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

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

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

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

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

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 -1.67 pCi/g (Ra-226 + Ra-228) Avg. soil increase – 0.03 pCi/g (Ra-226 + Ra-228) Maximum increase – 0.47 pCi/g (Ra-226 + Ra-228) 3.3 millirem/year to the future resident 14.4 millirem/year if you add in potential radon Illinois Emergency Management Agency

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

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

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

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

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

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

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

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

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.

Environmental Compliance Unit, BRS Contact Information Gary Forsee Environmental Compliance Unit, BRS Illinois Emergency Management Agency (217) 782-1322 Gary.Forsee@illinois.gov www.ready.illinois.gov Illinois Emergency Management Agency