Overview and Implementation of Radium Treatment Residual

Overview and Implementation of the Radium
Treatment Residual Regulations
32 Ill. Adm. Code Section 330.40(d)
Background and Involvement
– Illinois Environmental Protection Agency (IEPA)
• Drinking Water Compliance Section (Radionuclide Rule)
• Water Pollution Control NPDES & Wastewater Compliance
– Illinois Emergency Management Agency (IEMA)
• Environmental Monitoring: Radioactivity in the environment
and around nuclear facilities
• Verification and Oversight for Decontamination and
Decommissioning projects
• Performs site surveys and sampling for license termination
• Inspect/Escort certain classes of Radioactive Materials
• Respond / Investigate radiation alarms or allegations
• December 2010, Low Level Radioactive Waste Section to
implement Section 330.40(d)
Topics of Discussion
• How 32 IL Admin Code Section 330.40(d) came about.
• What the Regulations Seeks To Do.
• Specific Provisions and Requirements.
• What is the Scope of Regulated Persons?
• How is This Being Implemented?
• Question / Answer
How Section 330.40(d) Came About:
• 1984 MOA between Illinois EPA and IEMA
– 0.1 pCi/g increase above background for land
application sites.
– Implemented and monitored by Illinois EPA
• 2003 Radionuclide Drinking Water Standards
– Treatment installations/technologies increased
– Radium concentrations in residuals increased
• Municipalities encroached upon 0.1 pCi/g increase in soil
as a result of land application.
How Section 330.40(d) Came About (continued):
• Illinois Pollution Control Board Ruled the MOA an
“Unpromulgated Regulation”
– IEMA evaluated an increase to a 0.4 pCi/g Limit
– Opposition to the proposed rule Increased
• February 28, 2011 - 32 Ill. Adm. Code 330.40(d)
– Provided Exemption from Licensure
– Implemented by IEMA
– Limits the Amount of Radium Land Applied to
1.0 pCi/g increase
– Specifies Avenues for Proper Disposal
– Drinking water AND Wastewater Facilities
What exactly does the new rule do?
• Prior to this exemption, there were no exempt
concentrations or quantities for radium
• Therefore – all radium concentrated from the
treatment of water or sewage was subject to the
licensing requirements of IEMA-DNS
• The Rulemaking is an exemption.
• Provides specific criteria for the disposal of
treatment residuals containing radium less than or
equal to 200 pCi/g and/or land application of
treatment residuals containing radium less than or
equal to 100 pCi/g.
What does the rulemaking do?
• Creates an awareness among Drinking Water Treatment
– Radium residuals are often far more problematic
• Tracks Radium Land Applications in a manner similar to
Part 391 Metals’ Loadings and Ceiling Limits:
1.0 pCi/g increase in background radium concentrations
3.0 pCi/g ceiling limit
Up to 100 pCi/g biosolids can be land applied
Up to 200 pCi/g residuals can be landfilled
Monitoring and Reporting to Ensure Limits are Met and
Specific Rule Requirements
• Description of each requirement as listed in
Section 330.40(d).
• Short Discussion on the Types of Facilities to
which they would apply.
• Logic and process in which IEMA is
implementing each requirement.
Specific Rule Requirements
• Registration with IEMA
– Owners and operators of plants producing residuals
or sludge from the treatment of water or sewage and
containing radium occurring naturally from
– Owners and operators of IEPA permitted landfills
receiving residuals and/or sludge containing radium
– Applicators who apply these residuals and sludge to
agricultural lands
– Other (as determined by IEMA)
Specific Rule Requirements
• Registration (continued)
– Online Response: www.state.il.us/iema
– Verify Contact Information
– Verify Treatment
– Verify Facilities to Which a Waste Stream is
Sent / Received.
– Notifies Regulated Persons about the Rule
Specific Rule Requirements
• Landfill Disposal
– Residuals / Sludge Containing Radium with
Concentrations ≤ 100 pCi/g:
– Covered During Transport
– Packaged or Stabilized if Easily Dispersible
– Cover of 10 ft of Non-Contaminated Overburden (at
time of landfill closure)
– Applies to Drinking Water Treatment Media
– Applies to Wastewater and Drinking Water sludges or
biosolids produced.
Specific Rule Requirements
• Land Application
– Residuals / Sludge Containing Radium with
Concentrations ≤ 100 pCi/g:
– Cumulative Increase in Soil Radium Concentration
Limited to 1.0 pCi/g
– Limit Applies to the Sum of all Land Applications from
all Applicators
– Ceiling Soil Radium Concentration Set at 3.0 pCi/g
(background of 2.2 affords a 0.8 pCi/g increase)
Specific Rule Requirements
• Land Application (continued)
– Land Application in Accordance with Illinois EPA
Sludge Regulations
– Concentration of Treatment Residuals must be
Determined by Laboratory Analysis
– Baseline Radium Concentration must be Determined
prior to application. i.e. “Field Sampling”
Specific Rule Requirements
• Land Application (continued)
– Concentration of Treatment Residuals must be
Determined by Laboratory Analysis
• Some Illinois NPDES or Land Application Permits
have Radium Sampling Requirements. NOT ALL
• If Mailed a Registration Requirement by IEMA –
Land Applying your Residuals will Require a
Representative Sample.
• Frequency? Specified in your Illinois EPA Permit
or Determined by the Generator.
Specific Rule Requirements
• Land Application (continued)
– Baseline Radium Concentration must be Determined.
i.e. “Field Sampling” prior to use:
• Sampled by June 1, 2011 for fields land applied in
Spring of 2011.
• If Not Already Sampled, Sample Prior to Next Land
• Sampling to Determine the
Baseline Radium Concentration
is Performed Once.
Specific Rule Requirements
• Land Application (continued)
– Baseline Radium Concentration must be Determined.
i.e. “Field Sampling” prior to use:
• 12 inch depth
• 1 composite sample per 8 acres (391.510a), or
• Sampling in Accordance with the Illinois Agronomy
– “Zones of Common Characteristics”
– One composite sample per continuous, singleownership field.
Specific Rule Requirements
• Land Application (continued)
– Landowner (or authorized agent) must acknowledge
the he/she is aware that residuals or sludge
containing radium is being applied to their land
• Form Updated as ownership changes
• Form developed by IEMA with Stakeholder Input.
• Available in the Guidance Document.
• May be Incorporated into Existing Documentation.
– Concerted Education is Imperative.
Specific Rule Requirements
• Field Requirements for Land Application
– pH of 6.0
– Within top 5 feet and above bedrock and
• 6” layer with clay content of at least 18% (county
soil survey book)
• 6” layer with organic content of at least 12 tons per
acre (site specific testing)
– Tobacco may not be cultivated on fields land applied
with radium residuals.
Specific Rule Requirements
• Field Requirements for Land Application (continued)
– When the Increase in Soil Radium Concentration is
Calculated to be 0.8 pCi/g or when the Site’s Soil
Radium Concentration is Calculated to be 2.8 pCi/g:
• Discontinue use of field, or Land Apply Biosolids Sourced
from a Generator Not Regulated by Section 330.40(d)
• OR Repeat Soil Sampling and Radium Analysis
– If less than 3.0 pCi/g total radium, then continue use of
– If equal to or greater than 3.0 pCi/g, discontinue use of
– “Zones of Common Characteristics” whole field
compositing NOT Allowed.
Specific Rule Requirements
• Field Requirements for Land Application (continued)
– Calculating Radium Accumulation
• Soil Density of 90lbs/cubic foot
• Mixing Depth of 12”
• A 1.0 pCi/g increase equates to 1778 micro Curies
per acre.
• For each load of sludge / biosolids taken to a field
(from any generator, by any applicator) – the total
number of picoCuries applied are averaged over
the entire number of acres.
Specific Rule Requirements
• Field Requirements for Land Application (continued)
– Reporting Field Data
• Can be Done in an Annual Report or Prior
• Online Reporting Mechanism In Development
• Section, Township, Range, a central GPS point in the field,
and the Number of Acres.
• The Baseline Radium Sample Result.
• Signed Landowner Acknowledgement Form.
• pH, OM, and Clay Content Data – Certification Only
• Draft Form is Available Upon Request
• Final Forms will be mailed in January
Specific Rule Requirements
• Annual reporting requirements
– Landfill
• Quantity, Sample Result or IEMA Certification
Residual was Beneath 200 pCi/g, Date of
Disposal, Landfill Name/Location
– Land application
• Location, Background Radium Concentration (first
use of field), Sludge Analytical Result, Application
Rate, Date of Application
– Online or Mailed in. Similar to Format to IEPA
Semiannual Sludge Report.
Specific Rule Requirements
• For residuals/sludge containing > 100 and ≤ 200
– Method of disposal must be reviewed and approved
in advance by IEMA
• Landfill disposal is the likely disposition
• Notifies IEMA of possible worker exposure issues
and affords an opportunity to assess.
– Disposal in a licensed LLRW disposal facility is
another option
Who is Regulated under Section 330.40(d)?
• Drinking Water Treatment Facilities
– 1. Treatment Technology
– 2. Treatment Technology AND Aquifer
• Wastewater Treatment Facilities
– Only Those Receiving a Treatment Process Waste Stream
from a Drinking Water Treatment Facility Identified in the
Second Category Above.
• Land Applicators
– Anyone who takes the residuals from the generator
– Includes private contractors, golf courses, etc.
– Protects the liability of the generator and land owner
Who is Regulated under Section 330.40(d)?
• Following the Radium Starts at the Drinking Water
Treatment Facility.
• Not just MCLs or Radium Treatment
• Groundwater Treatment Only.
• Define the Treatment Technology
• Define the Aquifers
Drinking Water Treatment Media can far
Exceed Wastewater Sludge Concentrations
Drinking Water Treatment Media
• Responses include facilities NOT treating for
• Include Southern Illinois Communities
• Facilities treating for radium have been working
with IEMA to avoid creating residuals in excess of
200 pCi/g
• Many Drinking Water Facilities are not aware of
Radium Accumulation until Refused for Disposal
• Radium Removal Systems Pose the Largest
Disposal Problems in Backwash Holding Tanks
Drinking Water Treatment Media (continued)
• Even low levels of radium can be concentrated over
• Therefore, treatment is the first criteria for inclusion in
regulatory scheme.
Ion Exchange
Lime Softening
Anthracite or Activated Carbon
Greensand or Sand Filtration
Reverse Osmosis
• List Continually Refined and Residuals Sampled.
Drinking Water Treatment Media (continued)
• If a Drinking Water Treatment Facility utilizes one of
these treatment technologies, the media itself must be
monitored prior to disposal. (the sand, gravel bed, filter,
resins, etc.)
• Screening is acceptable for landfill disposal.
• These residuals not typically land applied.
– Lime Softening Exemption
• If the aquifer from which the facility draws source water
is not identified by the USGS as having elevated radium
concentrations from surrounding bedrock,
– No Wastewater Treatment Plant Registration
– No Land Application Requirements on the Sludges.
Drinking Water Treatment Facilities
• If the aquifer from which the facility draws source water
is identified by the USGS as having elevated radium
concentrations from surrounding bedrock...
– Any wastewater treatment facility receiving a waste
stream is a registrant as well.
– Any land applications or landfill disposals are
regulated under Section 330.40(d).
– Field Sampling and Tracking Radium Accumulation
for Drinking Water and Wastewater Sludges
Aquifers Designated by IEMA
• Typically deep
wells in Northern Illinois.
• However, also any aquifer that yields an MCL.
Who is Regulated under Section 330.40(d)?
• 1186 Drinking Water Facilities Utilizing a
Groundwater Source
• “Treatment” Defined – Resulted in 482 Community
Water Supplies required to register.
– These must all report and sample the MEDIA prior to
• Of the 482 Drinking Water Treatment Facilities, 182
draw Water from a Radium-Contributing Aquifer.
– These must follow land application requirements.
– Wastewater Treatment Facilities Receiving a Waste Stream
Flow must Register and Meet all Land Application / Landfill
Disposal Requirements.
Wastewater Treatment Facilities
Approximately 980 in state.
Only subject to Section 330.40(d) Regulation if
Receiving a Waste Stream from a Drinking
Water Treatment Facility that is:
1. Employing a Treatment Technology
Capable of Concentrating Radium.
2. Drawing Source Water from an Aquifer
Identified to Contribute Elevated Radium
147 Wastewater Treatment Facilities Currently
Meet this Criteria.
Who is Regulated under Section 330.40(d)?
• Land Applicators
– If persons utilize sludge or biosolids that are required to be
tracked according to Section 330.40(D) then they too must
comply with the provisions of Section 330.40(d).
– Individual Contractors
– Itemized in the Annual
Report of Sludge
Lacking a Regulatory “Box”
• Working with Individual Systems
• “CCA” Approach
• Case Specific Exemptions
– Sludges Beneath 3 pCi/g
– Land Application (and Lime) from Drinking
Water Facilities using ‘Treatment Only’
• Unique Circumstances by Design
– Golf Course Irrigation
– No Discharge
– Dilution From Surface Water Flow
• Goal is to Narrow Scope: Data Needed.
Additional Information
• www.state.il.us/IEMA
– Download a Copy of the Regulations
– Download the Guidance Document
– View Listings of Required Registrants
• Drinking Water Facilities - Treatment ONLY
• Drinking Water Facilities - Treatment AND
• Wastewater Facilities (Flow from Treatment &
Aquifer Drinking Water Facilities)
Additional Information
• Workshops, presentations or questions,
Gary Forsee
1035 Outer Park Dr
Springfield, IL 62704
(217) 782 1326