Management of Water Treatment Residuals Containing Radium. Presentation Objectives

Transcription

1 Management of Water Treatment Residuals Containing Radium 32 Ill. Adm. Code Section (d) Presentation Objectives Quick Overview of Radium in Water Treatment Residuals Discuss Who is Regulated by 32 IAC (D). Discuss Specific Provisions and Requirements. Monitoring and Reporting Requirements Question / Answer 1

2 Groundwater Radium in Illinois Half life of Ra226 = 1600 years USEPA - Radionuclides in Drinking Water Rule limits to 5 pci/l , Number of treatment installations Begins to Increase. Concentrations of Radium accumulating in Drinking water and waste water treatment facilities increased. Spent media and sludges disposed of in the environment contained much higher radium concentrations. Groundwater Radium in Illinois I don t have radium in my water I.e., Southern Illinois Certain Treatment Technologies Concentrate Over Time Changes in Water Chemistry and/or Demand I don t treat for radium I.e., Aquifer Radium < 5 pci/l Treatment Technology May Still be Removing Co-Precipitated with Barium, Iron I don t have an MCL I.e., Raw Water High, Finished < 5 pci/l Effective Removal = Higher Deposition Elsewhere Where is the radium going? I.e., Backwashed = N.M.P. Drinking Water Media Retention Backwash Catch Basins Lagoons / POTW Sludges 2

3 Accumulation of Radium in Drinking Water Treatment Facilities Especially high where Actively Treating for Radium (HMO, IX) Backwash Settling Basins > 2900 pci/g Filter Media can accumulate even at Low Raw Water Concentrations 1.7 pci/l with Anthracite > 225 pci/g Tanks, Piping, Valves Rejected and Returned to Municipality Monitor & Use proper disposal methods based on concentration Avoid Costly Impacts to Site Why is IEMA Involved? IEPA and USEPA regulate land application of sludges (metals) IEMA Division of Nuclear Safety regulates possession and release of radioactivity or contamination. 3

4 Why Manage Land Applications of Radium? Concentrations observed exceed ISCORS, NRC/EPA studies. POTW: ISCORS average = 2.82 pci/g, Illinois = pci/g POTW: ISCORS max = 85 pci/g, Illinois = 205 pci/g CWS: (No ISCORS review), Illinois = ave 267 pci/g, max = 2970 pci/g US EPA Superfund Sites in Illinois Remediate Soil with > (5 pci/g + Background) In excess of $40 million spent, with $50M projected RCRA and IEMA Regulations on Land Use CRCPD Part N No Land Application Greater than 10 pci/g Other States > 5 pci/g determined to be Low Level Radioactive Waste Why Manage Land Applications of Radium? Unlike Metals, site Life Climbs Quickly Not unlike Oil & Gas Problems with Hydrofracturing Proactive Approach Rather than Eliminate Application; Manage Large Socio-Economic Impact for Eliminating Land Application Quantified Health Impact for Exceeding Limits Economic Liability for De-valuing Farmer s Fields 4

5 Filter media classified as LLRW being segregated from regular trash. CERCLA Clean UP = ~7 pci/g Here: ~ 200 pci/g Although it may be sandy, filter media is probably not a good option for use as fill LLRW Disposal estimate..>$1200/drum 5

6 32 IAC (d) Contains Regulatory Requirements For: Drinking Water Treatment Facilities Consideration given to the Treatment Technologies in Use as well as the Aquifer Wastewater Treatment Facilities Concentrated in Sludges when CWS has High Backwash Concentrations Land Applicators Involved When POTW Sludges Contain Radium Municipal Solid Waste Landfills (RCRA Subtitle D) Ensure Concentrations can be Confined by Controls Aquifers Designated by IEMA Devonian Silurian Cambrian Ordovician Typically deep wells in Northern Illinois. However, also any aquifer that yields an MCL. 6

7 Treatment Technologies Identified by IEMA Ion Exchange (US EPA) Lime Softening (US EPA) Anthracite or Activated Carbon (US EPA) Greensand Filtration Reverse Osmosis HMO NPDES Discharge Filters List Continually Refined and Residuals Sampled. Who is Regulated under Section (d)? ~1186 Groundwater Drinking Water Facilities Treatment Only 482 Community Water Supplies Report and Sample MEDIA prior to Disposal Of those 482 Treatment Only CWS, 182 Also Draw Water from a Radium-Contributing Aquifer. Report and Sample MEDIA prior to Disposal Track Land Applications and Landfill Disposals Downstream POTW Facility Must Register ~ 980 Wastewater Treatment Facilities Only 147 Receive Wastestreams from CWS (Treatment & Aquifer) Track Land Applications and Landfill Disposals Report Annually 7

8 Who is Regulated under Section (d)? Land Applicators If persons utilize sludge or biosolids that are required to be tracked according to Section (D) then they too must comply with the provisions of Section (d). Generator or Applicator May Report Municipal Solid Waste Landfills (RCRA Subtitle D) Afforded 200 pci/g (dry weight basis) What exactly does the new rule do? The Rulemaking is an exemption. IEMA Regulates Licensees 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. 16 8

9 What does the rulemaking do? Creates an awareness among Drinking Water Treatment Facilities CWS Treatment residuals are often far more problematic Requires Monitoring/Reporting for Proper Disposal 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 Maintained Specific Rule Requirements Registration (99.9% complete) Notification to Regulated Persons Online Response: Verify Contact Information Verify Treatment Verify Facilities to Which a Waste Stream is Sent / Received. 9

10 Specific Rule Requirements (continued) Registrant Disposal Options Municipal Solid Waste Landfills (RCRA Subtitle D ) Concentrations: < 200 pci/g Dry Weight Basis Applies to: All Registrants Land Application Concentrations: < 100 pci/g Dry Weight Basis Reporting Requirements Apply to: Treatment and Aquifer CWS s & POTW s Treatment Only CWS Not Regulated < 3 pci/g (DWB) Not Regulated Specific Rule Requirements (continued) Landfill Disposal Subtitle D (Municipal Solid Waste Landfills) Covered if Easily Dispersible Concentrations 200 pci/g IEMA Review > 100 pci/g Report Annually: Quantity Concentration Location of Landfill 10

11 Specific Rule Requirements (continued) Land Application Radium Concentrations 100 pci/g In Accordance with IEPA Land Application Permit 1.0 pci/g Cumulative Radium Increase in Soil 3.0 pci/g Ceiling Concentration Limits Apply to the Sum of all Land Applications from all Applicators Concentration of Treatment Residuals must be Determined by Laboratory Analysis Receiving Fields Have Requirements for Application Specific Rule Requirements (continued) Land Application (continued) Field Requirements Sample the field to be land applied to determine the starting radium concentration. Done ONCE, a single Composite Sample Landowner Acknowledgement Form Field Reporting Form 80% of limits Specific Site Requirements 11

12 Specific Rule Requirements (continued) Annual reporting requirements (91.3% Complete) Forms Mailed Every January Similar to Format of IEPA Semiannual Sludge Report. Landfill Quantity, Sample Result or IEMA Certification Residual was Beneath 200 pci/g, Date of Disposal, Landfill Name/Location Land application Field Location, Sludge Analytical Result, Application Rate, Date of Application 12

13 Concentrations > 200 pci/g Treatment & Aquifer Community Water Supplies HMO & Ion Exchange Backwash Catch Basin where Sediments Build Up Keep Treatment Residuals in the System Avoids Unnecessary Worker/Public Exposure Avoids Contaminating Soil and/or Facilities (additional cleanup) CCA Approach IEMA Identifies Environmental / Health Issues Facility Poses Operational, Managerial, or Physical Address Provides Avenue to Identify Additional Problems Assess and Mitigate any Worker Exposure Issues Sampling, Shipping, Packaging (US DOT Hazmat > 270 pci/g) Free. 13

14 Ongoing Initiatives Implement Technical Criteria to Narrow Scope Collecting Data to Further Evaluate Some Municipalities may Require Licensure Unique System Designs and Disposal Methods Preserve Viable Disposal Options (landfilling and land application) by limiting and managing environmental impact Developing State s Regulations (> 5 = LLRW) Stress Proper Management of Residuals to Ensure Minimal Environmental Impact, ALARA Radiation Exposure, and the Protect both Landowners & Municipalities from Potential Economic Impacts and Liabilities. Additional Information Download a Copy of the Regulations Download the Guidance Document Download Reporting Forms View Listings of Municipalities Regulated Drinking Water Facilities - Treatment ONLY Drinking Water Facilities - Treatment AND Aquifer Wastewater Facilities (Those Receiving Flow from Treatment & Aquifer Drinking Water Facilities) 14

15 Additional Information Workshops, Presentations, Questions, Assistance with Program Requirements: Gary Forsee 1301 Knotts Street Springfield, IL (217) Michael Klebe 1035 Outer Park Dr. Springfield, IL (217)