1. Illinois Emergency Management Agency
Update on Draft Revisions to Rules Addressing Water Treatment TENORM
Gary Forsee
May 8, 2017
Illinois Emergency Management Agency

2. Overview
Like many states, regulatory oversight for TENORM (where it exists) is divided amongst multiple agencies
SSR-N, or some derivation, has not been adopted
LLRW Compact prohibits TENORM import
Oil and gas TENORM largely unregulated
TENORM resulting from treatment of groundwater is the primary focus

3. Regulatory Impetus 1984 MOA between Illinois EPA and IEMA
Afforded land application of wastewater treatment plant sludges
Limited soil accumulation of radium to 0.1 pCi/g
Landfill disposals handled on a case-by-case basis
2003 Radionuclide Drinking Water Standards Effective
Treatment installations/technologies increased
Radium concentrations in residuals increased
Municipalities encroached upon 0.1 picocuries per gram increase in soil as a result of land application

4. Regulatory Impetus 2011 promulgated 32 Ill. Adm. Code 330.40(d)
Exempted all persons from licensure < 200 pCi/g provided they comply with disposal criteria
Municipal solid waste landfill disposal afforded beneath 100 pCi/g
Land application limits radium accumulation to the lesser of a 1.0 pCi/g increase or 3.0 pCi/g (including background)
All analyses, disposals, and receiving fields reported annually

5. Landfilled Water Treatment Residuals
Tons per Year Landfilled
Annual Radium Concentration (pCi/g)
Annual average – 26,496 T/year
Annual average – 26.5 pCi/g
EPA Landfill Disposal Report
Water Treatment TENORM Landfilled
Percent as Volume
2010
13.97 million tons
Not yet tracked
2011
14.0 million tons
24,856
0.18%
2012
12.06 million tons
23,878
0.20%
2013
13.64 million tons
30,304
0.22%
2014
13.33 million tons
23,464
2015
Pending
29,327
Illinois Emergency Management Agency

6. Land Applied Water Treatment Residuals
Tons per Year Land Applied
Annual Radium Concentration (pCi/g)
Annual average – 35,853 T/year
Avg. concentration – 17.8 pCi/g
Since 2011, water treatment facilities have reported 133,581 tons land applied (2.33 curies Ra226 and Ra228) to 765 fields, 50,963 acres
Avg. field background pCi/g (Ra Ra-228)
Avg. soil increase – 0.03 pCi/g (Ra Ra-228)
Maximum increase – 0.47 pCi/g (Ra Ra-228)
3.3 millirem/year to the future resident
14.4 millirem/year if you add in potential radon
Illinois Emergency Management Agency

7. Draft Amendments for Consideration
Draft revisions (not yet proposed) under way:
Identified drinking water treatment facilities in possession of material greater than 200 pCi/g
Pathways for worker exposure require address
Avenues for environmental contamination require address
Stakeholder involvement has been extensive
Some requirements are duplicative of other agencies
Needed flexibility on behalf of both water treatment facilities and IEMA is absent
So, although the presentation also discusses some proposed changes to the exemption – what I’m going to focus on today is the issuance of licenses. Where we are at today and how the licensing process is evolving.
Illinois Emergency Management Agency

8. Disposal and Handling Problems
1400 pCi/g, 330 uR/hr
800 pCi/g, 250 uR/hr
460 pCi/g, 100 uR/hr
250 pCi/g, 70 uR/hr
Starting in 2012, we began to see contamination and exposure issues – not at wastewater facilities, but at drinking water treatment facilities
There weren’t always operational and institutional controls in place to limit worker (or even public) exposure
The concentrations were not always below 200 pCi/g
Up to 3,000 pCi/g, 2,000 uR/hr
Illinois Emergency Management Agency

9. Disposal and Handling Problems
~ 50 uR/hr
Starting in 2012, we began to see contamination and exposure issues – not at wastewater facilities, but at drinking water treatment facilities
There weren’t always operational and institutional controls in place to limit worker (or even public) exposure
The concentrations were not always below 200 pCi/g
Illinois Emergency Management Agency

10. Impacts from stakeholder input:
Tell us exactly what to put into a “radiation protection plan”
Original concept was specific license for persons doing work, and a general license for simple possession
Everyone wants to be under a general license
Really, no one wants a license at all…
Make it simpler, make it appropriate for the hazard present

11. Beneath 100 pCi/g or 60 pCi/L of combined radium:
Draft Rule Revision
Beneath 100 pCi/g or 60 pCi/L of combined radium:
Exempt from licensure and fees provided,
Don’t contaminate property greater than free release guidelines
Don’t expose the public > 100 mR/year (excluding radon)
Failure to comply requires remediation and coordinated plan to return to compliance
Register with the Agency
TENORM may be landfilled, land applied, or petitioned for alternative disposal
Cannot increase combined radium in soil > 1.0 pCi/g or 3.1 pCi/g (whichever is less)
Must sample and maintain records, including field baseline
Sample within 6 mos. or prior to next service entry

12. Draft Rule Revision
Greater than 100 pCi/g or 60 pCi/L of combined radium, but less than 200 pCi/g or 600 pCi/L:
Still exempt from licensure with the previous caveats
Still a ‘registrant’ with IEMA
All the same requirements exist, except that all disposals are authorized by the Agency in advance

13. Greater than 200 pCi/g or 600 pCi/L:
Draft Rule Revision
Greater than 200 pCi/g or 600 pCi/L:
Still exempt from licensure
Register with IEMA within 60 days of becoming aware
Limit workers to the public dose limit (100 mR/year from all sources, excluding contribution from radon) and 2 mR/hour
Establish restricted areas and post signage
> 1 microcurie activity (10x value in 10 CFR 20, Appendix C)
Ensure worker exposure to radon in occupied areas doesn’t exceed 30 pCi/l or 0.3 WL, not to exceed 4 WLM in one year
Parses facilities based on those requiring worker entry into restricted areas or contact with TENORM and those that don’t

14. Draft Rule Revision Greater than 200 pCi/g or 600 pCi/L: (continued)
Perform radiation surveys
Annual gamma surveys for no entry/contact
Before, during, and after entry; as well as contamination surveys
Provide worker training
2 hour awareness training annually for no entry/contact
8 hour (minimum) comprehensive training for entry and contact facilities.
All facilities develop emergency procedures to keep doses ALARA
Decommissioned equipment must meet free release criteria
Notification of spills
Disposals require advance authorization (generally as LLRW)
Designate an official responsible for implementing provisions
of the rule

15. Draft Rule Revision
Greater than 200 pCi/g or 600 pCi/L (continued)
Optimize operations: If the potential for dose to the worker exceeds the limits specified, submit a plan within 45 days to return to compliance.
Inability to reach the specified dose constraints results in loss of exempt status and issuance of a specific license.

16. Environmental Compliance Unit, BRS
Contact Information
Gary Forsee
Environmental Compliance Unit, BRS
Illinois Emergency Management Agency
(217)
Illinois Emergency Management Agency