BEFORE THE POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

REVISIONS TO RADIUM WATER

QUALITY STANDARDS:

PROPOSED

NEW

35

ILL ADM CODE 302.307

AND AMENDMENTS TO

35

ILL ADM

CODE 302.207 AND

302.525

)

)

)

)

)

)

)

RECEIVED

CLERK’S OFFICE

JUN

022004

STATE OF ILLINOIS

Pollution Control Board

R04-21

Rulemaking

-

Water

NOTICE OF FILING

To:

See Attached Service list

PLEASE TAKE NOTICE that on June 2, 2004, we filed the Illinois Pollution

Control Board the attached

COMMENTS

SUBMITTED ON BEHALF OF WRT

ENVIRONMENTAL (ILLINOIS) LLC

with the Pollution Control Board ofthe State

Letissa Carver Reid

WRT Environmental (Illinois) LLC

Sonnenschein Nath & Rosenthal LLP

8000 Sears Tower

233

S. Wacker Drive

Chicago, IL

60606-6404

IN THE MATTER OF:

ofIllinois.

Jeffrey C. Fort

THIS FILING IS

BEING SUBMITTED ON RECYCLED PAPER

---

BEFORE THE POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

JUN

02

2004

IN THE MATTER OF:

)

STATE OF ILLINOIS

)

Pollution Control Board

REVISIONS

TO

RADIUM WATER

)

QUALITY

STANDARDS:

PROPOSED

)

R04-21

NEW 35 ILL ADM CODE 302.307

)

Rulemaking

-

Water

AND AMENDMENTS

TO

35

ILL ADM

)

CODE

302.207

AND

302.525

)

COMMENTS SUBMITTED

ON BEHALF OF

WRT ENVIRONMENTAL (ILLINOIS) LLC

These comments are submitted by Sonnenschein, Nath & Rosenthal LLP on

behalf ofWRT Environmental (Illinois) LLC and its

related companies (“WRT”)

pursuant to the schedule for submitting public comments.

WRT also requests fora

further merit hearing before the Board considers this

matter for second notice.

At the

close of the public hearing on May 6, 2004, the Hearing Officer stated that the record

would close on June 3, 2004, and that any public comments

or request for further hearing

should be made by that time.

WRT was established to

aid municipalities in their efforts to

provide safe drinking

water, particularly with respect to the removal of radium and uranium as requiredby

U.S.EPA’s Radionuclide Rule.

All radium or uranium removal processes generate

radioactive residuals, but many communities

do not have the expertise

for the

safe

handling, transportation and disposal ofthese residuals.

WRT’s goal is to provide for the

safe removal ofthe contaminate from the rawwater supply,

and to ensure the final

disposal into a safe, secure licensed disposal site.

2

---

To that end, WRT contacted IEPA and the then IDNS in early2002,

and

commenced its first pilot plant that summer.

The pilot plant was run for approximately a

year and led to the issuance ofa permit for the Village of Oswego in the fall of2003.

At

about that time WRT met with representatives of the Board and the Agency, as well as

the Illinois Emergency Management Agency, and continued discussions with IEPA and

IEMA through the winter and

spring of2004.

The purpose of these meetings was to

advise the relevant agencies ofthe benefits ofthe WRT System, as it applied to the

removal ofradium from drinking water supplies in

Illinois.

However, WIRT was not

notified ofthe filing ofthis petition, and

learned ofthis proceeding only last Thursday,

May 27, 2004.

WRT has now had the opportunity to

reviewS the transcripts ofthe

hearings held, and was surprised to find no

reference to the existence oftechnology, such

as the WRT System,

that would allow the existing water quality standard for radium to be

maintained.

Nor does the record appear to contain any general review ofthe available

technology or economic costs associated with compliance technology were the existing

standard to be relaxed.

And we were very concerned to

see that there is no information

presented concerning the effect on sewers from backwash activities nor on accumulated

radium levels in sludge that could become land applied.

Some ofthe information that we believe relevant to

this proceeding is contained

in the exhibits

to this comment.

Exhibit A hereto is a copy of a letter dated

September 15, 2003, sent by WRT to

Chairman Johnson which sets forth WRT’s

perspective on the issues raised by this proceeding.

A similar letter was sent to

IEEPA and

other relevant agencies.

Exhibit B is a report entitled “Illinois

Summary ofRadium

Removal Methods and Disposal Issues as they Relate to Radium Removal from Drinking

3

---

Water,” dated May 2004.

And Exhibit C is

a copy ofthe permit issued by IEPA to the

Village ofOswego for use ofthe WRT System to treat for radium in its public water

supply.

The WRT System can achieve treated water quality that meets the existing radium

standard, which the Agency now proposes to

delete.

It can achieve those levels due to its

approach ofremoving radium from the raw water supply and separating it into a separate

solid waste medium, which is then disposed in

a low level radioactive waste landfill.

By

this approach, the WRT System avoids the need for filter backwash into the sewers at a

POTW.

This system, which was originally developed in mining operations, is

technologically feasible and costs no more to

build and operate than othertechnologies

for treatment ofradium from drinking water supplies.

Flushing the backwash ofradium residuals into public sewers poses adverse

effects.

The concentration of radium

in backwashes from radium removal systems

can be in the thousands of picocuries per gram on a

dry

weight basis, and any radium

removal system will concentrate the radium from the raw water supply.

Flushing the

residuals down a sewer, threatens sewer workers with an excessive exposure of elevated

radium levels.

Indeed,

it is quite

likely that these residuals may exceed

50 picocuries per

gram, and hence be classified as low level radioactive waste.

Flushing the residuals

down a sewer also results in the land application of sludge with elevated radium levels,

which may cause the receiving land

-

and its crops

-

to exceed criteria for safe land

application.

It

appears that there has not been any testimony on the available technologies to

meet public water supply requirements for radium.

WRT is aware oftwo existing

4

---

technologies which could provide appropriate radium treatment without the need for

sewer backwash ofthe concentrated residuals from that treatment.

WRT believes that

most ofthe other existing technologies

could be modified to

avoid using the sanitary

sewers for disposal ofthe radioactive materials extracted from the raw water.

But absent

thepresent regulatory structure, there maybe no regulatory impediment to such practices

in Illinois.

There also appears to

be no testimony about the longer term trends relating to use

ofdeep aquifers, which tend to

have elevated radium concentrations in northern Illinois.

The coming further restrictions on use ofLake Michigan water, and the growth of

communities

to

the south and west ofCook County, would indicate that more radium-

containing groundwater will need to be treated, rather than less.

Clearly,

the radium is

not going away any time soon, it cannot be broken down into a less harmful form and, as

the Agency admits, it is a human carcinogen.

Merely transferring radium to

another

medium, whetherby discharging it to surface waters or land—applying the sludge to

cropland, is not environmentally sound.

And the record is incomplete as to the

environmental effects ofthe proposed rule.

Indeed, we believe that there is information

on the adverse affects ofradium on biota and other potential receptors.

Given the directions ofthe Environmental Protection Act to

prevent or reduce

pollution at the source wherever feasible, and ofthe Low-Level Radioactive Waste

Management Act to use, to the greatest extent possible, alternatives to land disposal, we

submit that the proposed regulatory change is not appropriate.

We therefore urge the Board to accept these comments of WRT, and to schedule

another merit hearing on the proposed rule-change.

WRT would be prepared to

5

---

participate in such a hearing and to share its knowledge concerning the environmental

and engineering issues relating to the proposed rule.

WRT did not receive notice ofthe

proposed rule, norwas the information that WRT already had presented to

IEPA placed

into the record.

Without this information, we respectfully submit that the Board cannot

meet its obligations under section 27 ofthe Act.

Respectfully submitted,

Sonnenschein, Nath & Rosenthal LLP

Attorneys

r

Environmental (Illinois), LLC

June 2, 2004

Jeffrey

C.

Fort

Letissa Carver Reid

SonnenscheinNath

& Rosenthal LLP

8000 Sears Tower

233

5.

Wacker Drive

Chicago, IL

60606-6404

6

---

CERTIFICATE OF

SERVICE

The undersigned, an attorney, certify that

I have served upon the individuals

named on the attached Notice ofFiling true and correct copies ofthe COMMENTS

SUBMITTED ON

BEHALF

OF WRT ENVIRONMENTAL

ILLINOIS

LLC

by

First Class Mail, postage prepaid on June 2, 2004.

---

SERVICE LIST

Dorothy Gunn

Clerk ofthe Board

Illinois Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago,IL 60601

R04-21

Amy Antoniolli

Hearing Officer

Illinois Pollution Control Board

100 West Randolph Street

Suite 11-500

Chicago, IL 60601

Deborah J. Williams

Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

Joel J. Sternstein, Assistant Attorney General

Matthew J. Dunn, Division Chief

Office of the Illinois Attorney General

Environmental Bureau

188 West Randolph

20th

Floor

Chicago, IL 60601

Jonathan

Furr, General Counsel

Illinois Department ofNatural Resources

One Natural Resources Way

Springfield, IL 62701

Abdul Khalique, Radiation Chemist

Richard Lanyon

Metropolitan Water Reclamation District

Of Greater Chicago

6001 WestPershing Road

Cicero, IL 60804

Roy M. Harsch

Gardner Carton & Douglas

191 NorthWacker Drive

Suite3700

Chicago, IL 60606-1698

Claire A. Manning

Posegate & Denes

111 North Sixth Street

Springfield, IL 62701

Lisa Frede

CICI

2250 East DevonAvenue

Suite 239

Des Plaines, IL 60018

William Seith

Total Environmental Solutions

631

East Butterfield Road

Suite 315

Lombard, IL 60148

---

m

0~

---

September

15,

2003

Mr. Thomas E.

Johnson

Chairman

Illinois Pollution Control Board

1021

North Grand Ave. East

Springfield, IL 62794

Dear Chairman Johnson:

We

are very

grateful for the

opportunity

to meet withyouandyour staffthis

Wednesday.

We are looking

forward to meeting becausewe are concerned that inthe rush to meeta federally mandated deadline on the

removal ofradium from their drinking water, many

communities

in

Illinois maybe makingdecisions on

radium waste disposal thatmayhave an adverse impact on

future

landuseand produce costly long-term

health and financial liabilities.

More than 100 municipalities across Illinois

are required to reduce

theradium in their drinking water supply

toEPA mandated levels by~

December

8, 2003. These Illinois cities andtowns must decideon which radium

removal system they will obtain. Failure to meet the deadline means that residents are being exposed to the

health hazards associatedwith consuming this radioactive element andto

financial consequences which could

include fines of$10,000 foreach dayof non-compliance. These are multi-million dollar taxpayer-financed

decisions andwe would hope that the decisions taken will lead to a

permanent total solution and not create an

additional setofproblems.

The“scramble to dig new wells, install expensive water treatment systems or buy water from neighboring

towns” reportedby theChicago Tribune last week has raised a number ofimportant questions with respect to

radium removal. One ofthemost important issues, andone which hasnot received sufficient attention, is the

disposal ofradium-filled sludge.

Most if not all of theradium removal systems, other than theWRT System, involve discharging theradium

removed from the drinking water directly into the municipal sewer system. This radium is retained in the

sewer sludge.

Citiesandtowns using these systems may well be

burdened, on an ongoing basis, with the

costly, hazardous aftermath ofdealing with this radium-filled sewer sludge and manymay decide to dispose

oftheradium sludge within the boundaries ofthe State, eitherby

placing

it in Illinois landfills or by spreading

it on Illinois fields.

-more-

FROM

SOURCE TO SOLUTIONTM

‘‘4

5460 Ward Road,

Suite

100, Arvada,

Colorado

80002

.

tel

303.424.5355

fax

303.425.7497

email:

irifo@wrtnet.com

wob: www.wrtnet.com

---

Page 2/ Letter to Chairman Johnson

Nearly20 years ago, the Illinois Department ofNuclear Safety(IDNS) and the Illinois Environmental

Protection Agency (IEPA)moved to govern the management ofwater treatment plant sludge containing

elevated levels ofradium. A memorandum ofagreement between the

two

agencies

seta

standardsto limit the

level ofradioactivity in soil where radium contaminated sludge is applied.

To give you an idea ofthepractical impact ofthat memorandum ofagreement, we understand that a City the

size ofJolietwould have to find more than700 acres ofIllinoisfarmland

—

each year

—

to dispose ofthe

sludge containing radium it

would removefrom its drinking water. Once the sludge is applied, ofcourse, the

land may become environmentally tainted

—

radium has a halflife of some

1600 years and as

it deteriorates it

creates radon gas.

There is at least one alternative,

however, an environmentally progressive radium removal system that

addresses

this disposal issue.

Our system, the WRT System, not only removes radium from drinking water, it

also removes the radium from the entire State ofIllinois.

Our company offers a long-term contract to

municipalities

with no

up

front capital payment, we provide a performance guarantee ofradium removal, we

do not expose utility workers to radioactive waste and there is

no discharge-to the sewer system.

Our

Z~88TM

Media absorbs the radium and is then removed and disposed ofin fully licensed disposal facilities authorized

to accept this radioactive waste, and our terms are financially competitive.

We have enclosed a description ofour technology.

It has been piloted successfully by several municipalities

in Illinois.

We have also included some

information on our company and

a copy ofthe

Chicago Tribune story

that appeared earlier this week.

We look forward to meeting with you and your staff to discuss these issues and answer any questions you

may have.

Sincerely,

Charles S. Williams

President

Cc:Mike Garretson

FROM SOURCE TO SOLUTIONTM

‘4’

2

---

m

-1-

03

---

Summary of Radium

and

Disposal Issues

as they Relate

May,

WATER REMEDIATION TECHNOLOGY, LLC

---

Summary of Radium Removal Methods and Disposal Issues

as they Relate to Radium Removal from Drinking Water

The U.S.

EPA has set a radium maximum

contaminate level

(MCL)

of

5

picocuries (pCiiL) per liter of drinking

water.

Over 500

communities

nationwide

do not meet this

drinking

water

standard.

The Illinois

EPA has

the

responsibility to

insure

that

the

drinking

water

in Illinois

meets

all

drinking water

standards under the

Safe

Drinking

Water Act.

The

Illinois

Emergency

Management

Agency

has

the

responsibility

of

insuring

safe

handling

and

disposal of all radioactive

materials.

In Illinois

over 100

communities currently do

not meet this

standard

for

radium.

The

EPA

and

the

State

are

requiring

the

non-compliant

communities

to

come

into

compliance.

After

the

deadline

for compliance

(December

8,

2003),

the

State

can

impose

fines

for non-

compliance.

Most of the

communities have signed compliance

consent decrees promising to meet the MCL by

a

certain

date.

Currently

the communities are

conducting

pilot

plants

and engineering

studies to bring

their

community into compliance.

To

bring

the

water systems into

compliance

the

municipalities are

investigating five different types of radium-

removal systems that can be divided into three categories of waste disposalmethods.

1.

Systems that dispose ofthe radioactive water-treatment residuesinto the sewer system

2.

Systems that dispose of the radioactive water-treatment residues directly-on-the-land.

3.

Systems

that

dispose

of

the

radioactive

water-treatment residues

into

landfills/disposal

facilities

licensedto accept radium-bearing byproducts.

Systems that dispose ofthe radioactive byproducts into the sewer system

Hydrous Manganese Oxide (HMO)

This process uses the

addition of specialty chemicals or manufactured particles to promote the precipitation of

radium

and iron as insoluble particulates.

The precipitated

iron, radium, and manganese are then

filtered out in

a conventional sand filtration

system.

This sand filter is then backwashedperiodically,

sending the

radioactive

filter solids with the

backwash

water

to the

sanitary sewer.

The

system has been

used effectively for

iron

removal

for years.

Because not all of the

precipitant is

removed during

backwash, the filter media becomes

radioactive over

a

period of time,

quite

possibly to a concentration

that would

require

disposal to a

low

level

radioactive site.

An

advantage of this system is that it removes iron

as well

as radium in the same operation, if

both

are

a

concern

to

a

municipality

(similar

to

hardness

improvement

and

radium

correction

with

lime

softening).

The principal disadvantage is that the system requires the

discharge of radioactive solids down the

sewer where

they

may

collect

as

residue

in

the

collection

system.

These

solids

may

well

be

in

excess

of a

radium

concentration of 10,000 pCi/g.

Because of the high concentration of radium

in

the solids and theiact that these

are

discrete

particles,

disposal down the

sewer results

in sludge

containing discrete particles containing radium

in

excess

of

that

allowed

for disposal

at

the

U.S.

Ecology

LLRW

site in

Hanford, Washington

and at

the

Envirocare of Utah site inUtah.

Because of the high iron and magnesium content, the densityof these particles

is greater than typical sludge and segregation/settling of these particles may-occurin the sewer system.

Illinois

radiation protection

regulations,

32

Ill

Achn.

Code

340.1030

prohibits

a

licensee

from

discharging

radioactive

solids

down

the

sewer.

The

HMO

solids

are

very

high

in radioactivity,

and these

individual

particles have the

potential

for

two

types of exposure problems

—

1)

the

settling of these radioactive

solids in

areas of the

sewer

collection

system,

resulting

in sources of high radiation and exposure;

and 2)

the

periodic

backwash

and release of a

“slug” of highly-

radioactive

solids

may remain

as discrete

radioactive

“hot spots”

within the sewage

sludge.

2

---

This process requires

constant chemical feed to maintain the

effectivenes

fthe process-.

If the

chemical feed

stops,

the radium

removal

is

reduced.

The system requires

daily operator interaction

and

frequent expensive

radium monitoring to insure compliance.

The frequent backwash

of the sand- filter waste consumes

two

to four

percent

of the

water

treated.

Significant amounts

of

land

will be required for

land

spreading to

meet

the

maximum increase of

0.1

picocurie per gram

on

land where sludge will be applied (per

JEPA

—

IDNS

MOA,

1984). Local municipal workers are responsible for the maintenance, reagent handling and ultimate disposal.

Additional

occupational

training

and monitoring

for radiation exposure

of

sewer workers

in contact with

the

sludge may be warranted.

Ion

Exchange

This process removes radium by exchanging

sodium for calcium,

magnesium

and

radium on a resin.

When the

calcium is no

longer effectively removed, the

resin is then

stripped of the

collected

elements by

exposing the

resin to a sodium chloride brine.

The resin is then

rinsed and reused.

The sodium chloride brine bearing the

radium,

calcium,

and magnesium

is

then

discharged

to

the

sewer

followed by

disposal

of the

rinse

water.

When

the resin

is no

longer efficient at

removing the

radium

the

resin is

replaced.

The

life of the

resin is

determined by the

water chemistry but can be expected to be between

two

and seven years.

When replaced,

the

spent resin,

even after

a fmal

stripping

operation,

will likely contain radium

in a concentration

well

above

the

limit for

surface

land

application, requiring it to be

disposed

of in

an appropriate landfill

or

Low

Level

Radioactive

Waste

(LLRW)

disposal

site.

Advantages to

the

system

include softening

of the

water

while

removing radium and a relatively low capital cost.

Disadvantages to the

system include the

addition of sodium and

chlorides to both the -drinking

water

and

the

sewer

system.

Increase

in the corrosivity of the water may lead to the need to bypass and blend with untreated

water to avoid dissolution of heavy metals

and corrosion of the

distribution system.

This bypass

of untreated

water will raise the

level of radium

in the potable water,

and

communities with high radium may

find that this

bypass

prohibits the use of the

ion-exchange system.

The discharge of the rinse water and the

eluant brine to

the sewer can result in scale formation with significant radium content in the

sewer pipeline.

Within the

sewer

plant,

it

is

expected

that

the

majority

of the

radium

will

end

up

concentrated

in

the

sewage

sludge.

In

communities where

all

or most of the drinking water

that reports to a wastewater treatmentplant is

above the

MCL,

some level of training and monitoring

for radiation

exposure of sewer workers

in contact with the sludge

may be warranted.

-

Significant amounts of land- will be required for land spreading to meet the maximum allowable increase of 0.1

picocurie

per gram

on

land

with sludge

applied.

The

anticipated level of radium

in the

eluant water will be

dependent

on

the

frequency of

regenerations

and

the

original

level of radium

in the

feed

water

but can

be

expected to be between 3,000 PCi/Lto 6,000 pCiiL

(based

on recent analysis of eluant brine at an ion-exchange

treatment plant

in New Jersey).

Dilution with rinse water

may

reduce this concentration

to several

hundred

pCiJL.

On

a dry-weightbasis, the

concentration will be in excess

of

100,000

pCilg.

Local municipal workers

are responsible for the maintenance,

reagent handling, and ultimate disposal.

Calculations of radium content in

the brine and eluant may be performed using the

SPARRC Program’

Reverse Osmosis

Reverse

osmosis

is a

very fine

filter system where

water containing

contaminates

is pressurized

and

pushed

through

a permeable membrane

sized to prohibit passage

of

the

undesirable

elements.

The

process produces

approximately 80 percent of the

feedwater as

finished water.

The 20 percent reject water

contains the majority

ofthe

contaminants and is then

disposed of as a liquid wasteto the sanitary sewer.

Since the

concentration ratio

of reject water

to

feed

water

is

5:1,

the

radium

concentration in the

reject

water will be

5

times

that

of

the

original -feed water, e.g., a feed concentration of 15 pCi/L would result in 75

pCi/L

discharged to the wastewater

treatment facility.

The advantage of this system is that veryhigh quality water is produced.

Disadvantages include high capital and operating costs, perhaps- $1.50 to

$2.50

per 1,000 gallons produced. The

loss

of 20

percent

of the

feed

water

will be

a

problem for some

communities.

Within the

sewer

plant

it is

expected that

the

majority of the

radium will end

up

concentrated

in the

sludge.

Significant amounts of

land

will be required for land spreading to meet the

maximum

increase

-of-0.1 picocurie pergram on

land with sludge

3

---

applied.

Local municipal workers are

responsible for the maintenance,

reagent handling

and ultimate

disposal.

In communities where all ormost ofthe

drinking

water that

reports

to a wastewater treatment plant is above the

MCL,

some

level of training and monitoring for radiationexposureof sewer

workers

in contactwith thesewage

sludgemaybewarranted.

Systems that dispose of the radioactive byproducts directly on the land

Lime Softening

The addition of chemicals such as lime and soda ash causes the calcium, magnesium and also radium to

precipitate as

carbonate compounds, thereby softening the

water and

removing radium in

the same

operation.

The sludge generated by this process

is usually sent to dewatering lagoons and

later removed for land

application. An advantage to this system is that, if the municipality wants to soften the water, this will occur at

the same time the radium is removed, and the treatment residuegenerated by this process is often used onlow-

pH soils forsoil conditioning.

Disadvantages to this system include high capital and operating costs.

Significant amounts of land will be

required for land spreading to meet the maximum

allowable increase of

0.1 picocurie pergram on land where

sludge is applied. Radon

exposure

levels oflime softeningworkers may need to bemonitored.

It is anticipated

that the radium activity or concentration of the treatment residue on a dry weight basis would be less than 25

picocuries/g.

Local

municipal workerswouldbe

responsible for the maintenance~reagenthandlingandiiitimate

disposal.

Systems

that

dispose

of the

radioactive

byproducts

into

landfills

licensed

to

accept

radium bearing waste.

-

Adsorptive media

The radium is collected on

a

disposable

long-lived

media

that

requires

changing every

one to several

years.

Because

backwashing

is not required,

there is no water

wasted.

Chemical addition is not

required.

The media

is exchanged when it no longer removes sufficient radium to meet the

MCL.

The exchange and

transportation

is contractedto experiencedpersonnel.

In

addition, the spent media will be exchanged

while the concentration

ofradium is

low enough to

permit safe and economic transportation and

disposal.

One advantage

is the simple operation ofthe system (no backwashing

orchemical

additions); only

operational

monitoring of the equipment is required of the utility operators. This simpler operation results in these workers

having little exposure to radiation, estimatedat less than 10 mrem/year. The radium-bearingmedia is disposed

ofinalicensed disposalsite with long term maintenance and monitoring plans.

What are the repercussions of radium being disposed ofinto the sewer system?

Radium

removal systems that discharge into the sewer

either discharge the radium as a liquid (Ion Exchange or

Reverse Osmosis) or as a solid (Hydrous Manganese Oxide).

When discharged as a liquid the biological

treatment concentrates the

radium into the sewage sludge. The degree ofconcentration in the solids isnot well

documented

but has

been estimated by the New Jersey

EPA

to be in excess of 90 percent.

The

discharge by

a licensee

of radioactive

solids

into the

sewer

system is not

allowed by

Illinois

law but is

being pursued by some

municipalities.

Virtually

100 percent of these solidswould end up in the sewer system

or

the sewage sludge.

Discharge of

solids

or

liquids

into a

sewer

system

introduces

some

potential

impacts

that

need

to

be

investigated. Some ofthese are:

4

---

1.

What is

the

possibility

of

contaminating

the

sewer collection

system,

specifically

considering

the

probability of the

scale buildup within

the

piping and the

possible settling out of radioactive

solids in

areas of low flows?

Even Ion

Exchange

and

Reverse

Osmosis has

the

potential for radioactive

solids

to be precipitated within the collection system as scale when the water is mixed with air (CO2 forming

radium carbonates) and water (forming both radium sulfates and radium carbonates).

2.

What

is the potential

for sewer

worker

exposure throughout the sewer system?

The ISCORS2

report

indicates a reasonable expectation that

sludge handlers could be exposed to levels

that would require

training

as radiation workers and monitoring even if the radioactivity of the

sludge is at relatively low

levels.

The

exposure

to

these

workers

could

exceed

that

of

a

nuclear

power

plant

worker,

at

wastewater treatment facilities

that

accept water

with radium

concentrations

above the MCL.

(See

ARS Report3)

3.

What is the long term impact of the decay of radium and the release ofradon gas on land where houses

may be built in the

future?

Who will bear the cost ifradon mitigation is needed?

4.

What is

the

impact of radium

on

the

flora and fauna of the

area where

the

sludge

is being

spread

especially inthe case of HMO where discrete highly radioactive particles are being spread?

5.

What are

the

possibilities of the

radium being

spread on

the

farmland

leaching into the near

surface

aquifer endangering aquifers

that currently have no radium?

6.

What precautions

are

being

taken

to

ensure

that

runoff from

land

application

is

not

endangering

waterways?

-

-

7.

Who

is

going to be

responsible

for the

long term

monitoring

of sites where

radium

contaminated

sludge

is spread?

Is

there a mechanism so that future

land

owners will be informed that

radium has

been spread on the

land.

8.

How many communities have enough land

available for land application

at application rates far below

what is currently practiced?

What are the potential repercussions oflandfill disposal?

While all

removal systems remove roughly

the

same amount ofradium

in a year, adsorptivemedia.has z longer

life

between

disposals than

other methods dictating

that

more radium

is held

on

site prior to disposal.

The

concentration of radium, however, on

a dry weight basis (picocuries / gram) is less than any other method other

than

lime softening.

Transportation of radioactive

materials is completed under established Department of

Transportation regulations.

Because of the granular natureof the media and the low level of radiation contained

within the

loaded media, clean up

in the

event of a spill consists of collecting/vacuuming and repackaging any

spilled media.

The media, by

its very nature, removes radium

from water and does

not allow

it to leach back

into the

water, making

the

possibility of water

contamination

very minimal.

Disposal

occurs

in a licensed

landfill

appropriate

for

the

level

of

radium

contained.

Each

of

these

landfills

has

long

term care plans,

maintenance

plans

and

funding

in

place.

Long

term

contracts

for

disposal

are

in

place

for

the

Water

Remediation

Technology System insuring a disposal site until 2040.

Removal, transportation, and disposal of

the

media

are

performed by workers

specifically

trained in

the handling

of radioactive material.

Municipal

workers are not required to perform any ofthe servicing or maintenance of the equipment.

Decommissioning of sites

Each of

the

radium removal processes

are

intended

for long

term

use but there will come a time

when

every

system

must

be

decommissioned.

Each

system

will

require

an

in-depth

evaluation

of

decommissioning

requirements, but some general observations can be made for each system.

5

---

Hydrous

Manganese Oxide

-

The

filter media will have to be disposed

of in an

appropriate landfill or disposal site

and

the equipment

will

have to

be decontaminated.

The

sewer

line

will have

to be

surveyed

and appropriate clean

up

undertaken.

Elevated levels of radium in the

pipe

scale should be

expected.

Special care should be given to the

surveying

and

decommissioning

of the sewer line.

Ion Exchange

The ion exchange media

will

have

to be

disposed of in an appropriate disposal site.

The vessels

and pipelines

will

have to

be

surveyed

and

decommissioned

if

needed.

The

sewer

line

will

have

to be

surveyed

and

appropriate clean-up undertaken.

Elevatedlevels of radium in the pipe scale should be expected.

Reverse Osmosis

The equipment and sewer line will haveto be surveyed and decontaminated ifnecessary.

Lime

Softening

The vessels

and

pipelines

will need to be decommissioned.

The most problematic area for decommissioning

will be to reclaim the

drying

lagoons, which may be extensive.

Depending on

the

allowed level of radium

in

soil underlying

the lagoons, they

may have to be over-excavated

and

the soil hauled to an appropriate disposal

site.

This system has the largest footprint of any system.

-

Adsorptive Media

The filter media will have to be

disposed

of in an appropriate landfill or

disposal site and the

equipment will

have to be surveyed and decontaminated if necessary.

The equipment is stainless steel.

Notes/References:

1.

SPARRC Program Version

1

(Software Program to Ascertain Residuals Radionuclide Concentrations July

2003

—

website location for downloading the

software application

Website

www.n~despermits.com,s~arrc.

This is also

available

directly from WRT.

2.

ISCORS Technical Report 2003-03

—ISCORSAssessmentofRadioactivity in Sewage Sludge:

Modeling to

Assess Radiation Doses,

Nov 2003.

This is also available directly from WRT.

3.

American

Radiation

Services,

Inc.

report

—

Total

Effective

Dose Equivalent

(TEDE)

Calculations for

Radium-Bearing Sewage Sludge

Under

Various Exposure Scenarios,

Jan

26,

2004.

This report describes

potential radiation exposure for sewer workers.

It is available directly from WRT.

6

---

Reference

#1

SPARRC

SoftwareProgram to Ascertain Residual

Radlonuctide

Concentrations

-

-

-

-

Dowfl~ancio~mmentssu

-

-

~Q~!

I-~wnIoad-SP1

Welcome

to the SPARRC DoWnload and Comments Submission Site

What is SPARRC?

-

Several radlonudldes

such as radon, -radIum,

alpha

emitters,

and beta

and.photor~emltters

are regulated

by

the

US

Environmental

Protection Agency under the S~fC

Drinking Water Act.

When water

treatment

plants

remove

these

contaminants

from

drinldng-water sowces,

the

contaminants

are

transferred from

feed water to other media Including treatment

plant

prqcess

residuals suth as backwash

water,

brine,

and sludge. The

presence of

radionudides

In

treatment

plant

wastes,

dependIng

on

the

concentration

and

or

load

specified

In

allowable limits,

may restrict the

use of InexpensIve disposal options

for

those

residuals, Increasing treatment costs

Residuals may

be

dassifled

as hazardous under

RCRA dependIng

on

the concentration

of

co-contarninantspresentThe cost ofredduals

disposal,

Is

also a function

of

the

volUme

and/or

mass of the

residUals.

Therefore,

ft

Is

important

to

estimate

the-quan

Itlès-as

well

as the

concentrations

of r~dionudidesand

co-contamInants In

residuals

generated

by

~ater

treatment plants.

SPARRC

isa

desktop

software

application

that enables

users to

analyze the

potential

concentrations-of

radlonudides

in

residuals from drinking

water process streams.

-

Distribution of

SPARRC

-

-

SPARRC Version

1.0 is in the public domain and may be

copied and distributed freely.

We

ask

that

you:

1.

Report

any errors

or bugs

or

provide comments.

-

-

2.When distribUting this program, make

sure

that

all

documentation flies are included.

What woUld you

like to do?

-

-

Download

and

Install SPARRC

-

•

-

SubmIt

comments on

SPARRC

-

-

http://www.npdesperrnits.com/sparrc/

-

-

-

4/1/2004

---

Radium Disposal

Options

in Illinois

Water

‘Jr

/

/

__~

to Consumer

Loca~.

Landfill

Ra 226+228

5 pCi/g

Ra 226+22850

pCilg

(No permitted facilities in Illinois)

Land

Application-

Ra 226+228 50

pCilg

No more than

0.1

pCilg increase

in

soil

Low Level

Radioactive

Landfill

Ra 226 222

pCilg

Ra 226 10,000

Raw Water

‘Jr

I

/

/

/

/

Waterways

______________

~

---

Raw Water

1~

HMO Chemicals

Hydrous

Manganese

Oxide

Precipitant

Formed

Disposal

of

radium

bearing solids

into sewer system

/

is prohibited!

-

-

--:

-

-

Waste Water

-

-

-

Spent

-

Treatment Plant

— -

I~.I1.

-

-

--

-

-

ruLer:-

Media

Appropriate

Landfill

Waste

Water

Jr

Land

Appropriate

Application

Radium

Removal

Process

Radium

HMO Precipitant

¶

~-!~-~-~

~iI__•

-;

4

I

Jr

/

/

OR\

I

—

S

---

Ion

Radium

Removal

Loaded

Resir~

Exhausted

Resin

Appropriate

Landfill

Land

Application

I

I

t

Precipitation of

and Radium Sulfates

Waste Water

-

Treatment

Plant

Appropriate

Landfill

Violation of

Zinc limits from

Waste

I

Water

Jr

--p

Waterways

Jr

‘I,

Issues:

Sodium in drinking water

—7______

_----

--~

-—--—---------

---

Reverse

Radium

Removal

Process

R.O. Membrane

—

20

Feed Water

/

Sludge

/

Application

--

-

—

--

OR\

Jr

Deposition Of Radium as

Carbonates & Sulfates

-

Feed Water

/

/

Waste Water

-_____

Treatment

Plant

Waste

Water

Appropriate

Landfill

---

Lime

Radium Removal

Process

Drying

Raw Water

Na2CO3

Jr

Land

Application

---

Absorbent Media

Radium Removal Process

Licensed

& PermItted

Disposal

Facility

———-,

(

Raw Water

---

Summary of Memorandum of Agreement between IEPA and IDNS

1. If sludge

is

less

than50

pGiIg then land application is

permitted.

2. Ifsludge island applied it may not increase the radioactivity ofthe soil by more than 0.1 pCi/g

3. Ifsludge is

5pCi!g but50

pCi/g sludge may go to a IEPA landfill with a minimum of 10 foot

of cover being placed over the radium bearing material.

4. If sludge is

above 50

pCifg then IDNS must approve disposal method and site.

Sewer Sludge Application Parameters

Coding:

required input numbers:

numbers that are calculated but should be input if available:

comments:

Drinking water parameters

Level of total radium

in water

gallons per day pumped

gallons per year pumped

Picocuries radium

in

water per year

Sludge recovery parameters

Dilution factor

Gallons of water! day

treated

in

waste water

facility

Radium

in sewer influent

gallons of water! year

grams of sludge! gallon of effluent

Tons of sludge

produced

per year

dry

weight

Grams sludge produced

1

year

Picocuries radium in sewage influent

I

year

radium

reporting to sludge

radium remaining

in water

Anticipated radium content in

sludge

(Picocurie! gram)

Anticipated radium

content of water effluent

Land Application Parameters

Allowed radium increase in soil

(picocuries! gram)

grams of soil needed for mixture

Pounds

dry

weight per cubic footof soil

grams of soil / cubic ftsoil

cubic

ftof soil needed / year

Acres! year

if

mixed

in top 6

inches

Application

rate (tons! acre)

1 6~M

~

~

•

~

~

~

~‘

~

292,000,000

O

4of23~j~ay!~

From sewage treatment plant reports

116,800,000 grams

10,402,500,000

5

846

~Pe~O~1OpC~

0.47

Picocuries! liter

98,823,750,000

grams of soil

26,899.50

g/ cubic ft.

3,673,814

cubic

ft.

168.7

acres needed / year

076

tons! acre

•

~:ons! year

10,402,500,000 pCi! Year

---

Exhibit

C

---

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FROM:UILLAGE

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OSWE6IJ

630-554-3306

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1021

N. Grand Avenue East,

P.O~Box 19276

•

-

Springfield,

IL 627~4~9276

DMsiori of Public Water

SupplIes

•

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PUBLIC WATER SUPPLY

CONSTRUCTION PERMIT

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the provisions of

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Title

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Water Supplies

---

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NU,

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TO:3034257497

‘ILLINOIS ENVIRONMENTALPROTECTION AGENCY

1021

N.

Grand Avenue

East1 P.O. Box 19278

Springfield, IL 6V94-9276

J~—u~—~uuq

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FROM:UILLAGE OF DSNE~O

630-554-3306

•

Division of

p~6iic

Water Suppiles

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Teiephone.217/78?-1

724

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FROM: VILLRGE

OF OS~.E~O

630-554-3306

TO:3034257497

iLLiNOIS ENVIRONMENTAL PROTECTION AGENCY

1021

N.

Grand Avenue

Eset,

P.O.

Box

Springfield,

IL C2794-9276

P~MFNU~R~

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ADDITIONAL CC*lDfllONS:

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