BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
~
REVISIONS TO RADIUM WATER
)
R04-21
QUALITY STANDARDS: PROPOSED
)
(Rulemaking
-
Water)
NEW 35 ILL. ADM. CODE 302.307
)
AND AMENDMENTS TO 35 ILL. ADM.)
CODE 302.207 AND 302.525
)
NOTICE OF FILING
7~CEIVED
-
OFFICE
TO: See Attached Service List
AUG
152005
PLEASE TAKE NOTICE that on August 15, 2005, we ~
ofthe Pollution Control Board an original and ten copies ofthe attached
COz$rMPJ’N!,~0ard
SUBMITTED ON BEHALF OF THE CITY OF JOLIET,
a copy ofwhich is served upon you.
Respectfully submitted,
THE CITY OF JOLIET
By:___
One of Its Attorneys
Roy M. Harsch
GARDNER CARTON & DOUGLAS LLP
191 Wacker Drive— Suite 3700
Chicago, Illinois 60606
(312) 569-1000
THIS FILING PRINTED ON RECYCLED PAPER
COMMENTS SUBMITTED ON BEHALF OF
THE CITY OF JOLIET
Introduction
The Illinois Environmental Protection Agency proposed a revised water quality
standard for combined radium 226 and radium 228. Their proposal ofno numeric
standard except for a water quality standard of 5.0 pico-curies per liter combined radium
226 and radium 228 at water supply and food processing intakes provided the necessary
protections for the public and was consistent with the standards adopted by other states.
The Illinois Environmental Protection Agency proposal had been the subject of
two public hearings when Water Remediation Technologies, LLC decided to request an
additional opportunity to participate in the proceedings. Water Remediation
Technologies, LLC attempted to discredit the Illinois Environmental Protection Agency
proposal using each and every method possible. Water Remediation Technologies, LLC
would create additional opportunities for substantial profit if alternate radium water
treatment methods cannot comply with a regulation resulting from their participation in
the process.
The proposed rule subject to this first notice is apparently an attempt by the Board
to propose a rule that addressed the concerns expressed by Water Remediation
Technologies, LLC and yet at the same time provide relief to the publicly owned
treatment works discharging wastewater containing combined radium 226 and 228. The
proposed general limitation of3.75 pico-curies per liter is consistent with the information
presented by Water Remediation Technologies, LLC. and the 30 pico-curies per liter
limitation for the first mile downstream from a wastewater treatment plant receiving
influent including from a well system containing radium appears to provide relief to the
discharger if adequate dilution ofthe wastewater occurs in the first mile.
The United States Environmental Protection Agency in their June 10, 2005 letter
to the Hearing Officer makes it clear that the proposed rule will not be approved by the
USEPA. No justification has been presented for adopting a general limitation of 3.75
pico-curies per liter and providing an alternate standard of 30 pico-curies per liter
downstream from the wastewater treatment plants. The USEPA also points out that there
is no national criteria recommendationsfor the development of a radium water quality
standard to protect aquatic life or wildlife. By using USEPA methods, there is
insufficient data to support the derivation of either the 3.75 pico-curies or 30 pico-curies
per liter proposed in this rule.
As result of the USEPA letter, the Board will have to decide whether to adopt a
standard that will insure Water Remediation Technologies, LLC an increased market for
their services in Illinois or to adopt a standard consistent with the original lEPAproposal
which was to provide relief from the current 1.0 pico-curie per liter requirement.
Wastewater Plant Data Collection and Analysis
The City ofJoliet organized the efforts of water supplies and wastewater
treatment agencies to respond to the first notice proposal. The intent of organizing the
agencies was to obtain additional sampling results to present to the Board.
Joliet used the following procedure:
1. Listings ofthe water supplies that exceed the drinking water standard of 5.0 pico-
curies per liter were obtained.
2. The water supplies were matched with wastewater treatment plants.
3. Listings of the discharge point and average flow from the treatment plants were
obtained.
4. The seven day 10 year low flow from the receiving streams was obtained from
maps prepared by the Illinois State Water Survey.
5.
Wastewater Plants discharging to streams with a 0.0 c. f. s. seven day 10 year low
flow more than 1.0 miles downstream of their discharge location were identified.
This circumstance results in the wastewater plant being required to discharge
effluent complying with the 3.75 pico-curies per liter standard proposed.
6. The water supply combined radium 226 and radium 228 concentrations were used
as the influent value to the wastewater treatment plants.
7. The effluent concentrations were estimated based on 20, 50 and 80 removal
in the wastewater treatment plant.
Fourteen treatment plants were identified as having potential problems complying
with the proposed standards. Most of the problems were identified in the condition of
having low radium removal in the treatment plant (20) and inadequate dilution
downstream. Ten plants had potential problems based on 50 removal of radium in the
wastewater treatment plant.
Joliet contacted these wastewater plants and encouraged them to collect samples
and provide Joliet with the results. Joliet distributed the sampling results to the service
list. One additional treatment works provided information to Joliet on August 4, 2005.
Exhibit I includes the distributed results and the results received after distribution.
A review ofthe results for the five plants that provided influent and effluent data
indicates that removals vary widely. Twenty-three reports were provided of influent and
effluent samples collected at the same time. Fifteen of these reports were from the same
community. The data is summarized as follows:
Average influent concentration all data
9.09 pico-euries per liter
Average effluent concentration all data
4.84 pico-curies per liter
Average removal
45.6
2
Since fifteen reports were from the same community, that community’s samples
influenced the average. A separate analysis using the average influent and average
effluent for each ofthe five plants. The results are as follows:
Influent concentration
8.96 pico-curies per liter
Effluent concentration
4.69 pico-curies per liter
Removal
47.6
Other analysis also indicates that the anticipated removal of radium in a
wastewater treatment plant is 45-50.
Based on an influent of8.96 -9.09, 50 removal
results in effluent with a combined radium concentration of 4.44-4.54 pico-curies per
liter. For plants discharging to a stream with a seven day 10 year low flow of 0.0 c~is.,
this exceeds the proposed 3.75 standard. Using this influent range, plants must remove
approximately
57
ofthe radium to meet the proposed standard.
Anticipated Impact on Wastewater Treatment Plants
Using the 50 removal ofradium in a wastewater treatment plant, nine
wastewater treatment plants have been identified to have the potential to violate the
proposed standard. The concentration ofthe radium in the water supply, the 50
removal and the discharge to a stream with inadequate dilution in the first mile
downstream results in a concentration that exceeds 3.75 pico-curies per liter after one
mile. Many ofthese plants represent the entire stream flow during dry conditions. Plants
without significant dilution in the first mile must effectively meet the 3.75 pico-curies per
liter at their discharge point.
Additional wastewater treatment plants would violate the 3.75 pico-curies per liter
proposed standard if the Board does not proceed with the 30 pico-curies per liter alternate
standard because the USEPA’s objects. No specific estimate ofthe number ofplants
impacted has been developed.
The proposed standard is written requiring compliance with the water quality
standard under all flow conditions. Joliet is aware that the use of annual average flow
conditions may be proposed as an alternate. The use of the annual average would reduce
the number ofplants with potential violations from nine plants to a lesser number The
number ofplants is expected to range between two and six. This would result from the
use of annual average flows, estimated at 43,560 cubic feet per acre with a background
concentration ofcombined radium of 1.0 pico-curies per liter, to determine the average
radium concentration in lieu of the seven day 10 year low flow. Some ofthe smaller
plants may have adequate dilution to meet the 3.75 pico-curies at their discharge point
under the annual average approach.
3
Anticipated Impact on Non-wastewater Treatment Plant Discharges
There is one other issue that was included in the record ofthe proceeding, but was
not addressed in the proposed standard. There are other radium discharges in Illinois that
do not originate from wastewater treatment plants. Deep wells are used for irrigation of
golf courses and agriculture. Deep wells in communities using radium-bearing
groundwater pump theirwells to the storm sewers and other drainage ways during testing
and at start-up. Communities using Lake Michigan as their water source have retained
deep wells as an emergency supply. These wells are pumped to storm sewers and other
drainage ways when the wells are exercised to verify operations. Fire hydrants are
flushed on a regular basis and will discharge drinking water with a concentration less
than
5.0
pico-curies per liter, but greater than 3.75 pico-curies per liter.
Since this water does not pass through a wastewater treatment plant, it is not
eligible for the 30 pico-curies per liter standard, but must meet the 3.75 pico-curies per
liter at the point of discharge. This water has not received any treatment and radium is
discharged at the concentration that is pumped from the ground. Concentrations in wells
in Joliet that discharge to locations with no dilution at the discharge point are included in
Exhibit 1. Irrigation wells and standby wells in Lake Michigan communities have similar
concentrations.
The use of an annual average stream flow does not provide any relief to the deep
well situation. The Williamson Avenue Well in Joliet would require flow from other
sources equivalent to the runoffof approximately 900 acres and having a radium
concentration of 1.0 pico-curies per liter or less. The location of the storm sewer serving
this location does not provide any opportunity for dilution ofthis magnitude. Other wells
in Joliet require large volumes for dilution as well.
IEMA-IDNS Standards
The Illinois Emergency Management Agency, Division ofNuclear Safety
provided comments in this proceeding stating their position that the protection ofbiota
from radiation exposure was not the original intent ofgeneral use water quality standards.
Biota has been protected from other constituents by water quality standards, but not from
radiation. The Division ofNuclear Safety proposed a limit of 60 pico-curies per liter.
In spite ofthe comments from state agency with the most knowledge in this area,
the Board gave great weight to the testimony provided by Water Remediation
Technologies, LLC and ignored the Division ofNuclear Safety’s recommendation.
Joliet provided support for the Illinois Emergency Management, Division of
Nuclear Safety proposal in our post-hearing comments file in December 2004. Eli Port,
Certified Heath Physicist calculated the limit that is protective ofbiota at 64 pico-curies
per liter and recommended the 60 pico-curies per liter Illinois Environment Management
Agency limit as being prudent.
4
Habitat for Sensitive Biota Not Present
Although no information has been presented to indicate that the discharge of
water containing radium has harmed wildlife in Illinois, the proposed standard appears to
be intended to protect wildlife. The discharges from identified wastewaterplants with the
potential to violate the proposed 3.75 pico-curies per liter standard are to streams with
seven day ten year low flows ranging from 0.11 to 3.0 c. £ s. at the point that the 3.75
pico-curies per liter would apply.
When plants that could comply if an average flow was used to determine
compliance, the seven day ten year low flows range from 0.11 to 0.24 c. f. s. The
discharges from the wastewater treatment plants expected to violate the proposed
standard range from 0.05 to 0.24 c. f. s. It is unlikely that sensitive species live in the
receiving streams ofthese plants.
Joliet asked Don Blancher, PhD ofToxicological and Environmental Associates,
Inc. to review the habitat for muskrats and the availability ofhabitat in Illinois. The
review is attached to these comments as Exhibit 2. Dr. Blancher determined that low
flow streams represent pooror unsuitable habitat for species like muskrat and the length
of time for exposure in these areas would be minimal. This determination was based on
the U.S. Fish and Wildlife Services Habitat Suitability Index Model for Muskrat which
indicates that muskrat habitat is in streams with flow rates of 0.4 c. £ s. to 30 c. f. s. in
waters with depth of greater than 18 inches. Dr. Blancher also reviewed the low flow
stream maps provided by the Illinois State Water Survey and the National Wetlands
Inventory for areas with radium discharges.
The Board has proposed a standard to protect species that do not live downstream
of impacted treatment plants in Illinois. Without the sensitive species living downstream
ofwastewater treatment plants, there is no reason to establish such a restrictive standard.
The Illinois Emergency Management Agency, Division ofNuclear Safety proposal of 60
pico-curies is appropriate.
As Joliet proposed in previous comments, if the Board is uncomfortable with the
60 pico-curies per liter proposal, a safety factor can be applied. Ifa safety factor of 2.0
was applied, the proposed water quality standard would be 30 pico-curies per liter. This
standard would not impact wastewater plants, would allow irrigation and other direct
discharges of well water to continue and provide the necessary protection of the streams.
COSTS OF COMPLIANCE
Throughout these proceedings, Water Remediation Technologies, LLC has
indicated that their radium removal process is cost competitive with other water treatment
processes. Joliet requested Strand Associates, Inc. to prepare a cost analysis comparing
the technology used by Water Remediation Technologies, L.L.C. to the co-precipitation
ofradium with hydrous manganese oxide method. Exhibit 3 is the cost analysis.
5
The analysis reached many conclusions. Conclusions significant to these
proceedings are as follows:
1. Co-precipitation of radium with hydrous manganese oxide has been
demonstrated to be effective in several full-scale plants, while the WRT
process just recently started full scale operations in one community in Illinois.
2. The costs ofthe WRT process are greater than the costs ofhydrous
manganese oxide (HMO). For the first year of a 20 year operating period,
WRT is anticipated to cost 14.8 more than HMO. The last year ofa 20 year
operating period, WRT is anticipated to cost between 23.0 and 33.7 more.
The first year cost difference for Joliet would be approximately $37,000 per
year. The last year cost difference ranges between $645,000 and $1,045, 000.
Although the first year cost differences do not appear significant, annual cost
increases greater than 23 are significant when passed along to consumers.
6
Summary
A review ofthe available information in this proceeding can be summarized as
follows:
1. The current standard of 1.0 pico-curies per liter Radium 226 is not being met
in Illinois and must be revised.
2. The USEPA has not developed and is not developing water quality standard
guidance based on a technical or scientific justification that will support either
the 3.75 pico-curies per liter or the 30 pico-curies per liter standard. The
USEPA will not approve the standard as currently proposed.
3. The original Illinois Environmental Protection Agency proposal of5.0 pico-
curies per liter at water supply and food processing intakes and no numeric
standard as a general use water quality standard provides the necessary
protections.
4. The Illinois Emergency Management Agency, Division of Nuclear Safety
standard for discharge from facilities that they regulate is 60 pico-curies per
liter.
5.
The current proposal does not provide the intended relief to the current
dischargers ofradium.
6. No increased discharges ofradium will occur as the result ofestablishing a
standard in the range of 30-60 pico-curies per liter.
7. Wildlife in Illinois is at not risk due to radium discharges.
8. Communities that have complied with the
5.0
pico-curies per liter drinking
water standard will face additional costs to supply with a standard that does
not improve the environment if the proposed standard is approved. This
would be a waste ofpublic funds.
9. Communities in the process ofcomplying with the drinking water standard
should not face additional costs that other communities have not incurred
without a commensurate improvement in the environment.
CHO2/ 22403493.1
7
CERTIFICATE OF SERVICE
The undersigned certifies that he has served upon the individuals named on the attached
Notice ofFiling true and correct copies of
COMMENTS SUBMITTED ON BEHALF OF THE
CITY OF JOLIET
by First Class Mail, postage prepaid, on August
15,
2005.
R 04-21 SERVICE LIST
Deborah J. Williams
Stephanie N. Diers
Illinois Environmental Protection Agency
1021 N. Grand Avenue, East
P.O. Box 19276
Springfield, IL 62794-9226
Dennis L. Duffield
City ofJoliet
Department ofPublic Works & Utilities
921 E. Washington Street
Joliet, Illinois 60431
Albert F. Ettinger
Stanley Yonkauski
Environmental Law & Policy Center
Illinois Department ofNatural Resources
35 East Wacker Drive, Suite 1300
One Natural Resources Way
Chicago, Illinois 60601
Springfield, Illinois 62702-1271
Matthew J. Dunn
Office of the Attorney General
Environmental Bureau
188 West Randolph, 20th Floor
Chicago, Illinois 60601
RoseMarie Cazeau
Office of the Attorney General
Environmental Bureau
188 West Randolph, 20th Floor
Chicago, Illinois 60601
Dorothy M. Gunn
Amy Antoniolli
Illinois Pollution Control Board
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
William Seith
Total Environmental Solutions
631 E. Butterfield Road, Suite 315
Lombard, Illinois 60148
Claire A. Manning
Brown, Hayes & Stephens LLP
700 First Mercantile Bank Building
P.O. Box
2459
Springfield, Illinois 62705-2459
John McMahon
Wilkie & McMahon
8 East Main Street
Champaign, Illinois 61820
Richard Lanyon
Metropolitan Water Reclamation District
100 East Erie Street
Chicago, Illinois 60611
Lisa Frede
CICI
2250 E. Devon Avenue, Suite 239
Des Plaines, Illinois 60018
Abdul Khalique
Metropolitan Water Reclamation District
Of Greater Chicago
6001 W. Pershing Road
Cicero, Illinois 60804
Jeffrey C. Fort
Letissa Carver Reid
Sonnenschein Nath & Rosenthal
8000 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6404
CHO2/ 22403497.1
Exhibit 1
ROY M. HARSCH
(312) 569-1441
Fax: (312) 569-3441
rhanch@gcd.com
July 29, 2005
Deborah J. Williams
Stephanie N. Diers
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springficld, IL 62794-9276
Re:
R 04-21 Radium Sampling Results
Dear Ms. Williams and Ms. Diers:
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Verytruly yours,
Roy M. Harsch
RMH/dmc
Enclosure
cc:
Service List
CH02/ 22399573.!
ROY M. HARSCH
(312) 569-1441
Fax: (312) 569-3441
rhanch@gcd.com
July 29, 2005
Mr. Albert F. Ettinger
Environmental Policy Center
35 E. Wacker Drive
Suite 1300
Chicago, IL 60601-2 110
Re:
R 04-2
1
Radium
Sampling
Results
Dear Mr. Ettinger:
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
Roy M. Harsch
RMHJdmc
Enclosure
cc:
Service List
CUO2i 22399673 I
ROY M. HARSCH
(312) 569-1441
Fax: (312) 569.3441
rhaach@gcd.com
July 29, 2005
Mr. Matthew J. Dunn
Office of the Attorney General
environmental Bureau
188 West Randolph, 20th Floor
Chicago, IL 60601
Re:
R 04-21 Radium Sampling Results
Dear Mr. Dunn:
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
Roy M. Harsch
RMHIdmc
Enclosure
cc:
Service List
CH02i 22399673.1
ROY M. HARSCH
(312) 569-1441
Fax: (312) 569-3441
rhanch@gcd.com
July 29, 2005
Dorothy M. Gunn
Amy Antoniolli
Illinois Pollution Control Board
100 West Randolph St.
Suite 11-500
Chicago, IL 60601
Re:
R 04-2 1 Radium Sampling Results
Dear Ms. (3unn and Ms. Antoniolli:
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
Roy M. Harsch
RMHldmc
Enclosure
cc:
Service List
(7U02,
22399673 I
ROY M. t-IARSCH
(312) 569-1441
Fax: (312) 569-3441
thorsch@gcd.com
July 29, 2005
Ms. Claire A.
Manning
Brown, Hayes & Stephens LLP
700 Firs Mercantile Bank building
P.O. Box 2459
Springfield, IL 62705-2459
Re:
R 04-21 Radium Sampling Results
Dear Ms. Manning:
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
Roy M. Harsch
RMHid mc
Enclosure
cc:
Service List
CH02; 22399573
)
ROY M, HARSCI-I
(312) 569-1441
Fax: (312) 569-3441
rhanch@gcd.com
July 29, 2005
Richard Lanyon
Metropolitan Water Reclamation District of Greater Chicago
100 East Erie St.
Chicago, IL 60611-2803
Re:
R 04-21 Radium Sampling Results
Dear Mr. Lanyon:
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
Roy M. Harsch
RMHidmc
Enclosure
cc:
Service List
CR02, 22399673.1
-
S
~
ROY M. HARSCII
(312) 569-1441
Fax: (312) 569.3441
rhonch@gcd.com
July 29, 2005
Abdul Khalique
Metropolitan Water Reclamation District
Of GreaterChicago
6001 W. Pershing Road
Cicero, Illinois 60804
Re:
R 04-21 Radium Sampling Results
Dear Mr.
Khalique:
As
set forth in Joliet’s Motion for additional time, please find the enclosed Summary
of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
Roy M. Harsch
RMWdmc
Enclosure
cc:
Service List
CHO2/ 22399673.1
ROY M. HARSCII
(312) 569-1441
Fax: (312) 569-3441
rhanch@gcd.com
July 29, 2005
Mr. Dennis L.
Duffield
Dir, ofPublic Works & Utilities
City ofJoliet
921 East Washington St.
Joliet, IL 60433
Re:
R 04-21 Radium Sampling Results
Dear Mr. Duffield
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
Roy M. Harsch
RMHldmc
Enclosure
cc:
Service List
CUO2/2239’9673.t
ROY
0k
I-IARSCH
(312) 569-1441
Fox: (312) 569-3441
rharsch@gcd coin
July 29, 2005
Mr. Stanley Yonkauski
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, IL 62702-1271
Re:
R 04-21 Radium Sampling Results
Dear Mr. Yonkauski:
As set forth in Jolict’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
cUCLUAI
Roy M.Harsch
RMF/dmc
Enclosure
cc:
Service List
(H02/ 22399673.1
ROY M. HARSCH
(312) 569-1441
Fax: (312) 569-3441
rhanch@gcd.com
July 29, 2005
Rosemarie E. Cazeau
Illinois Attorney General’s Office
Environmental Bureau
188 W. Randolph Street
Chicago, IL 60601
Re:
R 04-21 Radium Sampling Results
Dear Ms. Cazeau:
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Very
truly yours,
Y44caJ~
Roy M. Harsch
RMHidmc
Enclosure
cc:
Service List
CHO2/ 22399673.1
ROY M. HARSCH
(312) 569-1441
Fax: (312) 569-3441
thanch@gcd.com
July 29, 2005
William Seith
Total Environmental Solutions
631 E. Butterfield Road, Suite 315
Lombard, Illinois 60148
Re:
R 04-21 Radium Sampling Results
Dear Mr. Seith:
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary
of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
Roy M. Harsch
RMH/dmc
Enclosure
cc:
Service List
CHO2/22399673.I
ROY M. HARSCH
(312) 549-1441
Fax: (312) 569-3441
rharsch@gcd,com
July 29, 2005
John McMahon
Wilkie & McMahon
8 East Main Street
Champaign, Illinois 61820
Re:
R 04-2 1 Radium Sampling Results
Dear Mr. McMahon:
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
Roy M. Harseh
RMH/dmc
Enclosure
cc:
Service List
CHO2/
22399673.!
ROY M. HARSCH
(312) 569-1441
Fax: (312) 569-3441
rhanch@gcd.com
July 29, 2005
Ms. Lisa Frede
Director of Regulatory Affairs
Chemical Industry Council of Illinois
2250E. Devon Avenue
Suite 239
Des Plaines, IL 60018
Re:
R 04-2 1 Radium Sampling Results
Dear Ms. Frede:
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
cp~vvuciatt~
Roy M. Harsch
RMH/dmc
Enclosure
cc:
Service List
CR02! 22399673
I
ROY M. HARSCH
(312) 569-1441
Fax: (312) 569-3441
rhonch@gcd.com
July 29, 2005
Jeffrey C. Fort
Letissa Carver Reid
Sonnenschein Nath & Rosenthal
8000 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6404
Re:
R 04-21 Radium Sampling Results
Dear Mr. Fort and Ms. Reid:
As set forth in Joliet’s Motion for additional time, please find the enclosed Summary of
Radium Samples for Various Communities in Northern Illinois.
Very truly yours,
Roy M. Harsch
RMHIdmc
Enclosure
cc:
Service List
CR02! 22399673.1
7/27/2005
Summary
of
Radium
Samples
for
Various
Communities
in
Northern
Illinois
Page
1
of
4
Date
Radium
226
RadIum
228
Combined
Radium
Intluent
Samples
Joliet
Eastside
Wastewater
Treatment
Plant
Feb-04
3
5.3
8.3
8-Mar-04
1.9
4.3
6.2
12-May-05
1.1
+1-0.8
2.2
÷1-0.7
3.3
+/-1.3
Joliet
Westaide
Wastewater
Treatment
Plant
Feb-04
2.9
5.1
8
8-Mar-04
3.9
6.1
10
12-May-05
1.8
+1-0.6
2.7
÷1-0.9
4.5
Community
A
Jul-00
4.3
÷1-0.8
1.4
+1-1.0
5.7
ti-lU
8-Feb-01
2.7
+/-0.1
3.9
+1-0.1
6.6
+/-01
22-Feb-01
2.6
+/-
0.1
3.8
÷1-
0.1
6.2
‘-I-
0.2
Dec-02
5.2-8.8
NA
3.7-6.9
Note
1
Jan-03
02-2.2
NA
2.6-4.2
Note
1
Feb-03
5.6
+1-1.9
c6.0
11.6
+16.0
Mar-03
3.1
+1-
1.2
5.6
÷1-
1.2
8.7
+1-2.4
Apr-03
5.7
÷1-
1.9
8.5
÷1-
3.0
14.2
÷1-
4.9
May-03
3.24
÷1-
1.48
8.22
+1-
4.23
11.46
+1-
5.71
Jun-03
7.38
÷1-
2.03
8.82
+1-
2.54
16.2
+1-
4.57
Jul-03
6.85
+1-
1.9
1.76
+1-
1.6
8.61
+1-
3.5
Aug-03
2.9
+1-
0.9
6.1
+1-
1.7
9
÷1-
1.6
Sep-03
7.47
÷1-
1.7
6.19
+1-
1.6
13.66
+1-13
Jan-04
5.75
+1-
1.6
8.12
+1-2.1
13.87
+1-3.8
Feb-04
5.25
±1-
1.4
3.13
÷1-0.96
8.38
+1-
2.36
Apr-04
3.87
÷1-
1.1
1.86
÷1-
0.71
5.73
±1-
1.81
Jun-04
3.12
+1-
0.9
3.55
+1-
0.88
6.67
+1-
1.78
Community
8
28-Apr-05
3
+1-
0.2
2.9
÷1-
0.6
5.9
+1-
0.8
DeKaIb
Sanitary
District
11-May-05
0.8
+/-
0.5
4.5
+1-
1.3
5.3
+1-
1.8
Prepared
by
City
of
Joliet
Department
of
Public
Works
and
Utilities
7/27/2005
Summary
of
Radium
Samples
for
Various
Communities
in
Northern
Illinois
Page
2
of
4
Date
RadIum
226
Radium
228
Combined
Radium
Effluent
Samples
Joliet
Eastside
Wastewater
Treatment
Plant
Feb-04
1.2
3.9
5.1
8-Mar-04
2.6
3.5
6.1
12-May-05
0.7
1.5
+1-0-7
1.5
+1-1.4
Joliet
Westside
Wastewatei-
Treatment
Plant
Feb-04
2
2.9
4.9
8-Mar-04
0.9
1
1.9
12-May-05
0.6
÷1-0.6
1.6
+I-O.7
1.5
÷1-1.3
Community
A
Jul-00
2.2
÷/-0.8
1.5
+~Q~9
3.7
÷/-1.0
8-Feb-01
2.1
~/-0.1
1.0
3.1
+1-0.2
22-Feb-01
0.9
1.0
1.9
Dec-02
3.0-5.2
NA
3.3-4.9
Note
1
Jan-03
2.7-5.1
NA
2.7-4.3
Note
1
Feb-03
3.6
÷/-
1.9
3.8
7.4
+/1.4
Mar-03
2.8
÷1-12
2.9
÷1-
1.2
5.7
+1-
2.4
Apr-03
2.8
÷/-
1.9
4.2
÷1-
1.6
7.0
tI-
3.0
May-03
2.26
÷/-
1.48
3.97
+1-
1.66
6.23
+/-
2.63
Jun-03
2.33
÷/-
0.84
3.72
~/-
1.76
6.05
+1-
.6
Jul-03
1.96
÷1-0.7
3.12
+1-
1.4
5.08
+/-2.1
Aug-03
3.4
+1-
1.0
3.4
÷1-
1.2
6.8
+1-
2.2
Sep-03
2.88
+1-0.75
2.47
+1-
1.1
5.35
+1-
1.85
Jan-04
3.01
+/-
1.1
3.22
+1-
1.2
6.23
+/-2.3
Feb-04
2.74
+1-
1.0
1.94
+1-
0.75
4.68
+1-
1.75
Apr-04
3.43
+/-
1.1
0.54
÷1-0.53
3.97
+1-
1.63
Jun-04
3.21
÷/-0.96
2.69
÷1-
0.69
5.9
+/-
1.65
Prepared
by
City
of
Joliet
Department
of
Public
Works
and
Utilities
7/27/2005
Summary
of
Radium
Samples
for
Various
Communities
in
Northern
Illinois
Page
3
of
4
Date
Radium
226
Radium
228
Combined
Radium
Community
S
28-Apr-05
3
2.9
5.9
Romeoville
15-Apr-05
0.7
÷1-0.1
0.5
+1-0.5
1.2
+1-0.6
Monmouth
North
11-May-05
0.6
6.6
7.2
Monmouth
Main
11-May-05
1.0
+1-
0.5
6.0
7.0
Dekaib
Sanitary
District
10-May-05
0.3
1.4
÷1-
0.5
1.7
+1-
0.8
Channahon
15-Apr-05
1.1
+/-
0.9
0.79
÷1-
0.83
1.9
+1-
0.9
Upstream
Samples
DesPlaines
River
at
Jefferson
Street
12-May-05
1.1
0.7
1.1
Hickory
Creek
Upstream
Joliet
ESWW1
12-May-05
0.1
0.7
0.8
Downstream
Samples
DesPlaines
River
at
Brandon
Road
12-May-05
0.7
0.7
1.4
DesPlaines
Riv&at
1-55
12-May-05
0.1
0.7
0.8
Romeoville,
1
mile
downstream
15-Apr-05
0.1
+1-
0.1
0.5
+1-
0.4
0.6
+1-
0.5
Prepared
by
City
of
Joliet
Department
of
Public
Works
and
Utilities
7/27/2005
Summary
of
Radium
Samples
for
Various
Communities
in
Northem
Illinois
Page
4
of
4
Date
Radium
228
Radium
228
Combined
Radium
Other
sites
DuPage
River
at
Caton
Farm
Road
12-May-05
0.1
0.6
0.7
Well
Sample
Results
for
Wells
pumped
to
storm
sewers
with
rio
dilution
in
the
first
mile
downstream
Williamson
Ave
18-May-05
9.9
÷1-
0.3
10.8
+/-1.1
20.7
+1-1.4
9-D
18-May-05
5.5
+1-
0.2
7.7
÷1-1.0
132
+/-1.2
10-C)
18-May-05
6.4
+/-0.3
7.7
f/-
1.1
14.1
+1-
1.4
11-0
18-May-05
5.6
÷1-
0.3
5.4
÷1-
0.9
11.0
÷1-
1.2
12-0
18-May-05
7.7
÷/-0.3
9.2
+/-
1.2
16.9
‘-I-
1.5
15-0
18-May-05
2.9
+1-0.2
4÷1-8
6.9
+1-
1.4
17-0
18-May-05
2.9
+1-0.1
5.1
÷1-0.6
8.0
+/-0.7
18-0
18-May-05
5.8
÷1-
0.3
4.5
+/-
0.7
10.3
+1-
1.4
21
18-May-05
3.2
÷1-02
2.9
÷1-0.5
6.1
~i-0.7
Note
1
Due
to
insufficient
sample
volume,
results
are
reported
as
a
range.
Results
are
based
on
statistical
average
results
for
multiple
analysis
Prepared
by
City
of
Joliet
Department
of
Public
Works
and
Utilities
R 04-21 SERVICE LIST
Deborah J. Williams
Dennis L. Duflield
Stephanie N. Diers
City ofJoliet
Illinois Environmental Protection Agency
Department ofPublic Works & Utilities
1021 N. Grand Avenue, East
921 E. Washington Street
P.O. Box 19276
Joliet, illinois 60431
Springfield, IL 62794-9226
Albert F. Ettinger
Stanley Yonkauski
Environmental Law & Policy Center
Illinois Department ofNatural Resources
35
East Wacker Drive, Suite 1300
One Natural Resources Way
Chicago, illinois 60601
Springfield, Illinois 62702-1271
Matthew J. Dunn
RoseMarie Cazeau
Office ofthe Attorney General
Office ofthe Attorney General
Environmental Bureau
Environmental Bureau
188 West Randolph, 20th Floor
188 West Randolph, 20th Floor
Chicago, illinois 60601
Chicago, illinois 60601
Dorothy M. Gunn
William Seith
Amy Antoniolli
Total Environmental Solutions
Illinois Pollution Control Board
631 B. ButterfieldRoad, Suite 315
100 West Randolph Street, Suite 11-500
Lombard, Illinois 60148
Chicago, illinois 60601
Claire A. Manning
John MeMahon
Brown, Hayes & Stephens LLP
Wilkie & McMahon
700 First Mercantile Bank Building
8 East Main Street
P.O. Box 2459
Champaign, minois 61820
Springfield, illinois 62705-2459
Richard Lanyon
Lisa Frede
Metropolitan Water Reclamation District
CICI
100 East Erie Street
2250 B. DevonAvenue, Suite 239
Chicago, Illinois 60611
Des Plaines, illinois 60018
Abdul Khalique
Jeffrey C. Fort
Metropolitan Water Reclamation District
Letissa Carver Reid
Of GreaterChicago
Sonnenschein Nath & Rosenthal
6001 W. Pershing Road
8000 Sears Tower
Cicero, Illinois 60804
233 South Wacker Drive
Chicago, illinois 60606-6404
CHO2I 22384969.!
EXHIBIT 1
SUPPLEMENT
Protecting Our Water Environment
— p
L
..L_
si_at
-
BOARD OF COMMISSIONERS
Torrents J. O’Brien
Preshjent
Kathleen morose Meany
Vice Presideni
Gloria
AJitlo Majewski
ChaIrman 0? FInance
Frank Avila
James C. Harris
Barbara J. McGowan
Cynthia M. Santos
Patricia Stung
Harry
Bus”
Thureil
Metropolitan Water Reclamation District of Greater Chicago
100
EAST ERIE STREET
CHICAGO, ILLINOIS 60611-3154
312’751’5600
Richard Lanyon
Director of Research & Development
August 3, 2005
3127515190
Mr. Dennis L. Duffield
Director ofPublic Works and Utilities
921 E. Washington Street
Joliet, IL 60431
Dear Mr. Duffield:
SUBJECT:
Radium Level at the Lemont Water Reclamation Plant (WRP) Influent and
Effluent, and in the Chicago Sanitary and Ship Canal (CSSC) at the Up-
stream of LockportPowerhouse.
The Village of Lemont uses groundwater, containing naturally occurring radium, for its cornniu-
nity water supply. The water treatment process backwash is discharged to the Lemont Water Reclamation
Plant (WRP), which is owned and operated by the Metropolitan Water Reclamation District of Greater
Chicago (District). At your request, the District sampled the influent and effluent of the Lemont WRP
and a location downstream of the plant in the Chicago Sanitary and Ship Canal for radium-226 and ra-
dium-228. The results are presented below.
Sample Location
Radium-226 (yCi/L)
_________________
Lemont WRP Jnfluent
8.0 ±0.4
Lemont WRP Effluent
4.8 ±0.4
CSSC -upstream of
0.1
Lockport Powerhouse
Please feel free to call Dr. Abdul Khalique at 708-588-4071 if any fi.irther information is required.
Sincerely,
Richard Lanyon
Director ofResearch and Development
RL:AK:nu
cc: Granato/O’ Connor/Khalique
Radium-228 (pCiI’L~
8.9±1.6
4.7±1.3
1.2
Exhibit 2
4
-e
To:
Dennis Duffield
From: Don Blancher, Ph.D.
CC:
Chris UIm, Jane Carison
Date:
May
16, 2005
Re:
Joliet
—
Radium Issues
MEMORANDUM
Work on Radium Impact Review
.
Habitat Requirements of
Muskrats
•
Low Flow Illinois Streams
National Wetlands Inventory of the study area
•
Riparian Species of Interest
Impact of Radium is focused on the imØact to various riparian species, especially mammals,
and especially the muskrat. We have reviewed a variety of information including:
One must keep in mind that risk from exposure to any toxicant, including radiological
compounds, is dependent on dose and exposure. Based on our review of the information
available, the risk from exposure to radium isotopes discharged
from
wastewater plants to
low-flow surface waters in northern Illinois is extremely low for aquatic mammals.
This is
based on the fact that these low-flow streams represent poor to unsuitable habitat for species
like muskrat, and the length of time for exposure in these areas would be minimal. The only
time these organisms may occasion these areas is during high flow situations, when dilution
would further minimize the exposure associated risks. The risk for aquatic mammalian
species like beaver and offer is even less likely due to their life history and behavior.
Habitat
Requirements of Muskrat
Review of the US Fish and Wildlife services Habitat Suitability Index Model (HSI) for Muskrat,
indicate that this ripatian mammal does not typically inhabit streams with either a very high
flow rate (greater than 30 cu ft/sec) or streams with low flow rates less than 0.4 cu ft/sec
(Allen and Hoffman, 1984). Of particular interest is the fact that the muskrat does not inhabit
waters with a depth of less than 18 inches. This restricts the mammal to a certain stream
size with enough flow to maintain suitable depth for the animal. Additionally, the organisms
require sufficient aquatic vegetation for forage, and according to the 1-151 model the
organisms would typically avoid areas lacking suitable aquatic species. It has been noted
that cattail
(Typha spp.)
are the preferred diet, and
this vegetation is typically found in
abundance around ponds, wetlands, and larger streams, with perennial (in)flow.
More
definitive delineation of specific habitats could be reasonably predicted using the HSl model.
However, it is highly likely that intermittent streams and small streams do not provide suitable
habitat because of lack
of water depth and flow, and lack of adequate forage and cover.
Toxicological
&
~ Environmental
a
Associates, Inc.
1
Memorandum:
5/16/2005.
Page 2.
Similar habitat restrictions would be applicable to other aquatic mammalian species, such as
otter. All these organisms are dependent on sufficient aquatic resources. Habitat Suitability
models for many of these species are also available.
Low-Flow Illinois Streams
Maps of the Illinois low-flow (7Q10)
streams were reviewed to provide information relative to
areas of concern. The maps of interest are presented in a power point presentation
associated with this memo.
These data represent a starting point for comparison with
various
wetlands maps to define habitats of interest to the radium
—
discharge
—
exposure
question.
National Wetlands Inventory of Study Area
National Wetlands Inventory maps of the study area
are available online
(httg://wetlandsfws.eruses.Qovfl and have been captured and presented in a series of power
point slides for this review (see associated
PPT files). These data are also available online
as ESRI Shape files (htto://wetlands.fws.gov/wetlands/shapedata nad83O.
Alternate
sources of data which describe wetlands areas in Illinois include the analyses performed--by
the GAP program to identify habitat areas of concern and associated models of vertebrates
inhabiting
such
habitats.
(http://www.inhs.uiuc.edu/cwe/Qao/vertmodeling.htm).
Unfortunately, GAP analyses are unavailable for Illinois.
Riparian Species of Interest
Endangered Species (mammals) for the area includes several species of bats and a
couple
of field mice species but not riparian. See http://dnr.state.il.us/espb/datelist.htm. There are
some mussels and crayfish potentially of interest, but these species are relatively unaffected
by the levels of radiation in the range discussed and/or have a rapid tumover (crayfish,
insects). Also, in the low flow areas of interest, we do not have good information on whether
the mussels even utilize that small stream habitat.
Amphibians such as the bullfrog and the red-spotted newt will be found within these areas as
well and have HSI
models available. Since these are mostly insectivorous, it is not clear if
they would be affected and perhaps this warrants further investigation.
A review of Illinois riparian mammals resulted in the following riparian species of interest:
Muskrat
(Ondatra zibethicus)
Beaver
(Castor Canadensis)
Mink
(Mustdlla v/son)
River Offer
(Lutra Canadensis)
There are some voles, lemmings and shrews in other states that get listed as riparian, but it is
not clear that they spend significant time in the ripadan area. Raccoon and opossum are
wide ranging, as are weasels, but they are not strictly riparian or aquatic. Hence, you would
have to factor in to any risk assessment the time of exposure in the riparian zone. Thus,
Muskrat are the primary animals who spend all their time in the water or riparian zone and
have a small range (except during one season). They eat only aquatic vegetation and are
S Page2
Memorandum: 5/16/2005. Page 3.
considered a good bioindicator of what happens in the riparian zone. Weasels may also
occasion the riparian zone but are still considered woodland and field species. Mink have
muskrat in their diet, and would be the next logical species to carefully look at, and are
always close to water.
The oiler and beaver are even less likely to be encountered in the low-flow streams under
consideration. And it has been shown studying bioaccumulation of radium in riparian
organisms, that animals like the beaver accumulate less radium than do muskrat,
presumably because of feeding habits and food source (Murka, et al. 1996).
Other species considered were the Marten,
(Manes amedoana)
and the Fisher,
(Mades
pennanfl)
but these two species are presumed extirpated from Illinois according to the
NatureServe Explorer website (http://www.natureserve.org/exolorer/).
References Cited:
Allen, A.W. and R. D. Hoffman. 1984. Habitat Suitability Index Models: Muskrat. FWS/OBS-82/10.46
S
Page 3
FWS/OBS-82/1
0.46
JUNE 1984
N
-
\ThUm4~ Research Center
L ‘.1’
.Ufld
WtIdflfe
Service
7~afunru~c-
Doulevard
L~uyeUe,La.
70506
HABITAT SUITABILITY INDEX MODELS:
MUSKRAT
~h and Wildlife Service
SK
361
.u54
~
82—
10.46
S.
Department of the
Interior
MODEL EVALUATION FORM
Habitat models are designed for a wide variety of planning applica-
tions where habitat information is an important consideration in the
decision process. However, it is impossible to develop a model that
performs equally well in all situations. Assistance from users and
researchers is an important part of the model improvement process. Each
model is published individually to facilitate updating and reprinting as
new information becomes available. User feedback on model performance
will assist in improving habitat models for future applications. Please
complete this form following application or review of the model. Feel
free to include additional information that may be of use to either a
model developer or model user. We also would appreciate information on
model testing, modification, and application, as well as copies of modified
models or test results. Please return this form to:
Habitat Evaluation Procedures Group
U.S. Fish and Wildlife Service
2627 Redwing Road, Creekside One
Fort Collins, CO 80526—2899
Thank you for your assistance.
Geographic
Species
________
-____
Location
_____________________________
Habitat or Cover Type(s) _____________________________________________
Type of Application: Impact Analysis
Management Action Analysis
Baseline
_____
Other _________________________________________________
Variables Measured or Evaluated
Was the
species information
useful and accurate? Yes
No
If not, what corrections or improvements are needed?
Were the variables and curves clearly defined and useful? Yes
No
If not, how were or could they be improved?
__________________
Were the techniques sug gested for collection of field data:
Appropriate?
Yes
No
Clearly defined? Yes
No
Easily applied?
—
Yes
No
If not, what other data collection techniques are needed?
Were the model equations
logical? Yes
No
Appropriate?
Yes
No
How were or could they be improved?
Other suggestions
equations, graphs,
for
or
modification or improvement (attach curves,
other appropriate information)
Additional references or information that should be included in the model:
Model Evaluater or Reviewer
_________________________
Date
Agency __________________________________________________
Address _________________________________________________
Telephone Number
Comm:
_________________________
FTS
F’WS/OBS-82/1O. 46
June
1984
HABITAT SUITABILITY INDEX MODELS: MUSKRAT
by
Arthur W. Allen
Western Energy and Land Use Team
U.S. Fish and Wildlife Service
2627 Redwing Road
Fort Collins, CO 80526—2899
and
Robert D. Hoffman
Ohio Cooperative Wildlife Research Unit
1725 Neil Avenue
Ohio State University
Columbus, OH 43120
Western Energy and Land Use Team
and
National Coastal Ecosystems Team
Division of Biological Services
Research and Development
Fish and Wildlife Service
U.S. Department of the Interior
Washington, DC 20240
This report should be cited as:
Allen, A. W., and R. D. Hoffman. 1984. Habitat suitability index models:
Muskrat. U.S. Fish Wildl. Serv. FWS/OBS—82/10.46. 27 pp.
PREFACE
This document is part of the Habitat Suitability Index (HSI) Model Series
(FWS/OBS—82/1O), which provides habitat information useful for impact assess-
ment and habitat management studies. Several types of habitat information are
provided. The Habitat Use Information-Section Is largely constrained to those
data that can be used to derive quantitative relationships between key environ-
mental variables and habitat suitability. The habitat use information provides
the foundation for HSI models that follow. In addition, this same information
may be useful in the development of other models more appropriate to specific
assessment or evaluation needs.
The HSI Model Section documents each habitat model and the information
pertinent to its application. Each model synthesizes the habitat use informa-
tion into a framework appropriate for field application and Is scaled to
produce an index value between 0.0 (unsuitable habitat) and 1.0 (optimum
habitat). The application information includes descriptions of the geographic
ranges and seasonal application for each model, its current verification
status, and a listing of model variables with recommended measurement
techniques for each variable.
In essence, the models presented herein are hypotheses of species—habitat
relationships and not statements of proven cause and effect relationships.
Results of model performance tests, when available, are referenced. However,
models that have demonstrated reliability in specific situations may prove
unreliable in others. For this reason, feedback is encouraged from users of
these models concerning improvements and other suggestions that may increase
the utility and effectiveness of this habitat—based approach to fish and
wildlife planning. Please send suggestions concerning the freshwater muskrat
model to:
Habitat Evaluation Procedures Group
Western Energy and Land Use Team
U.S. Fish and Wildlife Service
2627 Redwing Road
Ft. Collins, CO 80526—2899
Suggestions or questions concerning the application of the estuarine
muskrat model should be forwarded to:
Coastal Habitat Evaluation Procedures Project
National Coastal Ecosystems Team
U.S. Fish and Wildlife Service
1010 Gause Boulevard
Slidell, LA 70458
1~11
iv
Page
PREFACE
.
iii
ACKNOWLEDGMENTS
vi
HABITAT USE INFORMATION
1
General
1
Food
1
Water
3
Cover
4
Reproduction
6
Interspersion
6
HABITAT
SUITABILITY INDEX (HSI)
7
Model Applicability
7
Model Descriptions
8
Model Relationships
15
SOURCES OF OTHER MODELS
23
REFERENCES
23
CONTENTS
MOO ELS
V
ACKNOWLEDGMENTS
We gratefully acknowledge Dr. Robert Brooks, Dr. R. Chabreck, Mr. Alfred
Gardner, Mr. Greg Linscombe, Dr. Thomas Michot, Mr. John Orqan, Ms. Cathy
Rewcastle, Mr. R. R. P. Stardom, and Mr. Thomas Thornhill for their reviews of
earlier drafts of the HSI models for the muskrat. The comments and suggestions
of these persons have added significantly to the quality of these HSI models.
Appreciation is also extended to Dr. ~JonBart for the work he conducted in
evaluating earlier drafts of the inland and estuarine muskrat HSI models. The
cover of this document was illustrated by Jennifer Shoemaker. Word processing
was provided by Carolyn Gulzow and Dora Ibarra.
The estuarine HSI model was developed for the National Coastal Ecosystems
Team. Appreciation is extended to Rebecca Howard who served as Project Dfficer
for the development and evaluation of the estuarine portion of this document.
Partial funding for the development of this model was provided by the
Engineering and Research Center, U.S. Bureau of Reclamation, Denver, CO.
vi
MUSKRAT (Ondatra zibethicus)
HABITAT USE INFORMATION
General
The muskrat (Ondatra zibethicus) is the most valuable semi—aquatic fur—
bearer in North America, with a total fur trade income In the millions of
dollars (Willner et al. 1980). With the exception of Florida, and coastal
Georgia and South Carolina, native and introduced populations of muskrats
occur throughout most of North America. Muskrats are an important component
of the marsh ecosystem, serving as a food source for many predators (Wilson
1968), and can have a major Impact on wetland vegetation (O’Neil 1949;
Errington 1961, 1963; Weller and Spatcher 1965).
Food
Muskrats are primarily herbivorous although animal matter also is consumed
(Errington 1963). Muskrats utilize the most available plant species, therefore
commonly consumed foods will vary with the type of habitat (Takos 1947;
Errington 1963; Neal 1968; Willner et al. 1980). Perry (1982) presented a
regional-lied listing of food plants used by muskrats throughout North America.
The basal portions of aquatic vegetation are eaten most often followed by
rhizomes and leaves (Neal 1968). Cattail (Typha spp.) has frequently been
identified as a highly preferred food of the species (Hamerstrom and Blake
1939; Takos 1947; Bellrose 1950; Sather 1958; Errington 1963). Errington
(1948) concluded that broad—leaved cattail (I. latifolia) was a highly
preferred muskrat food and that marshes comprised of this species could support
twice the density of muskrats as marshes dominated by other types of emergent
vegetation. Feeding studies conducted in Manitoba have indicated that cattail
can support approximately seven times as many muskrats as an equivalent amount
of bulrush (Scirpus spp.) (Stardom pers. comm.). Other important food plants
include sweetflag (Acorus calamus), waterlily (Nymphaea spp.), arrowhead
(~gjttariaspp.), sedge (Carex spp.), and wild rice (Zizania aguatica) (Takos
1947). A wide variety of vegetation, including agricultural crops, will meet
the dietary needs of stream—dwelling muskrats (Errington 1961). The foods
consumed by stream and canal—dwelling muskrats tend to be more diverse than
those used by muskrats Inhabiting marshes (Perry 1982). Muskrats inhabiting
lakes and reservoirs tend to be opportunistic feeders and may feed upon animal
matter to a greater degree than do muskrats that inhabit marshes (O’Neil
1949).
1
In coastal marsh habitats muskrats are heavily dependent on bulrush and
cattail (Willner et al. 1975). Olney bulrush (S. olneyl) made up 80 of the
muskrat’s diet in brackish Louisiana marshes (O’Neil 1949). Olney bulrush,
common three—square bulrush (S. americanus), and cattail (I. latifolia, I.
anqustifolia) accounted for 80 of the muskrat’s diet In coastal Maryland
marshes (Smith 1938). Ulney bulrush has the highest weight per square meter
of any common marsh plant and grows year—round In Louisiana (O’Neil 1949).
The salinity tolerance of Olney bulrush has been investigated in several
studies (O’Neil 1949; Harris 1952; Schmidt 1958; Palmisano 1970; Rose and
Chabreck 1972). Results of these studies indicate that the salinity most
suitable for the growth of Olney bulrush ranges from 5 to 20 parts per
thousand. Food is limited in winter, and appreciable quantities are not
stored by muskrats (Smith 1938; Errington 1941; Schwartz and Schwartz 1959).
The main advantage of cattail is that Its rhizomes are of high nutritive
quality and are available as a winter food source (Cook 1952).
Muskrats typically reach their greatest densities in aquatic habitats
that provide dense emergent vegetation and are bordered by terrestrial herba—
ceous vegetation (Errington 1963). Brooks and Dodge (1981) recorded more
muskrat burrows and signs of activity in riverine habitats bordered by open
and agricultural land, whereas forested river banks had a significant negative
effect on muskrat burrow abundance. Increasing. muskrat density in Iowa was
associated with the presence of dense emergent vegetation (Neal 1968). Declin-
ing population levels were associated with less densely vegetated habitat.
“Food—poor” open water lakes, ponds, or dry lowlands choked with vegetation
are not conducive to high muskrat densities in northern regions (Errington
1963). In addition to the amount of emergent vegetation, the amount of addi-
tional food plants and materials available for lodge construction also may
regulate muskrat populations (Bishop et al. 1979). Ponds in Ohio with “good”
vegetative cover produced an average of 9.6 muskrats/0.4 ha (9.6/acre)
(Gilfillan 1947). Ponds with “fair” vegetative cover yielded an average of
8.7 muskrats/D.4 ha (8.7/acre), whereas ponds with no vegetative cover produced
no muskrats.
The importance of vegetation in providing cover is difficult to separate
from its role as a fo2d source. In high quality habitat, 50 or more of the
area is covered with dense, emergent vegetation. Dozier (1953) believed that
an 80:20 ratio of emergent vegetation to water would provide ideal muskrat
habitat. Errington (1963) rated marsh conditions as excellent when two—thirds
of the marsh was covered, but gave a poor rating to a marsh with only 17
coverage. Bishop et al. (1979) recorded an 18—fold increase in muskrats after
a lake in Iowa revegetated to a 75:25 ratio of vegetation to open water.
Muskrat feeding and house construction activities may have detrimental
effects upon aquatic vegetation (Willner et al. 1980). Danell (1978) reported
that stands of horsetail (Equisetum fluviatile) decreased as muskrat population
density increased. High muskrat population density may result in the elimina-
tion of preferred food plants in an area and an eventual decline in the muskrat
population (Errington 1963). “Eat—outs” by muskrats, discussed in detail by
Errington (1951), Harris (1952), Sipple (1979), and Willner et al. (1980), may
severely affect the humus layer and thus retard vegetative regeneration for
several years.
2
Water
Suitable muskrat habitat requires a permanent supply of still or low
velocity water (Errington 1963). Stream gradient and discharge were believed
to be key factors in determining the potential quality of streams as muskrat
habitat in a Massachusetts study (Brooks and Dodge 1981). Muskrats were
present where the stream gradient was low
6.1 m/krn (32.2 ft/mi) and
discharge exceeded 0.1 m3/s (4 ft1/s) but were absent on streams with a
gradient in excess of 9.0 rn/km (47.5 ft/mi) and discharge flows of less than
0.1 m3/s. Riverine habitats with mean annual discharge in excess of 30 m’/sec
(approxImately 1,000 ft3/s) are probably poor muskrat habitat because of water
level fluctuation, scouring, and erosion of the banks. Water stability has a
more direct effect on habitat quality than does water depth (Hamerstrom and
Blake 1939). Bellrose and Brown (1941) reported that muskrats were more
abundant in lakes having stable water levels than in lakes with fluctuating
water levels. Muskrat population density was more affected by changes in
water level than by the types of emergent vegetation present. Low water
levels result in reduced food and cover availability (Errington 1939). Low
water level during winter has a greater affect on muskrats than low water
conditions during summer (Perry 1982). Low water during winter may permit the
entire water column to freeze resulting in reduced availability of food
resources in the normally unfrozen water and substrate. Seabloom and Beer
(1964) associated the absence of snow cover in North Dakota to heavy ice
formation resulting in freezeout and subsequent high muskrat mortality.
High water also results in habitat deprivation by altering vegetative
composition and forcing muskrats out of refuge (lodge and burrow) sites (Sather
1958; Olsen 1959). Lakes in Ohio that were subjected to severe flooding
0.6 m (2 ft) rise in water level, produced 0.17 muskrats/0.4 ha (0.17/acre)
(Gilfillan 1947). Lakes that did not experience such severe flooding produced
1.45 muskrats/0.4 ha (1.45/acre). Muskrat production in severely flooded
marshes was 4.24 animal s/0.4 ha (4.24/acre) as compared to 8.59 animal s/0.4 ha
(8.59/acre) in marshes with stable water levels. The best muskrat marshes in
Manitoba experience cyclic water level fluctuations of approximately 0.6 m
(2 ft) (Rewcastle pers. comm.). It is believed that water fluctuation Is
required with some regularity (approximately every 5 years) to provide a
suitable seedbed for vegetative regeneration.
Water depth between 0.46 m (18 inches) and 1.2 m (4 ft) is most suitable
for muskrats (Errington 1963). Danell (1978) reported that 96 of all muskrat
lodges located in his study area were constructed in water or within 1 m
(3.3 ft) of water. The average water depth at lodge sites was 0.2 m (0.6 ft),
whereas the average water depth within 2 m (6.6 ft) of the lodge was 0.33 rn
(1.0 ft). All lodges located during a California study were in water 0.3 in
(1.0 ft) deep or less (Earhart 1969). Optimum water depth for lodge construc-
tion in Illinois was 0.3 to 0.40 m (1 to 1.5 ft) (Bellrose and Brown 1941).
Muskrats inhabiting streams prefer deep holes and backwater areas; however, a
lack of such conditions is not critical if adequate food is present (Errington
1937). Brooks and Dodge (1981) found that the number of coves and islands was
strongly associated with muskrat abundance in an evaluation of riverine
habitats in Massachusetts. Coves, islands, and other deviations in the main
channel provided increased shoreline length, areas of lower water velocity,
and often provided a source of emergent vegetation.
3
Lay and O’Neil (1942) and Lay (1945) believed that water depth in Gulf of
Mexico coastal marshes should be maintained at depths of 2.0 to 30.0 cm (0.8
to 11.8 inches) year—round to provide the best muskrat habitat. Palmisano
(1967) recommended that the water level should be maintained near the marsh
surface and should not fall more than 8.0 cm (3.1 Inches) below the substrate
surface for optimum propagation of Olney bulrush. Bellrose (1950) reported
that muskrats frequently moved to marginal vegetation when water depth dropped
to unfavorable levels. Fluctuating water depths were found to be the critical
factor limiting muskrat populations in North Carolina coastal marshes (Wilson
1949). Water level fluctuations also prevented establishment of desirable
muskrat food plants in Louisiana (Moody 1950). Perry (1982), citing a study
by Wilson (1968), concluded that in general, Atlantic coastal marshes managed
with control structures can yield 3 to S times as many muskrats as undiked
marshes.
Cover
immediate vici
tion seldom
1963).
in the banks adjacent
build either type
wetland habitats.
all influence site
ts often build two
lodges or platforms
begins on a firm
available i the
MacArthur and Aleksiuk (1979) distinguished between dwelling and feeding
lodges primarily on the basis of external size. Feeding lodges are smaller
than dwelling lodges and vary considerably in construction. In summer, and
throughout the year in the South, feeding lodges are usually thin—walled and
may be simple platforms. They are thick—walled in winter to provide insula-
tion in the northern region of the muskrat’s range. Structures called push—ups
are made when muskrats chew through ice or snow and push a 30.0 to 45.0 cm
(11.8 to 17.7 inches) pile of vegetation onto the surface. Push—ups are
typically used as temporary feeding sites (Perry 1982). Other temporary
shelters include hollow logs, the dens of other animals, and overhanging banks
(MacArthur and Aleksiuk 1979).
In the absence of
shelter in bank burrows
in a California study: (1) breeding burrows composed of numerous entrance
tunnels and chambers; (2) winter burrows composed of one tunnel and chamber;
and (3) shallow, simple feeding burrows (Earhart 1969). Clay soils provide
the most suitable substrate for burrow construction (Errlngton 1937, 1963;
Beshears and Haugen 1953; Earhart 1969). Beshears and Haugen (1953) reported
that the amount of sand in the soil was inversely related to burrow longevity.
Embankments with soils containing more than 70 sand su pported only temporary
burrows in
California (Earhart 1969). Soils with a high sand content may
provide suitable burrowing sites if dense vegetation is present (Errington
Muskrats may construct conical lodges or dig burrows
to aquatic habitats (Willner et al. 1980). The ability to
of shelter enables the species to inhabit most types of
Water depth, soil texture, and the amount of vegetation
selection for lodge construction (Danell 1978). Muskra
types of lodges, a main dwelling lodge and smaller feeding
(Oozier 1947; Sather 1958). Lodge construction typically
substrate and is made up of the dominant emergent plants
al. 1980). Submergent vegeta—
lodge construction (Errington
nity of the lodge site (Willner et
provides suitable material for
n
sufficient emergent vegetation
(Dozier 1953). Three types of
muskrats may establish
burrows were identified
4
1937). Earhart (1969) believed that burrow construction required a bank slope
of 100 or more regardless of soil sand content. Gilfillan (1947) reported
that optimum conditions for bank burrows exist when the slope of the bank is
300
or more and a minimum height of 0.5 m (1.6 ft). Muskrat burrows were
absent in riverine habitats in
a Massachusetts and Pennsylvania study where
the bank height was less than 0.2 m (0.6 ft), bank slopes were less than 10,
or the bank composition was in excess of 90 sand and gravel (Brooks 1982).
1.6 km (89/mi), whereas,
sparse
produced 45 muskrats/1.6 km (45/mi) and 22 muskrats/1.6 km (22/mi), respec-
tively (Gilfillan 1947). Although the main channel may serve as a travel
avenue, large streams and rivers are generally unsuitable habitat if they are
subject to fluctuating water levels, or are highly turbid (Errington 1963).
In such conditions, muskrats may be common in oxbows, tributary streams or
wetlands adjacent to the main channel. The availability of cover and backwater
areas is strongly correlated with muskrat abundance in riverine habitats
(Brooks 1980). Evaluation of riverine muskrat habitat in Massachusetts and
Pennsylvania indicated that pools and backwater coves were inhabited by
muskrats 35 more often than their relative availability (Brooks 1982).
Shallow, steep gradient streams with high water velocity and rocky substrate
are poor muskrat habitat
)
believed to be the most
habitat quality in small
Dodge in prep.). High
coarse to fine
substrates compri
Intensive grazing of livestock has detrimental effects on muskrat density
due to decreased vegetative cover, increased bank erosion, and trampling of
burrow systems (Errington 1937). Muskrat harvest data from Iowa indicated
that more than twice as many animals were captured along streams with ungrazed
banks than were along streams with grazed banks (Gilfillan 1947).
Brackish marshes in coastal habitats appear to have the greatest potential
as muskrat habitat. Aerial surveys of Louisiana coastal marshes Indicated
that approximately 72 of the muskrat lodges counted were in brackish waters
although this habitat type occupied only 37 of the area surveyed (Palmisano
1972). Brackish marshes characterized as being comprised of cordgrass
(Spartina spp.), saltgrass (Distichlis spicata), needle rush (Juncus
roemerianus) and Olney bulrush were attributed to be the most productive
muskrat habitat in coastal Texas (Lay and O’Neil 1942). Slightly brackish
marshes, dominated by Olney bulrush and cattail, adjacent to wooded areas
supported the greatest muskrat production in Maryland coastal habitats (Dozier
et al. 1948).
High quality muskrat habitat along streams generally has an abundance of
retreats (e.g., downfall, lodged debris, deep pools, backwaters, undercut
banks) and is bordered by dense herbaceous vegetation (Errington 1937).
Muskrat burrows in Massachusetts and Pennsylvania riverine habitats were
established where dense herbaceous vegetation or littoral zone emergent vegeta-
tion was present (Brooks 1982). Ohio muskrat harvest data indicated that
streams bordered by agricultural crops produced an average of 89 muskrats/
those bordered by dense and
native vegetation
(Errlngton
1937
. Stream gradient and discharge were
influential characteristics in determination of muskrat
streams in Massachusetts and Pennsylvania (Brooks and
gradient streams were characterized as having rocky,
substrates as compared to low gradient streams that had
sed of fine to organic materials
5
Reproduction
The reproductive habitat requirements of the muskrat are assumed to be
identical with its water, food, and cover requirements as described above.
Interspersion
The area occupied by muskrats may be Influenced by a variety of factors
that include environmental conditions, the size, configuration and diversity
of the aquatic habitat, social pressures, and season (Perry 1982). Neal
(1968) believed that habitat quality was more Important in determining muskrat
density than were intraspecific interactions. Muskrat home ranges in Iowa
were consistently larger in aquatic habitats with less dense vegetation than
they were in habitats with dense emergent vegetation. Danell (1978) reported
that the mean distance between muskrat lodges was 110 m (360.8 ft) and no
houses were closer together than approximately 40 m (131.2 ft). Most summer
and fall home ranges of muskrats in Iowa were 45.7 to 60.9 m (150 to 200 ft)
in diameter (Neal 1968). More than 50 of muskrat obserMtions in Manitoba
were recorded within 15 m (49.2 ft) of the primary dwelling lodge (MacArthur
1978). Few movements of muskrats exceeded 150 m (492 ft) whereas almost all
foraging took place within 5 to 10 rn (16.4 to 32.8 ft) of the lodge. Most
muskrats recorded in a New Brunswick study remained in the same habitat type,
within a relatively confined area, throughout the summer and fall seasons
(Parker and Maxwell 1980). Movement between habitat types occurred most
frequently between the fall and spring seasons probably due to muskrats being
forced from winter lodges and burrows because of early spring increases in the
water level. Several authors have reported that the home range size for
bank—dwelling muskrats in riverine habitats ranges from 200 to 300 m (656 to
984 ft) along the stream or river channel (Errington 1963; Stewart and Bider
1974). Brooks (1982) estimated the home range for muskrats inhabiting riverine
habitats to range between 250 to 400 m (273 to 437 yds) In length. Muskrats
inhabiting edge or linear habitats may have oblong home ranges, whereas
inhabitants of interior portions of marshes may have home ranges that are more
circular in shape (Perry 1982).
O’Neil (1949) reported that high—quality coastal Olney bulrush marshes in
Louisiana could support about 13 muskrats/0.4 ha (13/acre), although densities
were occasionally much higher for short periods of time because of immigration.
Marshes managed for muskrat production also may have much higher densities
(Perry 1982). Considerable variation occurs, however, in muskrat density
between years. These “cycles” in northern inland marshes have been extensively
discussed by Errington (1951, 1954, 1963); however, their causes are not well
understood. Lowery (1974) summarized the stages In a cycle as low muskrat
numbers, development of an abundant food supply, followed by a rapid build—up
of muskrat density with eventual severe overpopulation, habitat destruction,
and, finally, starvation. The length of the cycle varies geographically, and
cycles may be out of phase within a region.
6
HABITAT SUITABILITY INDEX (HSI) MODELS
Model Applicability
Geographic area. The inland muskrat model has been developed for applica-
tion in freshwater habitats throughout the range of the species.
The estuarine model is applicable to Atlantic and Gulf of Mexico coastal
marshes (Fig. 1).
Figure 1. Geographic applicability of the estuarine muskrat HSI
model. The freshwater muskrat model is applicable to wetland and
riverine cover types throughout the range of the species.
Season. These models
quality of year—round habi
Since vegetation type and
models may be most effective
have been developed to evaluate the potential
tat in both freshwater and estuarine habitats.
density must be determined, application of the
during the growing season.
Cover types. The freshwater muskrat model was developed to evaluate
habitat quality in the following cover types (terminology follows that of U.S.
Fish and Wildlife Service 1981): H&rbaceous Wetland (HW); and Riverine (R).
The estuarine model Is applicable in the
estuarine intertidal (El) habitats as described
Emergent (EM); Aquatic Bed (AB); and Unconsolidated
following classes
by Cowardin et al.
Shore (US).
of the
(1979):
7
Minimum habitat area. Minimum habitat area is the minimum area of
contiguous habitat necessary before an area will be occupied by a species.
Information on the minimum habitat area for the muskrat was not found in the
literature. It is assumed that potential muskrat habitat will exist in any
freshwater or estuarine cover type large enough to be classified as such, If
adequate food, water stability, and cover are provided.
Verification level. The freshwater and estuarine muskrat HSI models
provide habitat information useful for impact assessment and habitat manage-
ment. The models are hypotheses of species—habitat relationships and do not
reflect proven cause and effect relationships.
The freshwater muskrat models were reviewed by: Dr. Robert Brooks,
Pennsylvania State Univeristy, University Park; Mr. Alfred Gardner, U.S. Fish
and Wildlife Service, National Museum of Natural History, Washington, DC;
Mr. John Organ, U.S. Fish and Wildlife Service, Newton Corner, Massachusetts;
Mr. Richard Stardom, Manitoba Department of Natural Resources, Winnipeg; and
Ms. Cathy Rewcastle, Manitoba Department of Natural Resources, Winnipeg.
Suggestions and comments for improvement were incorporated into the model.
An earlier version of the herbaceous wetlands muskrat model was evaluated
by Dr. Jonathan Bart, Ohio Cooperative Wildlife Research Unit, Ohio State
University (Bart et al. 1984). HSI values were compared to 1 year’s estimates
of muskrat house density on 25 sites in northwest Ohio. The minimum amount of
persistent emergent vegetation present on any site was 30.6 and all but three
sites had greater than 40 emergent vegetation canopy cover. Measuring the
degree of linear relationship between muskrat lodge density and HSI’s yielded
a correlation coefficient of 0.441.
The estuarine model has been reviewed by: Mr. Greg Linscombe, Louisiana
Department of Wildlife •and Fisheries, New Iberia, LA; Dr. R. Chabreck,
Louisiana State University, School of Forestry and Wildlife, Baton Rouge;
Mr. Thomas Thornhlll, U.S. Fish and Wildlife Service, Daphne, AL; and
Dr. Thomas Michot, U.S. Fish and Wildlife Service, Lafayette, LA. The comments
and suggestions of these Individuals have been incorporated into this model.
An earlier version of the model was evaluated in coastal Loul?iana marshes
using the 3—year average pelt take as an indication of habitat suitability.
Subsequent revisions in the model were based on the results of this field
evaluation.
Model Description
Freshwater. Year—round habitat requirements of the muskrat can be ful-
filled within wetland habitats that provide herbaceous vegetation and permanent
surface water with minor fluctuations in water levels. Wetlands characterized
by seasonal drying, an absence of emergent vegetation, or both, have less
potential as year—round muskrat habitat than wetlands with permanent water and
an abundance of emergent vegetation. It is assumed that food and cover are
interdependent characteristics of the muskrat’s habitat and that measures of
vegetative abundance and water permanence within a wetland can be aggregated
8
to reflect habitat conditions favoring maintenance of the muskrat’s food and
cover requirements. The reproductive habitat requirements of the species are
assumed to be met when adequate water, food, and cover conditions are present.
Estuarine. The estuarine muskrat model describes and defines the
variables affecting habitat suitability in coastal (brackish and salt water)
wetlands. The model consists of a single component that reflects the potential
quality of food and cover. In order to provide potentially suitable year—round
habitat for muskrats, coastal marshes must support relatively stable water
levels and the water must be of sufficient chemical composition to support an
adequate food source. Prior to applying the following estuarine muskrat
model, the following factors must be considered to determine if the model
is applicable to the habitat being evaluated.
If marsh water level fluctuates more
than 90.0 cm (35.4 inches) per year
or below the marsh substrate during
summer or winter, or water salinity
exceeds 30 ppt for more than one week
Do not continue
with model; HSI
for muskrats is
assumed to be 0.0.
If marsh water level is relatively
stable, does not fluctuate 90.0 cm
(35.4 inches) per year or below marsh
surface in summer or winter, and water
salinity does not exceed 30 ppt for
more than one week
Continue with model
application to deter-
mine a HSI value.
The following sections provide documentation of the logic and assumptions
used to translate habitat information for the muskrat into the variables and
equations used in the HSI models. Specifically, these sections cover:
(1) identification of variables; (2) definition and justification of the
suitability levels of each variable; and (3) description of the assumed rela-
tionships between variables. Figure 2 is an illustration of the relationships
of habitat variables, life requisites, and cover types to a habitat suitability
value for the muskrat in freshwater habitats. Figure 3 is an illustration of
the relationships of habitat variables, life requisites, and cover types to a
habitat value for the muskrat in estuarine habitats.
9
Habitat
variable
Lire
requisite
Cover
types
Percent
canopy
cover
of
emergent
herbaceous
vegetation
_______________________
Uerbaceous
Wetland
Percent
of
year
with
surrace
wate
present
herbaceous
vegetation
Food
Herbaceous
Wetland~
Percent
canopy
cover
or
emergent
—
Percent
or
emergent
herbaceous
o
vegetation
consisting
of
olney
bulrush,
common
three—square
bulrush,
or
cattail
Percent
of
year
with
surrace
Water
present
Percent
stream
gradient
Percent
or
riverine
chan~thC0v~
River
i
ne
surrace
water
present
during
typical
minimum
flow
Percent
herbaceous
canopy
c~
Food
Ruverine~
HSI
Percent
or
riverine
channel
dominated
by
emergent
herbaceous
vegetation
within
10
m
(32.5
ft)
of
water’s
edge
Figure
2.
Relationships
of
habitat
variables,
cover
types,
and
life
requisites
in
the
freshwater
muskrat
model.
Habitat
variable
Life
requisite
Cover
types
Percent
canopy
Cover
of
emergent
herbaceous
vegetatIon
Percent
of
emergent
herbaceous
vegetation
consisting
of
persistent
i
fe
form
species
Percent
of
emergent
herbaceous
vegetation
consisting
of
Olney
bulrush,
common
three-square
bulrush,
or
cattail
Percent
of
open
water
supporting
submerged
or
floating
aquatic
vegetation
Figure
3.
Relationships
of
habitat
variables,
cover
types,
and
life
requisites
in
the
Food/Cover
Estuarine
KS
I
estuarine
muskrat
model.
Cover component: freshwater. Suitable cover for muskrats in wetland
cover types is a function of the presence and abundance of emergent vegetation
suitable for lodge construction and the permanence of water within the wetland
basin. Persistent emergent vegetation, such as cattail, normally remains
standing throughout the winter months as compared to nonpersistent emergent
vegetation whose leaves and stems break down at the end of the growing season
(Cowardin et al. 1979). Although both types of emergent vegetation may provide
food and cover for muskrats during the growing season, nonpersistent vegetation
will not provide optimum lodge construction materials. Woody vegetation in
shrub or forested wetlands may provide some cover and physical support for
lodge construction. However, it is assumed that emergent vegetation also must
be present in these cover types to provide suitable cover and material for
lodge construction. If emergent vegetation is absent in these cover types,
the cover is assumed to be minimal regardless of the amount of woody vegetation
present. It is assumed that optimum cover conditions are present when 50 to
80 of a wetland basin is dominated by emergent vegetation. Canopy cover of
emergent vegetation below 50 is assumed to reflect less suitable cover for
muskrats. Muskrats may establish bank burrows and are not totally dependent
upon the availability of vegetation for lodge construction, therefore, wetlands
devoid of emergent vegetation are assumed to have minimal value as muskrat
habitat. As the density of emergent vegetation increases above 80, it is
assumed that habitat quality will decrease slightly due to a reduction in
escape cover that is provided by open water. Muskrats inhabiting riverine
areas establish burrows within river and stream banks and are less dependent
upon emergent vegetation for providing adequate cover.
Water permanence is an important characteristic that defines muskrat
habitat potential and is assumed to be equally as important as the presence
and abundance of emergent vegetation in defining the quality of muskrat
habitat. Wetlands that provide permanent year—round surface water are assumed
to provide potentially optimum habitat conditions for muskrats. Conversely,
wetlands that contain water on a seasonal basis are assumed to have little, if
any, potential for meeting the year—round cover requirements of the species.
Major changes in water level, either drawdown or flooding, will result in
habitat deprivation for the species. Wetlands with water present for 75 of
the year (9 months) or less are assumed to be less suitable muskrat habitat,
regardless of the amount of persistent emergent vegetation present. Wetlands
with water present for 50 of the year (6 months) or less are assumed to be
unsuitable year—round muskrat habitat.
Within riverine cover types muskrats require permanent water of low
velocity for optimum cover conditions. The cover potential of muskrat habitat
in riverine cover types is assumed to be a function of the permanence of
surface water and stream gradient. A measure of actual water velocity may
yield a more precise indication of riverine habitat quality. However, due to
the potential variability in water velocity a measure of velocity at one point
in time may yield a relatively inaccurate estimate of habitat conditions when
considered on an annual basis. F,or the purposes of this model, water velocity
is assumed to be a function of stream gradient. Low gradient streams are
assumed to have greater potential as muskrat habitat than high gradient
streams. High water velocity, rocky substrate, low pool/riffle ratio, and
less cover immediately adjacent to the water’s edge are typically associated
12
with high gradient
characterized as
sediments, high
ratio,
banks, debris and vegetation in and
It is assumed in this model that
10 rn/km (53 ft/mi) or less will be indicative
conditions for the muskrat by providing water of
able for the establishment of burrow systems.
(211 ft/mi) or greater is assumed to be md
habitat. Brooks (pers. comm.) cautioned that
inaccurate indication of muskrat habitat qual
distances 1.0 km (0.6 mi). The presence of
incorrect estimate of habitat quality when long
of potentially optimum cover
low velocity and banks suit—
A gradient of 4 40 m/km
icative of marginal muskrat
stream gradient may give an
ity when applied over long
a dam or rapids may yield an
stream reaches are evaluated.
pid may result
tat potential,
may be of low
itat. Brooks
conditions by
used on an
Riverine cover types must provide permanent surface water for ideal
muskrat habitat. However, the amount of surface water present also has an
influence on habitat potential for the species. The amount of suitable muskrat
habitat in riverine cover types is probably no greater than the amount of
surface water present during minimum flow periods. Riverine cover types with
relatively stable discharge have greater habitat potential than do those that
have widely fluctuating flows. Intermittent streams probably have little, if
any, year—round habitat potential for muskrats due to a seasonal absence of
water in the channel. Riverine habitats that maintain minimum flows and/or
isolated pools during low flow periods are of minimum value as muskrat habitat.
Depending upon their size and depth, isolated pools may provide adequate
habitat during low flow periods from which muskrats may disperse during higher
flow periods. Therefore, in riverine habitats, the cover potential for
muskrats is assumed to be a function of the percent of the riverine channel
with surface water during minimum discharge periods.
Food component: freshwater. The major component of the muskrat’s diet
is herbaceous vegetation. High—density muskrat populations are typically
associated with wetland habitats that support dense stands of emergent vegeta-
tion. Cattail has often been identified as a preferred food in fresh water
wetlands, and is believed to be capable of supporting higher numbers of
muskrats than other types of emergent vegetation. Nonpersistent vegetation,
submerged aquatic vegetation, and terrestrial herbaceous vegetation also are
consumed by muskrats. However, it is assumed that the stems, leaves, and
rhizomes of emergent vegetation are the primary components of the muskrat’s
annual diet. Within wetland cover types food quality is assumed to be related
to the total amount of emergent vegetation present and the proportion of that
vegetation that consists of cattail.
streams (Reid 1961). In contrast, low gradient streams are
having low water velocity, substrates consisting of finer
pool/riffle
and more cover in the form of undercut
immediately adjacent to the water’s edge.
riverine reaches with a gradient of 1
For example, evaluation of a stream reach containing a large ra
in a relatively high gradient value, indicating low muskrat habi
even though the stream channel both above and below the rapid
gradient and represent potentially high quality muskrat hab
(pers. comm.) suggested that the evaluation of riverine habitat
Stream Order (Horton 1945) may be a more accurate method when
individual watershed.
13
Emergent vegetation, persistent or nonpersistent, is assumed to be most
suitable as a potential food source when present at a density of 50 to 80
canopy closure. Canopy coverage less than 50 or greater than 80 is assumed
to be indicative of less suitable food quality. Food quality is assumed to be
positively correlated to the amount of cattail making up the total amount of
emergent vegetation present. Stands of emergent vegetation consisting wholly
of cattail will be of maximum value as a muskrat food source. Stands of
emergent vegetation other than cattail are assumed to be of lower value as a
potential food source even though total density may be within the optimum
range. Wetlands with a density of emergent vegetation In excess of 80 are
assumed to have a lower potential as a diverse year—round food source for
muskrats due to a decreased availability of submergent vegetation resulting
from a reduction in open water. Inasmuch as muskrats will forage on submerged
aquatic and terrestrial herbaceous vegetation, wetlands devoid of emergent
herbaceous vegetation are assumed to have minimum potential for providing
muskrat food. However, not all wetlands are suitable muskrat habitat. For
example, alkaline wetlands (pH
?
7.4) probably have no potential as muskrat
habitat.
Muskrats inhabiting riverine habitats obtain most of their food from
terrestrial vegetation adjacent to the stream channel. Emergent vegetation
may be an adequate food source If present; however, the absence of such vegeta-
tion will not limit the potential food value if terrestrial herbaceous vegeta-
tion is present in an adequate amount. Due to the muskrat’s relatively small
home range size, it is assumed that density of herbaceous vegetation within
10 m (32.8 ft) of the water’s edge will indicate potential food availability.
The value of terrestrial herbaceous vegetation as a potential muskrat food
source is assumed to be positively related to density. Stream channels
bordered by trees and/or shrubs will probably have less dense herbaceous
ground cover than would channels bordered by open ground or cropland. Emergent
vegetation is an additional food source in riverine habitats that probably
contributes to a more stable food supply when considered on an annual basis.
The abundance of emergent vegetation is assumed to be twice as important as
the presence and abundance of terrestrial herbaceous vegetation in determining
potential year—round values of food resources for muskrats in riverine
habitats.
Food/cover component: estuarine. Emergent vegetation provides food and
cover for muskrats. The estuarine model does not attempt to separate these
functions. Fifty to 80 canopy coverage of emergent herbaceous vegetation is
assumed to be characteristic of optimum muskrat habitat in estuarine habitats.
Although muskrats will create small amounts of open water in dense stands of
emergent vegetation as a result of their feeding and lodge construction activ-
ities, estuarine habitats with a density of emergent vegetation in excess of
80 are assumed to be of slightly lower habitat potential due to a decreased
availability of escape cover provided by open water. Estuarine habitats with
no emergent vegetation are assumed to have almost no potential as muskrat
habitat. However, because dikes or shoreline habitats may provide sites for
bank burrows and submerged and floating aquatic vegetation may provide a
limited food source, the complete absence of emergent herbaceous vegetation is
assumed to represent estuarine habitats with minimum muskrat habitat potential.
14
Persistent emergent herbaceous vegetation is believed to be of greater value
for providing food and cover for the muskrat than is nonpersistent emergent
vegetation. Therefore, the suitability of muskrat habitat is assumed to
increase as the proportion of emergent vegetation consisting of persistent
life form species increases. However, the estuarine muskrat model is based on
the assumption that a marsh with no persistent emergent vegetation does have a
low value as muskrat habitat. Although there is no evidence that muskrats
exhibit a preference among emergent vegetation used as lodge construction
materials, coastal muskrats do prefer bulrush (Olney and common three—square)
and cattails as food items. It is assumed that an 80 to 100 occurrence of
these preferred species represents optimum food and cover conditions in
estuarine wetlands. However, these species are not required by muskrats and
wetlands with a 0 to 10 occurrence of bulrush and cattails are assumed to
retain a low value as muskrat habitat. Muskrats also feed on submerged and
floating—leafed aquatic vegetation and use these forms of vegetation in lodge
construction to a limited degree. It is assumed that the value of open water
habitat increases as the percentage of the habitat that supports submerged and
floating vegetation increases. The absence of submerged or floating aquatic
vegetation in a mixed open water/emergent marsh is assumed not to preclude
muskrat use of the area.
Model Relationships
Suitability Index (SI) graphs for habitat variables. The relationships
between various values of habitat variables and habitat suitability for the
muskrat are graphically presented in this section.
Cover
‘C
0)
0
C
I
type
Variable
HW,
El
V1
Percent canopy cover
of emergent
herbaceous
vegetation.
1.0
0.8
0.6
0.4
0.2
0.0
0
25
50
75 100
15
HW
V2
R
Vi
R
VI.
Percent of year with
surface water present.
Percent stream gradient.
Percent of riverine
channel with surface
water present during
typical minimum flow.
1.0
‘C
a)
-e
C
;o.6
~1~
~0A
~ 0.2
tO
0.0
0
25
50
75 100
1.0
0.8
‘C
a)
~0
C
0.6
.0
(U
4.)
0.4
c~)
0.0
‘C
a)
~0
C
~-4
I
1.0
0.8
0.6
0.4
0.2
0.0
0
25
50
75
100
16
R
Percent riverine channel
dominated by emergent
herbaceous vegetation.
V6
Percent herbaceous
canopy cover within
10 m (32.8 it) of
water’s edge.
V7
Percent of emergent
herbaceous vegeta-
tion consisting of
persistent life form
species.
17
ho
)C08
0)
0
.0
0.4
(U
4-,
to
0.2
0.0
0
25
50
75
100
1.0
0.8
‘C
0)
-4
C
R
El
•1~
I-
•1~
.0
(U
4-)
c-fl
0.0
0
25
50
75
100
1.0
~0.8
0
25
50
75
100
V3
Percent of emergent
herbaceous vegetation
consisting of Olney
bulrush, common three—
square bulrush, or
cattail.
V9
Percent of open water
supporting submerged
or floating aquatic
vegetation.
0.4
Equations. In order to obtain life requisite values for the muskrat, the
SI values for appropriate variables must be combined through the use of equa-
tions. A discussion and explanation of the assumed relationships between
variables for freshwater and estuarine habitats was included under Model
Description. The suggested equations for obtaining life requisite and HSI
values are presented in Figure 4.
HW,
El
1.0
El
‘C
a)
-
0
C
;0.6
I-
.0
(U
4~)
9-
to
0.0
0.4
0.2
1.0
‘C
0)
0.8
C
-4
-,
0.6
4-,
I-
.0
(U
44
~0.2
0.0
0
25
50
75
100
18
Life requisite
Cover type
Equation
CoverCoverFood
HWR11W
(V2 x(V(VV311
xxx
2VVV234)))111”””223
+
V5
~I + 9l~\i \*
Food
R
Y6
~\V5/
2
*In instances where
a value greater than
1.0 is obtained, the
value should be con-
sidered to equal 1.0.
Cover/Food
El
(V1 xV, x V,2)l/4 x (a)
+
V9 x
where:
a
=
the percent of the
total estuarine
habitat being eval-
uated that supports
10 emergent vegeta-
tion canopy cover
b
=
the percent of the
total estuarine habitat
being evaluated that
supports ? 10 emer-
gent vegetation canopy
cover
**See Application of the
Model section for specific
instructions for the cal-
culation of this value.
Figure 4. Equations for determining life requisite values by
cover type for the muskrat.
19
HSI determination. The HSI value in freshwater herbaceous wetlands and
riverine cover types is computed by assuming a limiting factor mechanism. The
HSI will equal the lowest life requisite value received for either cover or
food in either cover type. The HSI value in estuarine cover types is equal to
the cover/food life requisite value.
Application of the Model
Calculation of the food/cover life requisite for estuarine muskrat habitat
is a function of: (1) the quality of emergent vegetation (V1, V7. V,); (2) the
area dominated by emergent vegetation ( 10 canopy closure); (3) the percent-
age of the evaluation area in open water (? 10 canopy closure of emergent
vegetation); and (4) the amount of floating or submerged aquatic vegetation in
open water areas (V9). A weighted (weighted by area) food/cover value is
calculated by performing the following steps:
1. Stratify the estuarine habitat into areas dominated by emergent
vegetation and open water.
2. Determine the area dominated by emergent vegetation, area dominated
by open water, and total estuarine area.
3. Determine an SI value for the area dominated by emergent vegetation
(V1 x V7 x
~,2)l”4
and an SI value for the area dominated by open
water (V,).
4. Multiply the area dominated by emergent vegetation and the area
dominated by open water by their respective SI values (Step 3).
5. Add the products calculated in step 4 and divide the sum by the
total area of the estuarine habitat to obtain the weighted food/cover
life requisite value.
Definitions of variables and suggested field measurement techniques (Hays
et al. 1981) are provided in Figure 5.
20
Variable (definition)
Cover types
Suggested technique
V1
Percent canopy cover
HW,EI
Remote sensing, line
of emergent herbaceous
intercept
vegetation (the percent
of the water surface
shaded
by a vertical
projection of the
canopies of all
emergent herbaceous
vegetation, both
persistent and non-
persistent).
V2
Percent of year with
NW
Remote sensing, local
surface water present
data
(the proportion of
the year in which the
cover type has surface
water present).
V,
Percent stream gradient
R
Topographic map
(specific expression of
decrease in elevation
of a stream or river
bed; determined by
dividing the change
in elevation between
two points of the
riverine reach by
the horizontal distance
between those two points,
then multiplying the
product by 100).
V4 Percent of riverine
R
Remote sensing, line
channel with surface
intercept
water present during
typical minimum flow
(the proportion of the
riverine
channel covered
by
surface water during
the lowest discharge.in
the driest period of the
year).
Figure 5. Definitions of variables and suggested measurement
techniques for the freshwater and estuarine muskrat model.
21
Variable (definition)
Cover types
Suggested technique
V5
Percent of riverine
channel
R
Remote sensing, line
dominated by persistent
intercept
emergent vegetation the
percent of the stream or
river channel’s bed
that supports emergent
vegetation that normally
remains standing after the
growing season e.g., cat-
tail (Typha spp-) or bulrush
(Scirpus sppj.
V6
Percent herbaceous canopy
R
Line intercept,
cover within 10 m (32.8 ft)
quadrat
of water’s edge (the percent
of the ground surface within
10
m of the edge of the river—
me cover type which is shaded
by
a vertical projection of all
nonwoody vegetation).
V.,
Percent of emergent herba—
El
Remote sensing, line
ceous vegetation consisting
intercept
of persistent life form
species the proportion of
the emergent herbaceous
vegetation that normally
remains standing after
the growing season (e.g.,
cattail or bulrush).
V,
Percent of emergent herba—
HW,EI
Remote sensing, line
ceous vegetation (both per—
intercept, quadrat
sistent and nonpersistent)
consisting of Olney bulrush,
common three—square bulrush,
or cattail.
V9
Percent of open water
El
Remote sensing, line
supporting submerged
intercept, quadrat
or floating aquatic
vegetation.
Figure 5. (concluded).
22
SOURCES OF OTHER MODELS
Brooks
(1980) and Brooks and
using principle component regression
habitats. The model can be used to
and rank watersheds with respect
information gathered from remote sensing
physiognomic features of potential muskrat
tics and local population attributes are
sance. The model is not recommended for
forests, riparian habitats in arid regions,
data are used to identify gross
habitat. Microhabitat characteris—
investigated by on—site reconnais—
application in northern coniferous
or tropical climates.
No other habitat model designed for
habitat was located in the literature.
the evaluation
of coastal muskrat
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______________
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_______________
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______________
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____________
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______________
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____________
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_____________
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24
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25
_____________
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26
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_________
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,
Louisiana State Univ., Baton Rouge.
27
50212
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FWS/OBS-82/1O.46
3.
R.cipi..irs Acteeaaen Mo.
s.
rue and Subtltl•
Habitat Suitability Index Models: Muskrat
s.
~.oen Date
June 1984
y.
&~,mrsj
Arthur W. Allen and Robert 0. Hoffman
5.
r.a...
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Habitat Evaluation Procedures Group
Ohio Cooperative Wildlife
Western Energy and Land Use Team
Research Unit
U.S. Fish and Wildlife Service
1725 Neil Avenue,
Creekside One Building
Ohio State University
2527 Redwing Road
Columbus,_OH__43120
Fort_Collins,_CO__80526-2899
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P,Wsfl.sR/w.n, Unat No.
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western Energy and Land Use learn
Division of Biological Services
Research and Development
Fish and Wildlife Service
U.S. Department of the Interior
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Abstract
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Habitat preferences of the muskrat (Ondatra zibethicus) are described in this report,
which is one of a series of Habitat Suitability Index (HSI) models. A review and
synthesis of the literature is followed by development of estuarine and freshwater
habitat models incorporating life requisites of the muskrat. HSI models are designed
for use with Habitat Evaluation Procedures previously developed by the U.S. Fish and
Wildlife Service.
17. Oocuen.at Afl.i~,s
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Mathematical models
Wildlife
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US GOVERNMENT PRINTING OCFICE: 1964—760-540.9426 REGION NO 8
DEPARTMENT OF THE INTERIOR
U.S. FISH AND WILDLIFE SERVICE
As the Nation’s
principal
conservation agency, the
Department
of the Interior has respon~
sibility for most of our.natlonally owned public lands and natural resources. This includes
fostering the wisest
usa
of our land and water resources, protecting our fish and wildlife,
preserving thaenvlronmental and cultural values of our national parks and hIstorical places,
and providing for the enjoyment of life through outdoor recreation. The
Department
as
sesses our energy and mineral resources and
works
to assure that their development is in
the best interests of all our people. The Department also has a major responsibility for
American Indian reservation communities and for people who live in Island territories under
U.S. administration.
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Exhibit 3
ASSOCIATES
STRAND
INO~
ENGINEERS
1170
South Houbolt
Road
August 1,2005
Joliel, IL 60431
Phone: 815-744-4200
Fax: 815-744-4215
Mr. Dennis Duffield, PB., Director ofPublic Works and Utilities
Strand Associates,
Inc.
City ofJoliet
Madison,
w
921 East Washington Street
Lot~sviHe,KY
Joliet,
IL 60433
Lexington, KY
Indianapolis, IN
Re:
Cost Analysis:
WRT
vs. FIMO
Division Offices
SIECO
Columbus, N
Dear Dennis,
Lancaster, OH
Mobile, AL
At your request, we have performed a preliminary cost analysis comparing construction
and operating costs over time for two radium-removal technology approaches. Results of
the analysis are sumnarized below. Spreadsheets and graphs demonstrating analysis
www.slrand.com
results are attached to this letter report.
Conclusion
Removing radium via the Water Remediation Technology LLC (WRT) process is
estimated to cost up to $33 million more than the hydrous manganese oxide (HMO)
process over a 20•year period, under the various conditions analyzed. That cost
differential rises to as great as
$45
million using an extended, 30-year period of
evaluation.
Should regulatory restrictions on radium-containing treatment wastes be enforced, the
City may wish to convert from an HMO treatment process to an alternative treatment.
Analysis of conversion from FIMO to a radium•selective media (RSM) treatment
indicates that installation and operation of a convertible HMOIRSM process would be
more costly than use of the WRT process
if
conversion occurs within the first five years
of operation and no additional WRT fees are imposed. WRT is likely to be more costly
than the HMO/RSM option when conversion occurs after the sixth year, under the most
likely sets ofconditions.
Background
The three technologies considered for use in Joliet that are examined in this cost analysis
are radium-selective media provided by WRT, coprecipitation of radium with
manganese
removal using HMOs, and radium removal using a Dowex RSM system. All
three
technologies were demonstrated to be effective in removing radium from Joliet’s
wells during a pilot test performed between June 3, 2004, and July 15, 2004. The HMO
system and Dowex media generally removed greater than 90 percent of radium from
treated water, while the WRT system removed nearly 98 percent of combined Radium-
226 and Radium-228. All three technologies removed radium to levels significantly
better than the minimum level desired for effective treatment ofJoliet water.
Dennis Duffield, P.R
STRAND
ASSOC?ATES INC.’
City
ofJoliet
Page 2
August 1, 2005
In analyzing the overall cost of each technology, consideration was given to the
following factors:
1.
HMO filtration also will remove the iron produced by the City’s shallow wells.
WRT and RSM treatment will not. Thus, an iron removal facility will be required
if an East Side WRT radium removal facility is constructed to treat the combined
shallow wells. Likewise, if HMO filtration is converted to RSM, an upstream
iron removal facility would be necessary to treat the combined shallow wells.
2.
Radon regulations have not been finalized. Currently, it appears that the
minimum contaminant level (MCL) standard for radon in Illinois will be 300
pCi/L. Nathrally occuthng radon levels in untreated Joliet water have been
measured between 110 pCi/L and 180 pCi/L. WRT media captures and holds
radium, which naturally decays to radon. Radon emissions would be expected to
increase as the WRT media ages, unless WRT also holds radon. If radon
emissions from radium-laden WRT media are found to be a problem for treated
water, intermediate aeration, storage, and booster pumping will be necessary.
This same condition may occur if RSM technology is used.
Preliminary investigation into the likelihood of radon accumulation from WRT
treatment is under way. Figure 1 shows the results of radon testing on samples
taken during an extended pilot study of WRT technology downstream of the
WRT system at Joliet Well 9-D, as well as on raw-water samples drawn from
Well 9-D during the same time period. Also shown in the figure are linear-fit
trendlines for the sample data from each source. The trendlines indicate that
radon concentrations would be expected to increase with time for both WRT and
raw water supplies, while experience indicates that radon concentrations should
remain relatively level with time for the raw water.
APW:pIT\S;\~SAJ\25I-.3OO\255\3O3\Wrd\cosIanalysis IetterMGO reylsiondoc
a
STRAND
ASSOCIATES. INC.
E N
G
IN E E fl~
S
Dennis Duffield, P.E.
City ofJoliet
Page 3
August 1, 2005
A linear projection of the data for both sample streams places radon levels at
approximately
265
pci/L for WRT and 185 pCi/L for raw water afler
365
days of
operation. Statistical analysis of the data suggests that a linear correlation
between radon concentration and time is somewhat likely for the WRT data but
less likely for the raw water data. This would indicate that there is limited
confidence in projections using raw water data to a 1-year timeframe, and
slightly more confidence in projections using WRT-treated water data. Should
the linear projections be accurate, the statistical analysis indicates that WRT-
treated water would not contain radon concentrations in excess ofthe anticipated
standard for Illinois if the WRT media is replaced annually. It should be noted,
however, that it is possible radon concentrations would increase nonlinearly with
time. We therefore present a cost-analysis scenario that incorporates radon-
removal treatment, with the understanding that such measures may or may not
become necessary when using WRT and RSM technologies.
A?W~pll\S:\~SAl\25I--3OO\255\3O3\Wrd\costanalysis Ietter.MGO ,tvision.doc
Dennis Duffield, P.E.
STRAND
ASSOCIATES,
INC’
City
of Joliet
I NEE
Page 4
August 1, 2005
3.
HMO filtration has been demonstrated to be effective in several full-scale
operating plants, while the WRT process has just recently started full-scale
operation in one Illinois community. As a result, information on operating issues
and costs associated with the HMO process is available from field operations, but
such information is not available for the WRT process. All costs and potential
operating issues associated with WRT can be derived only from observations of
pilot operation and from WRT representatives.
4.
The draft WRT agreement is nearly 70 pages long and includes numerous clauses
for increasing payment for WRT treatment. The cost impact of several of these
clauses is impossible to evaluate since we cannot predict potential future
regulatory or physical-change impacts on such fees. Future media-disposal
charges or changes in water quality conditions, for example, cannot be
anticipated. For the purpose of this analysis, it is assumed that all base conditions
remain constant for the duration of the period under consideration. Actual annual
charges required by WRT under its agreement could be significantly greater than
reported here, should these conditions change with time. Additionally, the Illinois
Department of Nuclear Safety reportedly has indicated to communities with
WRT facilities under construction that a reserve find will be required in case
WRT is unable to maintain facility operations over time. The magnitude
of
the
reserve fund caimot be determined at present, and is not accounted for in this
analysis.
5.
WRT has not yet provided information as to how construction of additional wells
would be incorporated into the radium-removal agreement. It is assumed for the
purposes of this analysis that no new wells are added during the 20-year period
under consideration.
6.
Potential changes in regulation ofradium in the waste stream could force the City
of Joliet to seek an alternative tecimology to HMO in the near future.
Consideration is given in this analysis to the possibility that an HMO facility may
require conversion to a radium-selective system that would not release significant
radium into the waste stream during backwashing. For the purposes of this
analysis, HMO facilities are designed for conversion to RSM. Additional
modifications, including an East Side iron filtration plant and, potentially, radon-
removal equipment, would be constructed upon conversion from 1-IMO to RSM.
APW:pII\S:\@SAI~25I.-3OO\255UO3\Wrd\costanalysis ktler.MGO rev~siott.doc
Dennis Duffield, P.E.
STRAND
ASSOCIATES. NC.
City ofJoliet
ENGINEERS
Page5
August 1, 2005
Analysis Conditions
Three likely demand scenarios were developed to evaluate costs using the WRT and
HMO systems.
1.
Scenario A used a
flat,
average day water demand of 14.9 mgd, as determined in
the November 2003 Joliet
Radium Compliance and Water Supply Improvements
report. Figure 2 shows the Scenario A demand projection through 2024.
16
14
12
-~------~---
________
-
10
__________
B
6
4
-
__________
_____
2
0
2000
2005
2010
2015
2020
2025
2030
Figure 2 Projected Average-Day Water Demand Scenario A
APW:pIl\S:V~SAl\2Sl..400\255\303\Wrd\cost analysis
ietter.MGO
revisiondoc
Dennis Duffield, P.E.
STRAND
ASSOCIATES. N0’
City
of Joliet
EN
GI
NE E A S
Page 6
August 1,2005
2.
Scenario B used a linearly increasing water demand based upon a 2006 average
day estimate of 14.9 mgd and a 2023 average day demand estimate of 20.1 mgd,
as generated by the November 2003 report. Figure 3 shows the Scenario B
demand projection.
25
10
5
0
2000
2005
2010
2015
2020
2025
2030
Figure 3 Projected Average-Day Water Demand Scenario B
3.
Scenario C used a randomly varying annual average day water demand, using
water system fluctuations of typical magnitude as determined by a review of
water-use data for similarly sized communities. The overall increase in water
demand between 2005 and 2025 statistically mirrors the linearly increasing
demand of Scenario B with time. Figure 4 shows the Scenario C demand
projection.
2000
2005
2010
2015
2020
2025
2030
Figure 4 Projected Average-Day Water Demand Scenario C
APW:pI!\S:\®SAI\251..300\255\303\Wrd\cost
analysis IetterMGO rnision.doc
~0
STRAND
ASSOCIATES.
‘Na
ENGINEERS
Dennis Duffield, P.E.
City of Joliet
Page 7
August 1,2005
Inflation projections were generated using Consumer Price Indices between 1980 and
2004. Future CPI values were generated by projecting increase trends linearly to the year
2025. Figure 5 depicts the actual CPI values, as well as the Linear trend line projecting
future CPI values.
Capital costs were determined using previously generated opinions ofprobable cost for
construction ofsix 1,000 gpm facilities, two 2,000 gpm facilities, one 4,000 gpm facility
and one 6,000 gpm facility. Construction costs for the WRT option included only the
buildings that would house WRT equipment. Construction costs for the HMO option
included both the building and HMO/filtration equipment (an alternative evaluation
incorporating conversion to RSM treatment is provided below and is not included here).
Because of the need for iron filtration at the Fairmont/Garvin facility, an additional
capital expendithre for construction of a filter facility was included in the WRT
construction costs. Total construction costs for each option were amortized over a period
of 20 years at 4 percent interest to determine annual expenditure. Table I shows the
calculation ofconstruction costs for both WRT and HMO processes.
Operating cost components for each option differ significantly. Primary components of
the WRT operating costs, as incorporated into Condition Set No. I, include annual
contractual treatment charges, additional volume charges, and costs associated with
backwashing the iron removal filters at FairmontlGarvin. An additional expense is
included in Condition Set No. 2 for removal of excessive radon
in
the treated water, as
discussed above. Condition Set No. 3 provides an alternative scenario in which it is
assumed spent media must be disposed of in an alternate site at a higher cost that equals
the value proposed in current WRT agreements with other Illinois communities. The
300
250
200
5
150
100
50
0
Figure 5 Projection of Consumer Price Index Through the Year 2025
1980
1985
1990
1995
2000
2005
Year
2010 2015
2020
2025 2030
APW:pH\S:\~SAI\25!--3OO\255UO3\Wrd\costanalysis Ietter.MGO mvision.doc
Dennis Duffield, P.E.
STRAND
ASSOCIATES INU!
City ofJoliet
ENGINEERS
PageS
August 1, 2005
alternate site and cost, based on information provided by WRT, is more than double the
cost of media disposal incorporated into the proposed Joliet agreement. This third
condition set also includes costs for removal of excessive radon and, with the other two
scenarios, generates a likely range ofannual costs resulting from WRT treatment.
Potential charges and fees not included in any of the scenarios include new taxes or
government fees for disposal, fees resulting from water quality change other than radium
that affects media life, potential state-required reserve funds to support removal
technology, and additional fees resulting from an increase in source-water radium
content. For the purposes of this analysis, it is assumed that disposal charges, regulatory
fees, and taxes do not increase beyond the rate of inflation and that water quality (both
radium and nonradium) remains constant throughout the life of the term.
Components ofthe 1-IMO operating charges consist of chemical costs, costs associated
with backwashing the co-filtration vessels, and excess labor costs to maintain HMO
operations. Chemical costs were determined based upon chemical use at facilities where
full-scale HMO treatment is operational. No economy ofchemical costs because ofbulk
volume is assumed for the purpose ofthis analysis.
Table 2 shows a list of calculation values used to determine operating expenses for
HMO and WRT treatment processes. The same values were used for both processes
when comparable operating costs were generated (for example, backwash water costs
for the FairmontlGarvin iron filtration plant using WRT and
for all pressures filters using
HMO).
Process
Unit
Value
hon Filter Backwash Costs
Dollars/1000 gallons
$0.50
Labor
Hours/mgd/year
312
Average wage -2005
Dollars/hour
$15
Base WRT volume
Million gallons/yr
5,438.5
Base inflation index
n/a
194.74
Base WRT treatment charge
Dollars/yr
$1,124,200
Base WRT volume charge
Dollars/1000 gallons
$0.22
Base WRT disposal charge
Dollars/cubic foot
$35
Agreed WRT radium concentration
pCi/L
13.84
Table 2
Calculation Values Used in WRT/HMO Cost Analysis
APW:pII\&\6jSAI\25 I --300\255U03\Wrd\cost analysis Iettcr.MGO
revision.doc
STRAND
ASSCC~ATES. INC’
ENGINE
EflB
Dennis Duffleld, P.8.
City ofJoliet
Page 9
August 1,2005
Results
Evaluation of operating and construction costs for the two processes using each of the
three scenarios described above and no requirement for radon removal yielded the
results shown in Figure 6. The broken lines represent Scenario A, in which demand
remains constant throughout the study period; the dashed lines represent Scenario B, in
which demand increases linearly with time; and the jagged lines represent Scenario C, in
which demand changes irregularly with time
The actual dollar difference between the two technologies ranges from $376,000 for all
three scenarios in the first year to between $640,000 and $1.05 million in the final year
ofthe 20-year study period, depending upon scenario.
0
a
(5
C
$5,500,000
$5,000,000
$4,500,000
$4,000,000
$3,500,000
$3,000,000
$2,500,000
$2,000,000
Figure 6 Cost Analysis of WRT vs. HMO With No Radon Removal
2000
2005
2010
2015
2020
2025
2030
Year
—
-
lIMO
Scenario A —
—
HMO
Scenario B
HMO Scenario C
— - WRTScenariaA
—WRTScenarioB
WRiScenarioC
APW:pII\S:\~SAI\25l-.3OO\255\3O3\Wrd\costanMysisIetter.MGO rcvision.doc
Dennis Duffield, P.R
STRAND
ASSOCIATES.
NO’
City
ofjoliet
Page 10
August 1, 2005
Table 3 shows the percent difference between WRT and HMO annual costs with no
radon removal, For all three demand scenarios, WRT is nearly 15 percent costlier than
HMO in the first year. That difference increases to between 23 and 34 percent by the
final year ofthe study period, depending upon selection ofscenario.
Percent DiffIn Cost (WRT higher than HMO)
Year
Demand Profile
Scenario A
Scenario
B
Scenario C
2005
14.8
14.8
14.8
2006
15.2
15.2
15.5
2007
15.6
16.2
17.2
2008
16.1
17.1
19.7
2009
16.5
18.1
17.6
2010
17.0
19.0
18.4
2011
17.4
20.0
22.2
2012
17.8
20.9
22.1
2013
18.2
21.9
25.0
2014
18.6
22.8
20.7
2015
19.1
23.8
26.6
2016
19.5
24.7
24.2
2017
19.9
25.6
23.2
2018
20.3
26.6
24.9
2019
20.7
27.5
29.7
2020
21.1
28.5
33.4
2021
21.5
29.4
26.9
2022
21.9
30.3
28.3
2023
22.2
31.2
34.3
2024
22.6
32.2
31.3
2025
23.0
33.1
33.7
Table 3 Percent Difference in Cost for WRT Treatment,
Compared with HMO, With No Radon Removal
APW:pII~S:’@SAI\25I..)OO\255\3O3\Wrd\coscaualysis
IetlerMGO evjsiondoc
STRAND
ASSOCIATES. NO’
EN 3 IN E ER S
Dennis Duffield, RE.
City ofJoliet
Page 11
August 1, 2005
Radon removal significantly increases WRT costs. Figure 7 shows annual costs for WRT
and HMO treatment options when radon removal is required.
U,
a
C-)
It
C
C
‘C
$5,500,000
$5,000,000
$4,500,000
$4,000,000
$3,500,000
$3000000
$2,500,000
$2,000,000
P
I
I
2000
2005
2010
2015
2020
2025
2030
Year
-
1-IMO Scenario
A
— —
HMO
Scenario
B
HMO
Scenario C
__________
L— -
WRT Scenario A
— —
WRT
Scenario B
WRT
Scenario C
Figure 7
Cost
Analysis Of WRT vs. HMO With Radon Removal
The actual dollar difference between the two technologies ranges from
$739,450
for all
three scenarios in the first year to between $1,003,000 and $1,407,000 in the final year
ofthe 20-year study period, depending upon scenario.
APW:pII\S:VAJSAI\25 I.-3OO\255\3O3~Wrd\cosI
analysis Ielter,MGO
revision.doc
Dennis Duffield, RE.
STRAND
ASSOCIATES, NCft
City
of
Joliet
Page 12
August 1,2005
Table 4 shows the percent difference between WRT and HMO annual costs with radon-
removal equipment. For all three demand scenarios, WRT is 29 percent costlier than
HMO in the first year. By the final year ofthe 20-year study period, the cost differential
for WRT increases to 36 to 45 percent greater than liMO, depending upon demar~d
scenario.
Percent IDiff In Cost (WRT higher than HMO)
Year
Demand Profile
Scenario A
Scenario B
Scenario C
2005
29.0
29.0
29.0
2006
29.4
29.4
29.7
2007
29.8
30.3
31.2
2008
30.2
31.1
33.3
2009
30.5
31.9
31.7
2010
30.9
32.7
32.5
2011
3t3
33.5
3L5
2012
31.6
34.3
35.3
2013
32.0
35.1
37.9
2014
323
36.0
34.1
2015
32.7
36.8
39.3
2016
33.0
31.6
37.2
2017
33.4
38.4
36.3
2018
33.7
39.2
37.8
2019
34.1
40.1
41.9
2020
34.4
40.9
45.2
2021
34.7
41.7
39.5
2022
35.1
42.5
40.8
2023
35.4
43.2
45.9
2024
35.7
44.1
433°!.
2025
36.1
44.9
45.4
Table 4
Percent Difference in
Cost For WRT
Treatment, Compared With HMO, With
Radon Removal
APW:pII\S:~®SA!\15l-.3OO\255\3O3\Wrd\costanalysis Ictler.MQO rtvisiondoc
STRAND
ASSOCIATES
NU’
ENGINE
E
RB
Dennis Duffield, P.R.
City ofJoliet
Page 13
August 1, 2005
In past draft agreements, WRT has proposed disposing of spent media at Envirocare of
Utah, Inc.’s Clive, Utah, facility at a cost of
$78.75
per cubic foot. Recent
correspondence from WRT indicates that it is basing the Joliet contract on a different
disposal site with lower disposal costs, resulting in a stipulated disposal cost of $35 per
cubic foot. Should WRT contract with Envirocare instead ofthis alternative disposal site
after contractually agreeing to the lower stipulated cost, actual disposal costs charged to
Joliet could be significantly higher. Figure 8 shows annual costs for WRT and 1-IMO
treatment options should this situation arise and also includes costs for radon removal to
present a high-range likely annual cost. The sudden jump in annual costs between 2005
and 2006 for WRT occurs because there is no media disposal the first year, since the first
media change-out is projected to occur in year two.
Figure 8 Cost Analysis Of WRT vs. HMO With Radon Removal and
Excess Disposal Fees
The actual dollar difference between the two technologies ranges from $739,450
for
all
three scenarios in the first year to between $1.60 million and $2.00 million in the final
year ofthe 20-year study period, depending upon scenario.
$5,500,000
$5,000,000
$4,500,000
$4000000
$3,500,000
$3,000,000
$2,500,000
$2,000,000
2000
— -
HMO
Scenario A
—
- WRT
Scenario A
2005
2010
2015
2020
2025
2030
Year
—
“HMOScenarioB
— —
WRT
Scenario B
HMO
Scenario C
WRT
Scenario C
APW:pII\S~~SAI\251--3OO\255\3O3~Wrd~costanalysis Ietter.MGO revialondoc
Dennis Duffield, P E
STRAND
ASSOCFATE& NQ
City ofjoliet
ENGINEERS
Pagel4
August 1, 2005
Table
5
shows the percent difference between WRT and HMO annual costs for this
condition set. WRT is 29 percent costlier than HMO in the first year and climbs to
between 57 and
65
percent greater than HMO by the final year of the 20-year study
period, depending upon demand scenario.
Percent Duff Jn Cost (WRT higher than HMO)
Year
Demand Profile
ScenarioA
Scenario B
Scenario C
2005
29.0
29.0
29.0
2006
46.0
46.0
46.2
2007
46.6
47.0
47.8
2008
473
48.0
49.9
2009
47.9
49.0
49.3
2010
48.6
50.0
50.4
2011
49.2
51.0
52.6
2012
49.8
52.0
52.8
2013
50.5
53.0
55.2
2014
51.1
54.0
52.5
2015
51.7
55.0
56.9
2016
523
55.9
55.6
2017
52.9
56.9
55.2
2018
53.5
57.8
56.7
2019
54.1
58.8
60.3
2020
54.7
59.7
63.1
2021
553
60.6
59.0
2022
55.8
61.6
60.2
2023
56.4
62.4
64.5
2024
57.0
63.4
62.8
2025
57.5
64.3
64.6
Table 5
Percent
Difference
in
Cost
for WRT
Treatment, Compared With HMO, With
Radon Removal And Excess Disposal Fees
APW:pIIS:\L~SAT\25I--3OOU55\3O3\Wrd\costanalysis ktlerMGO
revisiondoc
sa
STRAND
ASSOCIATES. INC.
ENGLNEEPS
Dennis Duffield, P.E.
City of Joliet
Page 15
August 1, 2005
Figure 9 depicts the cumulative difference in cost over the 20-year study period between
WRT and HMO technologies. This figure shows the cumulative difference between the
two technologies using the linear demand scenario (Scenario B) under all three analysis
alternatives. Cumulative cost differences at the end of 20 years range from $14.5 million
when no radon removal is required for WRT to $32.4 million when radon removal and
excess disposal charges are incorporated.
$35
C
~ $30
E
4,
~$25
0
C,
.E
$20
$15
$10
(5
E $5
U
so
I—-No
radon —Radon —Radon/Disposal
Figure 9 Cumulative Difference in Cost
(WRT
More Than HMO) Over
20-Year Study Period Between
WRT
and HMO Technologies
0
2
4
6
8
10
12
14
IS
18
20
Year
APW:plI\S:\©SAI\251—300\255U03\Wrd\cost analysis Ielter.MGO revisiondoc
Dennis
Duffield, P.R
STRAND
ASSOCIATES NC’
City of Joliet
ENGINEERS
PageIó
August 1, 2005
Cost
Risk vs. Time
For this analysis, consideration is given to converting an HMO teclmo!ogy to RSM due
to regulatory restrictions. Only Demand Scenario B, using straight-line growth in
demand over the analysis period, is used for this evaluation.
The materials and equipment not included in initial capital costs ofa convertible system
are shown in Table 6, along with an opinion of their probable costs. Table 7 shows an
opinion of lost value for the initially installed HMO equipment and materials-thztwould
be unnecessary upon conversion to RSC. It should be noted that the cost of backwash
blowers at the Fairmont and Garvin plant is not included in the lost value, since blowers
at this facility could be salvaged for reuse in an iron-removal plant. This cost also is
factored into the opinion ofprobable cost to build a new iron removal plant at Fairmont
and Garvin.
Item
Opinion of Probable Cost
Remove and dispose of HMO
$100 000
Filter media
Purchase RSC media and install
$3,200,000
Build Iron Removal Plant at
t5
700 000
Fairmont and Garvin
4’
TOTAL
$9,000,000
Table 6
Opinion of Probable Costs to Convert Facilities from
HMO to RSC
Several changes in operational costs result from a conversion to RSM treatment. If HMO
facilities are converted to RSM, the radium-selective media will require disposal in a
licensed low-level radioactive waste facility, similar to WRT media in previous analyses.
The estimated annual cost for RSM media disposal and replacement is $1,270,000 in
2005 dollars.
Item
Opinion of Lost Value
lIMO chemical mixing and feed
$1,500,000
equipment
Backwash Blowers
$25,000
Granular Filter Media
$30,000
TOTAL
$1,555,000
Table 7
Opinion of Lost Value in Converting
Facilities
from HMO to RSC
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--300\255\303\Wrd\cost analysis lctIer.MOO revision.doc
1321
Dennis Duffield,
STRAND
ASSOCIATES. IMC
City ofJoliet
ENGINEERS
Pagel7
August 1,2005
A graph of the depreciation schedule for the lost value is shown in Figure 10.
Depreciation is calculated using a straight-line formula, with a $0 salvage value assumed
at the end of20 years.
:: _
__
$1.0
—_________
S
$0.8
—___________________________
Year
Figure 10 20-Year Depreciation Schedule of Lost Value in Converting
Facilities from lIMO to
RSM
Technology
Figures 11, 12,
and 13 show the running difference between the depreciated lost value of
HMO equipment and the cumulative WRT vs
HMO
cost savings per year, as shown in
the previous analysis. These figures do not include any changes in operating expenses
due to the conversion to RSM technology from HMO, nor do they include any capital
expenses that may be incurred initially if a convertible HMO-to-RSM treatment system
is installed at each facility rather than an HMO-only system.
APW:pIl\S:VJSAI\251--300\255\303\Wrd\cost analysis lcIter.MGO revisiondoc
Dennis Duffield, P.E.
STRAND
ASSOCIATES. INC
City
ofJoliet
ENGINEERS
PagelS
August 1, 2005
Figure 11 depicts the running difference for the no-radon-removal alternative. The figure
indicates that the depreciated lost value is offset by savings before year four.
$35
$30
—-.------.——..—----——-—-—~~---
—
j
$25
-~-~
~
$20
—---—__________
____________
___________
S.,
J
$15
~-~---..—---—
-.
Year
Figure 11
Difference Between Lost Value and Cumulative Cost Savings
of HMO vs. WRT Tcchnology With No Radon Removal
APW:pII\S:YiJSAI\25
I..3OO\255\3O3~Wrd\costanalysis IetterMGO revisloildoc
S
STRAND
ASSOCIATES
1N0
ENGPNEE~B
Dennis Duffield, P.E.
City of Joliet
Page 19
August 1, 2005
Figure 12 depicts the running difference assuming radon removal for WRT facilities
only, and does not incorporate costs should radon removal be needed for RSM treatment.
$35
$30
. ..~-..-—________
— ______——________________
?
$25
~
___________
_____-_~_--_
——__.-—
Figure 12
0
2
4
6
8
10
12
14
16
18
20
Year
Difference between Lost Value and Cumulative Cost Savings
of lIMO vs. WRT technology With WRT Radon Removal
APW:pII\S:\z~SAI\25I--3OO\255\3O3\Wrd\costanalysis Ietier.MUO revisiondoc
~fl
Dermis Dufuield, P.E.
STRAND
ASSOCrATES NO
City ofJoliet
ENGINEERS
Page2O
August 1, 2005
Figure 13 depicts the running difference assuming radon removal for WRT and excess
disposal fees for WRT spent media. As noted above, operating expenses such as spent
media disposal for RSM are not included in this analysis.
$35
:
___
Year
Figure 13 Difference between Lost Value and Cumulative Cost Savings
of flMO vs. WRT technology With WRT Radon Removal and
Excess
Disposal Fees
Extended Period Analysis
Additional cost analysis ofthe HMO and WRT technologies was performed using a 30-
year
study period for Scenario B only. Possible conversion to RSM is disregarded for
this analysis.
In this analysis, all physical costs (building and equipment) are fully depreciated at the
end of year 20. Also, all HMO injection equipment is replaced at the end ofthe 20 year
period and is financed using identical interest and time-period conditions as the initial
purchase. The cost of the replacement equipment has been adjusted based on the
Consumer Price Index to reflect inflation. Building construction costs for WRT, then, are
fully paid in the year 2025, while construction costs for only the HMO chemical feed
equipment are renewed after 2025. HMO building and filter equipment are fully
depreciated after the year 2025. In addition, the estimated depreciation cost for WRT
filter vessels and piping is subtracted off annual WRT operating costs after the year
2025. This presumes that WRT will renew its 20-year contract with the City of Joliet
without incorporating capital expenses into its annual fees. Thus, amortized costs of
APW:pII\S:\®SAI\25 I --300\255\303\Wrd\cost ailalysis Ictter.MGO ,tv~siondoc
Dennis Duffield, P.E.
STRAND
City ofJoliet
ASSOCIATES,
INC~
ENGPNEERS
Page2l
August 1, 2005
more than $666,000 for filter vessels and process piping are eliminated from WRT
annual fees beginning in the year 2026.
Figure 14 shows the annual difference in cost between the two technologies during the
30-year period for Scenario B under all three analysis alternatives. The initial cost
difference between HMO and WRT is greater for alternatives in which radon-removal
equipment must be built. When excess disposal charges are not incorporated into the
analysis, the cost difference between the two processes is identical once capital expenses
are fully depreciated. Annual cost differences range from $376,000 to $1.98 million over
the course of the 30-year study period, depending upon year and analysis alternative
selected.
$2500
.5
C
0
S3
In
0
U
C
SU
C
C
C)
E
z
$2,000
$1,500
$1 000
$500
so —
2000
F—iã~Tadon—Radon
Figure 14 Annual Difference in Cost Between WRT and HMO Over a 30-
Year Period for Linear Demand Scenario (Scenario B)
Year
2005
2010
2015
2020
2025
2030
2035
2040
—
Radon/Di~saI
APW:pII\S:\®SAI\25l--300\255\303\Wrd\cost analysis lctter.MGO
revisiondoc
Dennis Duffield, P.R
STRAND
ASSOCtATES. NC.’
City of Joliet
ENGINEERS
Page22
August 1,2005
Figure 15 depicts the cumulative difference in cost over the 30-year study period
between WRT and HMO technologies. This figure shows the cumulative difference
between the two technologies using the linear demand scenario (Scenario B) under all
three analysis alternatives. Cumulative cost differences at the end of 30 years range from
$20.6 million when no radon removal is required for WRT to $44.9 million when radon
removal and excess disposal charges are incorporated.
$50-
I~
!$40
•-----~~-~-——
___
—~—~-—---•
-
~
$35
.__-______~__
————.-————--—-—~
..——-
$30
—-—---~~
—--——.--~-
~$25
~
_~-.
-~
~$2O
--~-.———--
~---~--..-.
—
• $15-—-—-
---—-—-.-
..
~$1o
.--~.
~
C,
$~
~..
--
so
-
I
I
0
5
10
15
20
25
30
Year
E~No~don
-~Radon/Disp~l
Figure 15
Cumulative Difference in Cost between WRT and HMO over
a 30-year period for Linear Demand Scenario (Scenario B)
APW:pII\S:V~SAI\25I--300\255\303\Wrd\cost analysis Iet(erMOO revision.doc
S
STRAND
ASSOCIATES. !NC.
ENGINE
ER S
Dennis Duffield, P.E.
City ofJoliet
Page 23
August 1, 2005
Summary
The cost analyses performed indicate that cumulative costs over a 20-year period are
significantly lower with HMO than with WRT. If a convertible HMO/RSC system is
installed, the technology will be cost effective in comparison with WRT as long as
conversion occurs at least six to 13 years after start-up, depending upon conditions. That
conversion time frame could be shorter
if
additional fees and finanela requirements
associated with WRT are instituted. Those additional fees and financial requirements are
not evaluated in this analysis, since their value cannot be determined at the present time.
While conversion from HMO to RSC results in more capital expenditures, operational
expenses associated with cither technology are lower than operational expenses
associated with WRT.
Extended-period analysis indicates that the HMO technology continues
lower annual costs than WRT using the assumptions described above,
equipment is fully depreciated and replaced where appropriate.
to
generate
It should be noted that these cost evaluations for all technologies should be consideredeven
aftera
baseline range oniy. Please contact us to discuss further at your convenience.
Sincerely,
Mark G. Oleinik, P.E.
APW;pIIS:k~SAfl25I.-300\255U03\WnAcost aoalysis Iettcr,MGO revisiondoc
