RECE~V~D
CLERK’S OFFICE
BEFORE THE
ILLiNOIS
POLLUTION CONTROL
BOARD
DEC 082004
STATE OF ILLINOIS
IN THE MATTER OF:
Pollution
Control
Board
)
REVISIONS TO RADIUM QUALITY
)
R 04-21
STANDARDS: PROPOSED NEW 35 ILL. ADM
)
(Rulemaking—Water)
CODE 302.307 and AMENDMENTS TO
)
35
ILL. ADM. CODE 302.207 and
302.525
)
NOTICE
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 today filed with the Office of the Clerk of
the Pollution Control Board the POST-HEARING COMM
TS a copy of which is herewith
served upon you.
By.
J LIET
e of
i
‘s ttorneys
Dated: December 8, 2004
GARDNER, CARTON & DOUGLAS
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
Public Comment #29
RECEiVED
CLERK’S OFFICE
BEFORE THE
ILLINOIS POLLUTION
CONTROL BOARDEC
082004
iN THE MATTER OF:
))
U
0r’~IlUtiOfl
STATE OFControlILLIr~OISBoard
REVISIONS TO RADIUM QUALITY
)
R 04-21
STANDARDS: PROPOSED NEW
35
ILL. ADM
)
(Rulemaking—Water)
CODE 302.307 and AMENDMENTS TO
)
35 ILL. ADM. CODE 302.207 and 302.525
)
POST-HEARING COMMENTS OF CITY OF JOLIET
Mr. Dennis Duffield, the Director ofPublic Works and Utilities ofthe City ofJoliet,
participated in the rulemaking process because ofthe importance ofthis rulemaking. This
rulemaking will determine the costs to Joliet and other members ofthe regulated community to
comply with a water quality standard for combined radium 226 and radium 228. Joliet and other
municipalities are already facing the costs of drinking water treatment, and there may be
additional costs to be placed on the public for compliance with a radium water quality standard.
The Illinois Environmental Protection Agency’s proposal for a water quality standard has
resulted in a large volume of information to review.
The original intent ofthe rule proposed by the Illinois Environmental Protection Agency
was to maintain the current situation, which has existed since the first deep wells were placed
into service. Radium originating in well water is currently distributed to customers, collected in
the sanitary sewer system, treated at the wastewater treatment plant and discharged to the
receiving stream.. The quantity ofradium discharged to the stream was to be unaltered by
elimination ofthe present 1.0 picocurie per liter radium 226 water quality standard.
During the rulemaking process, issues unrelated to the water quality standard were
presented to the Illinois Pollution Control Board. Worker safety was presented as an issue
although it has no impact on water quality. The disposal of wastewater treatment sludge was
also presented as an element to be considered. Joliet, afterpointing out that these issues were
unrelated to water quality, presented information demonstrating that worker safety and sludge
disposal are not problems that could not be easily solved by wastewater treatment operators. See
Transcript 392-98 (Oct. 22, 2004), and attachments 1 through 4 ofSupplemental Information
filed by the City ofJoliet on November 24, 2004.
The United States Environmental Protection Agency is required to review the water
quality standards to be proposed by the Illinois Environmental Protection Agency and adopted
by the Illinois Pollution Control Board. The United States Environmental Protection Agency
approved the proposed standard and has not has not provided any basis or guidance for the
Illinois Environmental Protection Agency to use for purposes of development ofa numeric
radium water quality standard as an alternative to its proposal, consistent with the 1986 guidance
document which provides the methodology for deriving water quality standards from aquatic life
toxicity data orthe subsequent methodology to protect wildlife. Transcript 311-13, 382-85
(October 22, 2004). The Illinois Environmental Protection Agency properly advised the Illinois
Pollution Control Board that its research had not found studies ofthe quality normally used for
the development ofwater quality standards. Therefore, if the Board intends to develop a
numeric water quality standard for radium, the lack ofreliable research and guidance makes this
task very difficult and unnecessary as the expected radium levels would be below any
appropriate standard. Transcript 287-99 (October 22, 2004).
1.
UNITED STATES NUCLEAR REGULATORY COMMISSION LIMIT.
Standards exist that the Illinois Pollution Control Board may consider. While not
addressed at the hearing, the Illinois Division ofNuclear Safety of the Illinois Department of
Emergency Management has standards for the discharge to sanitary sewers. The standard for
2
combined radium 226 and radium 228 is 600 picocuries per liter. This is the limit determined by
the United States Nuclear Regulatory Commission and adopted by states for implementation.
The City ofJoliet requested Mr. Eli Port of RSSI, a health physicist engaged by the City, and he
addressed this issue in a letter to Dennis Duffield attached as Exhibit 1 to these comments. NRC
Regulations Title 10, Code ofFederal Regulations Part 20 Standards for Protection Against
Radiation Subpart K--Waste Disposal 20.2003 Disi~osalby Release into Sanitary Sewerage.
Appendix B to Part 20--Annual Limits on Intake (ALIs) and Derived Air Concentrations (DACs)
ofRadionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for
Release to Sewerage is the source ofthe limits. The state provisions are attached to this
comment as Exhibit 2. This source also provides the limits for discharge ofeffluent to streams at
a level of60 picocuries per liter. This value appears in Appendix B, but was not included in the
Illinois regulations.
2.
RESRAD
BIOTA.
Information provided to the Illinois Pollution Control Board
proposed the use ofthe Department of Energy “A GRADED APPROACH FOR EVALUATING
RADIATION DOSES TO AQUATIC AND TERRESTRIAL BIOTA”. This approach is not
appropriate for determining water quality by its own terms. Item 3 ofthe Foreword to this
document is shown below:
These methods (and the Biota Concentration Guides contained in them) are not intended
to be used as design criteria, indicators of the severity of accidental releases of
radioactive materials, or guides for mitigating the consequences of accidental releases.
Furthermore, this technical standard does not apply to the irradiation of biota for
experimental purposes, nor to research or experimental studies.
Water quality standards are design criteria for the stream. This document has been
proposed as the only available approach to protecting biota. Ifthis model is to be used, it is
necessary to examine how it should correctly be used. Mr. Eli Port ofRSSI, consulting health
3
physicist to the City ofJoliet, addressed this issue by letter to Dennis Duffield, which is attached
as Exhibit 1 to these comments.
Mr. Port points out that when proper inputs to the RESRAD program are used to meet the
requirements ofthe International Commission on Radiation Protection, the radium concentration
that is protective ofriparian animals is 64 picocuries per liter for Radium 226 and 67.6
picocuries per liter for Radium 228. This is considerably higher than the 3.75 picocuries per liter
limit previously provided to the Board.
The International Commission on Radiological Protection has proposed a standard of 1.0
rads per day for aquatic animals and 0.1 rads per day for terrestrial animals. This is the criteria
used in the tiered approach ofthe Department of Energy. Although the tiered approach is not
applicable to determination ofdischarge standards, it is based on the information of a recognized
standard setting organization for impact to the environment. The DOE tiered approachuses a
program named RESRAD BIOTA as the method ofrelating dose to concentration ofradiation
sources in the environment. There is very limited experience with the use ofthe program and it
appears to provide very conservative results.
Since the exposure ofan animal to radiation is a result oflong term exposure, the 7 day
10 year low flow normally used for the development ofwater quality standards is not
appropriate. The harmonic mean flow has been the stream flow of choice for carcinogenic
compounds. Radiation is carcinogenic. The harmonic mean flow better represents the average
flow experienced in the stream.
Joliet has previously provided testimony that upon start up after an idle period, wells
containing radium are routinely pumped directly to storm sewers or ditches for a short time
4
period. These storm sewers or ditches will have a harmonic mean flow of zero (0). Ifthe
duration annual discharge to these storm sewers or ditches is limited to 800 hours per year, this is
approximately 10 ofa year
3.
IMPACTS OF A NUMERIC WATER QUALITY
STANDARD. The water
quality standard ultimately adopted by the Board will have an impact the regulated community,
whether it’s the 60 picocuries per liter from the US ~uclear Regulatory Commission
Regulations, or the 3.75 picocuries per liter in the testimony from Water Remediation
Technologies. These examples provide a wide range ofoptions for the water quality standard.
None ofthese examples have an adequate scientific basis concerning biota to provide compelling
evidence for the selection of a specific alternative.
The water quality standard approved will impact wastewater treatment plants. Since the
highest reported radium concentration from a deep well in Illinois is less than 40 picocuries
combined radium 226 and radium 228, the selection of60 picocuries per liter combined radium
226 and radium 228 will allow the continuation ofexisting practices.
The selection of3.75 picocuries per liter combined radium 226 and radium 228 will
require modifications of the operations ofmany water supplies and wastewater treatment plants
to modify their operations. For wastewater treatment plant removing
50
ofthe radium in their
influent and discharging to a stream with a harmonic flow of0, the maximum influent radium
concentration to the wastewater plant is
7.5
picocuries per liter.
Most communities will not be able to continue operations in the current methods.
Compliance will depend upon the method ofdisposal of the water treatment waste, the influent
concentration to the wastewater treatment plant, the removal efficiency ofthe wastewater
treatment plant and the harmonic flow ofthe receiving stream. It may be necessary to decrease
5
the influent concentration to the wastewater treatment plant by disposing ofwater treatment
wastes separately from the sanitary sewer or increasing the radium removal efficiency ofthe
wastewater treatment plant. All ofthese options will increase the costs ofthe projects that
communities are required to implement to obtain compliance with the drinking water standard
4.
WET
PERFORMANCE
ISSUES.
The use ofa water treatment method that
does not discharge the radium removed from the drinking water to the sanitary sewer has been
recommended by a vendor ofthis type ofequipment. The vendor has indicated the use ofa
radium select media has advantages. The vendor admitted that the technology would not comply
with existing standards in zero low flow streams.
When questioned about the accumulation ofradon in this vendor’s treatment vessel,
representatives indicated that their experience had shown no radium accumulations. Transcript
157 (October 22, 2004). The vendor also testified that it has no experience with full scale units
and only data from short term pilot plants. Transcript 123, (October 21, 2004); Transcript 156
(October 22, 2004). Joliet hasjust completed a pilot test ofthe radium select media system
provided by Water Remediation Technologies, LLC ofArvada, CO. During the course ofa six
month pilot test, it was determined that radon from the treatment vessel may have been initially
discharged to the atmosphere and was not being found in the water being tested for radon. On
September 27, 2004, the test mechanism was regulated to assure that any radon developed from
decay of radium removed and retained in the media would be found in water samples. Radon
samples collected on November 29, 2004 indicate that there is a buildup ofradon in the system.
The influent radon to the treatment system was measured as 160
+1-
20 picocuries per liter. The
water leaving the treatment system was measured as 220
+1-
20 picocuries per liter. This
indicates an increase in the radon that will be delivered to customers ofthe water system if this
6
treatment method was employed. It is anticipated that there would continue to be an increase in
radon over time as the radium levels increase in the medium. This is consistent with the
information provided to Joliet by Layne Christensen, the supplier ofan alternate radium select
media treatment system. This is a critical issue, since radon is more dangerous to humans
because ofinhalation. In addition, technology would have to comply with radium and radon
standards. A radon standard of300 picocuries per liter has been proposed by U.S. EPA for
adoption as a primary drinking water standard, and if radon levels have already tested at
approximately 220, compliance with any standard adopted is questionable.
Conclusion.
The science to support a specific water quality standard is not available.
There is sufficient information to select a protective and workable standard. Joliet would
recommend that the results ofthe RESRAD BIOTA program be considered extremely
conservative and not selected as the water quality standard. Adequate protection ofthe
environment will result from the US Nuclear Regulatory Commission regulation of60 picocuries
per liter. To maintain the protection to the environment, Joliet recommends the following:
1. The water quality standard for combined radium 226 and radium 228 in streams used as
water supply or food processing intakes shall be
5.0
picocuries per liter.
2. The water quality standard for combined radium 226 and radium 228 for all other streams
shall be 60 picocuries per liter.
Should the Board choose to be more conservative in their determination of a standard, Joliet
would recommend a safety factor of2.0 be applied which results in the following:
1. The water quality standard for combined radium 226 and radium 228 in streams used as
water supply or food processing intakes shall be 5.0 picocuries per liter.\
2. The water quality standard for combined radium 226 and radium 228 for all other streams
shall be 30 picocuries per liter.
3. The water quality standard for combined radium 226 and radium 228 for discharges
limited to a duration of less than 800 hours per year shall 36 picocuries per liter.
7
Thank you for the opportunity to participate in this important rulemaking
RESPECTFULLY SUBMITTED
CITY OF JOLIET
By:_______
One fits Attorneys
“
Roy M. Harsch
Gardner Carton & Douglas LLP
191 North Wacker Drive
Suite 3700
Chicago, Illinois 60606
(312) 569-1441
8
R
s:’;’i
847-965-1999
Morton
63/2 West
Grove,
Qakion
-
IL 6O053-27~T5
Street
Fax 847-965- / 99/
December 8, 2004
Dennis Duffield, P.E., Director
1
Department of Public Works and Utilities
City of Joliet
921 Washington Street
Joliet, IL 60431
RE: Concentration Release Limits for Ra-226 and Ra—228
Dear Mr Duffield:
The following summarizes and explains the information that I
presented at the meeting with the Illinois Environmental
Protection Agency on November 30, 2004. At the meeting, I
discussed the role of two advisory bodies, the National Council
on Radiation Protection and Measurements and the International
Commission of Radiological Protection. This letter constitutes
my comments, which I request that you file with the Illinios
Pollution Control Board.
An understanding of several units is useful in following various
standards.
One curie is the quantity of material that undergoes 3.7x10’°
disintegrations per second or 2.22x1012 disintegrations per
minute.
The rad is the unit of absorbed dose. One rad is equal to an
absorbed dose of 100 ergs/gram.
The rem is the unit of any of the quantities expressed as dose
equivalent. The rem is an administrative unit used for
compliance purposes and as a measure of risk to human
populations. The dose equivalent in rems is equal to the
absorbed dose in rads multiplied by the Relative Biological
Effectiveness (RBE) quality factor (Q)
.
The rem is used only
for low doses, it is not used to predict injury or damage, and
it applies only to man.
EXHIBIT
I
/
Dennis Duffield
December 8, 2002
Page2
The International Commission on Radiological Protection (ICRP)
is an advisory body providing recommendations and guidance on
radiation protection. The ICRP is an independent international
network of specialists in various fields of radiological
protection. About one hundred scientists are actively involved
in its, work.
The ICRP considers the fundamental principles and quantitative
bases upon which appropriate radiation protection measures can
be established. It offers its recommendations to regulatory and
advisory agencies and provides advice intended to be of help to
management and professional staff. Legislation in most
countries adheres closely to ICRP recommendations.
Paragraph 14 of ICRP Publication 26 states that although the
principle objective of radiation protection is the achievement
and maintenance of appropriately safe conditions for activities
involving human exposure, the level of safety required for the
protection of all human individuals is thought likely to be
adequate to protect other species, although not necessarily
individual members of those species. The Commission therefore
believes that if man is adequately protected then other living
things are also likely to be sufficiently protected.
Paragraph 16 of ICRP Publication 60 states that 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 at 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. At the present time, the Commission concerns
itself with mankind’s environment only with regard to the
transfer of radionuclides through the environment, since this
directly affects the radiological protection of man.
The recommendations in ICRP publications 26 and 30 are the basis
for the derived standards in 32 IAC 340, IEMA’s Standards for
Protection Against Radiation. 32 IAC 340 incorporates by
reference the regulations of the U.S. Nuclear Regulatory
Commission in 10 CFR 20, the NRC’s Standards for Protection
Against Radiation. The limits on releases of radioactive
material to the environment and to sewage are in Appendix B to
Dennis Duffield
December 8, 2002
Page3
10 CFR 20. Table 2 Effluent Concentrations Col.2 of Appendix B,
lists the concentration limits in water released to unrestricted
areas to which the public has access and which may be ingested,
that will result in a dose of 50 mrem in a year. 50 mrem is
one-half the 100 mrem per year limit recommended by the ICRP,
NCRP and IEMA’s annual public doseTlimit. Table 3 lists the
concentrations converted to pCi/i that may be released to
sewage. These values are:
32 IAC LIMITS
Table 2
Col 2
(pCi/i)
Table 3
(pCi/l)
Ra—226
60
600
Ra—228
60
600
The US Department of Energy (DOE) has similar requirements for
operations of the DOE with respect to protection of members of
the public and the environment against undue risk from
radiation. These requirements in DOE Order 5400.5, adopt as
appropriate recommendations by authoritative organizations e.g.,
the NCRP and the ICRP. DOE 5400.5 contains derived
concentration guides for ingestible water that will result in
0.1 rem/year.
Doe 5400.5 states that based on cost and benefit considerations,
radioactive waste streams that contain radionuclide
concentrations of not more than the derived concentration guide
(DCG) reference values at the point of discharge to a surface
waterway normally will not require treatment to further reduce
the concentration. DOE requires that the best available
technology selection process be applied to the treatment of
liquid wastes released to sanitary sewerage when concentrations
of radionuclides would otherwise exceed five times the DCG
reference values. For Ra-226 and Ra-228, these values are
below.
Dennis Duffield
December 8, 2002
/?SSI
Page4
-
DOE 5400.5 LIMITS
Ingested Water
DCG
(pCi/l)
-~
Release to
Sanitary Sewerage
(pCi/l)
Ra—226
100
‘T’
500
Ra—228
100
. -
500
The National Council on Radiation Protection and Measurements
(NCRP) formulates and disseminates information, guidance and
recommendations on radiation protection and measurements
representing the consensus of scientific thinking. The NCRP was
chartered by the U.S. Congress in 1964 as the National Council
on Radiation Protection and Measurements. The Charter, Public
Law 88-376, recognizes the importance and the national character
of the NCRP.
The recommendations published by the Council provide the
scientific basis for radiation protection efforts throughout the
country. Governmental organizations, including the Nuclear
Regulatory Commission, the Public Health Service, the
Environmental Protection Agency and state governments utilize
the NCRP’s recommendations as the scientific basis of their
radiation protection activities.
Section 5 of NCRP Report 109 states that studies of contaminated
environments have shown that point discharges of radionuclides
generate a varying dose field in the recei~iingenvironment and
that the mean population exposure is less than the exposure at
the point of discharge either because the population of
sedentary organisms exist throughout the varying dose field, or
because mobile organisms experience a time-varying dose rate as
they migrate within the environment.
Thus, as the dose rate standard is applied to the organisms
subjected to the maximum dose rate in the contaminated
environment, then the average exposure of any population, or
sub-population of organisms will be less, and often much less
than the standard. For this reason it is suggested that a
maximum dose rate of 0.04 rad/h (0.96 rad/d) would provide
protection for endemic populations of aquatic organisms in
environments receiving discharges of radioactive effluent.
Dennis Duffield
-
December 8, 2002
Page5
-
There is an indication that a limit of 0.57 mrem/h equivalent to
5 rem/y has been adopted in the USSR to provide protection for
fish populations. However, in considering the environmentai
effects of the Chernobyl accident, -:studies have shown that
chronic exposures of 0.04 rad/h t5•aquatic biota, while causing
some fractional changes, maintains ecological stability at the
population and organism level.
Adoption of a reference level of 0.04 rad/h appears to represent
a reasonable compromise based on current information, i.e.,
considering botli the nature of the effects observed at this dOse
rate and the limited amount of information on effects of
radiation in natural populations, including interactions between
ionizing radiation and ecological conditions. Population
exposed to dose rates approaching 0.04 rad/h may also be at risk
from other factors such as overexploitation or environmental
stressors which might, in combination, result in an undesirable
impact.
In such circumstances, it would seem highly desirable to conduct
comprehensive ecological evaluation of the radiation exposure
regime along with the other factors in order to determine the
potential consequences. Thus, it is suggested that where the
results of radiological modeling and/or dosimeteric measurements
indicate that a radiation dose of 0.01 rad/h (0.24 rad/d) will
be exceeded, such an evaluation should be considered.
Section 7 of NCRP 109 states that a problem with calculating
alpha dose to aquatic biota is the differential response to
equal absorbed doses of different radiations. Qs have been
determined to account for the differences in RBE for a—,
~-,
and
y-radiation; however, these are currently defined only for the
purpose of human radiation protection. Factors equivalent to Q
for aquatic organisms are required in order to modify the
calculated absorbed dose and thus give a measure of the
biologically effective dose in aquatic organisms.
Because the soft tissue compositions of humans and other
organisms are generally similar in water content and basic cell
structure, similar values for RBE would be expected for the
different radiation types. However, because of the conservatism
Dennis Duffield
December 8, 2002
Page6
,
-
built into RESRAD Biot.a’s predecessor, BIORAD computer code,
quality factors were not considered.
RESRAD Biota was developed through the DOE’s Biota Dose
Assessment Committee (BDAC), an approved committee organized
through the DOE Technical Standard~ Program. The BDAC is
sponsored and chaired by the Office of Environmental Policy and
Guidance, Air, Water and Radiation Division. RESRAD-BIOTA is
for use in demonstrating compliance with DOE and
internationally-recommended dose limits for biota, and for
conducting ecological assessments of radiological impact. The
principal application of RESRAD Biota’s graded approach is to
demonstrate that routine DOE operations, such as the Hanford
Site, 586 square miles, and the Oak Ridge National Laboratory,
94 square miles, are in compliance with the biota dose limits
for protecting populations of plants and animals. It could also
be used for mixing zones but may not be suitable fOr determining
local discharge standards effecting a limited area.
RESRAD Biota appears to contain a significant conceptual error.
The results are reported as the concentration that will produce
a dose of 0.1 rads/d to a riparian animal. However, the doses’
in rads in calculations incorporate RBE’s, a practice
inconsistent with the system of units used in radiation
protection. To properly use the dose limits in RESRAD Biota so
that they are comparable with the dose limits in NCRP Report
109, the RBE’s must be set to unity. When used with dose limits
in units consistent with NCRP Report 109, RESRAD Biota
calculates the limiting concentrations to which a riparian
animal may be exposed 100 of its life as:
CONCENTRATION LIMITS CALCULATED BY RESRAD BIOTA
Concentration
in Water
(pCi/l)
Concentration
in Sediment
(pCi/i)
Ra—226
64
685
Ra—228
67.6
673
Several limits for releases of Ra-226 and Ra-228 in water to
unrestricted areas exist.
Dennis Duffield
December 8, 2002
/?SSI
Page 7
SUMMARY OF CURRENT LIMITS FOR RELEASE TO WATER
To the
Environment
IEMA
DOE
To Sewage
IEMA DOE*
Ra—226
60
100
600
500
Ra—228
60
100
600
500
*with the use of BAT
It would be prudent to consider the most restrictive limit, 60
pCi/i, the IEMA limit for releases to the environment. This
value is slightly lower than the values generated by RESRAD
Biota when the RBE’s are set to units consistent with the dose
limit recommendations of the NCRP.
Creating a new limit for any radionuclides may require that IEMA
reexamine the release limits for other radionuclides and would
require, a lengthy process of stakeholder involvement and, unless
the NRC first changed its regulations, could result in a finding
of incompatibility with 10 CFR 20.
As explained above, regulatory and scientific considerations
strongly argue for consistent limits among state agencies for
releases of radioactive material to the environment. Thank you
for forwarding this to the Illinois Pollution Control Board.
Sincerely,
Digitally signed by
Eli A.
Port
signature
9’ ~e ~
Z~
Locabon: Morton
Valid
Grove, Illinois
Eli A. Port, CHP, CIH, P.E.
H:\HOME\400001 Health Physics\Joliet\Summary ofPresentatiort.pdf
32 Ill. Adm. Code 340
Page 1 of 50
Ruj~J ~tatute~J
Important Notice. The texts ofrules and regulations provided on this system are unofficial and are for
the information ofreaders interested in the responsibilities ofthe Division ofNuclear Safety. Because
rules axe frequently amended, the texts ofthe rules provided on this system may at times not be current.
Also some formulas and tables may not be displayable. For matters affecting legal rights orrequiring
legal interpretation, readers should consult their lawyers. Official versions of department rules can be
obtained from the Secretary ofState.
ILLINOIS ADMINISTRATIVE
CODE
TITLE 32: ENERGY
CHAPTER II: Divisionof Nuclear Safety
SUBCHAPTER b: RADIATION PROTECTION
PART 340
STANDARDS FOR PROTECTION AGAINST RADIATION
SUBPART A: GENERAL PROVISIONS
Section
340.10 Purpose
340.20 Scope
340.25 Incorporations by Reference
340.30 Definitions
340.40 Implementation
SUBPART B: RADIATION PROTECTION PROGRAMS
Section
340.110 Radiation
Protection
Programs
SUBPART C: OCCUPATIONAL DOSE LIMITS
Section
340.210 Occupational Dose Limits for Adults
340.220 compliance with Requirements for Summation of
External and InternaL Doses
340.230 Determination of External Dose from Airborne Radioactive Material
340.240 Determination of Internal Exposure
340.250 Determination of Prior Occupational Dose
340.260 Planned Special Exposures
340.270 Occupational Dose Limits for Minors
340.280 Dose to an Embryo/Fetus
SUBPART D: RADIATION DOSE LIMITS FOR INDIVIDUAL MEMBERS OF
THE PUBLIC
Section
340.310 Dose Limits for Individual Members of the Public
340.320 compliance with Dose Limits for Individual Members
of
the Public
II~~I~~uI__II
https://www.state.il.us/idns/htmlllegallcodeslaws/340.htm
I
32 Iii. Adm. Code 340
Page 2 of 50
SUBPART E: TESTING
FOR
LEAKAGE
OR
CONTAMINATION
OF
SEALED
SOURCES
Section
340.410 Testing for Leakage or contamination of Sealed
Sources
SUBPART F: SURVEYS
AND
MONITORING
Section
340.510 General
340.520 conditions Requiring Individual Monitoring of External
and Internal Occupational Dose
-~
340.530 Location of Individual Monitoring Devices
SUBPART G: CONTROL OF EXPOSURE FROM EXTERNAL SOURCES IN
RESTRICTED AREAS
Section
340.610 control of Access to High Radiation Areas
340.620 control of Access to Very High Radiation Areas
340.630 control of Access to Very High Radiation Areas
—
Irradiators
SUBPART H: RESPIRATORY PROTECTION
AND
CONTROLS TO RESTRICT
INTERNAL EXPOSURE IN RESTRICTED AREAS
Section
340.710 Use of Process or Other Engineering Controls
340.720 Use of Other Controls
340.730 tise of Individual Respiratory Protection Equipment
SUBPART I: STORAGE
AND
CONTROL OF LICENSED OR
REGISTERED
SOURCES OF RADIATION
Section
340.810 Security and Control of Licensed or Registered Sources of Radiation
SUBPART J: PRECAUTIONARY PROCEDURES
Section
340.910 Caution Signs
340.920 Posting Requirements
340.930 Exceptions to Posting Requirements
340.940 Labeling Containers and Radiation Machines
340.950 Exemptions to Labeling Requirements
340.960 Procedures for Receiving and Opening Packag,~
SUBPART K: WASTE DISPOSAL
Section
340.1010
General Requirements
340.1020
Method for Obtaining Approval of Proposed Disposal Procedures
340.1030
Disposal by Release into Sanitary Sewerage
340.1040
Treatment or Disposal by Incineration
340.1050
Disposal of Specific Wastes
https
://www.state.il.us/idns/html!legallcodeslaws/340.htm
11/29/2004
32 111. Adm. Code 340
.
Page 33 of 50
Section 340.1030 Disposal by Release
into Sanitary
Sewerage
a) A licensee may discharge licensed material into sanitary sewerage if each of the
following conditions is satisfied:
1) The material is readily soluble, or is readily dispersible biological material,
in water;
2) The quantity oflicensed radioactive material that the licensee releases into
the sewer in I month divided by the average monthly volume of water released
into the sewer by the licensee does not exceed the concentration listed in Table
3 ofAppendix B to 10 CFR 20.1001 -.20.2401, effective January 1, 1994,
exclusive of subsequent amendments-or editions;
3) Ifmore than one radionuclide is released, the following conditions must also
-
be satisfied:
A) The licensee shall determine the fraction of the limit in Table 3 of
Appendix B to 10 CFR 20.1001
-
20.2401, effective January 1, 1994,
exclusive ofsubsequent amendments or editions, represented by
discharges into sanitary sewerage by dividing the actual monthly average
concentration ofeach radionuclide released by the licensee into the sewer
by the concentration ofthat radionuclide listed in Table 3 of Appendix B
to 10 CFR 20.1001
-
20.2401, effective January 1, 1994’, exclusive of
subsequent amendments or editions; and
B) The sum ofthe fractions for eachradionuclide required by subsection
(a)(3)(A) above does not exceed unity;
4) The total quantity of licensed radioactive material that the licensee releases
into sanitary sewerage in a year does not exceed
185
GBq
(5
Ci) ofhydrogen-3,
37 GBq (1 Ci) of carbon-14, and 37 GBq (1 Ci) of all other radioactive
materials combined; and
5)
In determining compliance with subsections (a)(1), (a)(2), (a)(3) and (a)(4)
above, the licensee shall not include the activity from radioactive material
excluded by subsection (b) below.
b) Excreta from individuals undergoing medical diagnosis or therapy with radioactive
material are not subject to the limitations contained in subsection (a) above.
Section
340.1040 Treatment or Disposal by Incineration
A licensee may treat or dispose of licensed material by incineration only in the amounts and
forms specified in Section 340.105,0 or as specifically approved by the Department pursuant
to Section 340.1020.
Section
340.1050 DisposaL ofSpecific Wastes
a) A licensee may dispose ofthe following licensed material as if it were not
https ://www.state.il.us/idns/html/legallcodeslaws/340.htm
11/29/2004
—
16.4
40—0
20-6
—
11•2
36—6
11-10
(or 0
woflln~ (or
0.33
lt,*l ..tthu) wertlog
IntO)
20.3
50•2
26—7
0010
3(1
0E•2
&•2
30-7
16-3
61-6
56°C
71-
30-10
3?-U
SCM
surf
(96°C)
—
—
—
16—7
60.0
20°C
70—10
30—12
So..t sort
(Z1•I)
-
-
-
20-7
60.0
76-1
30-10
90-13
—
Sort
surf
(20.3)
—
—
—
20—7
20.0
06-1
30—30
30-13
—
Bare
surf
(348)
—
—
-
66-S
20.4
16.4
60-6
—
—
Sons surf
Sane surf
(30.4)
(2t°4)
—
I(-S
36-4
26.0
10.0
96-10
20-12
—
S... surf
(46.0)
-
—
-
60-6
.
Table 1
Table 2
Table 3
-
0cc~çatIboaTValues
Off Ian
C,nc.norutleeo
blues., 6*
Intro
AUslc Sudlesoollda
Class
Ba.
Ccl.
0.1.2
1.1.3
Oral
-
1305511*.
Ini.al.tIo,
—
*t.l
-
ou
040
(4CI)
(,il)
(pCI/el)
1.0.1
CaLl
Air
Water
(pCI/cl)
(pCi/el)
Ooeithly
Anr~.
Cencentratlso
(pCI/el)
65
6s4o.r222
With
daugsthn
“SeMI
With
daaqSters
Insist
S. ill co*.ouq.45
0, all
csq.ou”ds
5, sf1 c~ow.45
57
Frar.cla—2&
U07
fr.ncla—222Sulfa-fl) 2
60
Sudla-224
0, all c~aun4s
60
P.adla-225
0, all c~ouods
68
Sudla-226
0. elI
co~ou.4.
6’
Sedia-2272
V. all coepep.di
0
Sedia—226
0. all casuals
69
Actlnla-224
0. all c~ound, ..c.pt
those glusu fur Wand V
0, Sal fIts sod cItrate.
7~safarI sod
hyoro.14.e
63
OctlolrZZb
0, usa
30—4
66-5
16-6
20-6
20-6
60-7
36-3
61-7
36-4
36-6
20.3
30.3
16-5
-
—
UI well
$..,e
surf
(26°)
(00.1)
—
50-31
36—3
—
S0°1
26-5
76-11
—
—
50•1
26-6
6611
—
50.1
36-1
10-10
-
-
UI
call
0050 surf
0
(36.1)
(30-1)
—
76-23
76—7
0, ~ 224k
—
6(1
30-IT
-90-03
—
1,
see
AC
—
60-1
30-30
96-1)
—
60
Actlnla—226
0. see 24o~
16°!
3(4
11-3
-
UI well
Sore
surf
(11.2)
(40.0)
-
50-U
004
—
50°C
20—3
76-3?
-
•
564
26-0
66U
—
26-1
404
26-13
—
lane sort
6...
curl
(40-1)
(81.4)
—
11-15
51—3
—
201
76-13
—
—
lana surf
-
(30-))
-
41-IS
-
—
40-3
26—U
6615
—
~.
~.,
0, see
67
Actlnlsa-227
a.
see
0, sue
7.
set
32 Ill. Adm. Code 340
Page 33 of 50
Section 340.1030 Disposal by Release into Sanitary Sewerage
a) A licensee may discharge licensed material into sanitary sewerage if each of the
following conditions is satisfied:
1) The material is readily soluble, or is readily dispersible biological
material,
in water;
2) The quantity of licensed radioactive material that the licensee releases into
the sewer in 1 month divided by the average monthly volume of water released
into the sewer by the licensee does not exceed the concentration listed in Table
3 of Appendix B to 10 CFR 20.1001 -20.2401, effective January 1, 1994,
exclusive of subsequent amendments-or editions;
3) If more than one radionuclide is released, the following conditions must also
be satisfied:
A) The licensee shall determine the fraction of the limit in Table 3 of
Appendix B to 10 CFR 20.1001
-
20.2401, effective January 1, 1994,
exclusive ofsubsequent amendments or editions, represented by
discharges into sanitary sewerage by dividing the actual monthly average
concentration ofeach radionuclide released by the licensee into the sewer
by the concentration of that radionuclide listed in Table 3 of Appendix B
to 10 CFR 20.100 1
-
20.2401, effective January 1, 1994, exclusive of
subsequent amendments or editions; and
B) The sum ofthe fractions for eachradionuclide required by subsection
(a)(3)(A) above does not exceed unity;
4) The
total quantity of licensed radioactive material that the licensee releases
into
sanitary
sewerage in a year does not exceed
185
GBq
(5
Ci) of hydrogen-3,
37 GBq (1 Ci) of carbon-14, and 37 GBq (1 Ci) of all other radioactive
materials combined; and
5)
In determining compliance with subsections (a)(1), (a)(2), (a)(3) and (a)(4)
above, the licensee shall not include the activity from radioactive material
excluded by subsection (b) below.
b) Excreta from individuals undergoing medical diagnosis or therapy with radioactive
material are not subject to the limitations contained in subsection (a) above.
Section 340.1040
Treatment or Disposal by Incineration
A licensee maytreat or dispose of licensed material by incineration only in the amounts and
forms specified in Section 340.1050 or as specifically approved by the Department pursuant
to Section 340.1020.
Section 340.1050 Disposal of Specific Wastes
a) A licensee may dispose of the following licensed material as if it were not
https://www.state.il.us/idns/html/legal/codeslaws/340.htm
11/29/2004
.
TubS. 1
Table 2
Table
3
Occotutlenal
Values
Off
beat
S.leuses 1*
.
Cosceotr.Lbens
Iroors
.
MacIc
Sudlooutlide
Class
Se.
Ccl.
1
0.1. 2
Ccl, 3
Oral
Isgostlan
Inisalutlan
oil
--
ALT
040
(pCI)
(pCI)
(pCI/al)
CoT. I
0.1. 2
Air
Water
(pCI/el) (pCI/el)
loathly
Aetrago
Cencuotratlat
(pCI/el)
56
6.1st-?!!
With
daughtin
enerod
—
164
40-6
164
-
With daughters
present
—
1I•2
30-6
11-10
—
(or 4 sortlag
(or 0.33
level seoths) esrtla4
level)
57
Fruscla—2d 0, elI casuals
20°)
I0°2
20-7
66-10
304
30-4
57
Fr.acla-2232
0, all
ca~oaado
66°?
&~2
30-7
16—3
50-6
66-S
60
Sudla-223
0,
sIb
co*.oursls
514
70-1
36-10
9?-U
-
-
Soot
surf
(9641
—
—
-
16-7
16-6
U
kadla-224
6, 51) ca~aunds
6000
2(4
70-10
26—U
—
—
Son, surf
620°i)
-
—
—
20-7
20-6
50
Sidle-US
6, all caeunds
0(00
76-1
36-10
36-1)
—
5sa4
surf
(26’l)
-
-
-
26-7
20-6
60
sudla-22t
0, all
ca000ds
204
56-1
36-30
961)
—
—
ear.
surf
(564)
—
—
—
66-5
50-7
6~
Osdlue—2272
0,
ill
coefsossas
20.4
16.4
66-5
—
—
—
Sons
surf
Sor,e surf
(20.4)
(:0.4)
—
30-5
31-6
36-3
• -
Sudla—225
0,
all casuals
264
164
56-10
20-12
—
—
lone
surf
(464)
-
—
-
SC—S
66-7
69
Attiola-224
a,
all
casuals setef.t
those glee. fur 8 and
7
2903
30°i
11-6
-
-
-
UI well Sane surf
(26°3)
(40°i)
—
11-Il
36—3
36-4
0, Ml lots and ultratau
—
5(°1
26-6
76-11
—
—
7,
ealdrs and IsysIrool
die
—
501
20-6
66—11
—
—
63
lctlola—223
5, set ~oc
50.1
30-1
10-10
-
-
—
ill wall Boo, surf
0,
5.5
226
224AC
(56•1)
-
(56—1)
60-1
—
36-12
-94-13
70—13
-
iS—i
75-6
-
7, set
AC
—
60-1
30-10
9613
—
-
59
Actbala—226
~,
~ 22d81
16°?
31.0
UI
—
—
—
UI wall
lane surf
8, see 224~
(102)
—
(404)
504
—
264
7612SI-U
-
264
20-5
—
7, sos
Ac
—
504
20-9
66-12
-
-
69
Actlnisa-227
0, ste 2~dc
261
40-4
26-i)
—
—
—
Sane
surf
Sun. surf
224
(41-1)
(60—4)
—
11—15
50-0
56-6
8, see
Ac
-
20)
76-1)
—
—
-
Sane
surf
224
—
(30-3)
—
40—15
—
-
7. set
AC
—
46-1
26-U
6011
—
CERTIFICATE OF SERVICE
It is hereby certified
that
true copies ofthe foregoing
POST-HEARING
COMMENTS,
were hand delivered to the following:
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
-
100 West
Randolph Street,
Suite 11-600
Chicago, Illinois 60601
and mailed via First-Class Mail on December 8, 2004 to the following:
SEE ATTACHED SERVICE LIST
THIS FILING IS SUBMITTED ON RECYCLED PAPER
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 of the 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 Reclamation District
100 East Erie Street
Chicago, Illinois 60611
Abdul Khalique
Metropolitan Water Reclamation District
Of Greater Chicago
6001 W. Pershing Road
Cicero, Illinois 60804
Dennis
L. Duffield
City ofJoliet
Department
ofPublic Works & Utilities
921 E. Washington Street
Joliet, Illinois 60431
Stanley Yonkauski
Illinois Department ofNatural Resources
Orie Natural R~sourcesWay
Springfield, IllInois 62702-1271’
Joel C. Sternstein
Office ofthe Attorney General
Environmental Bureau
188 West Randolph,
20th
Floor
Chicago, Illinois 60601
William Seith
Total Environmental Solutions
631 E. Butterfield Road, Suite 315
Lombard, Illinois 60148
John McMahon
Wilkie & McMahon
8 East Main S~’eet
Champaign,
Illinois
61820
Lisa Frede
CICI
2250 E. Devon Avenue, Suite 239
Des Plaines, Illinois 60018
Jeffrey C.
Fort
Letissa Carver Reid
Sonnenschein Nath & Rosenthal
8000 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6404
