REL.c’
— 1’
v
7 C
1—
CLERK’S CFF~CE
I
2~1j5
CHICAGO LEGAL CLINIC, INC.
~rfl,,+rr
STATE
CF
fl~r’~enl
LLINLO~S
.tr’~.rd
South Chicago
•
Pilsen • Austin •
Downtown
Rev. Thomas
J.
Paprocki, President
Downtown Office
EdwardMarta
C.Grossman,Bukata, DeputyExecutiveDirectorDirector
205
Chicago,W.
Monroe,IL
60606~
Floor
~
3
Keith I. Harley
Veronique Baker
Phone (312) 726-2938
Greta Doumanian
Fax (312) 726-5206
TDD (773) 731-3477
August 9, 2005
Amy Antoniolli
Hearing Officer
Illinois Pollution Control Board
100 West Randolph, Suite 11-500
Chicago, IL 60601
Hand Delivered
Re: R04-21
-
In The Matter of Revisions To Radium Water Quality Standards: Proposed
New 35 Ill. Adm. Code 302.307 and Amendments To 35 Ill. Adm. Code 302.207 and
3 02. 525
Dear Ms. Antoniolli:
Please be advised that I represent Citizens Against Ruining the Environment (“CARE”),
a Will County-based, not-for-profit organization. CARE is dedicated to protecting and
improving the health, welfare, and safety ofthe people who live and work in Will
County, Illinois. CARE’s members live in Will County, and have been actively
commenting on the permitting of Will County facilities for ten years. CARE’s members
have a particular interest in groundwater quality in Will County because, like thousands
of Will County residents, their water originates from regional groundwater aquifers.
The members of CARE are also committed to maintaining and enhancing the quality of
Will County’s surface waters and the quality of its land resources.
CARE strongly objects to the Board’s proposal to add Section 302.207(d), which would
allow a 30 pCi/L radium 226 and 228 standard for waters within one mile ofoutfalls from
some wastewater treatment plants. This standard would apply when a POTW is treating
wastewater that originates from a groundwater source with a radium concentration in
excess of 3.75 pCi/L.
Comment #1
-
Several public water suppliers in Will County use groundwater with
radium concentrations in excess of 3.75 pCi/L. Consequently, the downstream areas
within one mile of the outfalls ofthe associated POTWs will mark the boundaries ofthe
30 pCi/L water quality zones. In order to demonstrate the practical impact of the Board’s
proposal, CARE formally requests the Board to identify the dozens of outfall locations
for these POTWs, the one-mile areas of local waterways that would be subject to the less
stringent standard, the primary uses ofthese portions of these waterways (especia1ly
drinking water supplies), and any susceptible ecosystems (especially habitat for
threatened and endangered species) within these 30 pCi/L zones. It appears the Board is
proposing a rule without considering the total area that could be affected, andthejiuman
health and ecological factors within specific areas. For this reason, in order to evaluate
the practical effect of this proposal, CARE formally requests the Board to identify every
area of every waterway within one mile of every outfall ofevery Will County POTW that
could fall within 302.207(d), the primary use designation of this water, and any potential
ecosystem impacts created by the 30 pCi/L proposal.
Comment #2
—
The Board’s proposal under 302.207(d) is premature, and will be until at
least 2009. As noted by the Board, this is a time oftransition for public water suppliers
that do not comply with the radium 226 and 228 standards. Following the promulgation
of U.S. EPA’s final rule reaffirming its original standard, IL EPA notified non-compliant
public water suppliers that they were required to establish schedules that would achieve
compliance no later than 2007. Following the implementation of control measures, it
will take up to one year of monitoring to demonstrate ongoing compliance.
By the end of 2008, many of the problems anticipated by the Board’s 302.207(d)
proposal may be resolved. Like Lockport, some public water suppliers will change the
source of their water supply to sources that do not contain radium. Others will use
mixing techniques that combine sources that exceed the regulatory threshold with low or
non-radium sources, with corresponding reductions in the total radium concentrations in
wastewater and POTW effluent. Still others will use the technologies promoted by
companies like WRT, and will remove radium from source water without reintroducing it
into wastewater. The Board would be well-advised to abstain from establishing a rule
like 302.207(d) until public water suppliers achieve compliance, especially because many
of the techniques they may use will eliminate or substantially reduce radium in
wastewater. This will allow for rulemaking that is more tailored and that is based on
underlying compliance rather than non-compliance.
Comment #3
-
CARE asserts that any lessening of the 302.207(c) general use water
quality standard for radium 226 and 228 should only be allowed in cases where:
I. it is the direct and unavoidable consequence of achieving the SDWA radium standard;
2. it will occur despite the application of feasible wastewater treatment technologies that
are available to reduce radium wastewater concentrations;
3. it is not the result of any non-compliance by the public water supplier or the POTW;
4. it will not exceed a concentration set as close to the 302.207(c) standard as possible,
for as short a duration as possible;
5. it will not adversely effect human health or the cnvironment, based on an analysis that
is specific to the impacted receiving water; and,
6. it will comply with procedures and standards developed by the Illinois EPA that are
substantially similar to the standards contained in 35 Illinois Administrative Code
302.102, “Allowed Mixing, Mixing Zones and ZIDs.”
The approach contained in 302.207(d) would effectively allow a POTW to release
effluent containing radium in any concentration and quantity so long as the radium
concentration in the receiving water within one mile downstream does not exceed 30
pCi/L. Because of the reliance on the diluting power of the receiving water, 302.207(d)
is establishing a “de facto” mixing zone near the outfalls ofthese POTWs. However,
there are no procedures, restrictions, limitations or protections contained in proposed rule
302.207(d). CARE asserts this is in opposition to the well-developed regulatory
approach that already exists under 35 AC 302.102 that empowers the IL EPA to perform
a case-by-case review ofmixing zones based on a comprehensive application that must
address well-defined criteria. This type of approach
—
that allows for regulatory
flexibility under specific circumstances asjudged on a case-by-case basis by the IL EPA
—
is far preferable than the categorical, “carte blanche” for POTWs contained in proposed
rule 302.207(d).
In making its decisions on this matter, CARE strongly recommends the Board be guided
federal decisidns that have addressed the use of mixing zones. These decisions highlight
the need for such an approach to be carefully tailored. For example, while
acknowledging that mixing zones may be appropriate under some limited circumstances,
the court in
American Wildiands v. Browner,
94 F. Supp. 2d 1150 (D. Col. 2000)
identified several characteristics of an adequate mixing zone. Key issues are the
identification ofcriteria to limit the size of the mixing zone, in-zone quality requirements,
and dilution allowances.
Ida! 1162.
Allowable mixing zone characteristics should be
established to ensure that (1) mixing zones do not impair the integrity of the water body
as a whole; (2) there is no lethality to organisms passing through the mixing zone; and (3)
there are no significant health risks, considering likely pathways of exposure.
Id.
While
certain numeric criteria for a certain substance may not apply, all mixing zones are to be
free from substances that (i) settle to form objectionable deposits.. .(iv) are acutely toxic;
(v) produce undesirable or nuisance aquatic life. It is not possible to establish a wholly
deterministic (a black box) procedure with which to make all mixing-zone dilution
decisions. It is not advisable to make all mixing-zone dilution decisions based on a
simplistic approach which overlooks the mixing characteristics and water body uses
particular to a site.
Id.
Accordingly, mixing zone dilution policies should clearly set
forth the considerations, guidelines, and default assumptions that will be utilized in
making such case-by-case decisions.
Id. at
1162-63. Affirmed by
American Wilt/lands v.
Browner,
260 F. 3d 1192 (10th Cir. 2001).
InA,nerican Iron and Steel Institute v. EPA,
115 F. 3d 979 (D.C. Cir. 1997), the court
upheld a portion of a U.S. EPA rule that limited mixing zones in streams to 25 of the
cross sectional area ofthe river to allow a free zone ofpassage for aquatic organisms.
Id
at 997. A permitting authority must use all relevant available data, including facility-
specific effluent monitoring data where available and employ procedures which account
for existing controls on point and non-point sources of pollution, the variability ofthe
pollutant or pollutant parameter in the effluent, the sensitivity of the species to toxicity
testing and, where appropriate, the dilution of the effluent in the receiving water when it
determines whether a pollutant discharge has the reasonable potential to cause an
excursion above a water quality standard.
Id.
at 999, quoting from 40 C.F.R.
1 22.44(d)(1)(ii).
Comment #4
-
Prior to acting on any proposed rulemaking relating to radium in
wastewater, the Board should require the Agency to conduct a comprehensive review of
the adequacy of regulation of radium that originates in drinking water. Addressing the
water quality problem in isolation
—
without also considering related issues like the land
application of radium-containing POTW biosolids
—
is inadvisable. The wastewater issue
would be addressed best as part of a comprehensive, multi-media review that considers
whether the existing, piecemeal regulatory approach is adequate to protect human health
and the environment.
The Joliet example is instructive. Joliet must comply with the radium 226 and 228
standard. In order to address the requirements that originate in the Safe Drinking Water
Act, Joliet is choosing an approach that will remove radium from drinking water but will
reinject it into the wastewater system. Because of this choice, Joliet must solve two
additional problems. First, it must seek to lessen radium water quality standards near its
outfalls because its POTW effluent will still contain elevated levels of radium. Second,
Joliet is seeking approval to substantially increase the concentration of radium in
biosolids it will land apply. Using the Freedom of Information Act, CARE acquired the
following documents, all of which are attached and incorporated by reference into
CARE’s comments:
CARE Attachment One
—
4/9/04 correspondence from Dennis Duffield, City ofJoliet, to
Jeff Hutton, Illinois EPA, requesting Joliet be allowed “up to five applications of
sludge without regard to the increase in the background radium concentration.”
CARE Attachment Two
—
5/10/04 correspondence from Richard Allen, Illinois
Emergency Management Agency, Division ofNuclear Safety, to Allen Keller, Illinois
EPA, recommending denial of Joliet’s 4/9/04 request based on “public health and safety
considerations” and determining Joliet may be in violation of existing standards because
of the concentrations of radium in its land applied sludge.
CARE Attachment Three
—
Record of Biosolids Land Disposal, 2004, Joliet Westside
POTW, showing 25 land applications of biosolids totaling 881 dry tons for 2004
(compared to 895 dry tons land applied in 2003)
CARE Attachnwnt Four
—
Record of Biosolids Land Disposal, 2004, Joliet Eastside
POTW, showing 43 land applications of biosolids totaling 2425 dry tons for 2004
(compared to 2217 dry tons land applied in 2003).
CARE Attachment Five
-
2/28/05 correspondcncc from Dennis Duffield, City of Joliet, to
Allen Keller, Illinois EPA, requesting Joliet be allowed
“. .
.to land apply wastewater
treatment plant sludge to allow an increase in the background concentration ofcombined
radium 226 and radium 228 of 1.0 pico-cuies per gram in the soil.” Despite this tenfold
increase over the existing standard, Joliet nonetheless asserts this will not adversely
impact “future conversion ofthe land to residential use.”
CARE Attachment Six
—
5/9/05 correspondence from Richard Allen, Illinois Emergency
Management Agency, Division of Nuclear Safety, to Allen Keller, Illinois EPA, raising
significant questions about every aspect of the Joliet proposal.
As implied in Attachment Five, Joliet faces the issue that the Will County farmland on
which its radium-containing biosolids are disposed may be converted to residential
development. The concern is that homes will serve to contain radium that currently is
released from agricultural disposal sites into the ambient air.
Under these circumstances, the IPCB should create a regulatory approach to water quality
that has the co-benefit of discouraging the disposal of radium in effluent and biosolids.
At a minimum, the IPCB should not create a regulatory approach in which it promotes
approaches that will encourage radium disposal in surface waters and farm fields/next
year’s residential development sites. Section 302.207(d) creates a regulatory incentive
for municipalities like Joliet to commit to approaches to radium that will compromise
water quality, and use increasingly scarce land resources as low-level radioactive waste
disposal sites. Without Section 302.207(d), Joliet and similarly situated municipalities
will be forced to address the radium issue in such a way that will also eliminate or
substantially minimize the impact on surface waters and land resources. For the menibers
of CARE, all ofwhom live in Will County, a comprehensive approach to eliminate the
threats posed by radium in drinking water, surface water and land should be the goal of
these proceedings.
Thank you for your consideration ofthese comments.
Sincerely,
Keith Harley
Attorney at Law
—rr
ic
CITY
OF
JOLIET
Apnl 9. 2004
ISO WEST
JEFFERSON
STREET
Mr. Jeff
Hutton
JOLIE
.
LP~ 6fl4~
Division of Water Pollution Control
Illinois Environmental Protection Agenc~
APR 1 ~
1021 North Grand Avenue East
P.O. Box 19276
ILL/NOIS ENVIRONMENTAL
Springfield, Illinois 62794 -9276
PROTECT/ON AGENCY
BOWPIIPC/pERMrf- SECT~0N
Re:
Joliet Public Water Supply
Facility Number IL 1970450
Dear Nit Hutton:
Thank you for requesting that I provide you with a proposal concerning radium in wastewater
treatment plant sludge. Joliet is concerned that there is no specific plan for determinmg the impact of land
application of wastewater treatment plant sludge containing radium and that the regulatory plan will
evolve after communities have committed to a water treatment technique. This could result in the
additional expenditure of public funds in the future.
I have attached an analysis of the current situation as it is understood by Joliet. The analysis
includes our recommendations for sludge application. Joliet is requesting that the Division of Public
Water Supplies and the Division of Water Pollution Control and Illinois Emergency Management Agency
review our recommendations and provide comments.
‘The current criteria in the Enter-agency agreement between the Illinois Environmental Protection
Agency suggests that the land application of radium bearing sludge be limited to a calculated increase in
the background concentration of radium in the soil after land application of less than 0 1 pico-curie per
gram on a in’ weight basis, This criteria is yen’ restrictive. Joliet is recommending that this agreement
be changed to ailow up to five applications of sludge without regard to the increase in the background
radium concentration, The nsk from sludge application in Northern Illinois is primarily due to radium
226 and the generation of radon in a confined space. Radon is already a problem in some homes. The
monitoring of radon is already required by many mortgage lenders and will not represent a burden to the
future homeo\\.ners
Radium bearing sludge does not represent the only potential source of radium. Joliet has
measured background radium levels in soil that has not received radium bearing sludge that are higher
than levels measured after mu1tiple applications on other fields, The hazard to the public is not related to
the source of the radium, but to the concentration in the soil matrix and the potential for the accumulation
of radon
It should be noted that one of our samples from a field not recel\Thg sludge indicated high
comhthed radium ~6 and radium 228, although the major contribution was from radium 2:8.
CAgE
AIT’\CHMCtFI
o~Ja
Mr. Jeff Hutton
April 9, 2004
V
Page 2
Your assistance in determining the best approach to land application of radium bearing
wastewater treatment plant sludge is requested. If you have any questions concerning Joliet’s analysis
and proposal. you may reach me at
815-724-4230.
Smcerely yours,
Dennis L. Duffieldc~j/ector
Department of Public Works
and Utilities
City ofJoliet
Attachments
Analysis and Recommendations
Sampling result from Joliet Treatment Plants
Sampling Results from Hickory Creek
Soil sample results
Sample calculations for Radon Production
Cc:
Marcia Wilhite, Bureau Chief, Bureau of Water. IEPA
Toby Frevert, Manager, Division of Water Pollution Control. IEPA
Roger Selburg, Manager, Division of Public Water Supplies, IEPA
Al Keller, Manager, Permit Section, Division of Water Pollution Control. LEPA
Jern Kuhn. Manager, Permit Section, Division of Public Water Supplies
John NI. Mezera. City Manager, City ofJoliet
Jeffrey Plvman. Corporation Counsel, City of Joliet
James F. Eggen, Utilities Administrator. City’ of Joliet
Harold Flartv, Plant Operations Superintendent, Cit-v of Joliet
Mark Oleinik, Strand Associates, Inc.
Richard J. Christensen, Clark Dietz, Inc.
V.
Analysis and Recommendations of the City of Joliet concerning Radium in Wastewater
Treatment Plant Sludge Applied to Agricultural Land as a Soil Amendment
Treatment of Groundwater
The deep wells in Northern Illinois have combined radium 226 and 228 in concentrations
greater than the maximum contaminant level of 5.0 pico-euries per liter. This requires treatment
of the groundwater before delivery to consumers.
The treatment alternatives fall into the following two categories:
1.
Treatment methods that remove the radium from the water, but return the radium to
the sanitary sewer
2. Treatment methods that remove the radium from the water for disposal at low-level
radioactive waste disposal sites outside Illinois.
One of the treatment methods that is being proposed in Illinois (some facilities are under
construction) is the co-precipitation of radium with preformed hydrous manganese oxides, This
method is capable ofremoving approximately 80 of the radium from the water. For waters
with a combined radium concentration of 5-20 pico-curies per liter, 4-16 pico-curies per liter
will be removed from the water provided as drinking water and discharged to the sanitary sewer
as backwash from the filters employed in the HIMO process.
Disposal of Radium Bearinu Water Treatment Waste to Sanitary Sewers
Since the 4-16 pico-curies per liter is discharged to the sanitary sewer and combined with
the water used as the public water supply, the combined radium concentration into the
wastewater treatment plant is in the range of
5-20
pico-euries per liter. This is the same as the
concentration in thc groundwater originally.. This concentration may be reduced slightly by the
infiltration into the sanitary sewers of non-radium bearing groundwater.
The wastewater arriving at the wastewater treatment plant will have a radium
concentration identical to the concentration in the sanitary sewers. The range for this
concentration is 5-20 pico-curies per liter. Available information indicates that the tvastewater
treatment plants remove 30-80 of the radium in the influent, This results in effluent
concentrations of 0.83-12 pieo-curies per liter. The effluent situation is being addressed by EPA
in the pending rulemaking before the Illinois Pollution Control Board (R.2004-021). The
concentration in sludge would is estimated to range from 20-2 13 pico-curies per gram dry
weight
Prepared by City of Joliet
Page 1
Department of Public Works and Utilties
April 9, 2004
Land Aoplication of Radium Bearin2 Wastewater Treatment Plant Sludue
Land application of sludge generated from a wastewater treatment plant receiving radium
has been applied to agricultural land as a soil amendment. Loadings in the range of 5 dry tons
per acre are not unusual.
One application of sludge can increase the background concentration
of radium in the soil by 0.08-0.82 pico-curies per gram soil.
If the memorandum of
understanding with the Illinois Emergency Management Agency is applied, sludge applications
are limited to 0.12-1.3 applications per field to remain under the requirement of increasing the
background concentration by no more than 0.1 pico-curies per gram soil.
A review of the risks associated with radium on land indicates that the scenario that
presents the greatest future risk is the construction of homes on land that has previously received
wastewater treatment sludge containing radium. The risk does not result from the exposure pf
the body to the radium in the soil, but due to the resulting isotopes that result from the decay of
radium. The risk is primarily from the potential development of high concentrations of radon in
the homes. Since radon is a part of the decay chain for radium 226, but not for radium 228, the
concentrations of radium 226 in the wastewater treatment plant sludge are of greatest concern.
Radon Risk
USEPA recommends that homeowners limit the radon in their homes to 4.0 pico-curies
per liter of air in the home due to the risk of lung cancer. If the measured radon exceeds this
amount. USEPJ\ recommends that the homeowner increase the number of air changes in the
home to prevent the accumulation ofradon.
The radon risk scenario is developed in the ISCORS report “Assessment of Radioactivity
in Sewage Sludge: Modeling to Assess Radiation Doses”. Major elements in the scenario
include the construction of )mes with a slab on grade constructed on the topsoil that has
received the sludge appiicati.
This is unlikely in Northern Illinois as the construction of slab
on grade is not the normal a .truction method and topsoil is typically stripped from a site prior
to grading to establish the str~:ts and install utilities. Other elements of the scenario (convened
from metric used in the report) were mixing the sludge to a depth of 6 inches into a soil with a
unit weigh of iSO lbs per cubic foot and applying sludge at an application rate of 4.47 dry tons
per acre.
By specifying the
type of foundation and removing topsoil under the home, the risk is
reduced although the magnitude of the reduction is uncertain. Radon risk may also be mitigated
by the installation of additional ventilation in the home. Since the accumulation of radon will
not be certain in every home, monitoring ofeach home will be required and the installation of
ventilation only as needed.
Prepared by City ofJoliet
Page 2
Department of Public Works and Utilties
April 9, 2004
Recommendations
As a result of the review of available information, Joliet is recommending the following
actions’
1. The memorandum of understanding between the JEPA and the EEMA should be modified
to control radium 226 only since this isotope represents the greatest risk.
2. The IEPA should establish monitoring standards for radium 226 at the wastewater
treatment plant influent, effluent, sludge and in the soil. (Our sampling has shown a great
deal of variation which will make it difficult to calculate the actual radium application
rates)
3
The memorandum of understanding between the EPA and the IEMA should be modified
to allow an equivalent application of 25 pico-curies per gram dry weight sludge to
agricultural land using the 4.47 dry tons per acre criteria included in the ISCORS dosage
report without further review. This results in an estimated radon production of 4 pico-
curies per liter air in the home under the ISCORS scenario for future homes.
4.
EPA sludge regulations should be modified to allow five applications of sludge to a field
if the sludge generator and the property owner agree that the topsoil will be removed
from the area under homes constructed on the property. The property owner must also be
notified that radon should be monitored in any homes constructed on the site, Sludge
applications to the same field are currently limited to approximately five applications
because ofthe accumulation of phosphorus in the soil
5.
The policy of IEPA shoud be to continue to encourage the use of wastewater treatment
plant sludge as a soil amendment.
Prepared by City ofJoliet
Page 3
Department of Public Works and Utilties
April 9, 2004
Sampling result from Joliet Treatment Plants
The concentration of radium in the influent, effluent and sludge at the Joliet Treatment
Plants has been determined on two separate occasions, The samples were grab samples and the
results are shown below.
A weekly composite sample was collected the week ending April 3, 2004. These samples
have been submitted for analysis, however, the results will not be available until May.
The sample results are as follows:
Joliet Eastside Wastewater Treatment Plant
Radium
Radium
Date
Description
226
228
Total
Feb-04 Influent, pCi/liter
3.0
6.3
8.3
Effluent , pCi/liter
1.2
3.9
5.1
Primary Sludge pCi/gram dry
6.6
7.8
14,4
Digested Sludge pCi/gram dry 8.8
9.9
18.7
Per Cent Removal
60
26
39
based on influent and effluent
8-Mar-
04
Influent, pCi/liter
1.9
4.3
6.2
Effluent , pCi/liter
2.6
3.5
6.1
Digested Sludge
8.8
8.8
17.6
Per Cent Removal
-37°/s
19
2
Prepared by City of Joliet
Page 4
Department of Public Works and Utilties
April 9. 2004
Joliet Westside Wastewater Treatment Plant
Radium
Radium
Date
Description
226
228
Total
Feb-04 Influent, pCi/liter
2.9
5.1
8.0
Effluent, pCi/liter
2.0
2.9
4.9
Primary Sludge pCi/gram dry
17.8
28.9
46.7
Digested Sludge, pci/gram
dry
18.3
28.9
47.2
Per cent Removal
31
43
39
based on Enfluent and effluent
8-Mar-
04
Influent, pCi/liter
3.9
6.1
10.0
Effluent ,
pCi/liter
0.9
1.0
1.9
Sludge pCi/gram dry
15.6
20.4
36.0
Per cent Removal
77
84
81
Prepared by City of Joliet
Page S
Department of Public Works and Utilties
April 9, 2004
Sampling Results from Hickory Creek
Upstream from the Joliet Eastside Plant Outfall
March 8, 2004
Location
Radium 226 Radium 228 Jjotal
Upstream
0.1
1.3
1.3
Downstream 0.2
1.2
1.4
Prepared by City of Joliet
Page 6
Department of Public Works and Utilties
April 9, 2004
t.
Soil sample results
The control field is located west of Joliet and has not received sludge applications
Radon production has been calculated using the ISCORS conversion factors and results as
follows:
Field A
Field B
Control
gross alpha
2.0
pCi/g
3.4
pCilg
4.0
pCi/g
Radium 226
1.1
pCi/g
1.5
pCi/g
0.8
pCi/g
Radium 228
5.7
pCi/g
5.7
pCi/g
6.1
pCi/g
Combined
226 & 228
6.8
pCi/g
7.2
pCi/g
6.9
pCi/g
Biosolids applied to fields A and B multiple times
Control Field has not received biosolids
field measured 226 pCi/gram
pCi/gram
pCi/gram
soil
1.1
pCi/gram soil
1.5
soil
0.8
soil
conversion from SCORS for
sod concentrat:on to sludge
concentration
0.0044
0.0044
0.0044
sludge concentration
pCi/gram
pCi/gram
pC/gram
250.0
pCi/gram sludge
340.9
sludge
181.8
sludge
conversion from ISCORS for
sludge concentration to
radon concentration in air
0.159712
0,159712
0.159712
racon concentration pCi/liter
air
39.9
pCi/liter air
54.4
pCi/liter air
29.0
pCi/liter air
USEPA radon action level
4.0
pCi/liter air
4.0
pCi/liter air
4.0
pCi/liter air
Prepared by City ofJotiet
Page 7
Department of Public Works and Utilties
April 9, 2004
V.
Sample calculations for Radon Production
Radium 226
West Sampie A
East
West Sample B
Influent
3,90
3.00
2.90
Effluent
0.90
1.20
2.00
Sludge
3.00
1.80
0,90
per cent removal of
76.9
60.0
31.0
Flow liters per
year
1 2,720.079,620
24.334.065,360
12,720,079,620
Picocuries
per year
38,160,238,860
43,801
.317,648
11448,071,658
Acres per year
395.20
705,90
395.20
grams soil per acre
1,186,574,400
1,186,574,400
1,186,574,400
grams soil per year
488,934,202,880
837,602,868.960
468,934.202,880
radium 226 picocunes per gram
soil per application
0.08
0.05
0.02
Site life years based on 0.1
picocuries pec gram soil increase
1,2
1.9
4.1
Annuar Sludge procuction tons
988.0
2,4000
9880
lbs. per ton
2,000.0
2,0000
2,000.0
lbs per year
1.976,0000
4,800,000.0
1,975.0000
grams per lbs
454.0
454.0
454.0
grams per year
897,1 04,000.0
2.1 79,200.000.0
897,104,0000
picocuries per gram dry
425
20.1
12.8
Measured from March 9, 2004
sample
radium 226 conversion factor from
50085
0,0044
0.0044
0.0044
radium 225 concentration in soil
pcLlgram dry
019
0.09
.
005
Average application rate
1.37
3,39
1.37
IScOR application rate
4,46
446
4.46
Prepared by City of Joliet
Page 8
Department of Public Works and Utilties
April 9, 2004
r
Multiplier calculated from
application rates
0.30692432
0.760170191
030692432
estimated radiun
226
concentration in soil
pCi/gram dry
0.06
007
002
Site life based on 0.1 picocunes
pe gram soil
11
1.5
58
Radon from soil
p/Cl
p/Ci
p/cl
Radium 226 concentration in
gram
gram
gram
sludge
42.5
dry
20.1
dry
12.8
dry
ISCOR5 conversion to radon in
homes
0.159712371
0.1 5971 2371
0.159712371
estimated radon concentration in
homes
6.8
3.2
2.0
Average application rate
1.37
3.39
1 37
150085
application Rate
4.46
446
446
Multiplier calculated from
application rates
0.30692432
0.760170191
0.306924.32
Estimated radon concentration in
pci/liter
pciililer
pci/liter
homes per application
2.1
air
2.4
air
0.6
air
Site life based on 4.0
picocurles/Irter radon in homes
1.9
years
I 6
years
6 4
years
Prepared by City of Joliet
Page 9
Department of Public Works and Utilties
April 9, 2004
ciiii~i~I11\/II~
Rod R. Blagojevich, Governo
Illinois Emergency Management Agency
Division of Nuclear Safety
William C. Burke, Directo
May 10,2004
ILL/NO/SP,~OTECT/OIVENV/RONME,A~iTALAGENCy
BOW~WpC/pEnMlTSECTION
Alan Keller, P.E.
Manager, Permit Section
Division of Water Pollution
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Dear Mr. Keller:
The Division of Nuclear Safety, Illinois Emergency Management Agency, has
reviewed the request from the City of Joliet dated April
9,
2004, (contained in your letter
dated April 21, 2004). Joliet specifically requests to land apply five applications of
sewage sludge regardless of the radium concentration. The Agency recommends denial
of Jolie(s request based on public health and safety considerations.
The unrestricted land application of radium contaminated sewage sludge would
create sites requiring land-use restrictions. The limits established in the Memorandum of
Agreement between JEPA and the Division of Nuclear Safety was selected to prevent this
from occurring. Viable options are available to Joliet such that the limits in the
Memorandum can be complied with. The Agency’s comments on the Joliet proposal are
contained in Attachment 1.
Based on the information provided in Jolie(s analysis, the Agency has determined
that Joliet may be in violation of the Memorandum of Agreement. Specifically. Joliet is
applying sludge with concentrations of radium that result in the increase of soil radium
concentration greater than the allowed 0.1 pCi.’g. Attachment 2 shows the calculations
using Joliet information that indicates that Joliet may be exceeding the limits established
in the Memorandum.
CARE
MrrACt-tPvtcrJT tLiJC
1035 Outer Pork Drive Springfield, Illinois 62704
Telephone (2~7)785-9900
htlp://www.slate.il.us/iemo
Printed br the ou,hurin u/me State of
///inois
an Retitled Paper
Alan Keller. PP.
Page
\la\ IC. 2004
Please contact me regarding any administrative action to be brought against the
City ofJoliet for violating the Memorandum. Any other questions may be directed to me
at 782-1322.
Sincerely,
Richard Allen. Manager
Bureau of Environmental Safety
Attachments
cc:
Roger D. Selburg, JEPA
Attachment 1
Comments on the Joliet letter and attachment dated April 9, 2004
Fundamental Issues of Concern
In the letter from Joliet to EPA, Joliet requests permission to allow five applications of
sludge regardless ofthe radium concentration. As part of Joliet’s supporting logic, they
state, in essence, that since radon is already a problem in some homes adding more
radium to the soil would not represent a burden to the fuwre homeowners. This logic is
inconsistent with basic health physics principles of limiting public exposure. To
intentionally add to an existing problem or create an entirely new one is counter to
protecting the public health and safety.
Joliet provides insufficient sampling data regarding the radium concentration in the
sludge. Results from two grab samples were provided for each of the two sewage
treatment plants. These samples demonstrate some variability. In addition, no
information is provided regarding the timing of the samples in relation to the
backwashing of the filters associated with the hydrous manganese oxide (HMO) water
treatment process. Were the samples taken at a time that would not reflect the receipt of
the high concentration filter backwash? Joliet does not provide any information
regarding whether the backwash is sent to one or both sewage treatment plants. Since the
sewage influent will contain periods of low radium concentration associated with normal
receipt and periods of high radium concentration associated with the backwashing of the
HMO filters, will there be an associated drastic variation in sludge radium concentration?
Does Joliet blend the sludge to ensure a consistent and constant radium concentration?
The recommendation presented by Joliet focused only on Ra-226 and completely ignores
the hazard of Ra-228. In addition, the application rate proposed by Joiiet will great1~
exceed the current limits presented in the Memorandum of Understanding between JEPA
and IEi’vLA. It is not clear whether the proposed 25-pCi/g-sludge concentration is for Ra-
226 only or Ra-226 and Ra-228 combined. If it is combined then a single application
will result in an increase in soil radium concentration of 0.124 pCi/g. If it were Ra-226
only, then the total radium soil concentration increase would be 1.78 to 3.44 times higher
(based on ratios calculated from Joliet data). In addition, correcting for soil density, the
proposed sludge application rate would increase indoor radon concentration 4.5 pCi/I per
application. Five applications would result in an increased indoor radon concentration
of
22.5 pCil.
In July 2002. the Will County Health Department reported the results of indoor radon
measurements in 91 Will County homes. Of those 91. 69 demonstrated radon levels
equal to or greater that 4.0 pCi/I. with an average radon level throughout the county of
7.3 pCi/I. Both the U.S. Environmental Protection Agency and JEMA recommend taking
action to reduce indoor radon level when measurement results are 4.0 pCill or more.
There is no justifiable basis for adding to the existing problem of elevated indoor radon
concentration in Will County.
Calculation Issues
The ISCORS conversion factor for soil concentration to sludge concentration (0.0044)
assumes a mixing depth of 15 cm (6 inches), a soil density of 1.52 g!cm3 (94.85 #/ft3)
and an application rate of 10 metric tons per hectare (4.46 tons per acre). It is not clear
why Joliet is using this factor to back calculate a hypothetical sludge application for the
two fields that receive sludge and the control field. There appears to be no relevance in
this procedure.
Joliet identifies an ISCORS conversion factor for sludge concentration to indoor radon
concentration in air. Where did this conversion factor originate? It is not identified as
such in the available ISCORS documents. What are the variables used to calculate this
factor?
The calculations presented on pages 8 and 9 of the attachment only consider Ra-226 and
do not include Ra-228. The Memorandum of Understanding between IEPA and IEMA
(JDNS) does not single out Ra-266. Rather, it considers total radium.
The grams soil per acre was calculated incOrrectly. .Assuming the ISCORS values, the
soil per acre is calculated as
—
(1.52 a/cm~(l5 cm)(929 cm/ft)(43560 ft/ac)
=
922,653.072 gm;ac
The ISCORS assumption for soil density (1.52 gzcm) is not appropriate for typical
Illinois soil. Staff from the Illinois Department of Agriculture state that a value of 1.35
g/cm3 is appropriate for the silt-clay-loam soil typical of northern Illinois, Using this
value instead of the ISCORS assumption increases the soil radium concentration and
likely the indoor radon concentration by a factor of 1.52/1.35 or 1.126.
Using the Illinois Department of Agriculture value for soil density the grams soil per acre
is calculated as:
(1.35 ~cm~( 15 cm~(929crn/&)(43560 ft/ac)
=
819,461.610 gm/ac
The average application rate was calculated incorrectly for the West Sample A and B.
The correct calculation should be:
(988 tons) / (395.2 acres)
=
2.5 tons/acre
Using the corrected value for soil densit and considering total radium. Joliet may be
violating the standards and limits contained in the Memorandum of Understanding
between IEPA and IEMA (IDNS).
Sum ma rv
I.
The Joliet letter does not provide sufficient basis for modi~vingthe existing MOU.
2. Joliet’s recommendation #4 would likely result in deed restrictions limiting the
future use ofthe property receiving sewage sludge. This is an ill-conceived
precedent.
3. We agree with Joliet’s recommendation #2 that established monitoring standards
for radium (both Ra-226 and Ra-228) in wastewater treatment influent, effluent
and sludge are needed to define the variability in concentrations that will lead to a
more accurate determination of acceptable application rates and residual soil
concentrations.
Attachment
2
West Sample A
Calculation of Jotiet Radium Application Rate
influent—pCi/L
Effluent
-
pCi/L
l0bb~
L
Slud—pCi/L
8.1
Flow
—
Liters per year
12,72O,079,6?9J
Acres per year
A soil density of 1.35 g/cm3 was used for these calculations based on information
provided by the Illinois Department of Agriculture.
PicoCuries per year
—
=
Sludge activity x Flow
=
(8.1 pCi/L) x (12,720,079,620 L/yr)
=
103,032,644.922 pCi/yr
Grams soil per year
—
=
(Acres per year) x (soil density) x (15 cm mixing depth)
=
(395.2 Ac/vr) x (43.560 ft/Ac) x (929 cm/ ~2) x (1.35 g~cm3)x (IS cm)
=
323.851.228.272 g~vr
Radium per grams soil per application
—
=
PicoCuries per year / Grams soil per year
=
(103.032.644.922 pCi/yr) / (323,85 1.228,272 g/yr)
=
0.3 18 pCi/g
West Sample B
rlnnuentpCi/L
8.d_~j
Effluent
—
pCi/L
Sludge
—
pCi/L
3.1
Flow
—
Liters per year
12,720,079,6~
Acres per year
395.2
A soil density of 1.35 g/cm3 was used for these calculations based on information
provided by the Illinois Department ofAgriculture.
PicoCuries per year
—
=
Sludge activity x Flow
=
(3.1 pCiit) x (12,720,079,620 L/yr)
=
39,432.246.822 pCi/yr
Grams soil per year
—
=
(Acres per year) x (soil density) x (15cm mixing depth)
=
(395.2 Ac/sr) x
(43.560
ft/Ac) x (929 cm2/ ft2) x (1.35 a/cm) x (15 cm)
=
323,851,228,272 g/yr
Radium per grains soil per application
—
=
PicoCuries per :~ear/ OFams soil per year
=
(39,432.246,822 pCi/yr) / (323,851.228,272 g/yr)
=
0.122 pCi/g
East
Influent
—
pCi/L
Effluent—pCi/L
5.10
I
SIudEe—pCiJL
3.20
Flow
—
Liters per year
24.334,065,360
Acres per year
I
705,9
A soil density of 1.35 g/cm3 was used for these calculations based on information
provided by the Illinois Department of Agriculture.
PicoCuries per year
—
=
Sludge activity x Flow
=
(3.2 pCi/L) x (24,334,065,360 L/yr)
=
77,869,009,152 pCi/yr
Grams soil per year—
=
(Acres per year) x (soil density) x
(15
cm mixing depth)
=
(705.9 Ac/yr) x (43.560 ft2/Ac) x (929 cm/ ft1) x (1.35 g/cmb x (15 cm)
=
578,457,950,499 g/yr
Radium per grams soil per application
—
=
PicoCuries per year / Grams soil per year
=
(77,869.009.152 pCi/yr) / (578,457,950,499 g/yr)
=
0.135 pCi/g
CITY OF JOLIET
-
WESTSIDE
DATES OF BIOSOLID LAND APPLICATION
January 23, 2004
January 26, 2004
February 2, 2004
February 9, 2004
February 10, 2004
February 11,2004
April 29, 2004
May 5, 2004
May 6, 2004
May 11,2004
May 12, 2004
September 15, 2004
September 16, 2004
October 14, 2004
October 19, 2004
October 20, 2004
October 21, 2004
October 22, 2004
October 26, 2004
December 16, 2004
nr’r
,~..
,47 flflflA
L1c¼,eI
I
I
,
December 18, 2004
December 20, 2004
December 21, 2004
December 22, 2004
CARE ATTACHM&PTT liAR
Land Treatment Alternatives, Inc.
137 S. Slate St., Suite 215 • Geneseo, IL 61254
Soil and waste Management Consultants
Business
(309)
944-4112 • Fax (309) 944-4112
Illinois Environmental Protection Agency
Division of Water Pollution Control
Sludge Management Report
Year 2004
Reporting Period
Xl. January 1
-
June 30
(Circle One)
2. July 1
-
December31
NAME OF SLUDGE GENERATOR:
City of Joliet
-
Westside WWTP
NPDES PERMIT NO.:
1L0033553 IEPA# 2001-SC-2708
____________________
Indicate the Volume (cubic yards or gallons) ~ii4the Number ofDRY TONS of Sludge Generated and Disposed During the
Above Reporting Period:
SEMI-ANNUAL QUANTITY
ANNUAL OUANTITY*
(CUBIC YARDS)
(Or gallons)
(DRY TONS)
(DRY TONS ONLY)
QUANTITY OF SLUDGE GENERATED:
3,~3j~940al
267
QUANTITY OF SLUDGE DISPOSED:
______
_________
Agricultural Land Application
,~L24Q,g,~l
Dedicated Land Reclamation
____________
Disturbed Land Reclamation
_____
________________
Horticultural (Sod Farms, etc.)
______________
__________
Landfill
_____________
_____________
__________
Public Distribution
_______
______
_____
_____
Storage Lagoon
_______________
_____
Other
(Specify)
_____
______
_________
Sludge Hauler
Name(s) Sypa~oTechnologies
LEPA Permit # 2001-SC-3 167
Disposal Site Name(s)**_______
_______________
___________________
*
If this is the July I through December31 report, also indicate above the flJ~XTONS of sludge generated and disposed during
the preceding January through December.
‘~‘~
For Landfi I Disposal Onl
~
Date_L~~
Title Pl~t Ops. Supt.
Name of Contact Person Harold I-Iartv
Phone No. ~
(Please Print)
(The report shall be signed by a person that fulfills the requirements of Section 309.103(e) ofSubtitle C: Water Pollution)
This agency is authorized to require this information under Illinois Revised Statutes, 1979, Chapter III ½.5ection 1042.
Oisclosure ofthis information is required. Failure to do so may result in a civil penalty up to $10,000.00 per day of violation or a
fine up to $25,000.00 per day of violation and imprisonment up to one year. ‘This form has been approved by the Forms
Management center,
‘1 07 ‘2uOS 16:04 F.; g1$7~27215
S 7 P
FtEDLER
lit
inois Environmental Protection Agency
Division ofWater Pollution Con~ol
Sludge Management Report
Year 2004
Reporting Period
1. January 1 -June30
(Circle Otie)
X2. July 1
-
December 31
NAME
OF SLUDGE ~
-. —.
:cpDES
PERMIT ?4O.:J~Qj’55flEP~200i-S~7Q~
____
Isidi~atethe Volume (Cubic yards or ~aflons~~ the Number of
QBIJ~
ofSludge Oenerated and
Disposed
Durin2 t~:
Above Reporting Period
_____
Wy
(CUBIC YARDS)
(Or
gallons)
(DRY TONS)
(DRY TONS CE’~:
QUANTiTY
Cw
SLUDOè GENERATED;
~JJ,~I3~0~l
DL1~IQ3
Qt3ANT1TYOPsLIJDOED~$po$ED:
____
___
A~icalturaiLand Application
JjJ3360AC
.~_.
• 895 DTin2jC~
Dedicated Land Reclartxstion
______
_______
Disturbed
Land Reclamation
__________
_____
ort:ulturai (Sod Farms, etc.)
______ ,,,________
~
,andfiil
_____
“abi;c Disthbujiot
-__________
tor-a2e
Lagoon
_____
)ttier (Specify)
1ud~eHauler ~
_____
______
hsposal
Sitsr Namc(s)**
_______
______
~
_________
—~
If this is the. Jul’Q I through December
31
report, also indicate above the Qj~LYTONS of s1ud~eg erated and disposed th.zrit5-
~e preceding January thrnugh December.
~ For Landfill i3poral Only
iitle_~am ~sg~t
___
ame cii Contact Pcrson
Eq2j~j~_~
Phone No. J~j~fl24j6J.5_,,
(Please Print)
‘he
report shall be siyled ~y aperson that fulfills the re rncments
of
Section 309.103(e) of Subtitle C: Water Poilutioo)
rhis aaenc~a anitarized to requirr thjs nformaricn under tlljnotc fttvjsed Stxatu~g,1979, Choprer Ill v; Sectiar. 1342.
Thsdosuxe n(chjs intonation is required. Failure to tao
m4~
result in acivil penalcyup to $tO.000M0 per day of
viu:aL~ •,
Cr
fne up to ~25,C0O,O0pet day ofviolston and imprbon,ncx,t up
to
one year. This f~nibaa bee’ approved by the Focm:~
Manarrnen~Ccnter.
CITY OF JOLIET
-
EASTSIDE
DATES OF BIOSOLID LAND APPLICATION
January 8, 2004
November 17, 2004
January
9,
2004
November 18, 2004
January 10, 2004
November 23, 2004
January 14, 2004
December 27, 2004
January15, 2004
December 28, 2004
January 16, 2004
December 29, 2004
January 19, 2004
December 30, 2004
January 21, 2004
March 23, 2004
April 6, 2004
April 7, 2004
April 8, 2004
April 9, 2004
April 10, 2004
April 12, 2004
April 13, 2004
April 14, 2004
April 15, 2004
April 16, 2004
April 17, 2004
April 19, 2004
April 20, 2004
August 6, 2004
August 7, 2004
August 9, 2004
August 10, 2004
August 11,2004
August 12, 2004
August 13, 2004
October 27, 2004
November 8, 2004
November 9, 2004
November 10, 2004
November 12, 2004
November 15, 2004
~ARC ~1TACH4CsJtk~
November 16, 2004
Land
Treatment Alternatives, Inc.
137 S. State St., Suite 215 S Geneseo, IL 61254
Soil and Waste Management Consultants
Business (309) 944-4112 • Fax (309) 944-4112
Illinois Environmental Protection Agency
Division
of Water Pollution
Control
Sludge Management Repon
Year 2004
Reporting Period
Xl. January 1
-
June30
(Circle One)
2.. July 1
-
December31
NAME OF SLUDGE GENERATOR:
City of Joliet
-
Eastside WWTP
___________________
NPDES PERMIT NO.:
1002259 IEPA# 2001-SC-2708
__________________
indicate
the
Volume (cubic yards or
gallons)
and the Number of DRY
TONS of Sludge Generated and
Disposed
During the
Above Reporting Period:
SEMI-ANNUAL(CUBIC
YARDS)QUANTITY
ANNUAL QUANTITY4
(Or gallons)
(DRY TONS)
(DRY TONS ONLY)
QUANTITY
OF SLUDGE GENERATED:
~~~50al
1212
____________
QUANTITY OF SLUDGE
DISPOSED:
Agricultural Land Application
j~~250al~,,
J.Z12________
Dedicated Land Reclamation
____________
________________
Disturbed Land Reclamation
_______
Horticultural
(Sod
Farms.
etc.)
_______________
___________________
Landfill
_____________
Public Distribution
__________
_______
Storage Lagoon
)ther (Spcciiy)_____________
____________
,‘,!udge Hauler Name(s)_Synaairo Technologies
IEPA Permit #2001 -SC-3 167
— — ________________
‘~isposalSite Name(s)”
__________
_________
_______
_____________
______
~f this is the July I through December31 report, also indicate above the DRY
TONS
of sludge generated and disposed during
‘he preceding January through December.
For Land ii Disposal Only
Date~
Title_Plant Ops. Supt.
dune of Contact Person Harold Hartv
_______
Phone No. J~U)j24-367~_
(Please Print)
~
report shall be signed by a person that fulfills the requirements of Section 309.103(e) of Subtitle C: Water Pollution)
This
agency is authorized
in require this
information
under Illinois Revised
Statutes,
1979,
Chapter III
~.
Section
1042.
Disclosure of this information
is
required. Failure to do so may result in a civil
penalty up
to $10,000.00 per day of violation or a
fine up
to $25,000.00
per day
of violation and
iniprisonrnent
up to
one
year. This
form
has
been approved
by the
Forms
Management Center,
-.
F1EDLE~1
ti 07 200.5 i~ u~ FAX 8i57~2T2)
5
F S I
P
Illinois Environmental Protection Agency
Division of
Water Pollution Control
Sludge Management
Report
Year 2004
Repoiting Period
(Circle One)
X
•~AMEOF SLUDGE GI~NERATOR:_~j~ofp.lki
-
Easqj~eWWTP
____
_______
‘4PDES PERMIT
NO.:
_fl~2251 9J~LPA~20~2k~C-2i
___
.~
~
-—
ndicate the Volume (cubic yards or gallons) and the Number
of
jQ~ of Sludge Generated and Disposed During
tint
\bove Reporting Period:
SEMI-ANNUAL
QUANTITY
ANNI
kL
OUANDTY
(CUBIC
YARDS)
~(l~’gatlons~
(DRY TONS ON i.\
t221 7
Olin
-~
~3.30Oal.
_
kposal
Site Nam~),~__
t’ this is the
July 1 through Deetnber 31 report, also indicate above the QYQN~
of sludge generated and dspoted dur,ng
e~cectdingJenu~rvthrotsghDe~tnber.
For Landft I Disposal .J’,’
,~
~an~e
~t~U ~_
Date~
I~
ime
of Contact Person Harold Natty
__,
Phone No. j1j,5fl24-367L.__..,_...,,_,_
(Please Print)
he
report sh~i1
be signed by a person that fiitfjlls the requirements of Section 309.103(e) of Subtitle C: Water Pollution)
Ttis agency is
*jthon~dto ra4uire thu informazion under llthioisRevised Sramtes, 1979, CThapter 111 iS.
Section 1042,
Disctost~cof
*d~thlorrnziien
is rv’4uired.
Fafluic to ~OSo toZ’J re~uhIn
aciv~lptntlty up to St0,000OO pcr ~ayof ~i-ntadou
tine
up to $25.000.0O pa
da3 of
violadon and irnprisonniait up to oar var. This tnn has bccn ~ppreve4by the Loom
Managcinent Ceritcc.
L
J~iuaiy
1
.-
June 30
2..
July I
-Decemberi
(DRY TONS)
)UANT1TY OF SLUDGE GENERATED:
)IJANTITY OF SLUDGE DISPOSED.
_____
____
cgricultural Land Application
)edicated Land Reclamation
_______
______
iisturbed
Land Reclamation
_____
______
______
forticulturni (Sod Farms, etc.)
andfill
____________
ublic DisUihutiOn
:orage Lagoon
ther
(Specify)___
udge HauIet’Narne(s)~~pTechnot~gjn JEPA Pcrrnit #~00j~-3j~j
_________
221 7 DT in 2i~Q
DEPARTMENT OF PUBLIC WORKS
CITY OF
AND UTILITIES
815/724-4230
815/723-7770
M41?Q
4WJ
“flflr
‘~
ILL/No/s ENvIRONME,VTAL
PROTECT/ON AGENCY
BOWIWPC/PEAMIT SECTION
February 28, 2005
Mr Allen Keller. P.E., Manager
Division of Water Pollution ControL Permit Section
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
~OWEST2EFFERSCN ST~EE~r
- JLiET. LLINOS 6Oa32~Es
Reply to:
921 F. Washington ST
Joliet, IL 60433
U
~Uu5
ILL/NO/S ENVIRONMENTAL
PROTECTION AGENCY
BOW/WPC!PERMIT SECTION
Re:
Radium in Biosolids
Joliet Public Water Supply Facility Number ILl 970450
Joliet Eastaide Wastewater Treatment Plant NPDES 1L0022519
,Joliet Westside Wastewater Treatment Plant NPDES 1L0033553
Joliet Aux Sable Creek Basin Wastewater Treatment Plant
NPDES IL0076414 (under construction)
Dear Mr. Keller:
The City of Johet is pleased to submit a request for approval of the continued land
application of biosolids containing radium based on the 1984 Memorandum of Agreement
between the Illinois Environmental Protection Agency and the Illinois Department of Nuclear
Safety ( now Illinois Emergency Management Agency, Division of Nuclear Safety) concerning
the disposal of radium containing water and wastewater treatment plant sludge.
Paragraph 7 of the agreement is the basis for Joliet’s request. Paragraph 7 provides
for
alternative methods where it is economically infeasible to comply with other paragraphs of the
agreement and the radon exhalation rate is less than 5.0 picocuries per square meter per
second.
To support our request, Joliet employed a team of professionals to review our operations
and develop information for your review, Dose modeling was performed and is provided with
this letter.
JOLIET
Page 2
Mr. Al Keller.
February 11, 2005
The dose models were prepared using the radium concentrations for the Joliet Eastside
and Joliet Westside Wastewater Treatment Ptants, The models were based on the application
of sludge eight separate times over 20 years and nine separate times over 22 years. The
models were prepared by P551. Inc. a consulting health physics firm, and used the program
RESR,AD 6.22. This is the same model that was used by the Interagency Steering Committee
or Radiation Standards (ISCOPS) in their review of biosolids.
The program was run by RSSI, nc, a consulting health physics firm, at the direction of
the City of Joliet. The inputs to the model are in the written report and output material, The
future land use was based on single family homes with 3 units to the acre who do not have a
dairy cow or grow their own vegetables Water was to be supplied by the City of Joliet after
installation of the radium removal equipment. The applied radium concentrations were based
on Joliet experience One model with 8 applications over 20 years and another model for 9
applications over 22 years were used. All models conclude that the dose to residents is less
than 10 milli-rems per year. Modeling results are provided as Attachment 1.
A cost comparison of land application of biosolids and disposal in a landfill was also
prepared by Clark Dretz, Inc This report is also provided for your review. This report details the
increased costs that Joliet will incur if land application of biosolids containing radium was no
longer allowed
This supports our position that it is not economically feasible and that an
alternative methoo of disposal is required. This information is provided as Attachment 2.
A cost benefit comparison of the land application program based on the anticipated
increase in radiation dose and the cost of placing biosolids in a landfill is also provided. It also
supports the need icr the approval of an alternative to the methods provided in the MOA This
is information is provided as Attachment 3.
As a result of the information develcoed from these analyses. Joliet is recuesting that
IEPA-DWPC oetermine that land application of niosolics ccntaining radium ccnt:nues to be
acceotable metnod of disposal for Joliet Tnis determination is necessary so that Joliet can
proceed with toe seieciiuci of a methcd of radium removal for the Joliet Public Waler Supply
without concerns of future land application restrictions. Future restrictions could require the
installation of a different water treatment method and the associated additional costs.
The recommendation of the City of Joliet is that Joliet be authorized to land apply
wastewater treatment plant sludge to allow an increase in the background concentration of
combined radium 225 and radium 228 of 1.0 pico-curies per gram in the son. This will allow
multiple application of biosolids to the same field without adversely impacting future conversion
of the land to residential use. This also will limit the annual increase in radiation dose to a future
resicent to less than 13 milli-rems per year
IONS can advise you on the safety of allowing 10
milli-rerns per year. however. I am advised that 13 milli-rerns does not cause any ccncern to our
consulting health physicist.
Attachment L provides the calculations that suppor the 1.0
picccurles per gram
i:~.puhlicutiliiies~ waicr and sewer development program 2n03~w&sdp:003~.radiumcompliance
w&sdD2003H~asIeuisnO~airadiiin1~januar~
2005 submittal so a1 Leller~iaouar’~2003 proposal to iena for radium in
b iota lids. dcc
Page 3
Mr. A! Keller.
February 11, 2005
The increase in radium in the soil should continue to be a calculated number submitted
to tne IEPA on the basis of the radium concentrations in the biosolids expressed in picocuries
per gram dry and the application rate in dry tons per acre.
I
am available for a joint meeting of EPA and EMA after both agencies have had time to
review this information.
Consultants employed by Joliet will also be available to meet
concerning this submittal
If you have any further questions regarding this matter, please feel free to contact me at
815/724-4230.
Sincerely,
Dennis L. Duffield6
Director of Public Works & Utilities
OLD
Attachments:
1. Report of RSSI concerning Dose Modeling without RESRAD Printouts
2. Evaluation of Raoium Removal impacts to Sludge-Joliet Eastside
and Westside Wastewater Treatment Plant
3 Cost Benefit Analysis Prepared by City of Joliet
4 Calculation of Recommended Increase in Background Radium Levels
cc
John M. Mezera. City Manager
Jeffrey Plyman. Corooration Counsel
James E. Eggen. P.E., Utilities Administrator
Harold Harty, Plant Operations Superintendent
Roy M. Harsch, Gardner, Carton and Douglas
Richard Christensen, P.E., Clark Dietz, Inc
Daniel Fiedier, Land Treatment Alternatives
Mark Cleinik. P.E.. Strand Associates. Inc.
Eli Port. P.E., CHP, RSSI
Roger Selburg. P.E., Manager, PWS. BOW, IEPA
Toby Frevert, P.E., Manager, WPC, BOW, EPA
Marcia Wilhite. Manager. Bureau of Water, EPA
Jeff Hutton, Permit Section, OWPC. BOW with RESRAO Printouts
i:’~pubiicutiIities\l~arerand se\\er development program 2003~w&sdp2003\radiumcompliance
w&sdp2003\wasiedisposalradium’januar’v 2005 subrninal o aI keller\januarv 2005 proposal to epa for radium in
biosol ids.doc
Attachment I
REPORT OF RZSRAP DOSE ZIOOELTNG
FOR
WASTE WATER TRZAT?.EN’r PLANT SLUDGE
kPPLIED TO LAND CURRENTLY USED FOR AGRICULTURE
PERFORMED FOR
DEEARTMENT OF prietxc icoPacs AND UTILITIES
CITY OF :oLrsT.
ILLINOLS
6312
‘i
OkSCTON STRESI
MORTON GROvE, CLL:NOIS
October 23, 2004
~ ‘HCME,IXO 51
,, lISP s’;5lJoIie’.’Res,-~c
‘P.~OP.tQ: ~ES~.AU 00 SEMO
INTRODUCTION
Padium iRa, is a naturally occurring raoioactive eiement. It is
cresent in rock and soil and may be found in groundwater. The
more common isotopes of radium are Ra—226 and Pa-228. ?.a—226 is
the most important in terms of radiological health effects
because of its decay kinetics and metabolism. ?.a—llE and Pa-
228, collectively referred to as radium, both decay by emitting
alpha particles to two series of naturally occurrinc
radionuclides.
Surface water usuallyhas low radium concentrations, but
groundwater concentrations can be significant. Water drawn from
deep bedrock aquifers may contain concentrations of radium that
exceed regulatory standards. In Northern Illinois, hich radium
concentrations result trtm one presence of radium in the oranite
oedroc:K that surrounco the auuifers :rom whrcn water suoctiec
are drawn.
Radium in drinkir.o water nay pose a radiological health hazard.
About one-fifth of ingeste’d radium is taken up by
the
body and
the balance is excreted on feces. Some of the .absorbec radium
is subsequently excreted on urine. In the body, radium, a group
hA alkali earth element, behaves like other elements in the
group, such as calcium, end is deposited pr~marilv in bone
cortex.
The onternally deposited radium emits alpha particles that
damage tissues aojacerit to tne decaying atoms. Radiun rs riot
known to cause adverse healtn effects at levels typically found
on ~drinking water, ciet, or the environment. however, studies
of humans find that body ourdens in excess of 12 NCi result in
an increased incidence ci malignant disease.
The 3.5. Environmental Protection Agency (IJSEPAI has established
a maximum contaminant level iMCL) of 5 picocuries per liter
(pCi/l)for radium in public water supplies. The MC for radium
has been set well below levels for which health effects have
been observed and is assumed by the IJSEPA to be protectIve of
public ‘nealth. Public water supply systems whose radium
concentration exceed 5 pCi/l are not known to be inherently
unsafe, but are recuired to notify the public. These systems
must also evaluate ways to reduce
the
radium concentrations in
theor
water.
the ra’diun concentration in the
City
of Joliet .Joliet~water
supply is between 6 pCi/I and 10 poi/l, exceeding the current
NICE. Methocs are available to Jofiet’s water sucplv system to
remove radium from the water. The
total
amount of raoiu,m
remains ‘cncnangeo and racium removec trom one ‘water remains
some other form eno must be disposed of. Depending upon tne
method, treatment nay result in the radium being concentrated on
drinxing water treatment waste or ‘.~,‘astewater ‘.sewage treetmentl
sludge.
Joliet currently returns the radium initially in the water
supply to sewage treatment sludge. The sludge
is made available
for agricultural application to exploit its nutrient content.
The application of the sludge to land raises the radium
concentration uf the soil. This report describes modeling of
public dose resulting from these agricultural applications.
~THODOLOGY
RESRAD Model software
The RESidual P.ADioactivity
i
RESRADi Model, developed by Argonne
Mational laboratory, assesses the dose or risk associated with
residual radioactive material. RESRAD computes potentoal annual
doses or lifetime rosks resulting from exposure t~o raoioactive
materoal in soil, and concentratoons of radionuclides in air,
surface water, and ground water resulting from the activity in
soil. RESRAD supports cost-benefit analyses that can help in
derision-making.
The significant exposure pathways available in PESRAD mcdeling~
are direct external dose from the contaminated soil, and
onternal dose from inhalation of airborne radicnuclides
oncluding radon progeny, and from ingestion of fruita and
vegetables crown
in the contaminated soil and irrigated with
contaminated water, from meat and ingestion of milk
from
live
stock feo witt contaminateu fodder and water, from hrinkin.g
water drawn from a contaminated well or pond,
from ongestion
fish from a contaminated pond, and from ingestion of
contaminated soil.
This model of ~dose from sludge applications uses three patnways:
external exposure, inhalation, and radon. The model does not
consider plant food, meat, milk, acuatic foods, soil ingestion,
and drinking water because the planed use of land
is resident
with no option of growing iivestock or significant plant food.
Municipal water suoply will be used for drinkino, bathing .and
irrigation purposes.
External oadiatoon produces dose
from
radionuclides cuts~de the
body. Gamma and beta radiations from radionuciides dostrihuted
throughout the contaminated zone are the dominant external
radiation sources and are the only external radiati on pathways
considered in calculating soil guidelines.
The RESRAD model accepts multiple variables to describe the
environment. These are radionuclides and concentration,
rad~onuclide transport factors, time, area and thockness of the
c.ontaminated cone, cover, contaminated zone and saturated tone
hydrological data, occupancy, inhalation, and external .ganuma
‘data, unoontanonated unsaturatec tone parameters, external
1iser’ s monuai ~rr RASRAO version 6: Envoronme,qtal assessment ao,zrs:or,, J.ily
200:
radiation
area factors, me angestoon pathway, o~etary and
ounfietar,’
data, ulant factors, radcn ‘iata, ano sturase time
before use. Variables are listed below in the :NPr:: section.
The following inputs were provided by the Joiiet
or
are default
values.
F
U‘I S
Radionuclides:
Calculation time:
The dimension of
Sludge depth (Con
The length of the
The contaminated
Density of contam
Contaminated zone
Contaminated cone
Contaminated cone
Contaminate zone
Contaminated zone
Evapotranspi
Mind speed: 1.
Precipitation: 0
Irrigation: 0 me
Ac c u racy
Density o
S ,a
tura ted
Saturated
S a to rate
Saturated
Saturated cone N
•Satutatei tone b
Water table drop
Well pump intase
M•odel for water
Well punc rate:
Density of unsat
Unsaturated cone
Unsaturated cone
~ns.sturatod cone
Unsaturated zone
Unsaturated zone
:ohalat_on rate:
Mass loading for
through 25
50,000 square meters
zone): 0.2 meters
present
the field
raminated
side paraLleL to the aquifer flow:
zone soil: silty clay and
silty
clay
mated zone: 1.25 grams per cubic
cc
erosoon rate: 0 meters per :;ear
total torosity: 0.45
fielu cocacity: 1
hydraulic conductivity: 4,310
b parameter:
9.075
computations:
0.01
C:
1.25 jrams per cubic
osity: 0.45
porosity:
0.2
acity: I
rtnducti’•city:
4,310
meters
yradient: 0,02
9.075
.001
meters per year
10 meters below water table
t caramerers: nondisoersion
meters per year
488 meters
loam
ntimeter
ma—ra’z ano ra—LLc
years
ration coefficient: 0.5
5 meters per second
.8765 meters per year
ters
per year
meters
Per year
Runoff coefficient: 0.4
Watershed area for near by stream or pond: 2,532’,o’fE square
meter
5
f’or water/soil
f soturated ron
tone total por
tone effective
tone field cap
tone hydraulic
‘ydcaul
ic
pa tamer
rate: 0
depth:
cranspor
0 cubic
omet e
Per year
urated zone: 1.25 crabs per tubic centimeter
total porosity: 0.45
effectove porosity:
0.2
foeld capecoty:
0.2
hydraulor conductivity: 4,Jll’ meters per year
b parameter:
9.075
2400 uuhoo meters per rear
inhalation rate: 0.0001 grams per cubic meter
by a publoc
the Safe
Joliet has an Easoside Waste
r~ater
Treatment El
2Vesrsice
WWTP The annual radon dose and annual
resultono from two applioatoon patterns using s
Eastside WWTP and two application patterns usin
Wesrside WWTP follow.
ant WWTPI and a
totai dose
ludge from the
g ~~j~ge from the
Radium Concentrations in Sludge
Plant
Ra—226 )pCi/g•, Ra~22E .pCi~’o)
fasts ice
8.8 pCi/g
9.9 pCi;c
?Jestside
18.3
pci/g
28.9 pCo/g
Exoosure durato on: °0years
Inooor oust filtraticr. footor: 0.4
External camma sh~eacun’o factor: 0.7
:nooor tome fractoon: 0.5
Outdoor time rractoon: •~,.o
Shape of the contaminated mor.e: non—circular
Cover total porosity: C
uover vo..umetroc water content:
U
Covet radon diffusion coefficient: 0
Building foundation thickness: 3.1016 meters
Buildong foundatoon density: 2.103 gram per cubic centimeter
Buolding foundation total porosity:
0.1
Building foundation volumetroc water content:
0.03
Building foundation radon doffusion coefficient:
0.0000003
square meters per second
Contamomated raoon diffusron ooeffooient:
0.000002 square meters
per second
Radon vertical dimension
mixing:
2
meters
Buildina air exchange rate: C .3 liters per hour
Building room height:
2.5
meters
Building
indoor area factor: 0.08
Foundatorn depth below ground surface:
—1
Radon (En)—222 emanation coefficient: 0.35
Rn-20 emanation coefficoent: 0.15
Default values are bolded.
Most foelds in tde procram: 30—60 acres
The area of tne largest
field:
15’D acres (450 houses can he
boolt
~t
the L50 acres
Hc~use ormensoon: 27.5 feet by 40 feet
Ingestoon Pathway: the new homes will be served
water supply providing water that complies with
Drinking Water Act.
mouelec oosas result from. applocations
the coated ooncanorations at a
rate of .5
per acre )rer acre and moxong in soil woth
soomtr a depth of~ in
0.2 meters:.
acre onones =
l a ~
cm
At a uensutv of 1.2
per acre
The
of s
(Or
the
pCi
the
Eesuloo~oo5auoom lonrenoratoons
on urol
rr.oma songle Application
Plant
Ra—224 (pCi/.~(
Ba-
(
Easos~de
0.028 ~Ci/g
0
228
.231
(pCi/c)
p:J~g
~‘
Westside
0.058 pCi/c
0 .091 pCi/c
a a,
‘I
Application
Years
(0
18
of slucce
tons .3.1
a fensoty
ountaining
••~‘-rams
of 1.25
5
~
•8 acre inches = I a lC crams of soil
radoum in apciaa’o sludge
os distributed on
tnis I a 10° grams
coo per acre.
example, the Easoside Ra—6conrentration
is 8.3 pCi/g and
application
rate as 3.2 x 10° g/acre, resulting
in 2.8 x 10’
distributed
in 1 x io~grams of soil.
The concentration
in
20 cm thick layer is 2.8 x l0~ pCi/c.
Eastside Sludge
Model I
Model 2
Westsode Sludge
Model I
Model I
I
4
9
17
18
19
a
7
0 (0
19
20
7
19
20
a
RESULTS
The maximum annual dose
any arplication pattern
and tlestside annual and
graphic form. Eastside
Appencox A.
from tne total of all applications
is less than 3 mrem per year.
Eastside
cumulative doses follow in tabular and
and Westside P.ESP~AD modeling data are in
Eastside Model 1
Year
Annual Dose
Cumulative
Doses
Maximum 7
.
Cumulative
Year
Doses
Annual Radon
Dose
0
0.61
0.61
0.2
1
0.58
1.19
0.2
2
0.56
1.75
0.2
3
0.54
2.29
0.2
4
1.12
3.41
0.4
5
1.06
4.47
0.4
6
1.64
6.11
0.6
7
2.16
8.27
0.7
8
2.07
10.35
0.7
9
1.98
12.33
0.7
10
2.50
14.83
0.9
11
2.38
17.21
0.9
12
2.28
19.49
0.9
13
2.18
21.67
0.9
14
2.07
23.75
0.8
flis
1.99
25.74
0.8
16
1.91
27.65
0.8
17
1.84
29.48
0.8
18
1.76
31.25
0.8
19
2.31
33.55
2.31
1.0
20
2.84
36.39
5.15
1.1
21
3.35
09.74
8.49
1.3
22
3.83
43.56
12.32
1.5
23
3.68
47.25
16.00
1.5
24
3.55
50.79
19.55
1.4
L 25
3.40
54.19
22.95
1.4
E
E
U,
0
C
Applications from
Annual Dose
4.5
4.0~
Eastside Model I
—4—Annual Radon Dose
-* —
Annual Tolal Dose
3.5
3.0
2.5
2.0
1.5
10
05
0.0
—~-.
~.$
~
0
F~~~~hhhhI
10
15
20
25
30
Year
Eastside Model 2
‘.
rear
Annual Dose
.
Cumu1at~ve
Doses
Maximum 7 Year
.
Cumulative
Doses
.
Annuao Raoon
Dose
0
0.61
0.61
0.2
1
0.59
1.19
0.2
2
0.56
1.75
0.2
3
0.54
2.29
0.2
4
1.12
3.41
0.4
5
1.06
4.47
0.4
6
1.64
6.11
0.6
7
1.55
7.66
0.6
8
1.49
9.15
0.5
9
2.03
11.18
0.~
10
1.94
13.12
0.7’
11
1.85
14.97
‘0.7
12
1.77
16.75
0.7
13
1.69
18.44
0.7
14
1.61
20.05
0.7
15
1.55
21.60
0.6
16
1.48
23.08
0.6
17
2.05
25.13
0.8
18
2.56
27.69
1.0
19
3.08
30.77
3.08
1.2
20
3.58
34.35
6.66
1.4
21
3.44
37.79
10.10
1.3
22
3.30
41.09
13.40
1.3
23
3.15
44.25
16.55
1.3
24
3.04
47.20
19.59
1.3
L 25
2.91
50.19
22.50
1.2
Applications from Eastsido Model 2
Annual Dose
.
.
3.5
E
3.0
.- 2.5
2.0
/ —.4-
1.5
4~.
o 10
4—_.t.i_....____~_
05
- /
0.0
-—
———
Annual Racon
rose
LLI~T
.Azinua(
1~
I-
S
S
/
—
S..
I.’
L____........~_.........s_____________________________________
C
5
10
15
20
25
30
Year
Westside Model 1
Year
.
Annuao
Dose
,.
umulative
Doses
Maximum
7 Year
Cumulative
Doses
.
Annua~ Radon
Dose
C
1.48
1.48
0.42
1
1.42
2.90
0.41
2
1.35
4.25
0.40
3
1.28
5.54
0.39
4
2.69
8.23
0.80
5
2.56
10.79
0.78
6
2.44
13.23
0.77
7
.
3.78
17.01
1.17
8
3.59
20.60
1.15
9
4.90
25.50
1.54
10
4.65
30.15
1.51
11
4.41
34.56
1.48
12
4.18
38.75
1.45
:
13
3.97
42.72
1.42
14
3,76
46.48
1.39
15
3.57
50.05
1.37
16
3.40
53.45
1.34
17
4.74
58.19
1.73
18
6.01
64.20
2.11
19
7.23
71.43
7.23
2.49
.
20
8.39
79.82
15.62
2.86
‘
21
8.02
87.84
23.64
2.91
22
7.65
95,49
31.29
2.75
23
7.27
102.76
38.56
2.70
24
6.94
109.70
45.50
2.65
25
6.63
116.33
52.12
2.50
Applications from Westside Model
I
—.—Annua Racon Dose
Cot—
Annual iol~ Dose
Annual Dose
90
8.0
70
60
so
S
4)
U,
0
C
4°
3D
20
1.0
0.0
I,’.
//
~
p..
~.
7
~‘____
Sal.
.---iiti—-’
-~
“-S-I
~
•
-.
—~
:
a
10
15
20
25
30
Year
Westside Model 2
Year
.
aumulative
Annual
Dose
Doses
Maximum 7 Year
.
aumulative
Doses
,
.~nnual Radon
Dose
0
1.48
1.48
0.42
1
1.42
2.90
0.41
2
1.35
4.25
0.40
3
1.28
5.54
0.39
4
2.69
8.23
2.56
10.79
0.80
5
0.78
6
3.92
14.71
1.19
7
5.20
19.91
1.58
8
4.95
24.85
1.55
9
4.70
29.55
1.52
10
5.93
35.48
L.90
11
5.62
41.10
1.86
12
5.34
46.44
1.83
13
5.06
51.50
I.79~
14
4.79
56.29
1.~5
15
4.55
60.85
1.72
16
4.34
65.18
1.69
17
4.14
69.32
1.65
18
3.95
73.26
1.62
19
5.26
78.53
5.26
2.01
20
6.53
85.05
11.79
2.39
21
7.75
92.80
19.54
2.~8
22
7.42
100.22
26.95
3.13
23
7.09
107.31
34.05
3.07
24
6.78
114.09
40.83
3.01
25
6.49
120.58
47.32
2.95
E
0
0
0
0
Applications from Westside Model 2
Annual Dose
—‘4—
Annual Radon Dose
-a—- Aflnua( Total Doze
9.0
8.0
7.0
6,0
5.0
40
3.0
2.0
l.a
0.0
s-s.
,0’
-
a.
~
0
10
15
20
25
30
Year
CONCLUSION
The
Cosococr.3 :acement
0t the
health 9hvsocs Socoetv, Radiation
Risk on Rerspectove, a tares, “In accordance with current
Know~eoge
of
radiation health rrsks, the health ?b,vsics Society
reccnvnends against quantitative estimation of health risks below
an ondividual dose of S rem in one year cr a lifetime dose of 10
rem above that receivec from natural sources. Relow these
doses, risk estimates should not be used; exeressions of risk
should only be qualitative emphasizing the inabilit’; to detect
any increased health detriment i.e. cerc health effects are the
most likely outcome)
The above notwithstanding, attempts have been made to quantify
risk from low dose cadoaticn. ‘JSE?A nas used the most
cor.serva:ove avai1able
‘
‘alue, I x l0~car 1030 mrem from 1~CF.P
For s ;naxOn~,um
1,1
ICaL’ :.jmulaco’:e .cose cr 1.c0.of mcem or.
destside l4cdel I, the calculated oncrement In risk
is ‘ix
l0~
The horsmo censor;
.over
the 405 acres, to which sludse is beono
appiied, will be a
maxorLum of
3
houses per acre with a Joliet
average of
3.3
individuais
per house.
Therefore,
4253
indivoduals will he afiectad by these applications.
If sludge
with concentrations
o: P.a—226 and Ra—225 from the Westside plant
is applied using Model
,
the collectove
dose will be 513
person-rem.
The a’;erooe cesidencool frcpercocurnc’:er
rate os
‘ ccc year.
Etor a maxomum 7 year cumularove dose ci 47 mrem In d’es:side
Model 2, the calculated
Increment in rosk os 2.4
:
Attachment 2
Evaluation of Radium Removal Impacts to
Sludge Handling at the Eastside and
Westside Wastewater Treatment Facilities
Prepared For:
City of Joliet
Clark Dietz. Inc.
1817 South ~eil Street. Suite 100
Champaign, IL 61820
AUgUSt 2004
Evawarion or Roe/ion I?c,picivai
/fll000s
to .57nci~eHw1ati,7~
ci
the Euvt.cide and
W~asrsecIe~Vosteyater T;’c’atrnent Facilities
Jo/jet. Illinois
TAULE OF CONTENTS
1.1)
INTRODUCTION
I.!
Project Background and Objective
2.0
EXISTING SLUDGE HANDLING AND DISPOSAL METHODS
2.1
Westside
WWTP
2.2 Eastsidc WWTP
2.3
Land Application olSiudge
2.4
Current Costs for land Application
3.0
IMPACT OF WATER TREATMENT RESIDUALS
3.1
Racfium Removal Requirements
3.2
Proposed Water Treatment Technology
0.3
Current Radium Levels in Existing Sludue
4.0
ANALYSIS OF LANDFILL ALTERNATIVE
4.!
Design Objective and Approach
4.
Capital Costs tar New Dewatering Facilities
4.3
Annual O&M Costs for New Dewatering Facilities
4.4
Other Costs
4.5
Advantages and Disadvantages
5.0
RECOMMENDATION
tiarA Djetz,’nc.
I
August 2004
Eva/nat
ic i
or I? ad
mu
Re,nou
‘j/
Inwarts
to S/i tile
Hc
in ct//ti g
in
the
Ens o
tile
one
WestsitJe fta,vtesviztej’ Treatment buciltiws
Jo/jet,
Illinois
I INRODUCTION
1.1
Project
Background and Objective
The Ci1:~ofioliet currently owns and operates two w-astewater treatment facilities which
treat the City’s wastewater. The Eastside W WTP, located on the east side of the River. has
the capacity to treat an average daily tiow of 8 MCD, while the Westside WWTP has the
capacity to treat an average daily flow or’ 14 MCD. In addition, a third ~vastewatertreatment
plant. located on the far western edge ol’ the City in Kendall County, is currently under
construction,
which has the capacity to treat 3.2 MCD.
1he Fastside and Westside treatment facilities consist of the secondary treament activated
sludge process with primaiy settling upstream ofthe aeration tanks. The clarified effluent is
sent
directly to the receiving streams. The waste biosolids from the activated sludge process.
as well as the primary sltidge, is sent to the anaerobic digesters tar stabilization. After sludge
stabili,ation. the stabilized sludge is stored in holding tanks to he land applied on local
fanners’ fields.
As
part of the City’s continued population growth. the City is currently in the process of
providing upgraded and expanded water treatment facilities, Regulations require the City to
remove radium from the water supply. Due to the type of radium removal equipment.
concentrated discharges of filter backwash from the co-precipitation of radium with hydrous
manganese oxides will be discharged to the sewer system. causing radium to accumulate in
the biosolids. The radium accumulation in the biosolids will be similar to the radium
accumulation occurring at the present time. The waste sludge to be land applied may exceed
the
allowed amounts radium and may require that the waste sludge is disposed or in a landfill
rather than continuing with the current practice of land application.
The purpose of this report is to review the costs, as well as advantages and disadvantages, of
changing from the practice of land application ofbiosolids to disposal of the biosolids in a
landfill.
C/am’k Diet:. fire.
.-4ugust 2004
Evci/ucicion or
Raoiniri Rcmovui firrpacis
to
S/nc/en iforrcuiirc~
,it
die
Easrside
coil
IVe.vt.v,c/e II’c,steuvarci’ r10~it/lie/fl F(c’t//ties
/0/WI.
Illinois
2 EXISTING SLUDGE HANDLING AND DISPOSAL METHODS
2.1
Westside Wastewater Treatment
Plant
Ihe Westside Waste~vaterTreatment Plant was designed for an average daily flow of 14
MCD
and a peak flow of 23 MCD. The plant consists of an influent pump station which
pumps the flow to an intluent channel where it flows by gravity through a Parshall flume to
the grit removal tanks. The waste\vater then flows to the primary clarit3ers for primaiy
treatment and then on to the aeration tanks for removal of CBOD and ammonia from the
wastewater. After secondary clarification, the treated wastewater is discharged to the Des
Plaines River.
The primary sludge from the primary clarifiers. and the waste sludge from the secondary
clarifiers. are both sent to anaerobic digesters for sludge diu’estion. The digested sludge is
then transferred to sludee storage tanks whei’e it is held in storage until it can he land applied
to local farm tields. There are no thickening process units prior to the sludge storage tanks. It
is estimated that the sludge storage tank decant system will allow the operator to thicken the
sludge to the b to 3 percent range while in stoiage.
Based
on the i’ecords from the City ofioliet Land Application Program for 2003. the amount
of biosolids produced by the Westside WWTP and land applied was 895,3 dry tons. This
amounted to a liquid volume of sltidgc of 3.69 million gallons.
2.2
Eastside ~VastewaterTreatment Plant
The Eastside Wastewater Treatment Plant was designed for an average dail\ how of 18.2
MCD and a peak flotv of45 MCD. The plant consists ofan intluent pump station which
pumps the flow to an iofltient channel where
it flows by gravity to the grit removal tanks.
The wastewater then lows to the primary- clarifiers far primary treatment and then on to the
aeration tanks for removal ofCBOI) and ammonia from the wastewater.. \t’ter secondary
clarificauon. the treated ~\astewateris dischartted to the Des Plaines River
the primary sludge from the primary clarificrs. and the waste sludge tram the secondary
clarifiers. are both sent to anaerobic digesters for sludge digestion, The digested sludge is
then transferred to sludge storage tanks where it is held in stotage until it can be land applied
to local farm fields. A gravity belt thickener thickens the waste activated sludge and the
digested sludge.
Based on the records from the City ofioliet Land r\pplication Program for 2003. the amount
of biosohids prodticed by the Westside \V~TPand land applied was 2217.3 dry tons. This
amounted to a liquid volume of sludge o(\7.03 million gallons.
C/ark Diet:. Inc
3
.‘t
~usr
2004
Evaiunrt,cir or
Radiritn Rcniovc1i
finpLicis
to
S/udge hand/me or c/re
Easiside rind
It’e.sgside U’asceivaic’r rreart0ent
Facilities
.Jolicl. DOnors
2.3
Land Apphication of Sludge
Both the Eastside and \Vestsidc wastewater treatments use land application as the ttltimate
disposal option for the scastewater sludge generated by the treatment process. The sludge is
stored onsite in large sludge storage tanks and is taken to local farm fields by contract sludge
haulers.
The City currently uses about 23 different land application sites with a total area of
approximately 1287 acres. All oI’these sites are located in Will County, Illinois. The
biosohids are apphicd during approximately six months out of the year. A total of 25.7 million
gallons of hiosolids
were applied in 2003.
The local farmers agree to take the biosolids in order to provide the nitrogen required for the
crops. 1 here i5 a stibstantial difference between the biosohids generated by the Eastsid~plant
and the biosolids generated by the Westside plant. The Eastside hiosolids are lower in
nitrogen and therefore reqture note volume per acre (upproximatel~32.300 gal/acrei. The
Westside biosolids nrc able to meet the crop nitrogen reqturcments with approximately
21,400 gals/acre. The plant personnel attempt to obtain 6 to 3 solids in the sludge storage
tanks in order to reduce transportation costs and allow for more nutrient ~alue per gallon of
bioso lids.
The site application life for the farm fields is based on total phosphoi-us applied and is
generally limited to five years. The application of sludge to a field may not occur over five
consecutive years. hut nay be applied over 10 or more \eai’s, Application to a specific field
during a year depends on the crops planted. harvest time, rainfall, and other factors. The
sludge is applied to the farm field using chisel plows that inject the sludge o to 8” under the
surface.
The sludge from both plants consistently fleets Class B requirements for sludge disposal by
land application. Ihe anaerobic digestion process provides enough detcnti~ntime and a high
enough temperature to control pathogenic microorganisms. The majority of the biosolids are
injected below the soil surthce to allow nutrients to be readily available to the crop roots,
2.4
Current
Costs
for Land Application
he City bids out for the hauling services to haul the hiosolids to the tyrm fields for land
application. The cost for battling and disposal at the farm fields has historicall~ranged frotn
2 to 2.4 cents per gallon according to City records. This results in an approximate annual cost
of$6 17.000 based on the 2003 volumes of sludge removed from the wastewater treatment
plants. The City does not charge the landowners far the biosohids.
Clink Die’:. Inc.
4
.~ugus/2004
Ei~’c,i
1/UtiOt?
‘.1
Rout
teiri
tlci)cr)car
fnipocts to .Sluage F/airaimng
Lit
//re
Euszsiile
and
l1esLvl(le
fIaszeu airy Tie
atn,ent
Foe
b//ties
Jo/jet. ilhino,s
3 IMPACT OF WATER TREATMENT RESIDUALS
3.1
Radium Removal Requirements
The Safe Drinking Water act requires the removal of radium from drinking water supplies
down to the level nf5 picocuries per liter. The City ofiohiet’s water supply contains
naturally occurring m’adiumn at a level above the required 5 picocuries per liter limit. The City
is in the process ofevaluating water treatment technology to he installed at the new water
treatment facilities tbr the removal of radium from the water supply.
3.2
Proposed Water Treatment Technology
The radium removal technology being considered at present is hydrous manganese oxide
technology. The backwash horn the regeneration cycle will contain concentrated forms of
radium which can be discharged to the City’s wastewater collection system, and eventually.
to the treatment thcilities downstream. While the concentration ofraditmm in the backwash
stm’eam will he higher than the naturally occun’mng radium levels, the mass loading of raditim
to the wastewater treatment plants is not expected to change dtre to the mechanisms
by
which
radium is absorbed.
3.3
Current Radium Levels in Existing Sludge
The proposed water treatment technology is not expected to increase the amount of radium in
the sludge. Jests on the sludge and the t’armers’ Fields have indicated radium levels that have
not exc~-cdedhackeround levels of m’adium.
Since the mass loading ot radium is not expected to change, the quantity ofradiumn in the
waste siudge from the plant is not expected to change from the current levels. here tore, the
amount of madium currently being applied with the biosol ids to lhrm fields
\vi
II not he
inem’eased due to the installation of new water treatment technology.
r.
lurk
fame,:,
2,rc.
5
.
uglist 2004
!tYcI/tliJItl)ii (It Rizitiunc Demo vol Impacts to Sludge Humid/inn’ ut die
Eestszde and
West.side tVasteirater ii’catinent Fciciliz/e.y
jo/ice,
f/llno,s
4 ANALYSIS OF LANDFILL OF ALTERNATIVE
4.1
Design Objective and Approach
In evaluating the range of feasible alternatives for the tiltimnate disposal of sludge, if land
application is not available due to i’adiuni issues. the options that are available to the City ai’e
limited. Since there is a limiting constituent in the sludge (radium), options such as
composting and eventtmal use as soil amendment will have the same limitations as land
application. Therefoi’e. the only option available for ultimate disposal is disposing of the
sludge in a
landfill.
In order to decrease the amount of solids to the landfill, additional processes such as
incineration can be considered. Doe to the high capital cost, significant increase in operation
and maintenance costs. and the air pollution control considerations, the option of incineration
will not be considered at this
tune.
Instead. landfill disposal preceded by dewatering of the
sludge will he evaluated,
Landfill disposal will i’equir’e additional dewatering of the sludge in order produce a cake like
product without any free water. Belt filter pi’ess dewatering facilities will be i’eqtrired to
accompiish the required dewatering.
Belt filter presses can typically achieve between IS to 25 percent cake solids, In order to be
conservative in the amount ot sludge dewatered and disposed ofin the landfill, the cake
solids will be assumed to be 16 in the devvatered sludge. This will produce a somewhat
higher volume ofdried sludge for landfill disposal. The estimated sludge production l’rom the
wastewater treatment plants. based on design capacity how rates, is as follows:
Eastside Plant
Daily Production at 6 Solids wet)
40.000 gpd
Annual Prodtrction at 6 solids I wet)
14,600.000 gal
Annual Prodtrction at 16 solids (wet)
5.475.000 gal
Annual Solids
Production
47,487.960 lbs
Westside Plant
Daily Production at 6 Solids (wet)
34,000 gpd
Annual Production at 6 solids (wet)
12.410.000 gal
Annual Production at I 60o solids (vvet)
4.653,750
gal
Annual Solids Production
40,364,766 lbs
Clink
Diet:.
Inc
6
.1ugust
2004
Evcur,cuion of
Rorutum; Remnoi’ai Impacts to Sludge
h’andim;i~a: ore Rusts/dc end
TVesesjde
IVusee water
Treuonent Foci/u ie.s
jo/jet, Illinois
Therefore, the total solids reqturin~landfill disposal is approximately -T3.927 :ons. This
amount of material will require hauling from the plant and disposal at the landfill.
4.2
Capital Costs for
New Sludge Dewatering Facilities
New sludge dewatering facilities \vill consist of the following components at each ofthe
wastewater treatment plants:
Nenj building:
A
new
building will be required to house the dewatering equipment.
Dewatering equipment:
‘he
devvatering equipment will consist of belt filter presses. sludge
feed pumps. sludge conditioning equipment, polymer mixing and feeding facilities, conveyor
belts, sludge hoppers and trtrek loading areas.
Dried sludge storage:
In cider to
account for scheduling of trucks to haul 5udge to the
landfill, some type ofdried sludge storage facilities will be needed. This will most likely
consist of a large pole barn type building.
Odor control
facilities:
The sludge dewatering building and the sltrdge storage building will
be the source of significant odors. Therefore, extensive odor control facilities will be
required to remove the i’equired air changes per hour and treat the air for odors from these
two buildings.
Site
piping:
Significant piping modifications will be required in oi’der to route digested
sludge t’rom the digester’s to a new dewatering building.
Electrical:
‘he new dewatering facilities and odor control equipment w
ill require that new
electrical be routed from tire existing \ICC’s to the new buildings.
The capital costs for new sludge dewatering and odor control facilities are estimated as
foil ovvs:
Eastside Plant
New Building
$750,000
Dewatering Equipment
$500,000
Odor Control
$750,000
Dried Sludge Storage
$450,000
Electrical
$200,000
Site Piping
$250,000
Site Restoration
$50,000
\lisceilaneous
$50,000
Construction Cost Sub-Total
53,000.000
Clark Dieo, inc.
7
.1ugust 2004
Ervu
uatiOmm of
Pair
rmr Remmrovcl Immrpctc:s to
Sludge
Ham ma/i rig ~rrtire Eastsrde
~a
(Vest.crde rra,vuOcarer 7’reatnrent Facilities
.10/jet.
Illinois
Contingency
5600.000
Non-Construction Cost
5450.000
Project lotal
$4,050,000
~VestsicJePlant
New Building
$750,000
Dewatering Equipment
5500.000
Odor
Control
5550.000
Dried
Sludge Storage
5350.000
Electrical
$200,000
Site Piping
5250.000
Site Restoration
$50,000
Miscellaneous
.S50.000
Constrttction Cost Sub-Total
52.700.000
Contingency
$540,000
Non-Construction Cost
5405.000
Project Iotal
$3,645,000
4.3
Annual C) & .\I Costs for New Sludge Dewatering Facilities
In addition
ro the capital costs discussed above. there will be ongoing annual costs to operate
and maintain
the facilities, as well as the hauling and disposal costs for the dried sltrdge. The
annual 0 & M costs. for both
the Eastside and \Vestside plants. are estimated as follows:
Operation ot’presses
Powcr.
staft’. polymen
$400,000
Odor control facilities
5350.000
Hauling costs at $7.00 per ton (44,000 tons)
$308,000
Disposal costs at $30.00 per ton
51,320.000
Total
$2.3 78.000
Therefore, the estimated annual cost
for operating new sludge dewaterinti facilities and for
hauling and disposing the dried sludge at a landfill is approximately 52.400.000 per year.
This is a significant increase in operating costs for the City ofJoliet. This annual amount has
a present worth value over 20 years at the current rate ofinilation is approximatei~537
million dollars.
(‘lark
Diem:,
Inc
8
.4 ugu~t21)04
.•‘ivauicmtiomm at /?oc/irmmmr Rcorrivo/ immipoces to Sludge Homx/ling at time Rests/dc and
iVe,vtsu/e rp~z,vterivuem’
Trc’citmnent
Fact!
it/es
b/wi. Illinois
4.4
Other Costs
In addition to the capital and 0 & \I costs listed above. there are a number of other costs due
to switching to land fill disposal, some of which are not as easily quantified. These costs
include the following:
L,Tse
oJuui’iilahle landfill space:
The amount
U
f sltidge to
he disposed
of in a landfill is
approximately 44,000 tons per year. By using this available landfill space for sludge disposal
it reduces the capacihl available for normal domestic waste disposal. Normal domestic solid
waste generation is estimated to be approximately 4.4 lbs per person per day.
At this rate,
and considering each household to consist of 3.5 persons, disposal of waste sludge at a
landfill
will use the eqtuvalent capacity of over 15,000 households each year,
It is getting niore arid more difficult each year to site and permit landfills. heretbre, this
disposal alternative does have a significant impact on the available landfill capacity.
Nutrient value otsludge:
The
sludge which is currently land applied pro’. ides a substantial
nutrient benefit to the local farmers who participate in the pro~ram.The nutrient components
of the existing hiosolids consist of nitrogen, phosphorus, potassium, copper. zinc and
manganese. ‘he fertilizer value of the applied biosolids has been estimated at 530,28 per’ acre
in the first year of the program and at .544.65 per acre in the fourth year of the program. On
the average, the fertilizer value is .537,47 per acre. Based on a total acreage in the program of
1287 acres, the current benefit to the local farmers is a cumtilative annual savings of
approximately $48,000.
If the City is required to switch to landfill disposal, the local farmers wil I rave this added
cost due to the required purchase of fertilizer for their fields,
,4bandon,nent ot’extctingJacilities:
The existing
sludge storage thci lities would no longer
be required ifthe biosolids were disposed of in a landfill, These facilities consist of large
sludge storage tanks as well as iii ixing and transfer pumping systems. There are very few
equipment items from these systenis that can be used in the new deyvatering facilities.
Therefore, these facilities will be abandoned and the capital investment will he returning no
value as the facilities sit in a mothhalled state,
The construction cost of the existing sludge storage int’rastrtmcture at the Eastside Wastewater
Treatment Plant was 52.964.330. The construction cost of the existing sludge storage
infrastructure at the Wcstside Wastewater Treatment Plant was 54,075.000. Therefore. the
total cost of existing int’rastructirre that would be abandoned by going to landtill disposal is
approximately 57,000.000.
Clark Diet:, Inc.
9
.lrigiisl
2004
Eta!
uatiomm
of
Red)tan
Removal limipacts
to S/ridge Handling am the Las
tside and
Westside Was:etvuzer Treatment Facilities
Jo/ic!,
Illinois
5 RECOMMENDATION
Based on the costs required to switch to landfill disposal of the sludge, the landfill disposal
option of the sludge is not cost effective, The costs are summarized as follows:
Parameter
Planning Period. years
Inflation Rate,
Capital
Cast
Installation Cost
Present Value Capital Cost
Operatine Costs per Year
Present
Value Operatrnu Cosr
Total Lire Cycle Cost
-
Prescnt
Value
As
can be seen &om the above table, the present value life cycle cost is over 544 million
dollars, versus trnder $10 million dollars for the existing land application practice. This does
not account for the cost of abandoning facilities, the nutrient value of the sludge. or the
landfill space taken up by landfill sludge disposal.
Therefore, since landfill disposal olsludge is not required for environmental reasons, it is
recommended that the current practice of land application of the sltmdge on local thrmers
fields be continued as it is the most cost effective option for ultimate sludge disposal.
Proposed
Existing
L
Landfill
Land
Application
20
20
2.5
2.5
$7,695,000
~M1
52.378.000
SO
$61 7.000
.L
~&
Sa.-fl~~
(‘lark Diet, Inc.
10
August 2004
/712005
Attachment 3
Iacjp
oil
Calculation of Benefit to Cost Ratio
The benefit to lie public is hid cods are saved by cUriE
sins cit
Land appl’calion ciI biosolids(waslewalei in ealinent plant SIud9e)
The
savsiisjs
,‘ssucsaIed
wiiii
las ist spplicaliuii swore calculated by Claik Dietz, Inc sit lie upon entilled
Evaluation ol Radiuiii Eeiausat lisipacis on Sludge Ilandsisig at
tie
Eastsnsie arid WcsIsisje Waslowater Treatment Plants
The repoil provides 20 veal costs and must be adjusted 1325 years Adjsisrments were made to the operahing costs Only
Jolic I Easlsiste
Joliet Wesiside
Total
Capital
$
4.050,00000
$
3,645 000 lId
t
7,695 00000
20 year operating snciease
$
15 647 933 55
S
lb 804.58 45
$
27,452 51500
year tolal
$
19.697,93355
$
15.449.58145
$
35,147,51500
25 year total
$
22,543 536 32
$
17.596,49056
$40,140 32688
lie custs to the public are the cost associated with additional radiaiion eiposure The Nuclear Regrslaissiy Cctmrnilssion published
c:osls in 1995 at $2,000 per person tern Tins cost inhales to $2,500 per person rem in 2004 siding the consurirei pi ice index
tJ~niy
the radiation dose tar 25 yeas sum liii P551 S billy entaleri ‘ NE P0111 01 NE SRAIT MODEl INC Oil WAS I EWATER
TREATMENT PLANT SLUDGE APPLIED TO t 0110 CORNER IL’( IJSED ION ACIICUL lORE
The
25
year closes are as follows’
Jul el E asiside
Juliet Weslsrde
I clot
50 1 9000 mrenl
12058 mreill
1/0 77 mrem
curtvc-0 ho rein
000100 teiil’iniem
1)00100 reovmiern
000100 rens/mrenr
005019 rem
012058 renl
017077 tern
Acres receivitig biusolids
705 00
40500
1 11000
homes per acre
300
3 00
300
homes
211500
121500
3330 00
licuple pci home
3 50
3 50
3 50
People
7,403
4,253
11,655
371 53 poisOn rem
51277 person ieni
884 30 person-rem
$
2 50000
$fpeison-iem
S
2,50000
$/peison.resn
S
2,50000
S/person-rem
$
918 IC~HhO
Cost
$
I 281,916 13
CostS
$
2,210744 81
Cost
bIc’nulsts
$
22 543 835 32
$
1/,596,49056
$4014032588
Costs
$
928 12569
$
1,281,916 13
$
2.210.744 81
RaI,o
24-27
13.73
18,16
Jolier Eastside
Joliet Westside
Joliet Total
1/7/2005
Attachment 4
Page
I of 2
Calculation of Recommended Increase ID Background Radium Concentrations
Prepared by Ctty of Joliet, Department of Public Works and UtIlities
Concentrations in Sludge
Combined
Radtum 226
Radium 228
Radtum 226 and 228
plcocurles
picocurles
plcocurles
per gram,
per gram,
per gram.
Easlside
8.8 dry
9.9
dry
18.70 dry
picocu ne S
picocuries
picocu ries
per gram,
per gram,
per gram,
Weslside
18.3 dry
289 dry
47 20 dry
concentration in Soil after application at 3.5 dry tons per acre
Combined
Radium 226
Radtum 228
Radium 226 and 228
pic:ocurtes
picocuries
ptcocuries
per gram,
per gram,
per grain,
!~astside
0.028 dry
0031 dry
0.059 dry
picocuries
plcocurles
plcocurtes
per gram,
per gram,
per gram,
Westside
0,058 dry
0.091 dry
0 15 dry
I:\PublicUtilities\1 Water and Sewer Development Program 2003\W&SDP2003\Radium compliance W&S0P2003\wastedisposairadiumUanuary 2005
submittal to At KeiIer\ESTIMATED DOSAGE FROM ANNUAl, APPLICATIONS
)/7/2005
Attachment 4
Ptge
2
of 2
Calculation of Recommended Increase in Background Radium Concentrations
Prepared by Ctty
of Jollet, Department of Public Works and UtilitIes
From the RESRAD Modeltng, one appltcatton of sludge from the Joliet Westside Wastewater Treatment Plant at
3 5 dry Ions per acre results tn a dose of 1 .48 milli-rems per year for the first year
If 10 mtllt-rems per year is accepted as the dose limtt, how many applications may be made?
1000 milli-rems total
1 48 mIllI-rems per application
6 76 applications
6 76 applications
0.15 pico-curie per gram increase tn background per application
1.01 plco-curle per gram increase in background
use
1.00 pico-curies per gram
This is somewhat conservative due to the normal decline in dose over time
l~\PublicUtilities\1Water and Sewer Development Program 2003\W&SDP2003\Radium Compliance W&S0P2003\wastedtsposalradium\January 2005
submittal to Al Keller\ESTIMATED DOSAGE FROM ANNUAL APPLICATIONS
K~1iII~I1
I~\/1I/~s.
Rod R. BIago~evich,Governor
Illinois Emergency Management Agency
Division of Nuclear Safety
William C. Burke, Director
May
9, 2005
Mr. Alan Keller, PB.
Manager, Permit Section
Division of Water Pollution Control
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O.
Box 19276
Springfield,
IL 62794-9276
Dear Mr. Keller:
The Illinois Emergency Management Agency, Bureau of Environmental Safety,
(Agency) has reviewed the request from the City of Joliet dated February 28, 2005,
(contained in your letter dated March 3,2005). Joliet specifically requests to land apply
sewage sludge containing radium such that the radium concentration
in the soil receiving
the sludge would be increased 1 pCi/g.
The Agency has questions regarding Joliet’s application that must be addressed
before a decision can be rendered. The questions have been separated by the application
document and
identified by page and paragraph.
Joliet transmittal letter:
Pg 2,
6th
paragraph
—
Joliet requests authorization to increase radium soil concentration
by I pCi/g. This is ten times the current limit established in the Memorandum of
Agreement
between IEMA-DNS and TEPA. Joliet makes no commitment as to the
specific
number of applications, the application rate, or the application schedule. They
provide various scenarios as examples but do not make any guarantees they will adhere to
these examples. Calculations can demonstrate that different application scenarios could
result in a situation that will result in doses to
the public that exceeds those of the
examples. Joliet needs to provide clarification and or commitment on how the sludge is
applied and to
what degree the sludge is blended into the soil mass. Alternatively, your
office
may decide to dictate these values, but in any case we suggest that these values
need to be conditions of the permit.
Q~Rg_ATrA(~Mei’J1‘X
1035 Outer Park Drive . Spr~ngfieId, Flinois . 62704 Te~ephone(217) 785.9900 Http://w*’wstatei.us/iemc
Printed by the authority of the State ofIllinois an Recycled Paper
Mr.
Alan Keller. P.S.
Page
4
May
9, 2005
Attachment 4— Calculation of Recormnended Increase in Background Radium
Concentrations.
Was
Joliet planning on taking decay of Ra-228 into consideration in calculating when
soil concentrations are increased I pCi/g? If no, then the number of applications would
be limited to the same number as calculated by using a dose limit.
Any questions or concerns related to this correspondence should be directed to
Gary McCandless at the address above or at (217) 782-1329.
Sincerely,
Richard Allen, Chief
Bureau of Environmental Safety
RA tlk
cc:
Roger Selburg, IEPA
