IN THE MATTER OF:

)

)

NOTICE

(Rulemaking—Water)

RE

CLERK’S

CE

OFFICE

~V

ED

BEFORE THE ILLiNOIS POLLUTION CONTROL BOARD

NOV 24 2004

STATE OF

~LUNO~S

PoUUttOfl Contro’ Board

REVISIONS TO RADIUM QUALITY

)

R

04-21

STANDARDS: PROPOSED NEW

35

ILL. ADM)

CODE 302.307 and AMENDMENTS TO

)

35

ILL. ADM. CODE 302.207 and

302.525

)

TO:

Dorothy Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph Street, Suite 11-500

Chicago, illinois 60601

SEE

ATTACHED SERVICE LIST

PLEASE TAKE NOTICE that I have filed with the Office of the Pollution

Control Board the Supplemental Information as agreed to at the hearing held on October 21 and

October 22, 2004 on behalfofthe City ofJoliet, a

Date: November 24, 2004

Roy M. Harsch

Gardner Carton & Douglas LLP

191 North Wacker Drive

Suite 3700

Chicago, Illinois 60606

(312) 569-1441

THIS FILING IS SUBMITTED ON

RECYCLED PAPER

CHO2/ 22352356.2

~iI

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD CLERK~SOF

NOV 24 21)04

IN THE MATTER OF:

)

STATE OF

~

REVISIONS TO RADIUM QUALITY

)

R

04-21

Pdllut~onContro’ ~

STANDARDS: PROPOSED NEW

35

ILL. ADM

)

(Rulemaking—Water)

CODE 302.307 and AMENDMENTS TO

)

35 ILL. ADM. CODE 302.207 and 302.525

)

SUPPLEMENTAL INFORMATION

NOW COMES the City of Joliet through one of its attorneys, Roy M. Harsch, and

submits this Supplemental Information, as agreed to at the hearing held on October 21 and

October 22, 2004, to the Illinois Pollution Control Board (“Board”) and the participants listed on

the Service List.

The City ofJoliet is providing the following Supplemental Information:

1) Attachment 1. The Calculation ofthe Benefit to Public Costs in Dollars Per Person

—

rem for Land Application ofBiosolids prepared by Mr. Dennis Duffield.

2) Attachment 2. A report entitled “Evaluation ofRadium Removal Impacts to Study

Handling at the Eastside and Westside Waste Water Treatment Facilities,” prepared by

Clark Dietz, Inc. and dated August 2004.

3) Attachment 3. A report entitled “Report of Survey at Westside Waste Water Treatment

Plant in City ofJoliet, Illinois,” prepared by RSSI, and dated November 15, 2004.

4) Attachment 4. A report entitled “Report of RESRAD Dose Modeling for Waste Water

Treatment Plant Sludge Applied to Land Currently Used for Agriculture,” prepared by

RSSI, and dated October 18, 2004.

CHO2/ 22352356.2

---

WHEREFORE, the City ofJoliet by one ofits attorneys requests that these four

attachments be included as Exhibits in the record ofthis procedure.

Roy M. Harsch

Gardner Carton & Douglas LLP

191 North Wacker Drive

Suite 3700

Chicago, fllinois 60606

(312) 569-1441

CHO2/22352356.2

2

---

CERTIFICATE OF SERVICE

I, the undersigned, certify that I have filed with the Pollution Control Board and served

the attached Supplemental Information upon the person to whom it is directed, by placing it in an

envelope addressed to:

TO:

Dorothy Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph Street, Suite 11-500

Chicago, Illinois 60601

SEE ATTACHED SERVICE LIST

And mailing it by First Class Mail from Chicago, Illinois on November 24, 2004, with sufficient

postage affixed.

CHO2/ 22352356.2

THIS FILING IS SUBMITTED ON RECYCLED PAPER

I

---

R 04-21 SERVICE LIST

Deborah

J.

Williams

Assistant Counsel

Illinois Environmental Protection Agency

P.O. Box 19276

Springfield, IL 62794-9226

Albert F. Ettinger

Environmental Law & Policy Center

35

East Wacker Drive, Suite 1300

Chicago, illinois 60601

Matthew J. Dunn

Office ofthe Attorney General

Environmental Bureau

188 West Randolph, 20th Floor

Chicago, Illinois 60601

Amy Antoniolli

Illinois Pollution Control Board

100 West Randolph Street, Suite 11-500

Chicago, Illinois 60601

Claire A. Manning

Posegate & Denes

111 N. Sixth Street

Springfield, Illinois 62701

Richard Lanyon

Metropolitan Water ReclamationDistrict

100 East Erie Street

Chicago, Illinois 60611

Abdul Khalique

Metropolitan Water Reclamation District

Of Greater Chicago

6001 W. Pershing Road

Cicero, Illinois 60804

CHO2/ 22352375.1

Dennis L. Duffield

City ofJoliet

Department ofPublic Works & Utilities

921 B. Washington Street

Joliet, illinois 60431

Stanley Yonkauski

Illinois Department ofNatural Resources

One Natural Resources Way

Springfield, Illinois 62702-1271

Joel C. Stemstein

Office ofthe Attorney General

Environmental Bureau

188 West Randolph, 20th Floor

Chicago, Illinois 60601

William Seith

Total Environmental Solutions

631 B. ButterfieldRoad, Suite 315

Lombard, Illinois 60148

John McMahon

Wilkie & McMahon

8 East Main Street

Champaign, Illinois 61820

Lisa Frede

CICI

2250 E. Devon Avenue, Suite 239

Des Plaines, Illinois 60018

Jeffrey C. Fort

Letissa Carver Reid

SormenscheinNath & Rosenthal

8000 Sears Tower

233 South Wacker Drive

Chicago, illinois 60606-6404

---

Exhibit 1

---

Calculation of the Benefit to Public Costs in Dollars

I

Per Person — rem For Land Application of Biosolids

The Nuclear Regulatory Commission (NRC) gave recommendations of $2,000/person-

rem in NUREG-1 530

Assessment ofNRC’s Dollar Per Person-Rem Conversion Factor

Policy,

published in 1995.

The benefit to the public is that costs are saved by continued land application of

I

biosolids(wastewater treatment plant sludge). The savings associated with land

I

applications were calculated by Clark Dietz, Inc in the report entitled

“Evaluation of

Radium Removal Impacts on Sludge Handling at the Eastside and Westside

I

Wastewater Treatment Plants” The report provides 20 year costs and must be adjusted

to 25 years. Adjustments were made to the operating costs only.

I

Joliet Eastside

Joliet Westside

Total

I

Capital

$4,050,000.00

$3,645,000.00

$7,695,000.00

I

20 year operating

increase

$15,647,933.55

$11,804,581.45

$27,452,515.00

I

20 year total

$19,697,933.55

$15,449,581.45

$35,147,515.00

I

25 year total

$22,543,836.32

$17,596,490.56

$40,140,326.88

The costs to the public are the cost associated with additional radiation exposure. The

Nuclear Regulatory Commission published costs in 1995 of $2,000 per person-rem.

This cost inflates to $2,500 per person-rem in 2004 using the consumer price index.

Using the radiation dose for 25 years from the RSSI Study entitled” REPORT OF

I

RESRAD MODELING FOR WASTEWATER

TREATMENT PLANT SLUDGE

I

APPLIED TO LAND CURRENTLY USED FOR AGRICULTURE” The 25 year doses

are as follows”

I

Joliet

Joliet

I

Eastside

Westside

Total

50.19000 mrem

120.58 mrem

170.77 mrem

convert to

I

rem

0.00100

rem/mrem 0.00100

rem/mrem

0.00100 rem/mrem

0.05019

rem

0.12058

rem

0.17077 rem

---

Acres

receiving

I

biosolids

705.00

405.00

1,110.00

I

homes per

acre

3.00

3.00

3.00

I

homes

2,115.00

1,215.00

3,330.00

I

CHO2/ 22352525.1

I

II

---

m

N)

---

Evaluation of Radium Removal Impacts to

Sludge Handling at the Eastside and

City of Joliet

Clark Dietz, Inc.

1817 South Neil Street,

Suite 100

August 2004

---

Evaluation ofRadium Removal Impacts to Sludge Handling at the Eastside and

Westsjde Wastewater Treatment Facilities

1.0

INTRODUCTION

1.1

Project Background and Objective

2.0

EXISTING SLUDGE HANDLING AND DISPOSAL METHODS

2.1

WestsideWWTP

2.2

Eastside WWTP

2.3

Land Application of Sludge

2.4

Current Costs for Land Application

3.0

IMPACT OF WATER

TREATMENT

RESIDUALS

3.1

Radium Removal Requirements

3.2

Proposed Water Treatment Technology

3.3

Current Radium Levels in Existing Sludge

4.0

ANALYSIS OF LANDFILL ALTERNATIVE

4.1

Design Objective and Approach

4.2

Capita! Costs for New Dewatering Facilities

4.3

Annual O&M Costs for New Dewatering Facilities

4.4

Other Costs

4.5

Advantages and Disadvantages

5.0

RECOMMENDATION

Clark Dietz. Inc.

1

A iegiist 2004

---

Evaluation ofRadium Removal Impacts to Sludge Handling at the Eastside and

Westside Wastewater Treatment Facilities

1.1

Project Background and Objective

The City of Joliet currently owns and operates two wastewater treatment facilities which

treat the City’s wastewater. The Eastside W\VTP, located on the east side of the River, has

the capacity to treat an average daily flow of 18 MGD, while the Westside WWTP has the

capacity to treat an average daily flow of 14 MGD. In addition, a third wastewater treatment

plant, located on the far western edge of the City in Kendall County, is currently under

construction, which has the capacity to treat 3.2 MGD.

The Eastside and Westside treatment facilities consist of the secondaiy treatment activated

sludge process with primary settling upstream of the aeration tanks. The clarified effluent is

sent directly to the receiving streams. The waste biosolids from the activated sludge process,

as well as the primary sludge, is sent to the anaerobic digesters for stabilization. After sludge

stabilization, the stabilized sludge is stored in holding tanks to be land applied on local

farmers’ fields.

As part of the City’s continued population growth, the City is currently in the process of

providing upgraded and expanded water treatment facilities. Regulations require the City to

remove radium from the water supply. Due to the type of radium removal equipment,

concentrated discharges of filter backwash from the co-precipitation of radium with hydrous

manganese oxides will be discharged to the sewer system, causing radium to accumulate in

the biosolids. The radium accumulation in the biosolids will be similar to the radium

accumulation occurring at the present time. The waste sludge to be land applied may exceed

the allowed amounts radium and may require that the waste sludge is disposed of in a landfill

rather than continuing with the current practice of land application.

The purpose of this report is to review the costs, as well as advantages and disadvantages, of

changing from the practice of land application of biosolids to disposal of the biosolids in a

landfill.

Clark Diet:. Inc.

2

August 2004

---

Evaluation ofRadium RemovalImpacts to Sludge Handling at the Eastside and

Westside Wastewater Treatment Facilities

.Joliet, Illinois

2 EXISTING SLUDGE HANDLING AND DISPOSAL METHODS

-

2.1

Westside Wastewater Treatment Plant

The Westside Wastewater Treatment Plant was designed for an average daily flow of 14

MGD and a peak flow of 28 MGD. The plant consists of an influent pump station \vhich

pumps the flow to an influent channel where it flows by gravity through a Parshall flume to

I

the grit removal tanks. The wastewater then flows to the primary clarifiers for primary

-

treatment and then on to the aeration tanks for removal of CBOD and ammonia from the

I

wastewater. After secondary clarification, the treated wastewater is discharged to the Des

-

Plaines River.

The primary sludge from the primary clarifiers, and the waste sludge from the secondaiy

clarifiers, are both sent to anaerobic digesters for sludge digestion. The digested sludge is

then transferred to sludge storage tanks where it is held in storage until it can be land applied

to local farm fields. There are no thickening process units prior to the sludge storage tanks. It

is estimated that the sludge storage tank decant system will allow the operator to thicken the

1

sludge to the 6 to 8 percent range while in storage.

I

Based on the records from the City of Joliet Land Application Program for 2003, the amount

of biosolids produced by the Westside WWTP and land applied was 895.3 diy tons. This

I

amounted to a liquid volume of sludge of 8.69 million gallons.

2.2

Eastside Wastewater Treatment Plant

1

The Eastside Wastewater Treatment Plant was designed for an average daily flow of 18.2

MGD and a peak flow of 45 MGD. The plant consists of an influent pump station which

pumps the flow to an influent channel where it flows by gravity to the grit removal tanks.

The wastewater then flows to the primaly clarifiers for primary treatment and then on to the

aeration tanks for removal of CBOD and ammonia from the. wastewater. After secondaty

clarification, the treated wastewater is discharged to the Des Plaines River.

I

The primary sludge from the

primaly

clariflers, and the waste sludge from the secondary

clarifiers, are both sent to anaerobic digesters for sludge digestion. The digested sludge is

then transferred to sludge storage tanks where it is held in storage until it can be land applied

to local farm fields. A gravity belt thickener thickens the waste activated sludge and-the

digested sludge.

Based on the records from the City of Joliet Land Application Program for 2003, the amount

of biosolids produced by the Westside WWTP and land applied was 2217.3 dry tons. This

amounted to a liquid volume of sludge of 17.03 million gallons.

Clark

Diet:.

Inc.

3

August 2004

---

Evaluation ofRadium Removal Impacts to Sludge Handling at the Easiside and

Westside Wastewater Treatine;it Facilities

Joliet, Illinois

I

2.3

Land Application of Sludge

-

Both the Eastside and Westside wastewater treatments use land application as the ultimate

disposal option for the wastewater sludge generated by the treatment process. The sludge is

stored onsite in large sludge storage tanks and is taken to local farm fields by contract sludge

haulers.

The City currently uses about 23 different land application sites with a total area of

approximately 1287 acres. All of these sites are located in Will County, Illinois. The

I

biosolids are applied during approximately six months out of the year. A total of 25.7 million

-

gallons of biosolids were applied in 2003.

The local farmers agree to take the biosolids in order to provide the nitrogen required for the

crops. There is a substantial difference between the biosolids generated by the Eastside plant

and the biosolids generated by the Westside plant. The Eastside biosolids are lower in

nitrogen and therefore require more volume per acre (approximately 32,300 gal/acre). The

Westside biosolids are able to meet the crop nitrogen requirements with approximately

21,400 gals/acre. The plant personnel attempt to obtain 6 to 8 solids in the sludge storage

tanks in order to reduce transportation costs and allow for more nutrient value per gallon of

biosolids.

The site application life for the farm fields is based on total phosphorus applied and is

generally limited to five years. The application of sludge to a field may not occur over five

consecutive years, but may be applied over 10 or more years. Application to a specific field

I

during a year depends on the crops planted, harvest time, rainfall, and other factors. The

-

sludge is applied to the farm field using chisel plows that inject the sludge 6~’to 8” under the

I

surface.

-

The sludge from both plants consistently meets Class B requirements for sludge disposal by

land application. The anaerobic digestion process provides enough detention time and a high

enough temperature to control pathogenic microorganisms. The majority of the biosolids are

injected below the soil surface to allow nutrients to be readily available to the crop roots.

2.4

Current Costs for Land Application

The City bids out for the hauling services to haul the biosolids to the farm fields for land

application. The cost for hauling and disposal at the farm fields has historically ranged from

I

2 to 2.4 cents per gallon according to City records. This results in an approximate annual cost

-

of S617,000 based on the 2003 volumes of sludge removed from the wastewater treatment

I

plants. The City does not charge the landowners for the biosolids.

-

Clark Diet:, Inc.

4

August 2004

---

Evaluation ofRadium RemovalImpacts to Sludge Handling at the Eastsideand

Westside Wastewater Treatment Facilities

3.1

Radium Removal Requirements

The Safe Drinking Water act requires the removal of radium from drinking water supplies

down to the level of 5 picocuries per liter. The City of Joliet’s water supply contains

naturally occurring radium at a level above the required 5 picocuries per liter limit. The City

is in the process of evaluating water treatment technology to be installed at the new water

treatment facilities for the removal of radium from the water supply.

3.2

Proposed Water Treatment Technology

The radium removal technology being considered at present is hydrous manganese oxide

technology. The backwash from the regeneration cycle will contain concentrated forms of

radium which can be discharged to the City~swastewater collection system, and eventually,

to the treatment facilities downstream. While the concentration of radium in the backwash

stream will be higher than the naturally occurring radium levels, the mass loading of radium

to the wastewater treatment plants is not expected to change due to the mechanisms by which

radium is absorbed.

3.3

Current Radium Levels in Existing Sludge

The proposed water treatment technology is not expected to increase the amount of radium in

the sludge. Tests on the sludge and the faimers~fields have indicated radium levels that have

not exceeded background levels of radium.

Since the mass loading of radium is not expected to change, the quantity of radium in the

waste sludge from the plant is not expected to change from the current levels. Therefore, the

amount of radium currently being applied with the biosolids to farm fields will not be

increased due to the installation of new water treatment technology.

Clark Diet:, Inc.

5

August 2004

---

Evaluation ofRadium Removal Impacts to Sludge Handling at the Eastsia’e and

Westside Waste~t’aterTreatment Facilities

4.1

Design Objective and Approach

In evaluating the range of feasible alternatives for the ultimate disposal of sludge. if land

application is not available due to radium issues, the options that are available to the City are

limited. Since there is a limiting constituent in the sludge (radium), options such as

composting and eventual use as soil amendment will have the same limitations as land

application. Therefore, the only option available for ultimate disposal is disposing of the

sludge in a landfill.

In order to decrease the amount of solids to the landfill, additional processes such as

incineration can be considered. Due to the high capital cost, significant increase in operation

and maintenance costs, and the air pollution control considerations, the option of incineration

will not be considered at this time. Instead, landfill disposal preceded by dewatering of the

sludge will be evaluated.

Landfill disposal will require additional dewatering of the sludge in order produce a cake like

product without any free water. Belt filter press dewatering facilities will be required to

accomplish the required dewatering.

Belt filter presses can typically achieve between 18 to 25 percent cake solids. In order to be

conservative in the amount of sludge dewatered and disposed of in the landfill, the cake

solids will be assumed to be 16 in the dewatered sludge. This will produce a somewhat

higher volume of dried sludge for landfill disposal. The estimated sludge production from the

wastewater treatment plants, based on design capacity flow rates, is as follows:

Eastside Plant

Daily Production at 6 Solids (wet)

40,000 gpd

Annual Production at 6 solids (wet)

14,600,000 gal

Annual Production at 16 solids (wet)

5,475,000 gal

Annual Solids Production

47,487,960 lbs

Westside Plant

Daily Production at 6 Solids (wet)

34,000 gpd

Annual Production at 6 solids (wet)

12,410,000 gal

Annual Production at 16 solids (wet)

4,653,750 gal

Annual Solids Production

40,364,766 lbs

Clark Diet:, Inc.

6

.4ugust 2004

---

Evaluation of Radium RemovalImpacts to Sludge Handling at the Eastside and

Westside Wastevt’ater Treatment Facilities

Joliet, Illinois

Therefore, the total solids requiring landfill disposal is approximately 43,927 tons. This

amount of material will require hauling from the plant and disposal at the landfill.

4.2

Capital Costs for New Sludge Dewatering Facilities

New sludge dewatering facilities will consist of the following components at each of the

wastewater treatment plants:

New

building:

A new building will be required to house the dewatering equipment.

Dewatering equipment:

The dewatering equipment will consist of belt filter presses, sludge

feed pumps, sludge conditioning equipment, polymer mixing and feeding facilities, conveyor

belts, sludge hoppers and truck loading areas.

Dried sludge storage:

In order to account for scheduling of trucks to haul sludge to the

landfill, some type of dried sludge storage facilities will be needed. This will most likely

consist of a large pole barn type building.

Odor control facilities:

The sludge dewatering building and the sludge storage building will

be the source of significant odors. Therefore, extensive odor control facilities will be

required to remove the required air changes per hour and treat the air for odors from these

two buildings.

Site piping:

Significant piping modifications will be required in order to route digested

sludge from the digesters to a new dewatering building.

Electrical:

The new dewatering facilities and odor control equipment will require that new

electrical be routed from the existing MCC~sto the new buildings.

The capital costs for new sludge dewatering and odor control facilities are estimated as

follows:

Eastside Plant

New Building

$750,000

Dewatering Equipment

$500,000

Odor Control

$750,000

Dried Sludge Storage

$450,000

Electrical

$200,000

Site Piping

$250,000

Site Restoration

$50,000

Miscellaneous

$50,000

Construction Cost Sub-Total

$3,000,000

Clark Diet:, Inc.

7

August 2004

---

Evaluation ofRadium Removal Impacts to Sludge Handling at the East.ci~leand

Wesiside Wastewater Treatment Facilities

Joliet, Illinois

Contingency

$600,000

-

Non-Construction Cost

$450,000

Project Total

$4,050,000

Westside Plant

New Building

$750,000

I

Dewatering Equipment

$500,000

-

Odor Control

$550,000

Dried Sludge Storage

$350,000

-

Electrical

$200,000

I

Site Piping

$250,000

-

Site Restoration

$50,000

Miscellaneous

$50,000

Construction Cost Sub-Total

$2,700,000

Contingency

$540,000

Non-Construction Cost

$405,000

Project Total

$3,645,000

I

4.3

Annual 0 & M Costs for

New

Sludge De~vateringFacilities

-

In addition to the capital costs discussed above, there will be ongoing annual costs to operate

and maintain the facilities, as well as the hauling and disposal costs for the dried sludge. The

annual 0 & M costs, for both the Eastside and Westside plants, are estimated as follows:

I

Operation of presses (Power, staff, polymer)

$400,000

Odor control facilities

$350,000

Hauling costs at $7.00 per ton (44,000 tons)

$308,000

I

Disposal costs at $30.00 per ton

$1,320,000

-

Total

$2,378,000

Therefore, the estimated annual cost for operating new sludge dewatering facilities and for

hauling and disposing the dried sludge at a landfill is approximately $2,400,000 per year.

This is a significant increase in operating costs for the City of Joliet. This annual amount has

a present worth value over 20 years at the current rate of inflation is approximately $37

million dollars.

Clark Diet:, Inc.

8

August 2004

I

---

Evaluation ofRadium Removal Impacts to Sludge Handling at the Eastsia’e and

Westside Wastewater Treatment Facilities

4.4

Other Costs

In addition to the capital and 0 & M costs listed above, there are a number of other costs due

to switching to landfill disposal, some of which are not as easily quantified. These costs

include the following:

Use of available landfill space:

The amount of sludge to be disposed of in a landfill is

approximately 44,000 tons per year. By using this available landfill space for sludge disposal

it reduces the capacity available for normal domestic waste disposal. Normal domestic solid

waste generation is estimated to be approximately 4.4 lbs per person per day. At this rate,

and considering each household to consist of 3.5 persons, disposal of waste sludge at a

landfill will use the equivalent capacity of over 15,000 households each year.

It is getting more and more difficult each year to site and permit landfills. Therefore, this

disposal alternative does have a significant impact on the available landfill capacity.

Nutrient value ofsludge:

The sludge which is currently land applied provides a substantial

nutrient benefit to the local fanners who participate in the program. The nutrient components

of the existing biosolids consist of nitrogen, phosphorus, potassium, copper, zinc and

manganese. The fertilizer value of the applied biosolids has been estimated at $30.28 per acre

in the first year of the program and at $44.65 per acre in the fourth year of the program. On

the average, the fertilizer value is $37.47 per acre. Based on a total acreage in the program of

1287 acres, the current benefit to the local farmers is a cumulative annual savings of

approximately $48,000.

If the City is required to switch to landfill disposal, the local farmers will have this added

cost due to the required purchase of fertilizer for their fields.

Abandonment ofexistingfacilities:

The existing sludge storage facilities would no longer

be required if the biosolids were disposed of in a landfill. These facilities consist of large

sludge storage tanks as well as mixing and transfer pumping systems. There are very few

equipment items from these systems that can be used in the new dewatering facilities.

Therefore, these facilities will be abandoned and the capital investment will be returning no

value as the facilities sit in a mothballed state.

The construction cost of the existing sludge storage infrastructure at the Eastside Wastewater

Treatment Plant was $2,964,330. The construction cost of the existing sludge storage

infrastructure at the Westside Wastewater Treatment Plant was $4,075,000. Therefore, the

total cost of existing infrastructure that would be abandoned by going to landfill disposal is

approximately $7,000,000.

Clark Diet:. Inc.

9

August 2004

---

Evaluation qfRadium Removal Impacts to Sludge Handling at the Eastside and

Westside Wastewater Treatment Facilities

Joliet. Illinois

5

RECOMMENDATION

Based on the costs required to switch to landfill disposal of the sludge, the landfill disposal

option of the sludge is not cost effective. The costs are summarized as follows:

20

20

S7.695.000

$0

$0

$0

$7,695,000

$0

-.

$2378.000

.

5617.000

$37,071,028 .

. .

-

$9,618,513

Total Life Cycle Cost

-

Present Value ~

.~

As can be seen from the above table, the present value life cycle cost is over $44 million

dollars, versus under $10 million dollars for the existing land application practice. This does

not account for the cost of abandoning facilities, the nutrient value ofthe sludge, or the

landfill space taken up by landfill sludge disposal.

Therefore, since landfill disposal of sludge is not required for environmental reasons, it is

recommended that the current practice of land application of the sludge on local farmers~

fields be continued as it is the most cost effective option for ultimate sludge disposal.

Proposed

Parameter

Landfill

Land Application

Planning Period. years

Inflation Rate.

Capital Cost

Installation Cost

Present Value Capital Cost

Operating Costs per Year

Present Value Operating Cost

2.5

2.5

Clark Diet:, Inc.

10

August 2004

---

m

-J

ci

—1-

0)

---

REPORT OF SURVEY

AT

WESTSIDE WASTE WATER

TREATMENT PLANT

IN

CITY OF JOLIET, ILLINOIS

PERFORMED FOR

DEPARTMENT OF PUBLIC WORKS

AND

UTILITIES

CITY OF JOLIET, ILLINOIS

BY

RSS/

6312 W. OAKTON STREET

MORTON GROVE, ILLINOIS

November 15, 2004

H:\Home\400001 Health Physics\Joliet\Joliet survey.pdf

---

INTRODUCTION

On October 15, 2004, RSSI performed a survey and a sludge sample was

collected at the Joliet Westside Waste Water Treatment Plant (WWTP)

to measure the dose rate at the surface of sludge tanks and for

analysis for the radium concentration in the sludge.

METHODOLOGY

Direct Reading

Radiation levels were measured at the surface of sludge storage tank

no. 4 to determine if areas of elevated radiation were present. The

measurements were made using a Ludlum Model 3 survey meter with a

44-9 pancake probe. The probe was moved slowly approximately 1

centimeter from the surface of the surface and the tank between 3 to

6 feet above the base.

Exposure rate measurements were made at the surface of columns in a

Water Remediation Technology, LLC (WRT) demonstration project. The

demonstration project removes radium from a water flow of

approximately one gallon per minute (gpm)

.

The removed radium is

retained in four columns through which the water flows in series.

The exposure rate measurements were made using a Ludlum Model 3

survey meter with an Eberline HP—270 probe. The probe was moved

slowly approximately 1 centimeter from the surface of the columns to

located the areas of highest exposure rate for each column. At 1

gpm much less radium is removed than would be removed by a

production unit.

The Ludlum Model 3 is a general-purpose portable survey instrument.

It is used with a Ludlum Model 44-9 pancake type Geiger-Mueller (GM)

detector or an Eberline HP-270 energy compensated GM detector. The

Model 44-9 is sensitive to charged particle radiation, such as alpha

and beta radiation, and has limited sensitivity to photons. The HP-

270 is energy compensate, having a flat exposure rate response

between 70 keV and 1.3 MeV. With its beta shield closed it is

insensitive to particulate radiation.

Dose rates were measured using a Health Physics instrument (HPI)

model 1010 survey meter. Dose rates were measured at the surface of

the tank in the same areas as the radiation levels were measured.

The HPI Model 1010 is a portable survey meter with a soft tissue

equivalent gas multiplication chamber. It measures deep dose and

---

deep dose rates from photons and penetrating particles in continuous

-

or pulsed radiation fields. The reading in mrad/hour is multiplied

by the quality factor to obtain the dose equivalent in mrem/hour.

The quality factor for beta and gamma radiation is one.

Bulk High Resolution Gamma Spectroscopy

A 535 grams sludge sample was collected by a city employee in 500 ml

Marinelli beaker and counted for 48 hours in a Nucleus PCA II

Analyzer. The Nucleus PCA II analyzer is a PC based 8k channel

multichannel analyzer (MCA)

.

It is used with an Ortec GEM-30l85

high purity germanium (HPGe) detector, an Ortec 456 high voltage

power supply, and a Canberra Model 2021 spectroscopy amplifier.

Data are reduced using Quantum Technology gamma spectroscopy

software. This system performs qualitative and quantitative

analysis of spectra from the HPGe detector, identifying

F

radionuclides and the quantities present in samples.

1

The sludge sample was analyzed for the presence of the naturally

Fl

occurring uranium, thorium and actinium series and for potassium-40

H

using GDR software. Radium 228 is in the thorium series and emits

I

no significant photons. Radium 226 is in the uranium .series and has

only one low abundance photon at 186 keV.

1

The concentrations of surrogates with more abundant high energy

photons usually represent the concentration of Ra—228 and Ra—226.

Actinium—228, in the thorium series, is frequently used as a

surrogate for Raclium—228. Lead—2l4, in the uranium series, is

frequently used as a surrogate for Radium—226. These surrogates are

in equilibrium with the radium isotopes after one month in-situ.

RESULTS

Instrument Surveys

I

Background radiation levels at the WWTP were between 50 and 60

counts per minute (cpm)

.

Radiation levels at the surface of the

tanks were approximately 40 cpm. The background dose rate was 8

I

j.irad/hr. The dose rate at the surface of the tank was 5 ~.irad/hr.

-

Exposure rates at the surfaces of the columns in the WRT

-

demonstration project are below.

---

Column

Number

Exposure

Rate (mR/hr)

1

2.0

2

1.3

3

0.6

4

0.1

Bulk High Resolution Gamma Spectroscopy

-

The 535 gram sludge sample dried to 17 grams. It was analyzed when

collected and reanalyzed after being held 30 days to permit ingrowth

of the radium daughters. High Resolution Gamma Spectroscopy results

follow.

Isotope Initial

(pCi/g)

Final

(pCi/g)

Ac—228 19.0

28.0

Pb—214 14.5

20.1

Total*

48.1

*

Ra-226 and Ra-228 by surrogates

The changes in the activity of both surrogates are due to

disequilibrium in the thorium and uranium series when the sample was

collected. The lower initial concentration of Ac-228 suggests that

the sample had a lower initial concentration of Ac—228 than of Ra—

228. The ingrowth of Pb-214 occurs when a disturbance of

equilibrium results from the release of radon—222

CONCLUS IONS

• Radiation levels and dose rates at the surface of tank no. 4 lower

than background are expected because the tank and its contents

shielded the instrumentation from background radiation.

Significant concentrations of radium would have raised the

radiation levels and dose rates.

• The exposure rates at the surface of the WRT demonstration columns

would be scaled up for radium removed from a two stage system at

higher flow rates.

• The presence of significant radium in at least three stages of the

WRT demonstration indicate that at least three stages, and

probably four stages, may be required in a production operation to

prevent breakthrough of radium.