R~11

‘

NOV 2’l 2O~4

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

POlI~t~~~STATEOFgLL~NOISControl Board

IN THE MATTER OF:

)

)

I

REVISIONS TO RADIUM WATER QUALITY

)

STANDARDS: PROPOSED NEW

35

ILL.ADM. )

R04-21

I

CODE 302.307 and AMENDMENTS TO

)

(Rulemaking

—

Water)

35

ILL.ADM. CODE 302.207 and

302.525

)

)

I

NOTICE OF FILING

I

TO:

SEE ATTACHED SERVICE LIST

I

PLEASE TAKE NOTICE that on November 24, 2004 the undersigned filed the

METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO’S

SUPPLEMENTAL COMMENTS TO PROPOSED ADDITIONS

AND

REVISIONS TO

RADIUM WATER QUALITY STANDARDS

with the Illinois Pollution Control Board. A

I

copy of the filing accompanies this notice.

I

METROPOLITAN WATER RECLAMATION

DISTRICT OF GREATER CHICAGO

I

~t4~

0~’

Michael G. Rosenberg, Its ~tto~~y

Michael G. Rosenberg by

I

Ronald M. Hill

Metropolitan Water Reclamation

District ofGreater Chicago

100 East Erie Street

Chicago, Illinois 60611

(312)751-6583

RMH:jp

THIS FILING IS SUBMITFED ON RECYCLED PAPER

---

STATEOFILLINOIS

)

I

)SS.

COTJNTY OF COOK

)

CERTIFICATE

OF

SERVICE

I

I, Judith A. Pappalardo, being duly sworn on oath, certify that I caused a copy of the

-

attached

Metropolitan Water Reclamation District of Greater Chicago’s Supplemental

Comments To Proposed Additions And Revisions To Radium Water

Quality Standards to

be served by First Class U. S. Mail to the below named persons at their addresses as shown on

the attached Service List, with proper postage prepaid, from 100 B. Erie Street, Chicago, Illinois,

at or near the hour of4:00 p.m., on November 24, 2004:

TO:

SEE

ATTACHED SERVICE LIST

-

SUBSCRIBED and SWORN to

before me on November 24, 2004.

OFFICIAl-SEAL

RMH:jp

THIS FILING IS SUBMITTED ON RECYCLED PAPER

---

Printing Service List....

Page 1 of 2

Party Name

Role

City

& State Phone/Fax

Metropolitan Water Reclamation District

100 East Erie Street

Chicago

312/751-6583

Interested Party

IL 60611

312/751-6598

Richard Lanyon, Director of Research and Development

IEPA

1021 North Grand Avenue

Springfield

East

IL 62794-

217/732-5544

Petitioner

217/732-9807

P.O. Box 19276

9276

Deborah J. Williams

Stefanie N. Diers, Assistant Counsel

Chicago

312/569/1000

Gardner Carton & Douglas

191 N. Wacker Drive

IL 60606-

Interested Party

Suite 3700

312/569-3000

1698

Roy M. Harsch

Sasha M. Engle

Sonnenschein Nath & Rosenthal

8000 Sears Tower

Chicago

312/876-8000

IL 60606-

312/876-7934

Interested Party

233 South Wacker Drive

6404

Jeffrey C. Fort

Letissa Carver Reid

Environment

and PolicyL Center

35 East Wacker Drive

Chicago

312/673-6500

Interested Party

Suite 1300

IL 60601

312/795-3730

Albert F. Ettinger

Office of the Attorney General

Environmental188

West Randolph,Bureau20th

ChicagoIL

60601

312/814-2347312/814-2550

Petitioner

Floor

Joel

3.

Sternstein, Assistant Attorney General

Matthew J. Dunn, Division Chief

Wilkie&McMahon

1 East Main Street

Champaign

IL 61820-

217/359-2115

Interested Party

#214

217/359-2754

3615

John McMahon

Illinois Pollution Control B~gf

100 W. Randolph St.

Chicago

3128143956

Interested Party

Suite 11-500

IL 60601

AmyDorothyAntoniolli,M.

Gunn,HearingClerk

Officerof

the Board

City of Joliet, Department of Public Works and Utilities

Joliet

921 E. Washington Street

815-724-4230

Interested Party

IL 60431

Dennis L. Duffield, Director of Public Works and Utilities

Pose_gate & Denes

111 N. Sixth Street

Springfield

217-522-6152

Interested Party

IL 62701

Claire A. Manning

Springfield

JIll ii~ep&tmentof ~

One Natural Resources Way

IL 62702-

217/782-1809

Interested Party

1271

217/524-9640

Stanley Yonkauski, Acting General Counsel

2250 E. Devon Ave. Suite 23

Des Plaines

Interested Party

IL 60018

847-544-5995

Lisa Frede

IQt~i_EnvironmentalSohjtlons

631 E. Butterfield Rd.

Lombard

6309693300

Interested Party

Suite 315

IL 60148

6309693303

William D. Seith

M~tLcp_Qi1~an_Water

Red amation District of Greater

http ://www.ipcb.state.il.us/coollexternallcasenotifyNew.asp?caseid=6285&notifytype=Service

11/23/2004

---

Printing Service List....

Page 2 of2

_____

Cicero

I

Chicag~

6001 W. Pershing Road

708-588-4071

Interested Party

IL 60804

Abdul Khalique, Radiation Chemist

I

Total number of participants: 19

http ://www.ipcb.state.il.us/coollexternal/casenotifyNew.asp?caseid=6285&notifytype=Service

11/23/2004

I

---

CLER~csOFF~E5~E~

NOV 2 42004

BEFORE THE ILLINOIS POLLUTION CONTROL BOA~ATEOF ILLINOIS

PollutIon Control Board

IN THE MATTER OF:

)

)

REVISIONS TO RADIUM WATER QUALITY

) R04-21

STANDARDS: PROPOSED NEW 35 ILL. ADM.

) (Rulemaking

-

Water)

CODE 302.307 and AMENDMENTS TO

)

35 ILL. ADM. CODE 302.207 and 302.525

)

)

METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO’S

RADIUM WATER QUALITY STANDARDS

The Metropolitan Water Reclamation District of Greater Chicago (“District”), submits

the following comments in support ofthe proposed addition of 35 Ill. Adm. Code Part 302.307,

and amendments to 35 Ill. Adm. Code 302.207 and 302.525.

My name is Abdul Khalique. I am a Radiation Chemist at the Metropolitan Water Rec-

lamation District ofGreater Chicago. I am submitting the following addition to my verbal testi-

mony ofOctober 22, 2004 at the public hearing on the above subject.

The existing General Use Water Quality Standard, and the Lake Michigan Basin Stan-

dard for radium-226 (radium-226 shall not exceed lpCi/L) is excessively stringent. We agree

with the Illinois Environmental Protection Agency’s (IEPA) proposal of regulating combined

radium-226 and radium-228 at Public and Food Processing water supply intakes at a concentra-

tion of

5

pCi/L.

The current U.S. EPA maximum contaminant level for radium-226 and radium-228 in

drinking water is

5

pCi/L, and for beta particles and photon radioactivity it is less than or equal

to 4 mrem per year (40 CFR Parts 9, 141 and 142, December 7, 2000). It is our understanding

from the regulations that a combined radium-226 and radium-228 concentration of

5

pCi/L in

drinking water will result in a dose equivalent of4 mrem per year for humans.

---

Available data indicate that dose rates below 1 rad per day for aquatic animals and ter-

restrial plants cause no measurable adverse effects to population of plants and animals (U. S.

Department ofEnergy, DOE-STD-1 153-2002, July 2002, Attachment 1).

To convert the absorbed dose (rad) to dose equivalent (rem) the following calculations

are being submitted:

The dose equivalent is equal to absorbed dose multiplied by the quality factor (Q) (Hand-

book of Health Physics and Radiological Health, Third Edition, 1998).

irem

=

lradxQ

Absorbed dose due to beta particles and gamma rays:

irad

=

lrem±Q

H

1 rad per day

=

(1 rem

-~-

Q) per day

=

1 rem per day (where Q

=

1 for beta particles and gamma rays)

=

1000 mrem per day

=

(1000 mrem per day) x (365 day per year)

=

365,000 mrem per year

Absorbed dose due to alpha particles:

-

1 rad per day

=

(1 rem

—

20) per day (where Q

=

20 for alpha particles)

=

(1000 mrem ± 20) per day

=

5omremperday

=

(50

mrem per day) x ( 365 day per year)

18,250 mrem per year

2

---

The above calculations show that the U.S. EPA maximum contaminant level for drinking

water for radioactivity (4 mrem per year) is 4,562 to 91,250 times more stringent than the safe

level for aquatic animals and terrestrial plants.

The National Council on Radiation Protection and Measurements (NCRP) report No. 109

entitled “Effects of Ionizing Radiation on Aquatic Organism”, Chapter 7 “Dose to Aquatic Or-

ganism and Man from Environmental Radioactivity” (Attachment 2) reads as follows:

Radiation protection standards have been expressly developed foiE the protection of hu-

man health; however, it has been generally accepted and adopted by those involved with radia-

tion standards that by “protecting humans we are protecting the environment.” Statements for

general acceptance of this philosophy are found in the BEIR (Biological Effects of Ionizing Ra-

diation) Report, (National Academy of Sciences, 1972), which states that: “Evidence to-date in-

dicates that probably no other living organisms are very much more radiosensitive than man so

that if man as an individual is protected, then other organisms as populations would be most un-

likely to suffer harm.”

A similar statement can be found in the recommendations of the International Commis-

sion on Radiological Protection (ICRP, 1991), as quoted in the NCRP report, “The commission

believes that the standard of environmental control needed to protect man to the degree currently

thought desirable will ensure that other species are not put as risk. Occasionally, individual

members of non-human species might be harmed, but not to the extent of endangering whole

species or creating imbalance between species.”

Based on the above calculations and statements, we believe that the proposed rule, will

not have any adverse effects on the aquatic environment and relieve publicly owned treatment

3

---

works (POTW) of an unnecessary burden of being subjected to possible effluent limitations on

radium-226 in General Use water.

We also believe that the technical criteria contained in the Memorandum of Agreement

between IEPA and Illinois Department of Nuclear Safety (IDNS) (now a division of Illinois

Emergency Management Agency) of December 1, 1984 (Attachment 3) for agriculture use of

sludge containing radium from water treatment plants is extremely conservative. The criteria for

the level ofradium in the sludge is such that after the sludge is mixed with soil (for agriculture

use) the incremental increase ofthe radium concentration in the soil does not exceed 0.1 picocu-

ne per gram (dry weight). However, the Nuclear Regulatory Commission (NRC) has established

a level of25 mrem per year to designate a decommissioned facility suitable for unrestricted use.

The Association of Metropolitan Sewerage Agencies believe that this level is more appropriate

as a screening level for biosolids operations.

The Interagency Steering Committee on Radiation Standards (ISCORS) believes that if

the annual dose from all radionuclides detected in sludge or ash samples is 10 mrem or less, no

further steps are warranted. When the estimated annual dose from all radionuclides exceeds 10

mrem, ISCORS recommends that the POTW operators consult with the State Radiation Protec-

tion Regulatory Agency. Using the ISCORS document screening calculations, it is estimated

that 10 pCi ofradium-226 per gram dry weight of sludge or ash will give a radiation dose from

the non-radon pathway of 10 mrem per year to POTW workers and to individuals outside the

POTW.

The IDNS has set a decontamination guideline of

5

pCi/g dry soil for radium-226 (32 IL

Adm. Code: Chapter II, Section 340. Appendix A, January 2001).

4

---

Based on the above reasons we believe that a guidance limit of 0.1 pCi/g dry weight of

radium-226 in sludge is overly stringent, and needs to be re-evaluated.

Respectfully submitted,

Metropolitan Water Reclamation District

of Greater Chicago

By:

Abdul Khalique, Radiation Chemist

November 24, 2004

Metropolitan Water Reclamation

District of Greater Chicago

Lue-Hing R&D Complex

6001 W. Pershing Road

Cicero, Illinois 60804-4112

708-588-4071

THIS FILING IS SUBMIUED ON RECYCLED PAPER

5

---

Attachment 1

NOT MEASUREMENT

SENSITIVE

DOE-STD-1 153-2002

July 2002

DOE STANDARD

EVALUATING RADIATION DOSES TO

AREA ENVR

DISTRIBUTION STATEMENT A. Approved

for

public release; distribution is unlimited.

I

I

---

DOE-STD-1 153-2002

Scope, Purpose and Organization

This technical standard provides methods, models,

and

guidance within a graded approach

that

the U.S. Department of Energy (DOE) and its contractors may use to evaluate doses of ionizing

radiation to populations of aquatic animals, terrestrial plants, and terrestrial animals from DOE

activities for the purpose of demonstrating protection relative to Dose Rate Guidelines. It

provides dose evaluation methods that can be used to meet the requirements of DOE Order

5400.5, “Radiation Protection of the Public and the EnvironmenV’ (1990a) and DOE Order

5400 1, “General Environmental Protection Program” (1 990b) The technical standard assumes

a thre’shold of protection for plants and animals at the following doses for aquatic animals, 1

~a’d/d(10 mGy/d), for terrestrial plants, 1 rad/d (10 mGy/d), and for terrestrial animals, 0 1 rad/d

(1 mGy/d) Available data indicate that dose rates below these limits cause no measurable

ad~i’èrseêffècts to populations of plants and animals.

-

The DOE graded approach includes a screening method and three more detailed levels of

analysis for demonstrating cOmpliance with applicable dose limits for protection of biota. The

general screening method provides appropriately conservative limiting concentrations of

radionuclides in environmental media (termed “Biota Concentration Guides” or BCG5).

Radionuclide concentrations in samples of environmental media are easily compared with the

BCGs to evaluate compliance with biota dose limits. The three more detailed analysis methods

require more effort, but yield more accurate and realistic biota dose evaluations.

This technical standard is designed to be user-friendly, and is organized into three principal

Modules for ease of implementation. Material in each Module is cross-referenced to pertinent

sections in other Modules. There is some duplication of material across Modules by design, in

order to allow each to be used separately, if desired. Module

1

serves as the principal users

guide for step-by-step implementation of the graded approach to biota dose evaluation. Module

2 serves as a resource guide, providing detailed guidance for implementing key elements of the

graded approach identified in Module 1, and providing a “primer” on technical issues to be

considered when evaluating radiation as a stressor to the environment. Module 3 serves as a

technical reference source, providing the technical basis for the derivation of dose models,

screening values, and selection of default assumptions and parameters applied in the graded

approach. The organization and content of the technical standard are provided in FigUre 1.

xxi

-

---

__

OF IONIZING

:A’TION

ON

AQUATIC

.~I.SMS

‘-ia/CO

n Radiation

I

Protection and Measurements

—

—

-—

—

~TS

---

I,—

2 (ContiflU&l)

NCRP REPORT No.

109

EFFECTS OF

IONiZING

RADIATION 0 AQUATIC

ORGANSMS

• .

Recommendations of the

, ..

•• -

:NATIONAL COUNCiL~ON~~RADIATION

PROTECTION AND~MEASUREMENTS

Is$ued

August~3Q,~199L

M1~

~

t

~

~‘--~••~-•.

~~-t~~-

~

National Council bn Radiation Protection and Measurements

791

0’.WOODMONT~AVENUE.-/ ~

~

-~-~- ~

—

—

---

12

Attachment .2 (Continued).

7.

Dose to,’M:uatic,

Qrgaui,snis

and ‘Man

from Environmental

Radioactivity

Radiatio~rotectionstand’ardshav~beenèxpresslyde’kreloped for

the protectftri

of

human: health; howevér, it’h~been ge~iera1iy

aàcepte&and~:adoptedby those involved with radiatiOn standards

that

by”~protectingh’umansweareprotecting the environment!’

State-

ments forgeneral acceptance ofthis philosophy are foün iii the 1972

BEIR~(Biological Effects of‘Ionizing Radiation) Report ‘(National

Academy of Sciences, 1972) which states that:

“Evidence to-date indicates thatprobably no other living organ-

• .isms.~arevery i~juch~morerddiosensiti~ethan man s,b~-that,if

i~anas an individual. .i~protected, then. other organisms as

• pqpulations would be. most. unlihdy to suffer harm.”

A similar statement can be found in the recommendations~ofthe

International Commission on Radiological Protection; (ICRP, 1977):

“Although the principal objective of radiatioii protectiop. is the

-

achIeve1nent.and.rna~ntenançe~.Qfczppropriatelysafe conditions

for activities involving,.,hum-an ~exposure,.the level of safety

requiredfor theprotection ofhzpiiamindividuals isthought likely

to be adequate .taprotect other species,. a~thpugii.not.necessarily

-

individual members of those’species. The commission, therefore

believes that

if

man is~~4eq,uately protected then other living

things are also likely-to be sufflcien~lyprotected!’

Although this: viewpoint has been generally accepted, it haa not

‘previously

.2More recently

‘been

the

sèrio~is1y

ICRP has. modified

challengèd’no~

.its staternent.on

forma1ly~

the,subject.’as

defended.

follows:

2

“The Commission believes that the standard of environmental

control

needed,to

protect man to the degree currently thought desirable will ensure that otherspecies

are not put at riéh. Occasionally, individual members of non-human species might

be harmed, but

not

to the

extent

ofendangering whole species or creating imbalance

between species (ICRP, 1991),”

7.-DOSE TO

AQUAnO

01

~Jt’~iswell documented that.~radionudlidesin ~th

be-Lexpected±o:~producesimilar or.even.substanth

cert~in~o~anisms-than-topeople inhabiting and d

from’

.the~same.’environment.Therefore, the risk

(discounting variationstin~radiösensitivity,hf

appear as

high.Or

higher- fornatural biota than for:

there

is-

a basic thfferen~ce‘in how ‘we perceive

compared to other species.-For;thwnans, a .~reat

an individual member; and the~1oss~ofone ‘~or’

from radiation

exposure

is viewed: as a catastroj

contrary, most other’ species are’~”ewed~more~s

as identifiable individuals, and ‘the loss-of a few

the case of many aquatic organisms, thousands

be accepted without producing a noticeable or

the population (Section 3). This philosophy is e~i

not clearly, in the previous statements fromthe B

1972) and ICRP-26 (ICRP, 1977) and perhaps ex:

acceptance ofth~.st~tern~ntthatif

“humans ~r.~pr

tion then the environment is protected.”

, . -.

In Sections 2, ~and 4-we.~haye,reviewe~I~

on aquatic organisms,from

the

cellular 1e~e1.±oi~

and in Section 5 we’hav~‘made recommendation

protect the environment. Therefore,, by calculati

aquatic biota in a contaminated environment fro

receive a

limiting doseof.1 mSv

a’, the potential ~

on aquatic organisms and populatiohs canbe ass

radiation standards est~b1ishedfor, the protection

A number.ofapproaches have beentaken in cale

toaqiiatic.organisms in the environment.’ These’a:

cussed’ in Section 6 of this report. For the pre~

BIORAD computer code ~Trubey’and Kaye,’ 197.

calculate the internal’ añd~externaldose rate

ti

assumptions of,the.models’usediuBIORAD, only

of the individual ‘ra~dionuàIidesin water is ‘requi

dose rate to the biota.

It is assumed that the concentrations of radic

sediment and biota

are

at eQuilibrium and that tI

radioactivityin the water is ‘constant. The effecti’

to

humans

from. this environment is assumed I

limiting value

of~1inSv~a~,,The

question

i~w1’let

tion of radioactivity in the tissue of the .fi~h:an~

environment’is s~ifficientto produce a radiation~d

result in a detrimental effect ‘on the fish populat

---

Attachment 3

MEMORANDUM OF AGREEMENT

-

This Memorandum of Agreement Is entered into by

and

between

•

the

Illinois Environmental Protection Agency (IEPA) 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

containing 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 Protection Act,

Ill. Rev. Stat., 1983, ch. 111 1/2, pars. 1001 et. seq., and

Regulations adopted thereunder, and

WHEREAS, IONS has authority to require, registration of

• certain ‘installations 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

and 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 11,2, pars. 211 et seq..

THEREFORE,

it

is agreed- by and between IEPA

and IDNS as

follows:

-

1) Pupsuant to Ill. Rev. Stat., 1983, ch. 111

1/2, par.

-

194 et seq.

which

provides that every operator of a’

-

radiation installation must register with IONS, the

following individuals or entities must .register

directly with IONS and must comply

with

the

requirements

of that statute

an~ 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

Attachment 3 (Continued)

a)

Any

other person

or entity

that IONS

determines

is

required to register

under the provisions

of Ill.

Rev.

Stat.,

1983, ch. 111 1/2, pars. 194

et •s~q~

2) Sludge resulting from

the treatment ‘of water and

sewage and ‘containing radh.m occurring naturally from

ground water will be

exempt from the licensure arid fee

requirements

of

the Radiation Protection Act (Ill.

Rev.

Stat., 1983, ch-. 111 1/2, pars. 211 et seq.) based

on

• IDNS’ finding that such exemptid’n wifl not constitute

a

significant

risk to the health and safety of the

public.

‘

•

3) Sludge

resulting from the treatment of

water: and

sewage and containing naturally occurring’ radium from

ground

water

may be dispos~d 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

IEPA 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 Agreement.

‘

-

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 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.

---

Attachment

3

(Continued)

S)

If the

level of radIum ~n the s,ludoe is greater than 5

‘

picocurles

per gram (dry weight)

but less

than

50

plcocurles

per

gram

(dry

weight):

0

a)

the

sludge

may be

disposed

of In an

IEPA

‘permitted landfill

provided that there is

‘ at

leas,t 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.

b) the sludge 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):

a) 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

as surance that the exhal ation 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

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) th’at 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 into

the

sludge in

the

future.

7)

Alternative

methods of

sludge disposal may be utilized

In

emergency situations

or where it i’s technologically

‘or economically impracticable to dispose of sludge In

accordance with Paragraphs 4 through 6. Such

alternative methods may’

be used only if a

determination

Is made in advance by IONS (pursuant to

---

4

Attachment 3 (Continued)

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

fntrusi.on

into

the sludge

~n

the future.

8) a) In those cases where

a prior

determination is

needed from IDNS, IEPA will provide IDNS with a

copy of the pertinent permit application.

rn~s

will provide comments

to

IEPA ,regarding

these

permit applications, including its written

determination as to whether there Is reasonable

0

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 into 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

sludge 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 approvedby 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 IONS.

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:

~

(1~,

recur

-

Illinois Envi

Protection Agen

Dated:_______________

______________________________

D~rector

kO4~4L~1

Illinois Department of Nuclear Safety