BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
IN THE MATTER OF:
REVISIONS TO RADIUM WATER
QUALITY STANDARDS: PROPOSED
NEW
35
ILL. ADMIN. CODE 302.307
AND AMENDMENTS TO 35 ILL. ADMIN.
CODE 302.207 AND
302.525
PECE~VED
CLERK’S OFFICE
AUG 11 2OO~
STATE OF ILUNOIS
Pollution Contro’ Board
)
)
)
)
)
)
R04-21
Rulemaking
-
Water
NOTICE OF FILING
To:
See Attached Service List
Please take notice that on August 11, 2004, we filed with the Office ofthe Clerk
ofthe Illinois Pollution Control Board, an original and ten copies ofthe attached
Testimony
Of Charles
Williams
On Behalf Of Water Remediation Technology, LLC
a copy ofwhich is served upon you.
Jeffrey C. Fort
Letissa Carver Reid
Sonnenschein Nath & Rosenthal LLP
8000 Sears Tower
233 5. Wacker Drive
Chicago, IL 60606-6404
WRT Environmental Illinois LLC
TifiS FILING IS BEING SUBMITTED ON RECYCLED PAPER
RECE~VW
BEFORE THE POLLUTION CONTROL BOARD
CLERK’S OFFICE
OF THE STATE OF ILLINOIS
AUG 1 1 2EJ~4
STATE OF ILLII’401S
IN THE MATTER OF:
)
Pollution Control Board
)
REVISIONS TO RADIUM WATER
)
QUALITY STANDARDS: PROPOSED
)
R04-21
NEW 35 ILL. ADMIN. CODE 302.307
)
Rulemaking
-
Water
AND AMENDMENTS TO 35 ILL ADMIN.
)
CODE 302.207 AND
302.525
)
TESTIMONY OF CHARLES WILLIAMS
ON BEHALF OF WATER REMEDIATION TECHNOLOGY, LLC
I.
INTRODUCTION
My name is Charles Williams. I am the founder and President of Water Remediation
Technology, LLC (WRT). Under my direction, WRT has developed proprietary
technology for removing contaminants from water and wastewater and is specifically
concentrating on helping municipalities comply with the radionuclide rule in a safe and
non-polluting manner. I have worked with extractive metallurgical processes for over 30
years and have installed removal technologies for the removal of ammonia, gold, lead,
zinc, and silver. For the past four (4) years, I have directed research and development on
the removal of contaminants from drinking water, including such contaminants as
radium, uranium, arsenic, cadmium, lead, chromium, and selenium. WRT, under my
direction, has conducted radium removal pilot plant studies at over 20 sites in six (6)
states, 12 ofwhich sites are in Illinois. I am a co-inventor on five
(5)
patent applications
related to contaminant removal from water. WRT currently is constructing five
(5)
radium removal plants in Illinois; engineering is underway on an additional 20 sites. The
WRT process removes radium from drinking water and disposes of the radium-loaded
residuals into a low-level radioactive waste facility. My education consists of a B.S. in
Geology from North Carolina State University.
II.
SUMMARY OF EFFECTS OF PROPOSED REVISIONS TO THE
RADIUM WATER QUALITY STANDARDS
The impact ofchanging the 30-year-old water quality standard forradium, as proposed, is
to allow a known carcinogen to be discharged into the waterways of Illinois. The
proposed rulemaking effectively eliminates the general use water quality standard for
radium
—
to the detriment of Illinois rivers, streams and lakes. No monitoring of the
discharge from a Publicly Owned Treatment Works (POTW) or directly from a water
treatment facility would even be required in most cases. In effect, the discharge limit
would be changed from the current limit of 1 picocurie/liter (pCi/L) of Radium-226 to an
unlimited discharge. It should be remembered that the Maximum Contaminant Level
Goal (MCLG) for radium established by the United States Environmental Protection
Agency (EPA or U.S. EPA) is zero pCi/L. In other words, any radium in drinking water
is undesirable and any level above zero carries a health risk. The apparent reason the
Illinois Environmental Protection Agency (IEPA) has requested the rule change is to
permit public water systems that remove radium from their drinking water to dispose of
the radium-laden residuals into the sanitary sewer or a receiving stream. Neither ofthese
disposal practices is a sound environmental practice.
The removal ofthe radium discharge standard from the general water quality standard, as
proposed, is not necessary or advisable for the following reasons:
a. Treatment technologies are available that remove radium from the
drinking water without generating a radium-laden discharge to the
sanitary sewer or a receiving stream.
b. All radium removal technologies can be designed to avoid radium
release to the sanitary sewer or receiving stream.
c. Treatment technologies that do not discharge radioactive residuals to
the sewer are economically competitive with those technologies that
do discharge to the sewer or receiving stream.
d. Radioactive residuals that are not discharged into the sewer are
disposed of in a Low Level Radioactive Waste Disposal Site
(LLRWDS) with long-term maintenance plans and funding.
e. When radium residuals are discharged into the sewer, sewer workers
and other public works employees are exposed to higher levels of
radiation.
Not allowing radium residual discharge to the sewer
decreases the exposure of sewer workers to radiation and is consistent
with the As Low As Reasonably Achievable (ALARA) radiation
control principles.
f. Removing the radium discharge standard, as proposed, will allow low-
flow streams where the discharge from the POTW is the principal flow
to be many times the drinking water standard. This implies that the
life in a stream that is not used for drinking water has no value
—
fish,
birds, and plant life. Testimony from the EPA is that the majority of
affected treatment plants discharge to low-flow or zero-flow streams.
g. There are serious liability issues regarding potential harm to people
and the environment that the water treatment plant may be passing to
POTWs.
h. The discharge of radium treatment plant residuals into the POTW,
which will be allowed by this proposed rule change, will require
significant time and resources of government agencies to insure the
health and safety of Illinois citizens. Indeed, a significant new
workload will be placed on the government agencies to control and
monitor sewer worker safety and land-spreading ofresiduals.
2
i. The discharge of radium treatment plant residuals into the POTW will
create a significant increase in workload for site and worker
monitoring and worker training as well as liability for the POTW.
j. Under the proposed rule change, the irony is sludge that is too
radioactive for landfills is being permitted for spreading on good
Illinois farm fields and open land.
k. Based on the Memorandum of Agreement between the Illinois
Department of Nuclear Safety (IDNS) and the IEPA (attached hereto
as Exhibit 1), significantly more land than currently utilized will need
to be used in land application. Indeed, the limit ofa 0.1 pCi/g increase
in the soil may require a six- to ten-fold increase in land needed for
land application.
1. Common sense says that once you take a carcinogen out of the
environment, don’t put it back in.
For these reasons,
WRT
is opposed to this rule change.
As indicated by the IEPA, the source ofthe radium is natural radium dissolved in the raw
water pumped from deep aquifers to supply water to Illinois communities. Virtually no
radium is present in the surface waters ofthe State. Since radium is a known carcinogen
and the maximum contamination level goal is zero, any discharge into the Illinois
environment should be allowed only after comprehensive studies have been conducted
and then only if no other options exist.
Communities that draw water from radium-contaminated aquifers need to understand the
requirements, impacts and unintended consequences ofradium disposal. They can then
make an informed decision on which treatment process to use and be confident that more
restrictive discharge limits in the future will not cause a multimillion-dollar treatment
facility to become obsolete. Many of the communities with a radium problem are
experiencing population growth that requires increased pumping and greater dependence
on radium-contaminated aquifers. Oswego, IL, for example, is adding two new 1000
gallon per minute wells during the next year, a 40 increase in capacity. Elbum, IL is
adding one well next year, a
50
increase in capacity. Not only must Illinois contend
with the current production of radium, it must deal with more and more radium being
added to the surface environment each and every year in perpetuity.
Radium in drinking water is a serious and complex issue. To understand all of the
ramifications ofthis proposed rule change, one needs to know where the radium is being
generated, the potential disposal options available to the water producer, and the final
disposal site of the radium removed from drinking water and, ultimately, how the impact
ofradium on the environment can be minimized.
Table 1 and Figure 1 indicate radium levels encountered in ground water at sites where
WRT has conducted testing.
3
FEED
Ra-226
I
Ra-228
I Combined I
MCL
Woodsmoke Ranch, IL
18.0
4.6
22.6
5
Ken Caryl, CO
17.1
1.6
18.6
5
May Valley, CO
15.3
10.2
25.4
5
Edelstein, IL
12.8
1.5
14.3
5
Richiand Springs, TX
12.5
21.4
33.8
5
Elburn, IL
11.6
7.6
19.2
5
Joliet, IL
7.7
4.9
12.6
5
Jamesburg, NJ
11.2
2.0
13.1
5
Cortland, IL
8.4
3.9
12.3
5
ILPrairie Estates, IL
8.1
6.6
14.8
5
Oswego, IL
8.1
9.2
17.3
5
Reddick, IL
5.1
3.5
8.6
5
Breazeale, IL
5.1
3.6
8.7
5
Medina, MN
4.6
3.7
8.3
5
Brookfield, WI
4.0
2.6
6.7
5
Wynstone, IL
3.7
5.3
9.0
5
Sycamore, IL
3.4
3.2
6.6
5
Parkway, NJ
2.7
2.9
5.6
5
Bartlett, IL
2.4
4.8
7.2
5
Average All
Average Illinois
8.5
5.4
7.8
4.9
13.9
12.8
Table
1
F
Radium Levels in Feed Water
Ra-228
U
Ra-226
Figure 1
As can be seen from the chart and graph, the average radium level found by WRT in
Illinois is 12.8 pCi/L for the combined Ra-226 and Ra-228. In Illinois, the highest level
we have tested has averaged 22.6 pCi/L combined. The ratio of Ra-226 to Ra-228 is
4
quite variable and, while not shown on the graph, changes between sampling at
individual wells. Some wells are predominantly Ra-226 and some are predominantly
Ra-228. The average Ra-226 concentration is 7.8 pCi/L but the highest is Woodsmoke
Ranch, IL, which averaged 18 pCi/L Ra-226.
The first decision point is whether or not to treat for the removal of radium. If the raw
water contains less than
5
pCi/L Ra-226 and Ra-228 combined, then the water is pumped
directly to the consumer without any radium removal required. Since no treatment is
required, there is no opportunity to reduce the radium being introduced into the
environment.
Ifthe radium content (Ra-226
+
Ra-228) is greater than
5
pCi/L, then radium treatment is
required.
Radium treatment creates radium compliant water (less than
5
pCi/L
combined) to be sent to the consumer and radium-enriched residuals, either liquid or
solid, to be disposed of. Figure 2 shows the potential disposal options available for
radium disposal to the water treatment plant operator. Basically, there are three options
for the radium residuals:
1.
The radium can be disposed of by discharging the residuals directly to a
stream.
2.
The residuals can be disposed ofby discharging them to a sewer (in which
case a portion will be discharged into a receiving stream with the POTW
effluent and a portion will be disposed ofwith the sewage sludge).
3.
The radium residuals can be transported to an appropriate LLRWDS with
long-term maintenance plans and funding.
r
L
5
Landfill
Radium Disposal Options
for Water Treatment Plants
/~‘
Raw
Water
Figure 2
Current Regulations Protect Illinois Waterways
The current general water quality standard of 1 pCi/L effectively protects the citizens of
Illinois by preventing the discharge directly into a stream or the discharge of radium into
the sewer. Of the three options, only the transport to a LLRWDS of the water treatment
residuals keeps the radium out of the Illinois environment and is permissible under
current Illinois rules.
It is my belief that discharge of radioactive liquids or solids into either the sewer or the
waterways of Illinois is an unacceptable practice for the following reasons:
Rule Change Threatens Illinois Streams,
Rivers,
and Lakes
Discharge ofradium directly from the water treatment plant to a receiving stream will
mean the discharge of radium into a receiving stream at many times the current limit
of 1 pCi/L and indeed many times the drinking water standard. For example, a
municipality that produces water with a radium content of 15 pCiIL and installs a
reverse osmosis system, which concentrates the radium into a small percentage of the
raw water and then discharges that high radium concentrate water into a receiving
stream, would be discharging water into the receiving stream at levels of
approximately 100 pCiIL radium. This level is 20 times the drinking water standard
and if one-half of the radium is Ra-226, the level would be 50 times higher than the
current standard. The proposed rule change would permit just such a discharge.
Waterways
6
Open Land is Threatened
Discharge to the sewer creates not only a discharge to the stream of elevated radium
but also elevated radium in the sewer sludge, which usually is land-applied to farms.
It exposes the sewer workers to unnecessary radiation exposure. It exposes future
residents of the land to increased radon exposure (radon is a by-product of radium
decay). Indeed, it is my understanding that the level of radium in the sewage sludge
will be high enough that the sludge could not be disposed of in any currently
permitted Illinois landfill and could only be disposed of out-of-state in specially
constructed landfills designed to accept radioactive waste. The proposed rule change
will allow discharge down the sewer and the spreading of material on farms that
cannot be disposed of in landfills and the unregulated discharge of radium to the
streams.
Figure 3 shows the potential disposal sites and the radium limits for each site.
Radium Disposal Options in Illinois
Landfill
226+22850
pCUg
(No
permitted VacIllt~esin Illinois)
—
Disposal
Local
/
Landfill
Ra 226+228
5
pCi!0
Figure 3
Land
Application
Ra
226+22880
pCllg
No
more than
0.1
pCUg
Incraaso in
soil
Low Level
RadIóaj~tIv’o
Landfill
Ra
226 222 pCUg
(Idaho site)
Ra 226
10,000 pCWg
(Washington Site)
MOA Provides Rules to Protect Citizens
In 1984, the EPA and the IDNS signed a Memorandum of Agreement that outlined the
fate of radium-contaminated sewage sludge. At that time, there were no processes
J
P~cess ~
to
Consumer
Raw Water
______________
Waterways
7
available that avoided radium disposal down the sewer. The Memorandum established
three basic parameters:
1. If sewer sludge is over 50 pCi/g then: The disposal method must be approved in
advance by the IDNS and the method must limit radon exhalation and provide
reasonable assurance against accidental intrusion into the sludge in the future.
2. Ifsewer sludge is between
5
and 50 pCi/g then: The sludge may be disposed of in
an IEPA-permitted landfill with at least 10 feet ofoverburden.
3. Application of radium-contaminated sludge less than 50 pCi/g as a soil
conditioner is allowed to raise the level of radium in the soil by only 0.1 pCi/g.
The impact ofthese rules is as follows:
Disposal of radium-contaminated sludge should be done only under strict supervision
with upper limits on what can be disposed of. In order to minimize impact to future land
users, only a very small increase in radium is allowed. The impact ofthis last rule is very
significant.
Typically non-radium-bearing sewage sludge application rates are
approximately 3 tons/acre.
Table 2 indicates the application rates predicted for
radium-bearing sludge at the average and high Illinois radium levels. Based on these
calculations, the amount of land needed for land application will be increased
significantly if radium is in the sludge
—
typically 3
to 10
times.
Anticipated Application Rate of Sewage Sludge with Radium per Memorandum of
Understanding
Assumptions
~
Raw Water
Radium Level
Ra-226
+
Ra-228
pci/L
Projected
Application
Rate
dry
tons/acre
Case 1, 90
recovery in sludge
Average Illinois Case
12.8
0.49
High Illinois Case
22.6
0.27
Case 3, 20 recovery in sludge
Average Illinois Case
12.8
2.2
High Illinois Case
22.6
1.23
Case 2. 50 recovery in sludge
Averane Illinois Case
High Illinois Case
12.8
22.6
0.89
0.49
Note
—
The lower the recovery of radium in the sludge, the higher the level of radium in the effluent to
streams.
Table 2
8
Radium Removal Technologies
I have attached a report entitled “Illinois Summary of Radium Removal Methods and
Disposal Issues as They Relate to Radium Removal from Drinking Water” dated May
2004 and prepared by Water Remediation Technology, LLC. (See Exhibit 2.) The report
describes the processes for radium removal and advantages and the disadvantages of each
system. I would like to only briefly describe the systems here and discuss the potential
discharge levels of radium that could be expected to be generated by each system and
how the systems could be modified to reduce the discharge of radium into the Illinois
environment.
All
systems
can be modified to significantly reduce or eliminate the
disposal of radium removed from drinking water onto the land and into the streams
ofIllinois.
Table 3 shows the theory of operation and type of residual generated for each of the
radium removal methods.
Radium Removal
Method
.
Theory ofOperation
Type ofResidual
Generated
Reverse Osmosis
Filter out radium ions
through high pressure
membrane
Liquid
Solid (membranes)
Ion Exchange
(conventional)
Exchange sodium ion for
radium ion on an artificial
resin and regenerate with
salt brine
Liquid Brine
Solid Exchange Media
Hydrous Manganese Oxide
(HMO)
Add IronManganese
chemicals to cause the
radium to precipitate
Radioactive Solids ofiron-
manganese-radium particles
Lime Softening
Add chemicals to
precipitate the radium and
calcium
Finely divided calcium,
radium carbonate
Absorptive medias
Sand-sized particles cause
the radium to be collected
on the media either by ion
exchange or chemical
precipitation
Sand-sized particulates
containing radium
Table 3
Table 4 below shows the current disposal sites and anticipated levels of radium in the
residuals from each of the principal radium removal methods. It is difficult to estimate
the radiation content of the residuals because the radiation content is dependent not only
on the radium concentration in the raw water but also on the way the radium removal
plant is operated.
9
.
Radium Removal
Method
Current
.
Residual
.
Disposal Site
Anticipated Radium Level
.
of Residuals from
Water Treatment Plant
Reverse Osmosis
Streams or sewer 35-150 pCi/L in reject water
Ion Exchange
(conventional)
Streams or sewer 1,000 to 6,000 pCi/L in elluate;
several hundred pCi/L in rinse +
elluate
Hydrous Manganese Oxide
(HMO)
Streams or sewer Solid Component 5,000 to 15,000
pCi/g
Lime Softening
Land-spreading
25 to 50 pCi/g
Absorptive medias
LLRWDS
400 to 3,000 pCi/g
Table 4
According to the U.S. EPA, none of the residuals produced by water treatment plants
should be discharged directly to receiving streams or land-applied. ~
Theodore G.
Adams’s Exhibit I which contains relevant excerpts from the “Draft Suggested
Guidelines for Handling and Disposal of Drinking Water Treatment Waste Containing
Technologically Enhanced Naturally Occurring Radioactive Materials,” Office ofGround
Water Protection,
EPA November 2000
and “A Regulator’s Guide to the Management of
Radioactive Residuals from Drinking Water Treatment Technologies,”
EPA August
2004.)
In addition, the level ofradionuclides is sufficiently high so that WRT is unaware
ofany landfills in Illinois licensed to accept these residuals.
Many of the radium removal methods contemplate disposal of the radium-bearing
residuals down the sewer assuming that disposal down the sewer will dilute the radium
sufficiently so that it is no longer a health hazard. This is a dangerous assumption.
In order to calculate the radium content of POTW sludge and liquid effluent, a number of
assumptions must be made. These assumptions apply to all ofthe methods that dispose
ofthe residuals down the sewer.
These assumptions include:
1. How much ofthe radium will be contained in the sewage sludge and how much
will be contained within the liquid effluent.
2. The total amount of radium sent to the sewage treatment plant will be roughly the
same regardless ofremoval method.
3. The total amount of sludge generated by the sewage treatment plant will be
unchanged by the introduction ofwater treatment residuals.
4. The radium content of the sewer sludge will be dependent on the amount of
dilution influent received to the POTW from non-radium-bearing sources such as
infiltration, storm drains, and other water treatment plants.
10
5.
Since most of the radium contained in raw water ends up at the POTW, the
radium content of the raw water should be an indicator of the radium content of
the sewer sludge and liquid effluent from the water treatment facility.
Based on the above assumptions, an estimate can be made for the level of radium to be
anticipated in both sludge and liquid effluent. Based on the above assumptions, the
following calculations were performed varying the radium in the raw water, amount of
dilution, and the percent ofthe radium reporting to the sludge and to the effluent.
*Assumes 0.33 grams of sludge/gallon of fluent to POTW
Table 5
Radium Level
Ra-226 +
Ra-228
pCi/L
22.6
12.8
22.6
12.8
22.6
12.8
22.6
The conclusion from these calculations is that if water treatment residuals are discharged
to the POTW then significant levels of radium can be expected to be found in both the
sewage treatment liquid effluent and the sewage sludge. Radium levels in the POTW
liquid effluent will range from a low of 0.4 pCi/L total radium to a high of 18 pCi/L total
radium or almost four (4) times the drinking water standard. Radium levels in the POTW
sludge will range from a low of 20 picocuries/gram (pCi/g) of sludge to a high of over
230 pCi/g in the worst case.
These levels of radium are high enough to cause
significant concern for the safely of POTW workers.
POTW workers normally are not considered radiation workers and are not trained in
handling radiation exposure. To my knowledge, no radiation monitoring of sewage
workers currently is conducted.
Assumptions*
High Illinois Case
Case 1. 90 of radium in sludge.
10
of radium in effluent. No dilution
Average Illinois Case
Average Illinois Case
—
12.8
133
1.3
High Illinois Case
Case 2. 90 of radium In sludge. 10 of radium In effluent. 50 dIlution
Sewer
Sludge
pCilg
Sewer Liquid
Effluent
pCi/L
Averaae Illinois Case
High Illinois Case
234
Case 3, 50 of radium In sludge, 50
of radium
In
effluent, No dilution
2.2
Average Illinois Case
Hiah Illinois Case
88
156
0.4
1.5
Case 4, 50 of radIum In sludge, 50 of radium in effluent, 50 dilution
73
130
6.4
11
49
87
2.1
Case 5, 20 of radium In sludge, 80 of radium in effluent, No dilution
Average Illinois Case
12.8
30
10
High Illinois Case
22.6
52
18
Case 6, 20 of radium In sludge, 80 of radium in effluent, 50 dilution
Average Illinois Case
12.8
20
6.8
1-ugh Illinois Case
22.6
34
12
7.5
11
Modifications Required to Avoid Disposal Down the Sewer
As stated earlier, rather simple modifications to these processes can avoid the need to
discharge radioactive material down the sewer. Table 6 shows the modifications needed
to avoid land and stream pollution with radium.
Removal
.
.
.
Modification required to avoid disposal down the sewer
Disposal site
after
modification
Osmosis
Precipitate a radium salt in the water treatment plant
concentrate stream with barium sulfate, or use an absorptive
media such as Layne Christianson or WRT Media to recover
the radium.
LLRWDS
Precipitate a radium salt in the water treatment plant waste
brine stream with barium sulfate, or use an absorptive media
such as Layne Christianson or WRT Media to recover the
radium.
LLRWDS
Manganese
Clarify the backwash water to remove the radium
precipitants.
LLRWDS
Not disposed of to sewer. Radium can be removed prior to
lime softening using other methods.
LLRWDS or
land
application
medias
Not disposed ofto sewer.
LLRWDS
Table 6
Figures 4 through 11 are diagrammatic representations of each of the radium treatment
processes and of the modifications that could be made to avoid putting the radioactive
residuals into the sewer system.
As long as radium disposal down the sewer is allowed, the suppliers of these systems
have no incentive to develop radium removal systems that do not pollute Illinois
waterways and land. The technology exists to modif~jthe systems; the will can be
provided by banning disposal down the sewer.
12
Reverse Osmosis
Radium Removal Process
R.O.
Membane
Ret.cted
Water
I
Prnaur. .—~. I
I
Pump
I__________
RawWater
4
~
I Treated
I
Water
0l
Feed
Wator
\ Rathtzm /
CompUanJ
waler
/
-~
Raw
Water
~oD*I~~~ Of fl I~rfl
~rr
Cacbooalc, .c .Sotfalcs
-
~~ii~(
~)
/
W~$Io
W~te,
r,~~,rn,entPlanr
/oR\
Land
~I’
Appropriate
Application A Landfill
Figure 4
Modified Reverse Osmosis
Radium Removal Process
—
80
ol
/
Food
Water
\
\Complianhl
\
Rfidium
Walor
/
/
Land
Application
Appropriate
Landfill
Figure 5
‘N,
Wate,waVa
/
/
oR~\
13
Ion Exchange
Radium Removal Process
~~_1t’~~
Raw Water
____________
ApproprIate
Land
Landfill
Application
Figure 6
Precipitation of
Radium Carbonates
and Radium Sulfates
?itu
Jr
____T~atme~P~nt
Appropriate
Landfill
Modified Ion Exchange
Radium Removal Process
Land
Application
Figure 7
Issues:
Corrosion ofpiping & values
Sodium in drinking water
/oR\
Wateiways
I~flfljf
~
Sod
no,
in II.,nht03 wolni
I
Wato,wayt
Appropnate
Landfill
14
T~~V~rn
JOR\
~
i
Watatways
Modified Hydrous Manganese Oxide
Radium Removal Process
Waterelays
Hydrous Manganese Oxide
Radium Removal Process
Raw
Water
LIMO
I
Chemicals
Land
Application
Figure 8
Appropriate
Landfill
Raw
Water
I
LIMO
I
ChemIcals
Land
Appropriate
Application
I
Landfill
Figure 9
15
Lime Softening
Radium Removal Process
Mix
Tank
Reaction
(~)
~—~-
Vessel
—e-
Na2CO3
Figure 10
Drying
Lagoons
No disposal to sewer required
Raw
Water
1
Land
APP
tion
16
Absorptive Media Systems
Absorbent Media
Radium Removal Process
FIgure
11
No Modification Needed
Two companies, Layne Christianson and WRT, have developed processes that remove
the radium from the drinking water without creating a residual to be disposed of down the
sewer. Both of these systems use an absorptive media to remove the radium from the
drinking water and the loaded media is disposed of in a LLRWDS.
In the case of the WRT technology, WRT provides a complete system consisting of the
equipment, media service and disposal to a LLRWDS. Generally, water treatment plant
operators have no experience or training in handling radioactive materials. WRT also
provides radiation training to our personnel and to the water treatment plant personnel to
insure worker awareness of proper procedures. WRT personnel conduct all maintenance
and handle all fresh and loaded media. This enables the water treatment plant workers to
do their normal jobs without fear ofradiation exposure.
Licensed & Pe~lIlnd
Pl~posalFacUlty
Raw
Water
17
Cost of Radium Removal
The cost of the radium removal systems that do not dispose of radium to the sewer or
streams is competitive or lower than systems that do. The Mayor of Oswego has stated
that selecting WRT saved $2 million over the life of the contract. The mayor ofElburn
stated that, by selecting the WRT system, Elburn saved $2.6 million over the life oftheir
contract. (Copies ofrelevant press articles are attached as Exhibit 3.)
In addition, if the uncontrolled discharge of radium is allowed, when the radioactive
contamination is recognized and/or new regulations are enacted or legal suits brought to
stop the discharge of radium, the POTWs will have to change their disposal practices.
Since it is very difficult, if not impossible, to remove the radium once it is in the POTW
system, the POTW would have to:
• 1. Find an alternate disposal method for its sludge
—
at great expense.
2. Impose a pre-treatment standard on the water treatment plants that will require
retrofitting ofthe treatment plants
—
a costly proposition.
3. All parties will have to deal with the resulting litigation as to responsibilities.
18
III.
CONCLUSIONS
• The suggested rule change by the IEPA is ill-advised and could create many
more problems than it solves.
• Most significantly, the existing general water quality standard is the one
codified rule that effectively prohibits the reintroduction of radium from
drinking water to the land and waterways ofIllinois.
• Under the existing rule, Illinois is among the national leaders in protecting its
streams, rivers and lakes by preventing radioactive carcinogens from being
discharged into the waterways. The proposed rule change would turn that
upside down.
• The processes that discharge radium into the sewer, as currently allowed, are
not environmentally sound, best practices. After going through the sanitary
treatment process, the resulting sludge contains concentrated amounts of
radium that is then spread on Illinois farmland and open lands, many in the
fast-growing collar county areas ofNorthern Illinois.
• An unintended consequence ofsewer disposal is that in the absence of testing,
monitoring, and notice, sewer workers are not made aware oftheir exposure to
radiation or trained or equipped to handle it.
• Not only are the absorptive media technologies, such as that of WRT,
approved by the agency to provide a total removal in a cost-effective manner,
but all ofthe competing technologies can be re-engineered to provide a similar
total solution.
• This total removal approach does not require a new bureaucracy to enforce the
regulations governing the discharge of radium particulates into the sewer, the
spreading of radioactive sludge on the farmland or the discharge of
radioactive carcinogens into the streams and waterways. It does not require
the discarding oflongstanding state and federal environmental regulations.
• With all due respect to the Board, the result ofthis proposed rule change will
be to allow the unmonitored and unrestricted discharge of large quantities of
carcinogenic radioactive material to Illinois streams and the environment.
• We urge the Board to act in the interest ofhuman health and the environment
and to protect the long-term interests ofthe people ofthe State of Illinois and
reject the Agency’s proposal.
19
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 Testimony
Of
Charles Williams On Behalf Of Water Remediation Technology, LLC
and First Class
Mail, postage prepaid on August 11, 2004.
SERVICE LIST
R04-21
Dorothy Gunn
Clerk of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Amy Antoniolli
Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Deborah J. Williams
Stefanie N. Diers
Illinois Environmental 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 ofthe 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 West Pershing Road
Cicero, IL 60804
Roy M. Harsch
Sasha M. Engle
Gardner Carton & Douglas
191 North Wacker Drive
Suite 3700
Chicago, IL 60606-1698
Claire A. Manning
Posegate & Denes
111 North Sixth Street
Springfield, IL 62701
Lisa Frede
CICI
2250 East Devon Avenue
Suite 239
Des Plaines, IL 60018
William Seith
Total Environmental Solutions
631 East Butterfield Road
Suite 315
Lombard, IL 60148
John McMahon
Wilkie & McMahon
8 East Main Street
•
Champaign, IL 61820
Abdul Khalique, Radiation Chemist
Metropolitan Water Reclamation District of
Greater Chicago
6001 W. Pershing Road
Cicero, IL 60804
Exhibit 1
MANAGEMENT
OF WATER TREATMENT PLANT SLUDGE
•
•
CONTAINING
ELEVATED LEVELS OF RADIUM
Illinois Department of Nuclear Sa.fety
December 1, 1984
MANAGEMENT
OF
WATER TREATMENT PLANT SLUDGE CONTAINING
ELEVATED LEVELS OF RADIUM
I. Introducion
With
the promulgation of regulations by the U.S. Environmental Pro-
tection Agency (USEPA) requiring the removal of radium from drinking water,
a new problem
has
been created. The resultant sludge from Euch water
treatment plants contains elevated levels of radium.
There are currently no standards or guidelines for the management of
such sludges.
The Illinois Department of Nuclear Safety (IDNS) has developed the
following plan for the management of sludge containing
radium from water
treatment
plants.
Since
water treatment plants and resultant sludges are routinely
regulated by the Illinois Environmental Protection Agency (IEPA), IDNS
worked with IEPA in developing a Memorandum
of
Agreement (Attachment A)
pertaining to
the
disposal of sludge containing radium.
II. Objectives
The Memorandum of Agreement (MOA) has five (5) primary technical objec-
tives which serve as the basis for the criteria contained in the MOA. These
technical objectives are as follows:
1. Limit the misuse (inadvertent intrusion) of buried sludge for
an extended period of time.
2. Limit radon emissions from the surface of buried sludge.
3. Limit external radiation
exposure
from the buried sludge.
4.
Limit
the degradation of ground water quality resulting from
buried sludge.
5. Limit
undue internal radiation exposure resulting from sludge
used for agricultural purposes.
III.
Discussion
of Criteria
The
Memorandum of Agreement outlines four (4) criteria for the manage-
ment of sludge containing radium. If the
sludge
meets
the conditions of
Criteria 3. through 3, the sludge use/disposal will be under the purview of
the
IEPA in accordance with the Memorandum
of
Agreement.
If Criteria 1
through
3 cannot be
met, Criterion
4
states that
the disposal of such
sludge will be evaluated by IDNS on a case-by-case basis.
Management
of Water Treatment Plant Sludge
Containing Elevated Levels of Radium
-
2
-
Criterion 1
If
the
level
of radium in the sludge is 5
picocuries
per
gram
or less (dry weight), the sludge may be disposed of in a land-
fill permitted by IEPA to accept such sludge. (Item 4a of
Attachment A.)
The USEPA
“Standards for Remedial Actions at Inactive Uranium Processing
Sites”, 40 CFR 192.12, states that the concentration of
Radium 226 shall not
ex-
ceed 5 picocuries/gram (pCi/gm) averaged over the first 15 centimeters (cm) of
soil below the surface and shall not
exceed 15
pCi/gm averaged over 15 cm thick
layers of soil more
than
15 cm below the surface. These criteria apply to
cleanup of land (away from the tailings piles)
where
homes could be built.
The Conference of
Radiation Control Program Directors, Committee on
Natural
Radioactivity Problems,
Report No. 2, August 1981, states
that removal or controls
for soil containing up to
3
pCi/gm of Radium
226
would
not be
mandatory.
If the
concentration of Radium
226 exceeds 6
pCi/gm, removal or other controls would
then be mandatory.
The USEPA “Final Environmental Impact Statement for the Control of Byproduct
Materials from Uranium Ore Processing” (EPA 520/1-83-008—1, September 1983),
indicates that houses built on land with a concentration of 5 pCi/gm radium would
be expected to have indoor radon decay product levels of approximately 0.02 Work-
ing Level (WL) 1
(“Working
Level” (~L)
means any combination of short-lived
radon decay products in one liter of air that will result in the ultimate emission
of alpha particles with a total energy of 1.3 x lO~ MeV.) The estimated residual
risk of lung cancer due to a lifetime
exposure to
this level is approximately
2
in 100.2
The
gaitmia
radiation levels (from the sludge) to individuals living above such
a concentration of
radium would be approximately
80 millireni/year (mrem/yr)
.~
The sludge will
be placed in an IEPA permitted sanitary landfill which is
designed to have an approximately 5—10 foot thick clay
liner
to protect against
groundwater movement (permeability 1 x ~
cm/eec). In addition, the landfill
will have a final cover of at least two
feet of soil.
The design of such a landfill results
in protective measures in excess of
those required by the USEPA for
cleanup of
land containing uranium mill
tailings.
For example, placing a 24 inch cover of regular
soil over the sludge wil.
reduce
the radon emanation by approximately 57
(to 0.0086
WL)4
or approximately
2.2
picocurie/meter2-second
(pCi/m2—sec), while the external gaimna radiation levels
would be reduced to less
than
3 of original 5, excluding natural background.
Management of Water Treatment Plant Sludge
Containing Elevated Levels of
Radium
-
3
—
Should the
final
cover be removed in later years, the radium concentration
levels would still not exceed
5
oCi/gin.
(NOTE:
Calculated values, as presented in this
document, may
differ
from actual values due
to
varying
environmental, factors.)
Criterion 2
If the level of
radium in the sludge is greater than 5
picocuries
per gram (dry weight) but less than 50 picocuries per gram (dry
weight), the sludge may be disposed of in an IEPA permitted
landfill provided that there is at least
ten feet of non—
contaminated overburden between the sludge and grade level in
order to
provide: (1) reasonable assurance’
that the
exhalation
rate of radon to the atmosphere, or into a dwelling, will not
exceed an average rate of 5 picocuries
per
square meter per second;
and (2) reasonable assurance
against accidental intrusion into the
sludge in the future. (Item 5a
of Attachment A.)
Due to the fact that sludge containing up to 50 pCi/gm of radium
may
be
buried
in
a “non-radioactive waste” landfill, and one cannot
be assured of
control of the
site for an extended period of time, it is essential that the landfill be de-
signed such that unintentional intrusion into such sludge wastes
would
be
limited. Human
activities usually involve excavation to depths of 6 to 8 feet
(e.g., utility lines, basements, graves, etc.). Therefore, to prevent casual
intrusions into the sludge wastes, as well as to prevent erosion, a final cover
of ten feet
(below grade level)
is stipulated. This is
consistent with the
USEPA
guidance. 6
~ Such a cover is expected to provide excellent stablization
with the chance of misuse of the sludge wastes unlikely
and
erosion avoided for
thousandsUsingoftheyears.relationship8
that soil containing radium with a concentration of
1 pCi/gm has a radon emanation rate of 1 pCi/m2_se~~~aradon emanation ratá cf
50 pCi/m2-sec.
would be expected from the surface of sludge containing radium
at a concentration of 50 pCi/gm. Three meters of regular soil cover would reduce
the radon emanation rate to approximately 1 pCi/m2-sec. Such an exhalation rate
would be equivalent to average natural background levels as the average concentra-
tion of
radium
in soil is approximately 1
pCi/gin.
J2..
This resultant emanation rate is less than
that
stated in Criterion 1
(5
pci/m2-sec).
This would allow for accidental removal of a portion of the cover
(a little over a meter) before the 5 pCi/m2-sec level would be exceeded. In the
event that an excavation for a basement was made, a significant portion of
the
“cover” would be removed, resulting
in radon emanation rates exceeding 5 -pCi/in2-Sec.
However, if the cover was designed such that
the sludge was capped first with
a layer of clay approximately 1.3 feet thick, with the remainder
of the
cover being
Management of Water Treatment Plant Sludge
Containing Elevated Levels of
Radium
-
4
-
regular soil, one could excavate (approximately 8.5 feet
)
for a basement
to
within 1.3 feet of the buried sludge without exceeding a resultant radon emana-
tion rate
of
5 pCi/m2-sec. U.
The external ga~iaradiation levels would be reduced to less than 0.1 of
the initial radiation levels with only 1 meter of soil cover 12 (800 mR/yr x
0.001
=
0.3 mR/yr).
It should be noted that the sludge will again be
placed in an IEPA
permitted
landfill
with a clay
liner to
protect against
groundwater movement.
In
~uiimary,the
objectives of
this
criter±onareto
guard against accidental
intrusion, limit radon emanation,
limit
external radiation levels,
and protect
the groundwater.
Criterion 3
Sludge with radium levels less than 50 pCi/gm (dry weight) may
be used for soil conditioning purposes on agricultural crop-
land (corn, soybeans) but only if: (1) such use is in
accordance with IEPA procedures: and (2) the level of the
radium in the sludge is such that
after
the sludge is
mixed
with soil (for agricultural use) the incremental
increase
of
the radium concentration in the soil does not exceed 0.1
picocurie per
gram
(dry weight). The concentration of the
radium in the sludge (dry weight) shall be
determined by
laboratory
analysis.
The
incremental increase of the radium
concentration in
the soil
may be
determined by calculations
using
the previously determined concentration of
radium in
the sludge
and the estimated
amount of
mixture
with soil
during application. (Item 4b
and
Sb of Attackmtent
A.~
The intent of this
criterion is
to
allow sludge to
be used for agricultural
(soil conditioning) purposes.
The
normal
concentration of
radium in soil is approximately 1-2 pCi/gin.
The
mean daily intake of radium per day
(from foodstuffs) in the United States is
approximately 1.4 pCi/day, with an average intake in the Chicago, Illinois, area
of approximately 2.1 pCi/day. 13
(Water contributes an additional daily uptake
of radium.)
The Illinois Regulations for Radiation Protection, Part C, Schedule A, states
an exempt concentration of 1 x l0—~mnicrocurie/ntilliliter (uCi/mi). Jsing a con-
version of 1 ml/gm, an exempt concentration of 0.1 pCi/gui is derived.
The National Council on Radiation Protection and Measurements, Report No. 77,
indicates that agricultural land used to produce crops not directly consumed by
humans should not exceed a
concentration of
40 pCi/gm of Radium 226 in the soil.
Management
of Water
Treatment
Plant Sludge
Containing Elevated Levels of
Radium
-
5
-
This value is based on a dose limit of 500 mrenm/yr to bone (resulting from an average
dietary intake of 60 pCi/day
of radium)
and a
plant/soil
concentration ratio of
1 x l0—~. 14
Using
the
uptake coefficient of
1 pCi/Kg
radium
in fresh vegetables
per
1 pCi/gin
radium in the soil, with an average intake of fresh vegetables of 1.5 Kg/day, one
would receive an additional 0.15
pCi of radium per day, or 1.25 mrem/yr, by
adding
0.1 pCi/gm
radium
to the soil. 15
A U.S. Department of Energy
pathway
analysis
report indicates a source—to-
dose conversion factor of 21
(mrem/yr) / (pci/gm) for
Radium 226 in
soil.
~
Argonne
National
Laboratory, utilizing the new dosimetry models described
in the
International
Commission on Radiological Protection
publications Numbers
26 and 30,
has recalculated
this conversion factor to
be 28_(mrezn/yr)/(pci/gin) of Radium 226 in soil. As such,
an add~.tional 0.1
pCi/gm
of radaum an soal
would result an approxamately 3 mR/yr
additional dose to an individual based on
a worst case scenario. 17
IEPA
has indicated that all sludge application to farmland is regulated by theIr
agency. Sludge applications to land usually would not be more
fre ent than once
every
th~~~ars. As
such, it would
take a number of years
for the accumulated con—
centrataon of radium to increase significantly, and it is unlikely that sludge would
be applied to the same fields for an extended period of time.
Criterion 4
If the level of radium in the
sludge exceeds 50
picocuries per gram
(dry
weight): (1) the method of disposal of such wastes must be
reviewed
and
a determination must be made in advance by IDNS that there
is reasonable assurance that the exhalation rate of radon to the
atmosphere or into a dwelling will not exceed an average rate of
5 picocu.ries
per square meter per second and
there is reasonable assurance
against accidental
intrusion into the
sludge in the future. (2) the
sludge
may
be used for soil conditioning, subject to
the restrictions
provided in Criterion 3 and only if an affirmative determination
is
made
in advance by IDNS. (Items 6a
and b
-
Attachment A.)
If the levels of radium in sludge to be buried or applied on
land
for agricultur-
al use exceed those
values stated in Criteria 2 or 3, IDNS believes it is
necessary
to evaluate the final use/disposal of such sludge on a case—by-case basis.
IV. Suimnar
The above criteria should
provide a
mechanism for the practical management of
sludge containing radium, while at the same time providing
assurance that
the five technical objectives of IDNS
are
fulfilled.
P~ERENCES
1
USEPA
“Final Environmental Impact Statement for the Control of Byproduct
Materials from Uranium Ore Processing”(40CFR192),
EPA
520/1-83-008—1,
September
1983, Page 9—15.
US~A “Final Environment Impact Statement
for the
Control
of Byproduct
Materials from Uranium Ore Processing” (40~Rl92), EPA 520/1-83-008-1,
September
1983, Page 9—16.
3. USEPA “Final
Environmenta. Impact Statement for
the Control
of Byproduct
Materials from
Uranium
Ore
Processing”
(40cFR192),
EPA 520/1-83—008-1,
September 1983, Page 9—15.
4.
US~’A “Final Environmental Impact Statement for the Control of Byproduct
Materials
from
Uranium
Ore
Processing” (40~’R2.92),
EPA 520/1-83—008-1,
September 1983, Page 8—13.
5. USEPA “Final Environmental Impact Statement for the Control of Byproduct
Materials from Uranium Ore Processing” (40cFR192) EPA 520/1—83—008-1,
September 1983, Page 8—12.
-
6. USEPA “Final Environmental Impact Statement for the Control of Byproduct
Material! from Uranium
Ore Processing” (40cFR192), EPA 520/1-83-008—1,
September
1983, Page 10—10.
7. USEPA “Final Environmental Impact Statement for Remedial Action Standards
for Inactive
Uranium
Processing
Sites” (40~’Rl92), EPA 520/4—82—013-1,
-
October
1982, Page 91.
8. USEPA “Final Environmental Impact Statement for the Control of Byproduct
Materials from Uranium Ore Processing” (40CFR192), EPA 520/1-83—008-1,
September 1983, Page 10—3.
9. USEPA
“Final
Environmental Impact Statement for the Control of Byproduct
Materials from Uranium Ore Processing” (40 CFR192),
EPA 520/1-83-008-1,
September 1983, Page 3-5.
10.
USEPA “Final Environ~ental Impact Statement for the Control of Byproduct
Materials from Uranium Ore Processing” (40CFR192), EPA
520/1—83—008-1,
September 1983, Page 3—5.
11. USEPA “Final Environmental Impact Statement for the Control of Byproduct
Materials from Uranium Ore Processing” (40CFR192), EPA 520/1—83—008-1,
September 1983, Page 8—10.
12. USEPA “Final
Environmental
Impact Statement for the Control of Byproduct
Materials from Uranium Ore Processing”
(40CFR192),
EPA 520/1—83-008-1,
September
1983, Page 8—12.
•
—a—
:~
13.
National Council on Radiation Protection and Measurements, “Natural
Background Radiation in the United ta,
Report No.
45, November
1975, Page 92.
14. National Council
on
Radiation
Protection
and
Measurements, “Exposure
from
the
Uranium Series with Emphasis on Radon
and
its Daughters”,
Report No. 77,
March
1984, Pages 60, 90, 103, 104.
15. National Council
on Radiation
Protection
and Measurements, “Exposure
from the Uranium Series with Emphasis on Radon
and its
Daughters”,
Report No. 77,
March
1984, Pages 61, 104.
16. USD05, “Pathways Analysis and Radiation Dose Estimates for Radioactive
Residues at Formerly Used
~D/AEC
Sites”, ORO-832(Rev), March 1983, Pages
5—13.
17. Argonne National
Laboratory,
Letter signed
by ‘Thomas •L.
Gilbert,
Senior
Physicist, dated 7/24/84.
-
-
——
ATTACHMENT A
MEMORANDUM OF AGREEMENT
This Memorandum of Agreement Is entered Into by and between
the Ii
Ii
noi
S
EnvIronmental Protection Agency (JEPA) and the
Illinois Department of Nuclear Safety (IDNS).
This
Memorandum
of Agreement Is entered into for the purpose of delineating
certain responsibilities of IEPA and IDNS regarding the disposal
of sludge resulting from
treatment
of water or sewage and
contal ning radium occurring naturally from ground waters.
WHEREAS, many public water supplies in the State of
IllInois
draw their raw water from deep wells which contain
naturally occurring radium, and
WHEREAS, such radium Is removed from the raw water during
treatment thereby concentrating it in sludge, and
WHEREAS, IEPA has authority to regulate the management and
disposal of said sludge under the Environmental Protect~on Act,
--
Ill. Rev. Stat., 1983, ch. 111 1/2, pars. 1001 et. sea., and
Regulations adopted thereunder, and
WHEREAS, IONS ~t~as authority to require registration of
certain install ations storing radioactive material under the
provisions of Ill. Rev. Stat.,
1983, ch. 111 1/2, pars. 194 et
seq., and
WHEREAS, IONS has authorIty to require the licensure of
certain sources of radiation arid has authority to promulgate
regulations to govern the possession and use of any radiation
source under the Radiation Protection Act, Ill. Rev. Stat.,
1983, ch. 111 1/2, pars. 211 et seq..
THEREFORE,
it
Is agreed by and
between IEPA and IDNS as
follows:
1)
Pursuant to Ill. Rev. Stat., 1983, ch. 111 1/2, par.
194 et sea, which provides that every operator of a
radiation installation must register with IONS, the
following indIviduals
or entities
must register
directly
with IDNS and must comply with the
requirements
of that statute
and implementing
-
regulations:
a)
Owners and operators of facilities
or plants
which produce sludge resulting from the treatment
of water or sewage and containing radium
occurring naturally from ground water; and
b)
Owners and operators of IEPA permitted landfills
if
the sludge
Is
disposed of in such landfills;
and
,:~-
~
2
c)
Any other person or entity that IDHS determines
is
required to register under the provisions
of Ill. Rev. Stat., 1983, ch. 111 1/2, pars. 194
et sea.
2) Sludge resulting from the treatment of water and
sewage and containing radLn occurring naturally from
ground water will be exempt from the licensure and fee
requirements of the Radiation Protection Act (Ill. Rev.
Stat., 1983, ch. 111 1/2, pars. 211 et seq.) based on
IONS’ finding that such exemption will not constitute
a significant risk to the health and safety of the
public.
3)
Sludge resul ting
from the treatment of water and
sewage and contai’ning naturally occurring radIum from
ground water may be disposed of In accordance with the
provisions of this Memorandum of Agreement and the
requirements of IEPA and the Rules and Regulations of
the Illinois Pollution Control Board, as implemented
by IEPA. Any permit issued by the JEPA pursuant to
this Agreement shall contain conditions based on the
technical criteria contained herein and in any
regulations which IEPA and OHS agree to adopt pursuant
to
this Agre~rnent.
4) If the level of radium in the sludge Is 5 picocuries
per gram or less (dry weight):
a) - the sludge
may be disposed of In a landfill
permitted by IEPA to accept such sludge;
b)
the sludge may be used for soil conditioning
purposes on agricultural
crop land (e.g., corn,
soy beans) but only if:
(1) such
use is in accordance with IEPA
procedures;
and
(2) the level of radium in the sludge is such
that after the sludge is mixed with soil
(for
agricultural
use) the increment-al
increase of the radium concentration in the
soil does not exceed 0.1 picocurie per gram
(dry weight). The concentration of the
radium in the sludge (dry weight) shall be
determined by laboratory
analysis.
The
incremental
increase
of the radium
concentration
In the soil may be determined
by
cal c ul ations using the p revi ously
)
determined concentration of radium in the
sludge
and the estimated amount of mixture
with
soil during application.
)
-
-.--
-
-
3
a) the sludge may be disposed of in an IEPA
permitted landfill provided that there is at
least ten feet
of non-contaminated overburden
between the sludge and grade
level in order to
provide:
(1) reasonable assurance that the exhalation
rate of radon to the atmosphere, or into a
dwel 1 ing, will not exceed an average rate of
5 picocuries per square meter per second; and
(2) reasonable assurance against accidental
intrusion into the sludge in the future.
b) the Si udge may be used for soil conditioning,
subject to the restrictions provided in paragraph
4( b);
6) If the level of radium in the sludge exceeds 50
picocuries per gram (dry weight):
the method of disposal of such wastes must be
reviewed and a determination must be made in
advance by IDNS (pursuant to procedures set forth
in Paragraph 8) that there is reasonable
assurance that the exhalation rate of radon to
the atmosphere or into a dwelling will not exceed
an average rate of 5 picocuries per square meter
per second and reasonable assurance against
accidentlal intrusion into the sludge in the
future.
b) the sludge may be used for soil conditioning,
subject to the restrictions provided in paragraph
4(b) and only if a determination is made in
advance by IDNS (pursuant to procedures set forth
in Paragraph 8) that there is reasonable
assurance that the exhalation rate of radon to
the atmosphere or into a dwelling will not exceed
an average rate of S picocuries per square meter
per second and reasonable assurance against
accidential intrusion into the sludge In the
future.
7) Alternative methods of sludge disposal may be utilized
in emergency situations or where it is technologically
or economically impracticable to dispose of sludge In
accordance with Varagraphs 4 through 6. Such
alternative
methods
may be used only if a
determination is made in advance by IDNS (pursuant to
5) If the level of radium in the sludge is greater than
S
picocurles per gram (dry weight) but. less than 50
picocurles per gram (dry weight):
a)
P.
~,,•
4
procedures set forth in Paragraph 8) that there is
reasonable assurance that the exhalation rate of radon
to the atmosphere or Into a dwelling will not exceed
an average rate of 5 plcocuries per square meter per
second
and reasonable assurance against accidential
intrusion Into the sludge ‘ri the future,
8)
a)
In those cases where a
prior determination Is
needed from IONS, IEPA will provide- IDNS with a
copy of the pertinent permit application.
IONS
will provide
comments
to IEPA regarding these
permit applications,
including
its written
determination as to whether there is reasonable
assurance that the exhalation rate of radon to
the atmosphere or into a dwelling will not exceed
an average rate of 5 picocuries per square meter
per second and reasonable
assurance against
accidential
intrusion
i.nto the sludge in the
future.
b)
In emergencies IEPA and IONS may meet to discuss
the situation and determine acceptable
alternatives
for temporary resolution of the
emergency.
IDNS must approve
the
alternative
chosen.. for
temporary resolution. Approval or
denial of the method of final disposal of the
si
udge
will
be in accordance with procedures
described in subparagraph 8(a).
9)
All
analysis
of sludge shall be conducted by a
laboratory
certified
by the United
States
Environmental
Protection Agency to perform radio-
logical
analysis, and concentrations of radIum will be
determined by a method approved by IONS.
10) Copies of all permits issued by IEPA relating to
disposal of sludge containing radium occurring
naturally from ground water will be forwarded to rDNS,
11) IONS agrees to provide IEPA with technical support in
any proceeding in which the technical criteria
contained in this Memorandum are at issue.
Dated:
~
(~(~/
-
rector
~7
Illinois Envik~n,i~enta
Protection
Agency
Oated :
I (~~‘9
D~rector
kO~*~
Illinois Department of Nuclear Safety
I
1
Exhibit
2
Illinois
Summary of Radium Removal Methods
and Disposal Issues as they Relate to
Radium Removal from Drinking Water
May, 2004
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
(pCiJL) 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 decreespromising 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 disposal methods.
1. Systems that dispose of the radioactive water-treatment residues-into 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
licensed to 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 backwashed periodically, sending the
radioactive
filter solids with the backwash
water to the sanitaly 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 the fact 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 in Utah. Because of the high iron and magnesium content, the density of these particles
is greater than typical
sludge and segregation/settling of these particles may occur
in the sewer system.
Illinois radiation protection regulations, 32 111 AcIm.
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 effectiveness of the 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 IEPA
—
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 treatment plant 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 allowableincrease
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 PCiJL to 6,000 pCi/L (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
pCi!L.
On a
dry-weightbasis, the concentration will be in excess of 100,000 pCi/g. 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 fme 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 feed water as finished water. The 20 percent reject water contains the majority
of the contaminants and is then disposed ofas a liquid waste to 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 ofthis system is that very high 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 per gram on land with sludge
3
applied. Local municipal workers are responsible for the maintenance, reagent handling and ultimate disposal.
In communities where all or most of the drinking water that reports to a wastewater treatment plant is above the
MCL, some level oftraining
and monitoring for radiation exposure of sewer workers in contact with the sewage
sludge may be warranted.
Systems that dispose ofthe 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 residue generated by this process is often used on low-
pH
soils for soil 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 per gram on land where
sludge is applied. Radon exposure levels of lime softening workers may need to be monitored; 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 workers would be responsible for the maintenance, reagent handling and ultimate
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 contracted to experienced personnel. In addition, the
spent mediawill be exchanged while the concentration
ofradium is low enough to permit safe
and economic transportation and disposal.
One advantage is the simple operation of the system (no backwashing or chemical 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, estimated at less than 10 mrem/year. The radium-bearing media is disposed
of in a licensed disposal site with long term maintenance and monitoring-plans;
What are the repercussions ofradium 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 of concentration in the solids is not well
documented but has been estimated by the New Jersey EPA to be in ex.cessaf 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 solids would 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 of these 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 of radon 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 in the 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 of radium in a year, adsorptive media
has a 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
r
than lime softening.
Transportation of radioactive materials is completed under established Department of
Transportation regulations. Because of the granular nature of 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 of the 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. Elevated levels of radium in the pipe scale should be expected.
Reverse Osmosis
The equipment and sewer line will have to 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.npdesoermits.com.sparrc.
This is also available directly from WRT.
2. ISCORS Technical Report 2003-03
—
ISCORSAssessment ofRadioactivity 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
Software Program to Asce.laln
ResIdual Radlonudilde
Concentmtlone
-
-
-
Downi,j~iandccmmenfssu
HQM! I Downloid SPI
Welcome to the SPARRC Download and Comments Submission Site
What Is SPARRC?
-
Several radlonudides such as
radon,
radIum,
alpha
emitters, and beta and photon
emitters are-regulated
by the US Environmental Protection Agency
under the Safe
Drinking
Water Act When
watertreatment
plants remove these contaminants from
drinking
water sources, the
contaminants
are
transferred from
feed water to other media Including treatment plant prgcess residuals suth as back asitwater, brine,-
and sludge. The
presence
of
radlonudides
In
treatment plant wastes, depending onthe-concentratlon
and or load specified
In allowable
limits,
may restrict the use of
Inexpensive
disposal options for those
residuals, ln~reaslngtreatment costs. ResIduals may be dassifled as hazardous-under RCRA depending
on the
concentration
of co-contaminants present. The cost of residuals disposal.Is also a function of the
volume and/or
mass
of the residuals. Therefore, it Is Important to estimate the quantities as-well as the
concentrations
of radlonudkles and co-contaminants In residuals
generated
by Water treatment plants.
SPARRC Is a desktop software application that enables use~rsto analyze the potefltial concentrations of
radlonuclides in residuals from drinking water
process
streams.
-
-
Distribution of SPARRC
-
SPARRC Version 1.0 Is In tad 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 files are induded.
What would you like to do?
Download
and
Install SPARRC
-
Submit
comments on SPARRC
http://www.npdespermits.comlsparrc/
-
4/1/2004
Radium Disposal Options in Illinois
Compliant Water
to Consumer
SOLJD
4
Ra 226+228 5
pCilg
Landfill
Ra 226+228 50
pCiIg
(No permitted facilities in Illinois)
Land
Back to top
Apphcation
Ra 226+228 50 pCi/g
No more than
0.1 pCi/g increase in soil
Low Level
Radioactive
Landfill
Ra 226 222 pCi/g (Idaho site)
Ra 226 10,000 pCi/g (Washington Site)
Raw Water
Jr
/
/
/
- -
.~aste
-
Water
#4.
Jr
Local
Landfill
Waterways
Hydrous Manganese Oxide
Raw Water
Jr
I-.
HMO Chemicals
Radium Removal Process
Radium
HMO Precipitant
Precipitant
Formed
- -
F~adiUm
Loaded~
-
Spent
Filter
~-~-
Media
Appropriate
Landfill
I
1~
4
Disposal of radium
bearing solids
into sewer system
/
is prohibited!
Sewer: Pipe
-:‘
--
-
Waste Water
_____
Treatment
Plant
/
Sludge
Land
/
-Application--
oR\
‘V
Waste
.Water,
Waterways
Appropriate
- -
Landfill
Jr
•0
Ion Exchange
Issues:
Corrosion of piping & values
Sodium in drinking water
I
I
$
I!
Land
Application
Precipitation of
Radium
Carbonates
and Radium Sulfates
Violation
of
Copper, Lead &
Zinc limits from
corrosion
Waste
Water
_____
__________
Treatment Plant_____
Appropriate
Landfill
Waste
--
:Water--
Jr
--p
Waterways
Radium Removal Process
1~
Back to top
-Loaded
Resin
L -,~‘.,j--~-
Exhausted
Resin
Appropriate
Landfill
I
-
--
r
-
—~
‘I
Reverse Osmosis
-
Radium Removal Process
R.O. Membrane
— 20
of
Feed Water
Ra
+
/
- ~
Sludge
Land
/
Application
oR\
Deposition Of Radium as
Carbonates & Sulfates
Appropriate
Back to top
Landfill
Raw Water
-
Sewer Pipe
-
of
Feed Water
/
Waste Water
Treatment
Plant
‘V
Jr
Waterways
‘-I
“-I
Lime Softening
Radium Removal Process
Raw Water
Na2CO3
Land
-Application,: -
4
:~Cl:arjfier
V
1
Ra+~,
Sludge
1
Back to top
Drying
Lagoons
V
CaO
/
I,
I
—
Absorbent Media
Radium Removal Process
/-
S..
Licensed & Permitted
Disposal Facility
-
¼.
—
~~
~
Raw Water
Summary of Memorandum of Agreement between IEPA and IDNS
1. If sludge is less than 50
pCi!g
then land application is
permitted.
2. If sludge is land applied it may not increase the radioactivity of the soil by more than 0.1 pCi/g
3. If sludge 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
pCi/g then IDNS must approve disposal method
and site.
Sewer Sludge Application Parameters
Drinking water parameters
Level oftotal radium in water
gallons per day pumped
gallons per year pumped
Picocuries radium in water per year
Coding:
required input numbers:
numbers that are calculated but should be
input
if available:
comments:
-
-
--15 pCi/L
500
000
~
t ~0Q~g~ ~S c~llj~tmje.~
182,500,000 gallons! year
10,402,500,000 pCi! 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
I
year
Picocuries radium in sewage influent ! 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
foot
of soil
grams of soil
I
cubic ftsoil
cubic ft of soil needed ! year
sewage
treatment
plant
reports
116,800,000 grams
10,402,500,000
5
846 ~Pp~i~4Q!~
lLm~J~0pct&g
0.47
Picocuries! liter
0.1
~
98,823,750,000 grams of soil
26,899.50 gI cubic ft.
3,673,814
cubic ft.
Acres!
year if mixed in top 6 indies
Application rate (tons! acre)
168.7 acres needed
I
year
0.76 tons
I
acre
-
___1.(
-—
- -
-
I
-r----—
m
-~-
-J
0~
—1-
0)
I
—
-----~~-----—~---—-
—----- —-—
The
Beacon
OSWEGO
—
The process of removing radium
from the village’s water supply should begin this
winter, after contract negotiations were completed
this week with the company that will do the work.
Village Board members this week approved a
$2.8 million contract with Colorado-based Water
Remediation Technology Inc. to rid the water of
radium, a naturally occurring yet potentially
harmful element.
In 2000, the Illinois Environmental Protection
Agency found that Oswego was one of 130 Illinois
communities with higher-than-normal levels of
radium in their water, and mandated that they
either correct the problem or have a plan in place
to do so by this December.
Village officials originally estimated that it
would cost more than
$5
million to complete the
task through filtering or softening, but later
discovered that a process called ion exchange
would do the job more efficiently and for almost
half the price.
“It’s the most environmentally sound and most
cost-effective way to do what we need to do,”
Village Administrator Carrie Hansen said.
On average, the village’s five water wells
contain about 6.5 units of radium per liter, 1.5
units higher than the EPA allows. Once the
removal process begins, however, levels should be
almost undetectable, officials say.
Studies have shown that water with high levels
of radium can cause bone cancer if consumed in
October 22, 2003
mass quantities and over a long period of time.
Oswego board members agreed to give the job
to WRT last May, but recurring disputes over the
wording of the contract stalled the process until
this week.
But Mayor Craig Weber said the wait was well
worth it.
He said WRT’s $2.8 million price tag
—
about a
third of which will be paid with federal grant
money
—
was far lower than any other offer the
village received.
Still, trustees are considering a “slight” increase
to the village water rates to help defray the cost,
Weber said.
“This was something that we simply needed to
do,” he said. “It’s going to provide us with safe
drinking water and (contracting with WRT) is
going to save us more than $2 million in the
process. I think we’re all pleased with this
agreement and ready to get the process started.”
Other local communities, including Elburn and
Sycamore, also have used the WRT technology
with
good results, officials from those
communities said.
In January, officials in Yorkville approved a $10
million contract with another company to remove
radium using a method called “cat ion exchange.”
Batavia and Geneva are among other Fox
Valley cities where radium-removal procedures
are also under way.
Oswego will pay $2.8 million
to remove radium
By Ed Fanselow
from water
STAFF WRITER
“...
WRT’s $2.8 million price tag
wasfar lower than any other offer
the village received.”
—
Mayor Craig Weber
“It’s the most environmentally sound
and most cost-effective way to do what
we need to do.”
—Village Administrator Carrie Hansen
THE ELBURN HERALD
Independently Serving the Kaneland Community
—
Since 1908
June 17, 2004
Elburn
New
considers
ratewillhelppay
first
forradium
water
removal
rate
project,
increase
otherinfrastructure
in 18
costs
years
By
JenniferDuMont
While Elburn residents may pay 34.5
percent more for water, village officials
pointed out Monday that the residents’ glasses
are
still
half full.
Elburn’s
water rates have not changed
since 1986, village officials explained. During
the past 18 years, the current rate of $2 per
100 cubic feet of water meant that Elburn
residents bought 3.74 gallons of water for one
penny.
“WRT’s zeolite technology
is saving Elburn millions of
dollars.”
—
Village President
Jim Willey
“Compare that to a gallon of distilled
water at the store versus out of the tap,” said
Village President Jim Willey. “II’ our rates had
been adjusted five-percent over the last 18
years, our current rate would be $4.81 per 100
cubic feet. If our rates were adjusted
2.5
)
percent, our rate would be $3.12 per 100
cubic feet versus the $2 we currently pay.”
While the current cost is the half-full
portion of the glass, the half empty part is the
additional funding needed to pay for a village
radium removal system. The mandated
project to remove radium from the village’s
water supply will cost $2.2 million. More
good news can be found when considering
this cost of $2.2 million to use Water
Remediation Technology’s (WRT) radium
removal process is drastically reduced from
the $14 million it would cost to use the lime
)
softening method of radium removal, or the
$5 million it would cost to use the ion-
exchange method, which was the original
choice Elburn was prepared to make.
“1 give us a lot of credit for being nimble
enough to say we’ve got to look at this new
technology (of WRT’s) that removes radium
and carts it o!’f to an approved trace radium
site, instead of redistributing it (as other
radium removal methods do),” said Willey.
The $2.2 million cost Elburn must invest
for radium removal is further reduced when
the $474,000 in federal funds secured by U.S.
Speaker Dennis Hastert and the $350,000 in
developer contributions are subtracted from
the price tag. This leaves a balance of $1.7
million to be paid from the village to WRT.
The Arvada, Colo.-based company also offers
a prepayment plan of the $575,000 in capital
costs it will take to install WRT’s system. By
paying this amount up front, the village will
save several thousands of dollars over the
next 20 years, the length of the WRT contract.
There is further good news here, said
Willey,
when
you
consider
other
municipalities are seeking low-interest loans
to pay for radium removal, when Elburn has
savings to cover the $575,000 prepayment
cost.
“Paying a little more money up front
means less money overall,” said Willey. “This
is very significant. We were prudent with our
funds because we knew this was coming.”
However, the residents will still need to
pay more for water. Village officials selected
the 34.5-percent increase as one of three
options. This option will raise the rates to
$2.69 per lOO cubic feet of water, and the
village will save money in the long run by
paying capital costs up-front, allowing for
$28,500 in recapture costs and helping build a
reserve to pay for improvements to water
mains in town, such as improvements that
must be made to increase fire flows in the
northwest quadrant of the village.
While increasing the water rate from $2 to
$2.69 per 100 cubic feet, the village plans to
keep the sewer rate at the current $2/100
cubic feet rate, which translates to an
“effective” rate increase in a homeowner’s
total water bill of 17.25-percent. On an
average, a quarterly household bill of $80
would increase to $93.80.
“We needed to raise water rates anyway in
my opinion,” said trustee Jeff Humm. “We
need to replace existing water mains and raise
connection rates for capital improvements.”
“We didn’t ask for this, but we’re trying to
figure out what to do,” said trustee Jeffrey
Metcaltl “We’ve done the best we can and
we’re farther ahead (because of planning
ahead).”
“Tomorrow’s headlines will probably say
‘Elburn Considers Raising Water Rates by
34.5 percent,” but that’s not the whole story,”
said Willey. “What the headlines might not
say, but should, is that Elburn hasn’t raise its
water rates for 18 years and the increase is
really only a 17.25 percent increase on the
total water bill by holding the sewer rate the
same. Also, Elburn can solve its radium
problem without borrowing, which represents
a tremendous savings to future taxpayers.
WRT’s zeolite technology is saving Elburn
millions of dollars over the ion-exchange or
lime softening methods, and Elburn’s radium
will be properly disposed of and not flushed
into streams, spread on a farm field or
dumped into an unsuspecting landfill. We’ve
always tried to be environmentally conscious
here.”
“Elburn ~ radium will be
properly disposed of and not
flushed into streams, spread
on afarm field or dumped
into an unsuspecting
landfill.”
—
Village President
Jim Willey
At next Monday’s Village Board meeting,
trustees will vote to approve the 20-year
contract with WRT to remove radium from
the village’s water supply. The state of Illinois
requires municipalities with higher than
acceptable levels of radium in their water to
remove the radium from the water. It is
believed that exposure to high enough levels
of radium for long enough periods of time
may cause cancer. WRT has completed a pilot
plant study in Elburn and has determined its
patented process can effectively remove
radium here.
The
Beacon
.Fu ne
I
~.
2fl( 1.1.
Elburn sees savings in new
water filtering technology
By Linda Girardi
SPECIALTOTHE BEACON NEWS
ELBURN
—
The village has found
a way to remove trace levels of radium
in its drinking water supplies without
significantly raising residential water
rates.
“It’s a tremendous savings,” Mayor
Jim Willey said of the $2.2 million
federally mandated project.
The Village Board is expected
Monday to authorize signing a 20-year
lease agreement with Water
Remediation
Technology
for a
relatively new technology patented to
remove trace levels of radium from
drinking water supplies.
Per the agreement, the village’s
water100
cubicrate
wouldfeet
to
increase$2.69
perfrom100$2cubicper
-
feet. The average quarterly bill per
household would go up
from $40 to
$54, village officials estimate.
Elburn’s water rates have remained
constant since 1986.
Radium is a naturally occurring
element found in deep wells across
northern Illinois. The Environmental
Protection Agency is demanding
municipalities remove the radium to
reduce the risk of cancer over a
prolonged time.
In the last couple of years, the
Village Board has studied the use of
ion exchange and lime softening that
would require the construction of
centralized plants, costing in the range
of $5 million to $9 million. In addition,
the systems would have required costly
operational and maintenance costs.
“We had to look at this technology
—
the savings was too great,” Willey
said of the Water Remediation
Technology proposal.
Water Remediation Technology
radium removal pi’ocess involves
passing Elburn’s drinking water
through a resin to absorb the radium
out of the water. The filtering system is
changed approximately once a year.
Willey said
the WRT lease
agreement has a $575,000 capital
prepayment option which could save
the village several thousands of dollars
over the life of the agreement.
Elburn is a recipient of a $474,000
federal grant obtained by U.S. House
Speaker Dennis Hastert, R-Yorkville.
The village must fund the remaining
$1.7 million balance for the project.
“Our village has the funds available
to pay for this project and to take
advantage of the prepayment option
without any borrowing,” Willey said.
The
Beacon
- -
January 22, 2004
Elburn to go high tech
to remove
ByLindaGirardi
radium
SPECIAL TO THE BEACON NEWS
ELBURN
—
The village has agreed to move
forward with a relatively new technology that will
remove trace levels of radium from its drinking water
supplies.
The Village Board this week authorized the mayor to
sign an agreement with the Illinois Environmental
Protection Agency, outlining the village’s
responsibilities relative to funding, preparation and
completion of the process.
“There’s an incredible savings here on
behalf of the community,”
—Village Administrator David Morrison
The
IEPA agreement sets a compliance date of
December 2005.
“There’s an incredible
savings here on behalf of the
community,” said Village Administrator David
Morrison, adding there might be even better news next
week when the board discusses the overall impact on
residential water rates.
Radium is a naturally occurring element found in
deep wells across northern Illinois. The EPA is
demanding municipalities and villages remove the
radium to reduce the risk of cancer over a prolonged
time.
The Village Board has studied the use of ion
exchange and lime softening that would require the
construction of centralized plants, costing between $5
million and $9 million. In addition, the systems would
require on-going operational and maintenance costs.
Mayor Willey said the village received a $475,000
federal grant through the help of U.S. House Speaker
Dennis Hastert. The village would lease the equipment
to eliminate additional costs.
“For an unfunded mandate, to save the citizens this
much money is huge,”
Trustee Craig Swan said.
Village Engineer Bill Gain, of Rempe Sharpe &
Associates in Geneva, said the Water Remediation
Technology Z-88 radium removal process involves
passing Elburn’s drinking water through a resin to
absorb the radium. The filtering system is changed once
a year.
The process would involve building two structures,
resembling farm
silos at Well No. 3 and Well No. 4 on
First Street and North Street.
Gain said the Well No.
4 structure would stand about
28 feet above ground. It would
sit four feet below
surface and would be situated away from the Veterans
Memorial.
“For Well No. 3, we recognize it is a residential area
and we’ll sink it into the ground about 12 feet, giving
the structure a height of approximately 19 feet,” Gain
said.
“We have gone through the pilot
testing, so we know the process does work
and it was accepted by the IEPA. That
removed most of the risk out of it.”
—Village Engineer Bill Gain
“We have gone through the pilot testing, so we know
the process does work and it was accepted by the IEPA.
That removed most of the risk out of it.”
Construction is scheduled to begin in March 2005.
Gain said the system would not drastically alter the
condition of the drinking water supply.
“There may be some difference,” he said, “but not a
great difference.”
