 for 2.0

-

3.9 pCi/L. For males over

25,

it was

6.2 and 5.5 higher.

WRTOO8.wpd /

T.

C. ADAMSAND ASSOCIATES, INC., 12/06/04

Page 8

---

4.

Page 1, Paragraph 6, Sentence 1:

Inconsistency with JEPA information. Range from IEPA calculation, September 2003

Engineering Report was 8.1

-

17.2 pCi/L radium, average 13.3 pCi/L for Joliet water

supply.

5.

Page 2, Paragraph 1, Sentence 2:

Please clarify the meaning of “some other form.” Is “other form concentrated radium

particles up to 16,000

-

70,000 pCi/g?” There is no mention ofconcentrated particles.

6.

Page 2, Paragraph 2, Sentence 1:

Confusing. Should read something like,

“Joliet currently ‘discharges’ the radium initially

in the water supply to the POTW where it is concentrated in the sludge or

released to the Fox River.”

7.

Page 3, Paragraph 3, Sentence 2:

“planed”

8.

Page 3, Footnote 1:

“RASRAD”

should read

“RESRAD.”

9.

Page 4, Paragraph 1, Sentence 2:

“by the Joliet?”

10. Page 8, Paragraph 1, Sentence 1:

No reference to HPS position statements is provided (it is August 2004).

11. Page 8, Paragraph 2, Sentence 2:

No reference.

12. Page 8, Paragraphs 3 and 4, Sentence 1:

No reference.

13. Page 8, Paragraph

5,

First Word:

WRTOO8.wpd /

T. G.

ADAMS ANDASSOCIATES, INC., 12/06/04

Page 9

---

“Joliet”

i/

WRTOO8.wpd / T. C. ADAMS AND ASSOCIATES, INC., 12/06/04

Page 10

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14. Input Parameters. Page 4:

See Table 1, Comparison ofInput Parameters between RESRAD, ISCORS, and Joliet

(document number WRTOO1.wpd).

Dimension ofField

150 acres x 4,047 m2/acre

=

607,050 m2

(not

590,000 m2)

Contaminated Zone Hydraulic

4,310 rn/yr vs 210 mlyr conductivity

Contaminated Zone b Parameters

9.075 vs

2.895

or

5.3

Watershed for Nearby Stream

Saturated2,589,988Zonem2

vsHydraulic1,000,000Conductivitym2

4,310 m/yrvs lOor 100

Saturated Zone b Parameters

9.075 vs

5.3

Model for Water Transport

Non-dispersion, but RESRAD printout says Mass Balance.

Has no thickness for unsaturated zone.

Exposure duration

-

not used for dose calculations only risk.

General Joliet RESRAD analysis not consistent with input parameter in ISCORS

RESRAD analysis, i.e., shutting off plant food, meat, milk, aquatic foods, soil ingestion,

and drinking water.

WRTOO6.wpd /

T.

C. ADAMSAND ASSOCIATES, INC., 12/06/04

Page 11

---

15. Page 6:

3.5 tons x 1,016 Kg/ton x 1,000 g/Kg

=

3.56

x 106 glacre

not 3.2 x 106 g/acre

16. Page 6, Table Radium in Soil Field:

Eastside Plant: 0.028 pCi/g + 0.031 pCi/g

=

0.059 pCi/g

Westside Plant: 0.058 pCi/g + 0.091 pCi/g

=

0.15 pCi/g

0.15 pCilg 0.1 pCi/g JEPA / IEMA limit.

WRTOO8.wpd /

T.

C. ADAMS AND ASSOCIATES, INC., 12/06/04

Page

12

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ATTACHMENT 3

COMPARISON OF ILLINOIS ENVIRONMENTAL PROTECTION AGENCY AND

RSSI ESTIMATES OF RADIUM ACTIVITY IN THE CITY OF JOLIET’S SLUDGE

A comparison ofthe amount ofradium activity reported to be in the city ofJoliet’ s sludge by the

Illinois Environmental Protection Agency (IEPA) (T.G. Adams Supplemental Testimony,

Attachment G, dated October 8, 2004) and RSSI (R.M. Harsch Supplemental Testimony,

Attachment 3, November 24, 2004) was performed. The information and methodology used to

perform the comparison is presented in Calculation #3. The methodology incorporates data from

the JEPA, RSSI, and Clark Dietz documents provided as supplemental testimony.

The comparison ofthe IEPA and RSSJlClark Dietz calculations related to radium activity in the

city ofJoliet’s sludge identified the following:

Total Annual Radium Activity in Sludge

0.294 Cl/yr

IEPA

0.093 Ci/yr

RSSI (using IEPA annual sludge production rates)

0.2 Ci/yr

0.294 Ci/yr

IEPA

0.085 Ci.yr

RSSI (using Clark Dietz sludge production rates)

0.21 Ci/yr

0.2 Ci/yr

0.21 Ci/yr

The basic question is where did the rest of the radium go? Ifit is assumed that all ofthe radium

in the raw well water went into the sludge, then the annual radium activity should be shown to be

approximately 0.294 Ci/yr for both the IEPA and RSSI calculations. Instead, there is a large

discrepancy (0.2 Ci) between the JEPA results and the RSSJIClark Dietz results. Once again,

where did the radium go?

Thus, the attempt to develop a reasonable mass balance for the Joliet POTWs using the IEPA and

RSSIICIark Dietz was unsuccessful.

Given: Information from IEPA Calculation and RSSI Report

Radium Concentrations (pCi/g) in Sludge’

Westside Plant

47.2

Eastside Plant

18.7

WRTOO4.wpd / T.C. ADAMS ANDASSOCIATES, INC., 12/07/04

Page 1

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CALCULATION #3

COMPARISON OF ILLINOIS ENVIRONMENTAL PROTECTION AGENCY AND

RSSI ESTIMATES OF RADIUM ACTIVITY IN THE CITY OF JOLIET’S SLUDGE

Activity (annualproduction)

Westside Plant

0.047 Ci

47.2 pCi/g ~‘ x 988 dry tons/yr’2~x 1,016 Kg/ton x 1,000 g/Kg

=

4.74 ElO pCi

(using IEPA annual sludge production rate)

47.2 pCi/g ~ x 895.3 dry tons/yr (3) x 1,016 Kg/ton x 1,000 g/Kg

=

4.29 ElO pCi

(using Clark Dietz annual sludge production rate)

Eastside Plant

0.046 Ci

18.7 pCi/g x 2,400 dry tons/yr x 1,016 Kg/ton x 1,000 g/Kg

=

4.56

ElO pCi

(using IEPA annual sludge production rate)

18.7 pCi/g x 2,217.3 dry tons/yr x 1,016 Kg/ton x 1,000 g/Kg

=

4.21 ElO pCi

(using Clark Dietz annual sludge production rate)

Total Activity in Sludge

(annual production) ~

0.085 CL/yr (Clark Dietz)

Total Activity in Raw Water

Supply (2)

0.294 CL/yr (IEPA)

and hence sludge (i.e., assume 100

of radium in water goes to sludge

Where did the Radium go?

0.294 CL/yr

-

0.093 CL/yr

=

0.2

CL/yr (IEPA)

0.294 CL/yr

-

0.085 CL/yr 0.21 CL/yr (Clark Dietz)

0.2

0.21

WRTOO4.wpd / T.C. ADAMS AND ASSOCIATES, INC., 12/07/04

Page 2

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OF JOLIET POTW SLUDGE ON LOCAL FARM FIELDS

A

review of the JEPA calculations/analysis ofthe application area (acres) required to allow

placement ofthe sludge from Joliet’s POTWs (East Plant and West Plant) on local farm fields

was performed. The 1EPA analysis is presented in Attachment G of T.G. Adams supplemental

testimony dated October 8, 2004. The IEPA/IEMA agreed upon radium concentration of 0.1

pCi/g (refer to IEPA/IEMA Memorandum ofAgreement dated September 13, 1984) was utilized

as a limit for the radiumlsoil field mixture.

The review identified two major errors in the JEPA’s calculations. The first error occurs in the

IEPA’s calculation ofthe “radium loading” forthe Westside and Eastside plants. The values of

52.065

gIft2 and 70.809 g/ft3 should be multiplied not divided by the radium concentrations

(98.40 pCi/g and

94.53

pCi/g), respectively, in the radiumlsludge mix.

Hence, the radium loading should be:

Westside Plant

not the

98.401.89

pCi/ftpCilg2

xcalculated

52.065

gIftby2the

=

5,123JEPA.pCi/ft2

Eastside

Plant

not the

94.531.335

pCi/ftpCi/g2xcalculated70.809

g/ftby2

=

the

6,693.5

IEPA.pCi/ft2

The second error occurs in the JEPA’s calculation ofthe “assumed soil weight” for the farm

fields. A density of 120 #/ft3 is the density of rock (i.e., granite) and is not realistic. A more

reasonable density value would be 78 #/ft3, which is the density for soil (see RSSI RESRAD

Report, Attachment 4, R.M. Harsch Supplemental Testimony, dated November 24, 2004). The

RSSI report used a value of 1.25 g/cm3 or 78 #/ft3.

Hence, the assumed soil weight for the farm fields should be:

not the

78

54,531.09

#/ft x 453.5924g/ft3

calculatedg/#

=

35,397by

theg/ftIEPA.3

WRTOO5.wpd

I

TO. ADAMS AND ASSOCIATES, INC.,

12/07104

Page

1

---

The overall impacts due to the IEPA calculation errors are:

Radiumlsoil field mix concentration is much higher

Westside Plant

0.29 pCilg vs 6.94

E-5

Eastside Plant

0.38 pCilg vs 4.9 E-5 pCi/g

Application area is increased

Westside Plant

1,146 acres vs

395.2

acres

Eastside Plant

2,682 acres vs

705.9

acres

Thus, the amount of acreage required to allow application of the Westside Plant sludge is 2.9

times (i.e., 1,146 acres) more than the amount calculated by the JEPA. The amount ofacreage

required to allow application ofthe Eastside Plant sludge is 3.8 times (2,682 acres) more than the

amount calculated by the JEPA.

In summary, the total amount of acreage required to allow placement ofthe sludge from both the

Eastside and Westside POTW plants in compliance with the 0.1 pCi/g JEPA/JEMA limit is 3,828

acres, not the 1,100 acres as calculated by the JEPA.

Details ofthe corrected IEPA calculations are presented in Calculations #4-A and #4-B.

WRTOO5.wpd / T.G. ADAMS AND ASSOCIATES, INC., 12/07/04

Page

2

---

CALCULATION #4-A

RADIUM/SOIL FIELD MIX

-

WESTSIDE PLANT

Given: From IEPA Calculations

(1)

(and T.G. Adams corrections)

Westside Plant

Sludge

8.963 E8 g

Proportionate Radium

88.2 E9 pCi

Radium/Sludge Mix

98.40 pCiIg

Sludge Loading

Radium Loading

52.065 gIft2

98.40 pCi/g x

52.065

g/ft3

=

5,123 pCi/ft2 (instead of 1.89)

*

5,123 pCi/ft2

Soil Weight

78 #/ft3 x

453.594

g/#

=

35,380 g/ft3 (instead of 54,431)

35,380 g/ft3

Plow Down

0.5

ft

Radium/Soil Field Mix

0.29 pCi/g

5,123 pCi/ft2/35,380 g/ft3

(0.5

ft)

=

0.29 (instead of 6.94 E-5)

*

Application Area

1,146 acres

*

JEPA calculated

395.2

acres, but with corrected Radium/Soil Field mix, need 2.9 times

the acreage

(395.2)

or 1,146 acres to comply with the 0.1 pCi/g IEPAJIEMA limit

(e.g., 0.29/0.1

=

2.9).

WRTOO5.wpd / T.G. ADAMS AND ASSOCIATES, INC. 12/07/04

Page 3

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CALCULATION #4-B

RADIUM/SOIL FIELD MIX

-

EASTSIDE PLANT

Given: From IEPA Calculations

~

(and T.G. Adams corrections)

*

Sludge

2.177E9g

Proportionate Radium

205.79 E9 pCi

Radium/Sludge Mix

94.53

pCi/g

Sludge Loading

Radium Loading

70.809

gIft2

94.53 pCi/g x 70.809 g/ft3

=

6,693.5

pCi/ft2 (instead of 1,335)

6,693.5

pCi/ft2

Soil Weight

78#/ft3 x

453.594

g/#

=

35,380 g/ft3 (instead of 54,431)

35.380 g/ft3

Plow Down

0.5 ft

Radium/Soil Field Mix

0.38 pCilg

6,693.5

pCi/ft2/35,380 g/ft3

(0.5

ft)

=

0.38 (instead of4.9 E5)

*

Application Area

2,682 acres

*

IEPA calculated 705.9 acres, but with the corrected Radium/Soil Field mix, need 3.8 times

the acreage (705 acres) or 2,682 acres to comply with the 0.1 pCi/g IEPAIIEMA limit

(e.g., (0.38/0.1

=

3.8).

Total Acreage Required

WRTOO5wpd/TG.ADAMSANDASSOCIATES, INC., 12/07/04

Page 4

---

CALCULATION #4-B

RADIUM/SOIL FIELD MIX

-

EASTSIDE PLANT

Westside Plant

1,146

Eastside Plant

2,682

Total 3,828 acres (not 1,100 acres as IEPA calculated)

(1)

EPA Calculation (T,G. Adams Supplemental Testimony, Attachment G, October 8, 2004)

WRTOO5.wpd /

TO. ADAMS AND ASSOCIATES, INC., 12/07/04

Page

5

---

ATTACHMENT

APPLICATION RATE AND RADIUM CONCENTRATIONS

An evaluation was conducted of the radiumlsoil field mix (pCi/g) that was calculated by utilizing

an application rate of 3.5 dry tons/acre and radium concentrations of48 pCi/g and 18 pCi/g for

Joliet’s Westside and Eastside plants, respectively, as documented in the RSSI report (R.M.

Harsch Supplemental Testimony, Attachment 4, dated November 24, 2004).

Details of the subject calculations for both the Westside and Eastside plants are shown in

Calculation

#5.

The results ofthe calculations show that for an application rate of 3.5 dry tons/acre and the

radium concentration of48 pCi/g and 18 pCi/g for the Westside and Eastside plants, respectively,

the 0.1 pCi/g JEPA/JEMA limit will be exceeded by the Westside Plant (0.198 pCi/g vs 0.1 pCi/g

IEPAIIEMA limit).

WRTOO6.wpd / 1G. ADAMS AND ASSOCIATES, INC., 12/07/04

Page

1

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RADIUM/SOIL FIELD MIX USING JOLIET DATA

Radium in Sludge

Westside Plant

48 pCi/g

Eastside Plant

18 pCi/g

Westside Plant

Sludge Loading

3.5

drytons/acre x 2,000 #/ton x

453.592

g/#

Radium/

43,560Loadingft2/acre

72.9

=

72.9

g/ft2

gIft2

3,499 pCiIft~

48 pCi/g x 72.9 g/ft2

=

3,499 pCi/ft2

Soil Weight

78 #/ft3 x 453.594 g/#

=

35,380 g/ft3

Plow Down

0.5 ft

Radium/Soil Field Mix

0.198 pCi/g

3,499 pCi/ft2 / 35,380 g/ft3 (0.5 ft) 0.198 pCi/g

Note: O.198pCi/g 0.1 pCi/g IEPA /IEMA limit.

Eastside Plant

Sludge Loading

WRTOO6.wpd / TO. ADAMSAND ASSOCIATES, INC., 12/07/04

Page

72.92

g/ft2

---

RADIUM/SOIL FIELD MIX USING JOLIET DATA

3.5

tons/acre x 2,000 #/ton x 453.592 g/# / 43,560 ft2/acre

=

72.9 g/ft2

WRTOO6.wpd / T.O. ADAMS AND ASSOCIATES, INC., 12/07/04

Page

3

---

CALCULATION

#5

(continued)

Radium Loading

18 pCi/g x 72.9 g/ft2

=

1,312 pCi/ft2

Soil Weight

1,312 pCi/ft2

Plow Down

0.5 ft

Radium/Soil Field Mix

0.07 pCi/g

1,312 pCi/ft2 / 35,380 g/ft3 (0.5 ft) 0.07 pCi/g

Note: 0.07pCi/g 0.1 pCi/g IEPA /IEMA limit.

WRTOO6.wpd / T.O. ADAMSAND ASSOCIATES, INC., 12/07/04

Page 4

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WESTSIDE AND EASTSIDE POTW SLUDGE

AT A RADIUM CONCENTRATION OF

5

pCi/L

IN THE INFLUENT TO THE PLANTS

An evaluation was conducted ofthe radiuin/soil field mix from Joliet’ s Westside and Eastside

POTWs utilizing information from the IEPA analysis ofJoliet’s water and wastewater plants.

The radium effluent concentration from the Joliet water treatment plant was limited to

5

pCi/L,

the USEPA drinking water limit.

The details ofthe calculations are presented as Calculations #6-A and #6-B.

The results ofthe calculations show that with a water treatment effluent radium concentration of

5

pCi/L, and assuming all radium in treated drinking water goes to the POTWs, the radiumlsoil

field mix for either the Westside or Eastside plants will meet the 0.1 pCi/g IEPA/IEMA limit.

WRTOO7.wpd/T.G.ADAMSANDASSOCIATES, INC., 12106/04

Page 1

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CALCULATION #6-A

RADIUM/SOIL FIELD MIX

-

(5 pCi/L in water supply)

Given: From IEPA Calculations~’~(and

5 pCIIL

Sludge

Average Radium Concentration

5 pCi/L

Radium Production

1.1 Eli pCi/yr or .11

Ci/yr

16 mgd x 3.785 L/gal

=

60.56 E6 L/day

60.56 E6 L/day x 5 pCi/L

=

302.8 E6 pCi/day

302.8 E6 pCi/day x 365 days/yr

=

1.1 Eli pCi/yr or .11 Cilyr

Proportionate Radium (30)

3.33 EiO pCi

1.1 Eli pCi x .30

=

3.33 Ei0 pCi

Radium/Sludge Mix

37.2

pCi/g

3.33 ElO pCiI8.963 E8 g

=

37.2

RadiumSoilSludgeWeight

78

37.2

2.5

LoadingLoading

#/ftdry

pCi/g

3

tons/acrex

453.594

x 52.065

x

g/#

2,000

g/ft

=

2

35,380

=

#/ton

1,937

g/ftx

pCi/ft

453.59243

2

1,93752.06535,380

/

43,560pCi/ftg/ftg/ft322ft2/acre

=

52.065

gIft2

WRTOO7.wpd / T.O. ADAMS AND ASSOCIATES, INC., 12/06/04

Page

2

---

CALCULATION #6-A

RADIUM/SOIL FIELD MIX

-

WESTSIDE PLANT

(5 pCi/L in water supply)

Plow Down

Radium/Soil Field Mix

0.11 pCilg

1,937 pCi/ft2 /35,380 g/ft3 (0.5 ft)

=

0.11 pCiIg

Note: Meets/comes close to

meeting

0.1 pCi/g IEPA/IEMA limit. Will meet limit when taking

into consideration not all radium will go to sludge.

(1)

IEPA Calculation (T.G. Adams Supplemental Testimony, Attachment G, October 8, 2004)

WRTOO7.wpd / 1.0. ADAMSAND ASSOCIATES, INC., 12/06/04

Page

3

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CALCULATION #6-B

RADIUM/SOIL FIELD MIX

-

EASTSIDE PLANT

(5

pCi/L

Sludge

Average Radium Concentration

5.0 pCi/L

Radium Production

1.1 Eli pCi/yr or .11 Cl/yr

(see calculation for Westside Plant)

Proportionate. Radium (70)

7.77

ElO pCi

1.11 Eli pCi x .70

=

7.77

ElO pCi

Radium

I

Sludge Mix

35.7 pCi/g

7.77 ElO pCi/2.177 E9 g

=

35.7

SludgeSoilRadiumWeight

78

35.73.4LoadingLoading

#/ft

drypCilg

3

70.809x

g/#2,000g/ft

=

3

35,380

#/ton2,528x

g/ft

pCi/ft453.5924

3

2

g/ft2,52835,38070.809

/

43,560

pCi/ftg/ftg/ft232

ft2/acre

=

70.809 g/ft2

WRTOO7.wpd / 1.0. ADAMSAND ASSOCIATES, INC., 12/06/04

Page 4

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CALCULATION #6-B

RADIUM/SOIL FIELD MIX

-

(continued)

Plow Down

0.5 ft

Radium / Soil Field Mix

0.14 pCilg

2,528 pCi/ft2

I

35,380 g/ft3 (0.5 ft)

=

0.14

Note: Meets/comes close to meeting 0.1 pCi./g IEPA/IEMA limit. Will meet the limit when

taking into consideration not all radium will go to the sludge.

WRTOO7.wpd/T.G. ADAMS AND ASSOCIATES, INC., 12/06/04

Page

5

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COMMENTS ON “CONSERVATISM” OF DOE BIOTA DOSE METHODOLOGY

The IEPA provided testimony that the DOE Biota Dose Assessment Committee (BDAC)

methodology was overly conservative and did not provide realistic assumptions and/or

limits in which to evaluate the effort(s) of radionuclides (radium)-on~ak:organismsand

riparian animals (limiting organism for radium).

As will be demonstrated in the subsequent paragraphs and accompanying dose

calculations, this statement is not correct (for a more detailed presentation ofthe DOE

BDAC and the related DOE Standard 1153-2002, please refer to T.G. Adams Supplemental

Testimony, Attachment B, dated October 8, 2004).

To demonstrate that the DOE BDAC methodology can at times be less than conservative, a

comparison was made between the results of a standard biota dose determination using the

RESRAD Biota model and a manual calculation used in determining the dose to an aquatic

organism (i.e., a mussel).

Information from a study on the effects ofRadium-226 in several central Florida lake

ecosystems~1~(see T.G. Adams Supplemental Testimony, Attachment D, dated October 8,

2004) was used as input data for both approaches.

The following input data from the study was used:

Medium

Ra-226 Concentration

(pCi/L

or

pCi/g)

Lake Water (Round Lake)

1.6

pCi/L

Sediment (Round Lake)

Mussels (Round Lake)

205 pCi/g

Inserting the Ra-226 values for water (1.6

pCi/L)

and sediment (12.2

pCi/g)

from the

Florida study into the RESRAD Biota Dose computer model resulted in the model

concluding that the Ra-226 concentrations in the water and sediment did not exceed the

established respective radium Biota Concentration Guide (BCG) for water (4.0

pCi/L)

or

sediment (101 pCi/g). Thus, the DOE Biota Dose model concluded that the radium water

and sediment concentrations were less than their respective BCGs and hence resulted in the

sum of the fractions of less than 1.0.

1.6/4.0

+

12.2/101

=

.4

+

.12

=

.52 1 (See RESRAD

Table 1)

WRTOO3.wpd / T. G. ADAMSAND ASSOCIATES, INC., 12107/04

Page 1

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CALCULATED DOSE RATES USING DATA FROM FLORIDA STUDY AUGUST 2000

Furthermore, the Dose to the aquatic and reprian animals calculated by the

RESRAD

Biota Dose model were 1.58E-l and 5.13E-2 RAD/day, respectively, which is less than the

1.0 and 0.1 R&D/day DOE limits (See

RESRAD

Table 2).

WRTOO3.wpd /T. 0. ADAMS ANDASSOCIATES, INC., 12/07/04

Page

2

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CALCULATED DOSE RATES

USING

DATA FROM FLORIDA

STUDY AUGUST 2000

Therefore, based on the results above, the DOE established biota protection limit of0.1

Rad/day for the limiting organism,

the

riparian animal or 1.0 Rad/day for aquatic

organisms was not exceeded.

In comparison, the

same information from the Florida study was used to determine the

dose to an aquatic organism

(i.e.,

mussel) applying the methodology used by Blaylock et al,

September i993.(2) The details ofthe determination of the dose (both internal and external)

due to the radium in the Florida lake ecosystem is presented in Calculation

#7.

Results ofthe calculation show that the most contributing internal dose comes from the

alpha emitters

(Ra-226

and related daughters). The contribution of external dose from

radium related alpha,

beta,

or gamma emitters were negligible. Most importantly,

however, was the fact that the internal dose calculated for the mussels was 1.68 Rad/day.

This dose is greater than the 1.0

Rad/day

limit for aquatic organisms established by the

DOE standard to protect biota. This dose is also comparable to the

5.5 Rad/day

determined by Hazardous Substance and Waste Management Research, Inc., in their

August 2000 study~’~(T.G. Adams Supplemental Testimony, Attachment D, dated October

8, 2004).

Thus, contrary to

the

IEPA’s contention, the DOE Biota Dose approach can be less

than conservative under certain conditions.

(1)

Hazardous Substance and Waste Management Research, mc,, Human Health Risk Assessment and Preliminary Ecological

Evaluation Regarding Potential Exposure to Radium-226 in Several Central Florida Lake Ecosystems,August2000

(2)

Blaylock, et al, Methodology for Estimating Radiation Dose Rates to Freshwater Biota Exposed to Radionuclides in the Environment,

ES/ERITM-78, September 1993

-

WRTOO3.wpd

11.0.

ADAMS AND ASSOCIATES, INC., 12/07/04

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CALCULATED DOSE RATES USING DATA FROM FLORIDA STUDY AUGUST 2000

Given: Information-from human Health Risk Assessment and Preliminary Ecological

Evaluation Regarding Potential Exposure to Radium-226 in Several Central Florida Lake

Round Lake Radium-226 concentrations in:

Sediment:

12

pCi/g, dry

Water:

1.6

pCifL

Mussel:

205 pCi/g, dry

Mussel

Activity

205

pCi/g x 1,000 g/kg x I Bq/27 pCi

=

7,593 Bq/kg (dry) x .75

=

5,695 Bq/kg (wet)

Sediment Activity

12

pCi/g x 1,000 g/kg x 1 Bq/27 pCi

=

444 Bq/kg (dry) x

.75

=

333 Bq/kg (wet)

Water Activity

1.6

pCiIL x 1 Bq127 pCi

=

0.06 Bq/L

Dose Rates to Mussels from Ra-226

*

Given: Isotopes

Ra-226

and short-lived progeny

Geometry

Mussels

Activity in Organism

5,695 Bq ofRa-226/kg (wet weight)

Water Activity

0.06 (Bq/L)

Sediment Activity

333 Bq of Ra-226/kg (wet weight)

Ra-226 is a member of the U-238 decay chain and has a series ofprogeny with short half-

lives. It is reasonable to assume that because of their short half-lives, these progeny will be

present at the same activity level as

Ra-226. However, Ra-226 decays to

Rn-222, which is a

gas with a 3.8 day half-life.

Rn-222

produced in water or surface sediment would escape to

the atmosphere; therefore, the succeeding progeny would not be present in surface

sediment or water unless other sources were available. In this calculation, it is assumed

that 30

of the Rn-222 produced within a mussel remains in the mussel tissue so that the

activity level

of the succeeding progeny will also be 30

of theRa-226.

*

Based on “Methodologyfor Estimating Radiation Dose Rates to Freshwater Biota

Exposed to Radionuclides in the Environment, “B.G. Blaylock et al, ES/ER/TM-78,

September 1978.

WRTOO3.wpd / 1.0. ADAMS ANDASSOCIATES, NC., 12/07/04

Page 4

---

Alpha Emitters

Using average energies from Table A.2, the internal” dose rates for Ra-226 and its short-

Da 5.76 x 10~~ n C0

_Gy h’

Rn-222Ra-226

D..

D

==

(5.76

(5.76

x

x

10~)(4.86)(5,695)

i0~)(5.59)(5,695x 0.30)

==

15.9

5.5

_Gy

_Gy

h’h~1

Po-218 D

=

(5.76 x i0~)(6.i1)(5,695x 0.30)

=

6.0

Gy h’

Pb-2i4 D~

=

no alpha

Bi-214 ~

=

no alpha

Po-214 D

=

(5.76 x 10~)(7.83)(5,695x 0.30)

=

7.7 _Gy

Total.0001

Rad/_GyInternal”xDose20 Rem/RadRate

=

0.07

=

Rem/hr

35.i _Gy h1

-

0.07 Rem/hr

x 24 hrs/day

=

1.68 Rem/day 1.0 Rad/day DOE Biota Limit

Gamma Emitters

The internal dose rate from the

—

emitters with the highest energies is calculated as follows:

=

5.76 x i04 E_n_

—

C0

_Gyh’

Pb-2l4Bi-214D_=D_=(5.76(5.76

Total

xxi0~)(1.46)(0.007)(5,69510~)(0.248)(0.009)(5,695

Internal

—

DoseRate

xx0.30)0.30)

===

3.201.002.19xxxl0~i0~i03

_Gy_Gy_Gyh’hh11

WRTOO3,wpd

IT. G.

ADAMS AND ASSOCIATES, INC., 12/07/04

Page

5

---

CALCULATION #7

CALCULATED DOSE RATES USING DATA FROM FLORIDA STUDY AUGUST 2000

3.2 x i0~ Gy h’ x 0.0001 Rad/Gy x 24 hrs/day

=

7.7

x 106

Rad/day

WRTOO3.wpd / T. C. ADAMS AND ASSOCIATES, INC., 12/07/04

Page

6

---

Beta Emitters

The internal dose rate from the

—

emitters with the highest energies is:

D_

=

5.76 x 10~E_ n_

—

C0

.

Pb-214Bi-214

D_=D=

(5.76

(5.76

x

x

10~)(0.648)(1)(5,695

10~)(0.291)(1)(5,695

x

x

0.30)

0.30)

==

0.64

0.29

_Gy

Gy h’

h~1

Total Internal

—

Dose Rate

=

0.93

_Gy h’

Conclusion

As shown above, the internal

—

dose rate is

more than an order of magnitude greater than

the internal dose rates from the

—

and

—

emissions. Additionally, the relative biological

effectiveness of radiation is

20 times greater than

—

or

—

radiation; consequently, the main

concern for internal dose to the mussels from Ra-226 would be from the

—

dose.

Notes

Alpha Emitters

=

Dose rate for alpha emitters (Rem/day)

=

Energy of alpha particle (MeV)

~

=

Proportion of transitions producing an alpha particle

C0

=

Beta Emitters

=

Dose rate

for beta emitters (Rad/day)

=

Average energy of_ particle (MeY)

n_

=

Proportion of transitions producing

—

particle of energy Ec

(MeV)

—

=

Absorbed fractions (Fig A-4)

C0

=

Gamma Emitters

=

Dose rate for gamma emitters (Rad/day)

E_

=

Photon energy

(MeV)

n_

=

Proportion of disintegrations producing a gamma ray

—

=

Absorbed fractions (Fig A-i)

In addition to calculating the internal dose to the Florida mussels for completeness,

WRTOO3.wpd IT. C. ADAMSANDASSOCIATES, INC., 12/07/04

Page

7

---

CALCULATION #7

external doses to the mussel were also determined.

WRTOO3.wpd IT. C. ADAMS ANDASSOCIATES, INC., 12/07/04

Page 8

---

-

CALCULATED DOSE RATES USING DATA FROM FLORIDA STUDY AUGUST 2000

External Radiation Dose Rates

External Alpha and Beta Radiation Dose Rates from Water and Sediment

External alpha and beta radiation dose rates from water and sediment would be

insignificant because the mussel’s shell would serve as an effective shield.

External Gamma Radiation Dose Rate from Water

D

=

5.76 x i0~E_ n_ (1-J C~

Pb-214

=

5.76

x

i0~(0.248) (1-.009)(0.06)

-

=

(8.6 x 106)(.991)

=

8.5

x 106 _Gy/hr

8.6 x 106 Gy/hr x 0.0001 Rad/Gy x 24 hrs/day

=

2.0

x 108 Rad/day

Bi-214

=

5.76

x 10~(1.46) (1-.007)(0.06)

=

5.OxiO5_G/hr

5.0

x 10~ G/hr x 0.0001 Rad/Gy x 24 hrs/day

=

1.2

x i07 Rad/day

External Gamma Radiation Dose Rate from Sediment

=

5.76x10~En(1-jC~R

Pb-2i4

=

5.76 x i0~(0.248) (1-.009)(.333)(i)

=

4.7x105_Gy

4.7 x 105_Gy/hr x 0.0001 Rad/_Gy x 24 hrs/day

=

1.13 x i0~Rad/day

Bi-214

=

5.76 x 10~(1.46) (1-.007)(.333)(1)

=

2.8E4Gy/hr

2.8 E Gy/hr x 0.0001 Rad/Gy x 24 hrs/day

=

6.7 x i0~Rad/day

WRTOO3.wpd / T.

C. ADAMSAND ASSOCIATES, INC., 12107/04

Page 9

---

CALCULATION

#7

CALCULATED DOSE RATES USING DATA FROM FLORIDA STUDY AUGUST 2000

Conclusion

The external doses to the mussel as a result of alpha, beta, or gamma radiation from Ra-

226

daughters (Pb-214 and Bi-214) were determined to be insignificant.

Notes

D_

=

Dose rate

for gamma emitters (Rad/day)

=

Photon energy (MeY)

n_

=

Proportion of disintegrations producing gamma ray

—

=

Absorbed fractions (Fig A-4)

C~

=

Concentration of radionuclides in water (Bq/L)

C,

=

Concentration of radionuclides in sediment (Bq/kg, wet weight)

R

=

Amount of time organism is in contact with sediment (1)

WRTOO3.wpd IT. C. ADAMSAND ASSOCIATES, INC., 12/07/04

Page 10

---

Table

1:

Aquatic BCG Report for Level 2

Sum of Total Ratio: 5.13E-O1

Sum of Water Ratio: 3.93E-O1

Sum of Sediment Ratio: 1.21 E-O1

__

__

~

UC

~

e

.~C

.ceit~ätiön:~

(pCiIL)

~pCi/L)

BC~:~~

~1Jn~t1iii

orgarcism

Ra-226

1.60E+OO

.~ 4.08E+OO

3.93E- j

Ripanan

...

~ Se~áub,ent~~

~

rconcentration

BCG

R ~

Limiting

Nuclide

~pciIg)

a ‘0 Organism.

Ra~22.3~1.22E+oij

1.O1E+o2 1.~E-

---

Table 2: Aquatic Dose Report for Level 2 in

radld

.!_JL~1!ILJL!I~!~

•~ .~

j~h

~‘ I

~

JL±!~_i

iL~

~ ~

Summed

lIt000E+QO

8~42~O4 Il~

I

58E01

~

~

~

N~c~ide

Watel*

~o,l

~

---

Dec 07. 04 OS:36p

Theodore 6. Adams

716-592-3439

p.2

FIGURE

A.1

DERIVED ABSORBED FRACTIONS AS A FUNCTION

OF

y-RAY

ENERGY

(SMALL FISH,

LARGE INSECTS AND

MOLLUSCS,

AN-SM ~

C

I

0.0I

From: B. G. Blaylocket al, Methodologyfor Estimating Radiation Dose Rates to Freshwater

Biota Exposed to Radionuclides in the Environment, ES/ER/TM-78, September 1993

0.1

I..

oo~

0

fish

0.001

•

0.01

0.04

0.1

0.4

1.0

Gamma-..ray energy, Mev

---

Dec 0704 OS:36p

Theodore 6. Adams

716-592-3439

p.3

FIGURE

A.4

ABSORBED FRACTION AS A FUNCTION OF B-PARTICLE ENERGY

FOR THREE SMALL GEOMETRIES

V

~2

0

From: B. G. Blaylock et al, Methodologyfor Estimating Radiation Dose Rates to Freshwater

Biota Exposed to Radionuclides in the Environment, ES/ERJTM-78, September 1993

1.0

Sxnafl F~h

0.4

Large

Ifls~cth

andMoflusc.,

0.2

a

I

3

•M~xinium

~3-P4rtjcja

~navgy,MeV

4

---

ED

TABLE

A.2

fliciogical

AversOs

alpha

&

Miximum

bels

Average

Average

Conc~nttai1ori

Radiological

sipha

recoil

.nergyA

beta

energy

gamma

energy

Element

Factor’

UaU.lile

(MeV

MeV)

(MeV)

-

(MaY)

Uranium

Series

CA)

Ursolum-238

10

4.StEfOO

y

4.36E+00

1.OoE-02

1.36E.03

0)

Thortum.234

100

24.1

d

5.92E.02

9.34E.03

Proiacllnlum.234m

10

1.11

in

..

2.29E+0O

8.20E.01

1.13E.02

Uranlum-234

10

2.47E+0S

y

4.84E+00

1.32~~02

l.73E~03

—~

Thorlum~23O

100

7.76+04

y

4.74E+00

1.466.02

1.SSE.03

a.

Radlum~P26

60

1.626+03

y

4,86E+004t

3.596-03

&47E.03

Radon-222

-•

3.823

d

5.59E+00~

1.096-05

3.98E.04

to

Poionkim-218

50

3.05

in

6.116+00

‘#

I.426.05

9.126•0S

0)

Lead-214

300

26.8

~

--

6.706-01

2.91E•Ot

~

2.486-01

‘C

Asfatlrta-218

(.02

yIeld)

•

2;

0.826+00

4ooE-02-

6.725.03

Biemuih~214

10

19.7

in

3.26E400

6.48E-01

~

1.46E+00~

Poiontum-214

50

164

p5

7.83E+00

~

8.796-07

B.33E.05

Luad-2l0

300

22.3

y

a.80E.02

4.816-03

Rlsmuth.210

10

5.01

d

1.16E-pDO

3.09E.O1

Polonkim-210

50

138.4

d

.

5.406+00

8166.08

8.60E~06

Actinium

Series

liranlum.235

10

7.04+08

y

4.476+00

4.BOE-02

1.546-01

Thorium-231

100

•

25.6

h

-.

1.63E~01

2.556-02

Protaciln)um..231

1

0

3286+04

y

5.046+00

6.286-02

4.766-02

9)

Acllnium-227

21.77

y

6.006.172

1.56E02

2.31E.04

CD

Thotlum-227

100

18.7

d

5.95E+00

4.57E~02

1.OSE.01

P.adlum-223

50

11.43

d

575E+00

7.46E02

1.33E01

CA)

Radon.219

4-0

a

5.086+00

6.30E.03

5.506-02

Polonium-216

50

1.78

mc

7.526+00

830E-06

1766-04

CD

L.ad-211

300

36.1

m

-.

1.36E+00

4.54E-01

S.03E-02

SImuth-211

10

2.15

in

6.68E+00

ThaIIium-201

10000

4.79

m

-.

1.52Es00

4.936-01

221E.03

From:

B.

G.

Blaylock

et

a!,

Methodology

for

Estimating

Radiation

Dose

Rates

to

Freshwater

flora

Exposed

to

Radionuclides

in

the

Environment,

ES/ER/TM-78,

September

1993

I

-------

--~

----------------~--------—--

---

From: B.G. Blaylock et a!, Methodology for Estimating Radiation Dose Rates to Freshwater Biota Exposed to Radionuclides in

tire Environment, ES/ER/TM-78, September 1993

---

•

Dr. Brian D. Anderson

33

Taft.Drive

Rochester, IL

62563

December 7, 2004

A. Antoniolli

Illinois Pollution Control Board

State ofIllinois

Suite 11-500

100 W.Randolph

Chicago, IL 60601

Dear Rearing Officer

Antoniolli,

•The Illinois Environmental Protection Agency’sproposal to eliminate the General Water Quality

Standard and Lake Michigan Water Quality Standard for radium is not acceptable based on the

risk radium poses to aquatic life, as well as risk to municipal infrastructure, POTW workers, and

human and wildlife health at sites where radium contaminated sewer sludge is land applied. This

risk is well documented in the record before the Illinois Pollution Control Board. It appears the

Agency’s response is to try and cast doubt on nationally and internationally accepted standards

and methodologies for protecting biota from the impacts ofradiation, which became the focus of

supplemental testimony offered by IEPA staff on 21 October 2004; testimony which raised more

questions and concerns that it purported to address.

The agency’s biologist, Robert Mosher, related a conversation wherein he discussed the

application ofthe DOE standard with Stephen Domotor, Chair ofthe BDAC. He claimed Mr.

Domotor cautioned him against use of DOE Standard-i135-2002 (hereafter, the DOE Standard)

in the development ofa Water Quality Standard because it’~mightbe too conservative~’While the

introduction to Module 3 emphasizes the conservatism ofthe graded approach, the conservatism

the authors are referring to is in the context ofsite-specific remediation. The question that

should be asked is whether the screening criteria are too conservative to have any application in

development ofa Water Quality Standard. In a site-specific remediation, the opportunity exists

to do a detailed investigation ofon-site receptors and available pathways ofexposure. That is

certainly not the context of a General Water Quality Standard. The intent of a Water Quality

Standard is to be protective ofall flora and fauna. As expressed in Module 3 on page 1 ofthe

DOE Standard,’Since the screening limits would be chosen to protect”all biota everywher~’they

would, by their nature, be restrictive, and in many circumstances conservative with regards, to

specific environments~’Since General Water Quality Standards are meant to be applied in ~

waters and protect ~ species, the DOE Standard is, therefore, directly applicable. And since, if

a Water Quality Standard is repeatedly exceeded the party can go to IPCB for an exemption

based on site-specific data, this process is directly analogous to the graded approach around

which the DOE Standard is built. Furthemiore, in Table 3.1, Module 1, pages 22-23 ofthe DOE

Standard, compliance with the Clean Water Act is even identified as one ofthe potential uses of

the DOE Standard, along with Superfund Risk Assessments and Natural Resource Damage

Assessments, among others.

---

Mr. Mosher also testified that the underlying assumptions ofthe DOE Standard are not met by

any’~ipariananimal’that he could think ofother than the manatee, which spends 100 ofits time

in the water. He argued that since the manatee does not occur in Illinois, the DOE Standard is

not applicable. On page 2 ofModule 3 the DOE Standard points out that:’~A.fourth category of

organisms, riparian animal, was added after recognizing that the riparian pathways ofexposure

combine aspects ofboth the terrestrial and aquatic systems’ Notice that this acknowledges that

there are’terrestrial pathway~’forexposure. The organism doesn’t have to be immersed in the

contaminated water orthe contaminated sediments to be exposed, flooding for example, can

redistribute contaminated sediments in riparian soils, and organisms can physically redistribute

contaminated media. Besides, the manatee is actually a threatened aquatic (not riparian) mammal

with a very limited range. The DOE Standard clearly states that it was developed to be

applicable at any DOE-operated facility, as well as to be employed in the context ofSuperfund

clean-ups. In other words, the DOE Standard explicitly states that it is intended to be widely

applicable. Logic therefore dictates the rejection of Mr. Moshefs argument. While the default

value forthe screening criterion j~based on the assumption ofa one hundred percent residence

time for the riparian animal, for small mammals with limited home ranges like mice, voles, and

shrews, this criterion is fully met. Some larger mammalian species like muskrats, beaver, otter,

and mink can also meet this criterion; as can many species ofbirds with high affinities for

riparian areas like wading birds and waterfowl. In all these cases the entire diet of these species

comes from the river or stream, which also brings them into direct contact with potentially

contaminated sediments. In fact, on page

5

ofModule 3, in a discussion about how external dose

coefficients were calculated the DOE Standard points out that: ~‘.cnlypenetrating radiation

(photons gamma and electrons beta) are ofconcern, and non-penetrating radiation (i.e., alpha

particles) need not be considered:’ Clearly the IEPA’s contention that the DOE Standard assumes

a riparian animal must spend 100 ofits time in the water, is a misinterpretation. Since radium

226 is an alpha emitter no external dose coefficient is used in the calculation ofthe BCG for

riparian animals for radium 226. That number is based almost entirely on the ingested dose

(there are a few short lived beta emitters in the decay series that mayhave been included in the

calculation). This obviously indicates that BDACs definition oñiparian animal’is not as narrow

as suggested by Agency staff. The actual assumption built into the DOE Standard for radium

226 is that 100 ofan animal’s food and water is taken from within the riparian corridor (or

stream). This is an assumption that holds for nearly all species occurring in the riparian corridor,

the only exceptions would be things like raccoons and foxes, where some individuals may feed

part ofthe time in uplands.

IEPA staff also fail to acknowledge that the screening criteria derived using the DOE Standard

are very liberal in that they reflect the dose below which no population level effects have been

observed. Impacts to individuals at exposures well below the screening criterion are statistically

probable. Consequently, the screening criterion does not meet the requirements ofthe Illinois

Endangered Species Protection Act to protect individuals oflisted species. The General Water

Quality Standards are supposed to be designed to protect all aquatic useby wildlife, not just

protect populations ofwhole groups ofspecies (for example all small mammals) from extirpation

due to reproductive impairment.

The DOE standard is very liberal when compared to the standard being employed to protect

human health. In testimony before the IPCB a health physicist with Metropolitan Sanitary

District ofGreater Chicago, testified that the federal MCL for drinking water of

5

picoCuries/L

2

---

resulted in an exposure of4 millirems/yearto humans, while the BDAC standard forradium

• resulted in an exposure of42 millirems/hour to riparian animals. The calculated BDAC

screening limit forradium is clearly not”overly conservativ~’asMr. Mosher testified.

Mr. Mosher also argued before the IPCB that since the discharge ofconcentrated radium will be

to flowing water, aquatic animals would not suffer from continuous exposures to radiation from

• radiumreleased to rivers or streams. Re argued that releases would beintermittenf and therefore

the exposure assumptions inherent in the DOE standard would not apply. This ignores the fact

that the impacts ofradiation exposure are cumulative not threshold-based like chemical

pollutants. This line ofreasoning also ignores the likelihood ofsediment contamination with

radium and the fate ofthat sediment. The Florida Study as noted in my prior testimony and

attached graphs documents that radium levels are likely to dramatically increase through time.

Everyone who is familiar with the dynamics ofIllinois’ sediment-strangled waterways should be

aware ofthe propensity ofsediment to accumulate in slower moving parts ofour rivers and

streams and in sensitive, historically productive, backwaters. Where such sediments concentrate,

so too will the radium. Furthermore, the intermittent exposure argument totally ignores food

chain impacts, which are substantial given the bio-concentration factor of3200 for radium. The

Agency criticized using data from groundwater-enhanced lakes in Florida because they are not

flowing systems, while failing to acknowledge that the IEPA’s proposal would eliminate the Lake

Michigan Water Quality Standard for radium as well and that the General Water Quality

Standard which is applicable to all waters, including lakes and impounded streams and rivers.

There is also an assumption built into the DOE Standard which the Agency has tried to ignore.

Notice on page

5

ofModule 3 at the very end, when talking about the External Dose Coefficients

the DOE Standard states:’This assumption results in reasonablyrealistic estimates ofdose rates

for radionuclides

which are dispersed in the source medium

(emphasis added). Later when

talking about the underlying assumptions in the Internal Dose Coefficients on page 16 ofModule

3 :‘The radionuclides were presumed to be

homogeneously distributed

in the tissue:’ In other

words, the screening criteria calculated using the DOE Standard are not protective

AT

ALL if

radioactive particulates are allowed into the stream (or POTWsthen streams). Ifan organism

picks up a single particle it could receive an acute exposure! If there are many particles present,

whole populations and species could be wiped out. And with a half-life of 1600 years it is

difficult to anticipate where radium particulates will eventually turn up.

So, to protect aquatic life uses ofour rivers and streams some waymust be found to limit

radioactive particulates from getting into streams (or POTWsthen streams). Ifwe prohibit

discharge of radioactive particulates, a DOE Standard-calculated screening criteria may be

protective. However if discharge ofradioactive particulates is not prohibited, the current

standard of 1 picoCurie/L of radium 226 (which is really 2 picoCurie/L, radium 226 and 228

combined), should be left in place. POTWs that cari’t meet that standard could still seek an

Adjusted Standard.

Perhaps the most alarming supplemental testimony given by the Agency was that acknowledging

the Agency has never monitored its agreement with the Division ofNuclear Safety regarding

land application ofradionuclide-contaminated sludge. The Agency testified it had asked POTWs

land applying sludge to voluntarily test their sludge for radioactivity for the first time this past

March. This revelation also begs the question ofwhether POTWs from Illinois’ radium belt are

meeting the radiological guidelines for sludge disposal in landfills. The Agency testified that

3

---

radiation levels from 1.3 picoCuries/g. to 47 picoCuries/g. have been reported so far. The latter

is very close to the 50 picoCurie/g. limit imposed by the TDNS/IEPA memorandum ofagreement

for land application (the same limit in place for landfill disposal), and this is without

concentrating the radium to meet the new federal MCL for drinking water. A Chicago Tribune

article which followed the 21 October 2004 hearing indicated that the Agency had sent warning

letters to five communities land applying sludge, something the-Agency failed to disclose to the

Board. NRC licensees and DNS licensees are no prohibited from discharging radioactive

particulates, yet because there is presently no prohibition against water companies dumping

radium particulates down the drain, radiological contamination ofwastewater facilities, landfills,

and farmland beyond federally allowable limits may, in fact, be occurring. It is unfathomable

whythe Agency, with suchdata in hand, would propose to eliminate the General Water Quality

and Lake MichiganWater Quality Standards for radium.

The Agency’s testimony continues to demonstrate a pervasive, dismissive attitude toward the

potential heath and environmental effects of a known carcinogen and mutagen that has been

demonstrated to bioaccumulate in the environment. Taken together with IEPA’s supplemental

testimony that they filedthis proceeding without knowing what the levels already were in

sewage treatment sludge in affected areas ofthe state, that they don’t actually know how many

POTWs are affected by radium contaminated discharges from water treatment plants, and that

they do not know the radioactive concentrations in the Technologically Enhanced Naturally

Occurring Radium (TENORM) (which could be 10,00 to 70,000 PicoCuries/g or if the

TENORM will contaminate the POTWs receiving it.. Reliance on the Agency’s recommendation

to eliminate the radium standards could easily be characterized as arbitrary and capricious, and

would not likely be upheld should such a decision be appealed.

Finally, it is important to recognize that elimination ofthe General Water Quality Standard for

radium opens the door to other potential discharges ofradium into Illinois’ waters. Radioactive

groundwater from a Superfund cleanup could be discharged to a stream without the radium

standard in place (not only from radium clean-ups, like those at Ottawa, IL, but also from any

thorium or uranium-contaminated site, since radium isotopes would be present as decay

products).

Based on these considerations I recommend the Board reject the Agency’s proposal.

Sincerely,

Dr. Brian D. Anderson

4

---

December 7, 2004

A. Antoniolli

Illinois Pollution Control Board

State of illinois

Suite 11-500

100 W. Randolph

Chicago, IL 60601

Dear Hearing Officer Antoniolli,

Several questions were raised by the Report of Survey at the Westside Waste Water Treatment

Plant in City Of Joliet, Illinois: by RSSI Dated November

15,

2004 which I would like to

address.

First WRT, from the beginning, has monitored the radium content and emissions from its radium

removal system. The pilot plant system is representative of the operation and related exposures

ofthe full scale treatment system. The municipal workers in a full scale plant are exposed to

only a small increase above background and will be trained and advised ofthat exposure. The

expected exposure to a municipal worker is estimated to be approximately three millirem per

year, assuming that one person does all ofthe monitoring task which is unlikely. (see attached

excerpt from IDNS application) The three millirem exposure represents only 3 percent ofthe

maximum exposure allowed to a member of the general public from a licensed facility. Most

importantly we will be monitoring the exposure to workers and will know if an exposure

problem occurs.

In contrast, according to the testimony, no exposure estimates have been made for water

treatment personnel for exposures resulting from the HlVIO or the ION Exchange process.

Testimony from Ted Adams and Brian Anderson clearly demonstrates the exposure to workers

and biota from unrestrained disposal of radium to our streams and sewers can clearly lead to

exposures that may be harmful to both human and biota. The failure of both the IEPA to even be

aware ofthe levels of radiation that could occur on the radioactive solids from a H?s’IO process is

disappointing.

RSSI conclusion that the WRT process will need three to four stages in the full scale plant is

incorrect. The typical full scale design calls for a minimum depth of 6 feet ofmedia per stage

compared to a pilot plant that has only two feet ofmedia per stage. Therefore, the typical stage in

a full scale system has three times the media for a given flow rate than the pilot plants. Each of

the WRT plants is designed forthe specific application.

5460 Ward Road, Suite 100, Arvada,FROM

SOURCEColorado

‘‘4

TO80002SOLUTIONtel

303.424.5355TM

fax 303.425.7497

email: info@wrtnet.com web: www.wrtnet.com

---

Joliet’ s assertion that there may be a radon problem with ourprocess is disingenuous when their

own results after six months oftesting by Joliet personnel of our system shows there is no

evidence that radon is any higher after our system than before. (See RSM Extended Pilot- WRT

Radon Results, provided by Joliet.)

Also attached are Joliet’s results ofthe Joliet Pilot Plant which indicates that the radium in the

feed averaged 13.5 pCi combined Ra 226 and Ra 228 and had a high of 16.4 pCi Ra combined

while the discharge after the WRT pilot plant was average 0.28 pCi Ra combined with a high of

0.8 pCi Ra combined. Recovery was 98 of the contained radium.

Removing radium from the water and concentrating the radium into a concentrated form prior to

disposal is a fundamental change from simply passing the radium through the system as has been

historically occurring. While the total amount ofradium may be unchanged the form of that

radium is entirely different. In the case of HIVIO the particulates of very high radium content will

be discharged to the land and stream intact, and may very well have significant consequences to

both the aquatic and land based biota. Most surprising of all is the fact that this rule change is

being requested without the studies that demonstrate no impact and in the face of studies and real

life examples such as the Florida lakes and ElliotLake, Canada where a very real impact has

been measured.

I would like to thank the Illinois Pollution Control Board forthe opportunity of expressing our

opinion on this very important issue.

Sincerely,

Charlie Williams

President Water Remediation Technologies

FROM SOURCE

4’’

TO SOLUTIONTM

2

---

WRT Radon Results, provided by Joliet

FROM SOURCE

4’’

TO SOLUTIONTM

3

---

Page

1

of

I

Day

I

Thursday,

6/3104

Day

5

Wednesday,

6/9/04

Day

7

Friday,

6111/04

Day

10

Wednesday,

6/16/04

Day

12

Friday,

6118104

Day

15

Wednesday,

6/23/04

Day

17

Friday.

6/25/04

Day

20

Wednesday,

6/30/04

Day

22

Friday,

7/2/04

Day

25

Wednesday,

7/7/04

Day

27

Friday,

7/9/04

Day

30

Wednesday.

7/14/04

Strand

Associates,

Inc.

City

of

,loliet

Wisconsin

Radium

Effluent

Lab

Testing

All

results

in

pCi/L

Well

9-0

Raw

WRT

Grossa

Gross~

Ra-226

Ra-228

Combined

Radium

Grossa

Gross~

Ra-226

CombinedRadium

Result

Result

Result

Result

Result

Result

Removed

Result

Removed

Result

Removed

Result

Removed

Result

Removed

30

29.5

7.9

3.4

11.3

1.2

96.00

8.9

69.83

0.12

98.48

0.2

94.12

0.32

97.17

25

27

8.1

4.9

13

0.9

96.40

10.5

61.11

0.01

99.88

0.2

95.92

0.21

98.38

26

274

7.6

5.6

13.2

1.1

95.77

11.4

58.39

0.15

98.03

0.1

98.21

0.25

98.11

33

32.6

7.8

5.8

13.6

2

93.94

13.4

58.90

0.14

98.21

0

100.00

0.14

98.97

24

28

7.8

5

12.8

1.9

92.08

11.5

58.93

0

100.00

0.1

98.00

0.1

99.22

30

30.6

7.8

5.5

13.3

2.1

93.00

12

60.78

0.1

98.72

0.1

98.18

02

98.50

25

28

7.3

5.6

12.9

1

96.00

12

57.14

0.15

97.95

0

100.00

0.15

98.84

26

25.8

8.6

5.4

14

22

91.54

11.7

54.65

0.08

99.07

0.1

98.15

0.18

98.71

32

31.3

7.6

52

12.8

1.1

96.56

11.7

62.62

0.08

-

98.95

0

100.00

0.08

99.38

30

31.8

7.1

8.1

15.2

1.3

95.87

10

68.55

0.7

90.14

0.1

98.77

0.8

94.74

23

26

8.4

8

16.4

0.6

97.39

12

53.85

0.47

-

94.40

0.3

96.25

0.77

95.30

21

25.4

8.4

5.1

13.5

0.9

95.71

12.6

50.39

0.18

97.86

0

100.00

0.18

AVG

27.08

7.87

5.63

13.50

1.36

0.13

0.10

-

0.28

98.00

MIN

21.00

7.10

3.40

11.30

0.60

0.00

0.00

0.08

MAX

33

8.6

8.1

16.4

2.2

0.47

0.3

0.8

~

~.-~---

-~---~-~

---

Strand AssoCiates, InC.

City of Joliet

Pilot Study

Friday, 6/18/04

Wednesday, 6/23/04

Friday, 7/2/04

Wednesday, 7/7/04

Monday, 9/27/04

Monday, 9/27/04

Thursday, 9/30/04

Friday, 10/1/04

Monday, 10/11/04

Monday, 10/18/04

Monday, 10/25/04

Monday, 11/1/04

Monday, 11/8/04

Monday, 11/15/04

Monday, 11/22/04

30-day vendor pilot

Friday, 6/18/04

Wednesday, 6/23/04

Friday, 7/2/04

Wednesday, 7/7/04

Well 9-D

Raw

WRT

Result

Result

pCi/L ±

20

pCi/L ± 20

TM

130

120

130

110

140

150

‘~

~Jr’t~_’~

LI

OLILU

~

150

130

RSM Extended Pilot

-

WRT Radon Results

Well 9-D

WRT

pCi/L ±

20

pCi/L ±20

130

120

130

110

140

150

150

130

180

190

160

110

120

140

140

140

120

160

190

140

130

Before pressurization

After pressurization

5

---

Table 22-2

Full Scale Radium Removal System

Estimated

Annual Dose to Operators

Illinois —

Typical Treatment Systems

-

1,000

gpm well

with two

15-ton stages of media

- Maximum total-radium activity of

Stage

I =

3,000

pCi/g,

1,500

pCiIg

each

Ra-226 and

Ra-228

- 3-year media life

-

Estimated

average dose rate is for the last year prior to exchange of Stage I media

- The annual dose is based on one person performing all the tasks

.

Distance

from Tank

(m)

Task

Duration.

(mm)

Task

Frequency

Total

Task

Time

(hr/yr)

Estimated

Dose

Rate

(mrem/hr)

Estimated

Annual

Dose

(mrem/yr)

flow and pressure

3.0

3

5 daysfwk

13.0

0.023

-

.

0.3

inspection

.

1.5

4

5 daysfwk

17.3

0.055

1.0

external filter

. 1.5

10

every 2

weeks

4.3

0.055

0.2

survey meter

1.0

3

.

2times/mo

1.2

. 0.082

0.1

water

3.0

4

2times/mo

1.6

0.023

0.04

task time within

1.5

5

5 days/wk

21.7

0.055

1.2

task time within

4.0

30.0

0.015

0.5

Average

89.1

0.037

3.3

Notes:

1. Based on instrumentation and remote readoutfor pressures and flows

2.

Utility operators will not handle treatment media

3. Source of estimated dose rates - MFG, Inc. Dose Rate Calculator

IL DNS

—

Radioactive Material License Application

Full Scale Radium-Removal System

September, 2004

54

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Exhibit 22-1

MEMORANDUM

MFG PROJECT: 181050

TO:

Duane Bollig

Environmental Manager

Water Remediation Technology. LLC.

FROM:

Jan Johnson, Ph.D.

Craig Little, Ph.D.

MPG, Inc.

DATE:

September 20,2004

SUBJECT:

Calculation ofWater Treatment Tank Exposure Rate

—

3-year media life case

The dose rates from a water treatment tank at full capacity were calculated assuming a receptor

at the surface ofthe tank and at several distances from the surface of the tank. The calculated

dose rates are based on very conservative assumptions and simplifications that result in

uncertainty in the numerical values ofthe estimates. These estimates are provided in order to

project the ‘upper limit of potential doses to workers. The estittiated doses should not be

construed as representing the actual doses that workers may incur from the WRT water treatment

technology. When the equipment is in operation, doses to workers and members ofthe public

will be determinedusing area gamma exposure ratemeasurements and personal dosimeters.

Dose

at Specific Distances from the Tank Surface

Calculation of dose rates from point sources, line sources, and plane sources can be done by

employing standard equations. However, estimation ofthe dose rate from a solid source with

finite dimensions such as the water treatment tank is not a straightforward calculation but one

that requires making some simplifying assumptions. Our approach to this problem is consistent

with the recommendations of standard texts. For example, the following is an excerpt from a

recent health physics textbook.

“Many radiation sources can, with ease and utility, be represented as a point or an approximate

point source; however, many real-world situations cannot: for example, long pipes or tubes

(typical of a line source), contaminated areas (representative of a disc or infinite planar source),

IL DNS

— Radioactive Material

License Application

Full Scale Radium-Removal System

September, 2004

consulf3n.g.

scIentIsts and

englneer.s

55

---

and

various volume sources. Fortunately, various practical calculations, some ofwhich are fairly

complex, can be used to determine the photon flux, which can then be applied in the usual way to

calculate radiation exposure. Such calculations are generally conservative in that they tend to

overestimate exposure, but considerable simplification ofthe calculations is obtained and errors

in the estimates are not large.”

“Volume sources such as large drums or tanks of radioactive

material produce scattered photons due to self-absorption by the medium in which they are

produced

good information can be obtained for such geometries by dividing them up into

several point-source subdivisions and summing the contributions of each.” (From “Physics for

Radiation Protection”, James E. Martin, Wiley and Sons, 2000:)

Our calculation method for the radium removal tank system takes such an approach. Based on

information provided by WRT, the tank was assumed to be a cylinder 11’ feet in diameter and 20

feet tall with two chambers, a lower stage (Stage 1) and an upper stage (Stage 2). Each stage

contains 15 tons oftreatment media. Typically, for a fully-utilized water well, WRT expects a

stage ofmedia to have approximately a two-year life before requiring exchange. The following

example models a somewhat more conservative scenario in which a well is only partially

utilized, resulting in a longer life for a stage ofmedia

—

three years. This scenario also results in

a slightly higher average activity in both stages ofthe media during the last year prior to the

exchange ofmedia. The fully-loaded media stage in the tank was assumed to be changed out on

a three-year schedule (one ofthe two stages in a tank is exchanged every

1.5

years). At the time

ofeach exchange, the lower stage (Stage 1) will be removed andthe upper stage contents (Stage

2) physically moved to the lower chamber becoming the new Stage 1 ofthe treatment column.

Fresh media will be installed in Stage 2.

The maximum radium loading was assumed to be achieved in Stage 1 after three years of

operation. Based on results from WRT’s pilot-scale testing at municipal well sites, it’s

reasonable to expect the media in Stage 1 to adsorb at least

1.5

times the amount ofradioactive

material adsorbed by Stage 2 during the same period oftime, under steady-state conditions. At

the time ofthe exchange ofStage 1, whenits activity is assumed to be at the proposedmaximum

of 3,000 pCi/g total radium, the maximum loading in Stage 2 would be approximately 40

percent ofmaximum loading,

The maximum concentrations in the tank would occur at the end ofthe third year ofoperation in

each cycle. For this dose-rate estimate, the activity concentration in Stage 1 at the start of the

third year was assumed to be 60 percent ofthe maximum loading and 100 percent at the end of

the year. The average loading in Stage 1 would then be approximately 80 percent of the

maximum or 2,400 pCilg. The activity concentration in Stage 2 at the start ofthe third year was

assumed to be approximately 13 percent ofthe maximum loading and 40 percent at the end of

the year for an annual average of approximately 27 percent (800 pCilg). Average dose rates

were estimated for the third and last year before the media in Stage I is exchanged.

As noted above, the calculation of exposure rate from a source such as the water treatment tank

is not straightforward. For the purpose of these calculations, each stage was assumed to be

configured into six cylindrical disk elements, each 1 foot thick, stacked vertically. The disc

elements were assumed to have an inside radius one foot smaller than the outside radius (the

radius ofthe tank). The gamma radiation emitted by the loaded media at a depth greater than

IL DNS

—

Radioactive Material License Application

Full Scale Radium-Removal System

September, 2004

56

---

one foot into the tank was assumed to be negligible, such that the remainder of each disc was

ignored for the purposes ofthis calculation. Self-shielding would reduce the dose contribution

for the remainder of each disk to less than 1 of the total.

Each disc was divided into 16

segments. The receptor was assumed to be located at specific distances from the surface of the

tank, ranging from

0.5

meters to 3 meters, at a height of 3 feet above the bottom surface of the

adsorber in the tank. Only the segments of the disc facing the receptor were assumed to

contribute to dose.

The gamma emission rate from each of the segments in each stage was calculated based on the

total mass ofthe material in the segment and the, assumed activity concentration, 2,400 pCilg Ra-

226 and Ra-228 for Stage 1 and 800 pCiig for Stage 2.

For the purpose of calculating the emission “flux” at the receptor attributable to each of the

segments or elements in the disc, the total activity in each element was assumed to be contained

in apoint source at the center of the surface of the element, The “flux” (d/s per cm2) from each

element at the receptor was estimated by dividing the total disintegration rate by the surface area’

of a sphere with a radius equal to the distance from the center surface of each element to the

receptor. The total activity was calculated by multiplying the mass ofmaterial in the elementby

the activity concentration.

“Flux”

=

A/4itd2

where: A

=

activity in the segment in d/s

d

=

distance from the segment to the receptor in cm

Activity

=

mass of the elementx the average activity concentration for the stage

The distance from each element or source to the receptor was calculated using trigonometric

relationships as described in the attached Excel spreadsheets and the Figures. It should be noted

that this is not a true gamma flux, because each disintegration of Ra-226 and Ra-228 results in

emission of several gammas. However, this is a convenient way of expressing the amount of

electromagnetic energy in the form of gamma radiation that passes through an area of 1.0 cm2,

per second.

The dose rate was calculated by multiplying the ratio Of the calculated flux from the water

treatment tank to the flux from a point source of 1 MBq of Ra-226 or Ra-228 by the literature

value (Handbook of Health Physics and Radiological Health) for the dose rate from a point

source of 1 MBq ofRa-226 or Ra228. The decayproducts ofRa-228 and Ra-226 were assumed

to be in equilibrium with the parent, that is, the activity concentration of each of the decay

products is equal to the activity concentration of the parent. This is a reasonable assumption

since equilibrium would be reached for both radium isotopes within a few weeks of radium

adsorption onto the media.

Dose rate (tank) (D):

D

=

(flux from tankat receptor)/(flux from 1MBq at lm)dose rate at im from 1MBq

The calculations are given in the attached Excel spreadsheets.

IL DNS

—

Radioactive Material License Application

Full Scale Radium-Removal System

September, 2004

57

---

Dose Rate At the Surface of the

Tank

In contrast to the calculation of dose rate at one meter from the surface of the tank, the dose rate

at the surface can be estimated by simply assuming that the tank is an infinitely thick, infinite

plane source. The annual average dose rate at the surface ofStage 1 was calculated assuming an

annual average Ra activity concentration of 2,400 pCi/g (1,200 pCilg Ra-226 and 1,200 pCi/g

Ra-228). A reasonable approximation of the dose rates can be obtained from the values given

for these isotopes and their decay products in EPA Federal Guidance No. 12 that contains dose

conversion factors for external radiation.

The dose rate from an infinitely thick, infinite plane source of Ra-226 and its decay products in

equilibrium is 1.3 microrem per hour per pCilg. The value for Ra-228 in equilibrium with its

decay products is 1.8 microrem per hour per pCilg.

These values were calculated for

contaminated soil. However, they are probably reasonably applicable to the media in the water

treatment tanks.

The total dose at the surface of an unshielded source with these two radium isotopes at activity

concentrations of pCi/g each would be as follows:

Ra-226 dose rate

=

(1,200 pCilg)(l.3 ‘uRfhr/pCi/g)

=

1.56 mremThr

Ra -228 dose rate

=

(1,200 pCilg)(1.8 uRlhr/pCilg)

=

2.16 mrem/hr

The total average annual unshielded dose rate would be approximately 3.72 mrem!hr. Assuming

a shielding factor of approximately 0.8 for the tank wail, the dose rates for Ra-226 and Ra-228

forwould be approximately 1.2 mrem/hr and 1.7 mremlhr respectively for a total of2.9 mrem/hr.

The shielding factor was obtained from Ra-226 transmission curves in the Handbook of Health

Physics and Radiological Health (1999). The activity concentration in Stage 1 (lower stage) of

the tank was used in the surface dose calculation as the worker is more likely to contact the

ground level stage than the upper stage and it is the most conservative assumption.

Dose Rates at Intermediate Distances

The dose rates at distances less than 1 meter from the surface ofthe tank should not be calculated

in the same maimer as the dose rates at 1 meter because the uncertainty resulting from the

assumptions that were required to be used in the calculations would have a much greater impact

on the estimated dose than for the 1.0 meter calculation. The closer to the source the receptor is

placed the greater the error in the calculation. One approach could be to interpolate between the

calculated surface dose rate and the estimated 1.0 meter dose rate. A second approach would be

to use inverse square law to calculate the dose at distances less than 1 meter.

IL DNS

—

Radioactive Material LicenseApplication

Full Scale Radium-Removal System

September, 2004

58

---

Summary

of Dose Rates

The calculated or estimated annual average dose rates from the tank assuming an average total

radium activity concentration in Stage 1 during its last year in the treatment tank of 2,400 pCi/g

and 800 pCi!g in Stage 2, both equally divided between Ra-226 andRa-228 are given below:

Table 1: Estimated Dose Rates at Specified Distances from

the Surface of the Water

Distance

Ra-226 Dose Rate

(mremlh)

Ra-228 Dose Rate

(mremlh)

Total Dose Rate

(mremlh)

Surface

1.25

1.73

2.98

0.5m’

0.639

0.890

1.53

0.5

in2

0.124

0.204

0.328

1.0 m

0.031

0.051

0.082

1.5

m

0.021

0.034

0.055

2.Om

0.015

0.024

0.039

2.5m

0.011

0.018

0.029

3.0 m

0.009

0.014

0.023

‘Interpolated value

2lnverse square valuebased on calculated 1.0 m dose

Potential Doses to Workers

Workers will be equipped with personal dosimeters at least until the negligible doses calculated

above are verified by the dosimetry data. Workers will be instructed not to linger in the vicinity

of the tank. Radiation doses to workers and members of the public will be kept As Low As

Reasonably Achievable (ALARA).

The maximum a1lowab1~doserate in areas where members of the’ public might have occasional

access is 2 mrem per hour. The estimated distance at which this would occur at the average

medialoading for the second year of operation is approximately

0.5

meters. The maximum dose

rate at the end ofthe second year of operation would be 10 percent higher than the loading used

in calculating the ‘dose to a worker. However, this would not change the estimated distance at

which the allowable dose rate to a member of the public would be exceeded,

0.5

meters. This

distance will be verified using measured exposure rates. As noted above, exposure rates in the

treatment facility and at the surface of the tank will be measured at least monthly after the

treatment facility goes into operation..

The estimated dose rate at the surface ofthe tank is 3.3 mremlhour. This does not exceed the

dose rate at which posting as a Radiation Area is required; however it does exceed the dose rate

that is acceptable for members of the public. Therefore, the water treatment operators must be

considered radiation workers even though the estimated annual dose to the worker is below the

allowable annual dose to a member ofthe public. This means that all workers who have access

to the treatment facility must be appropriately trained and the facility must develop and

IL DNS

—

Radioactive Material License Application

Full Scale Radium-Removal System

September, 2004

59

---

implement a program to keep radiation doses As Low As Reasonably Achievable (ALARA).

The Radiation Safety Officer (RSO) for Water Remediation Technology (WRT) will serve as the

RSO for each facilityusing its equipment. Ifthe measured doses to all individual workers at the

treatment facility are below 500 mrem per year, no individual dose tracking will be required.

IL DNS

—

Radioactive Material License Application

Full Scale Radium-Removal System

September, 2004

60

---

Schematic Representation ofWater Treatment Tank

*—

Layers

(Z

dist.)

foot

T~ourfoot break

between two sets

disks.

Receptor

Centerlines

3

2

1

Full ScaleRadium-Removal System

September, 2004

61