What we know (so far) or think we know:
- 32 IL Adm Code Part 622 has the potential to affect every water system using wells that isn’t located near a river or stream (that isn’t using an alluvial/shallow sand and gravel aquifer).
- This is a regulation administered by the Illinois Emergency Management Agency, not a regulation administered by the Illinois EPA.
- At a minimum, the Regulation requires:
- Proper handling of water treatment residuals (e.g., lime sludge, spent filter media, filter backwash water, etc.);
- Proper disposal of residuals;
- Worker protection from residuals, and disposal of residuals (especially if the residuals contain radioactive materials).
- The regulation also applies to wastewater treatment facilities that receive water treatment residuals (backwash).
- The regulation has particular focus on worker safety that includes substantial requirements for protecting those handling residuals with radioactivity levels greater than 200 pCi/g1.
- It appears that most water systems are going to have to do training for their operations staff on TENORM (Technologically Enhanced Naturally Occurring Radioactive Material).
- The Regulation requires record keeping and reporting of “incidents.”
What we are unsure about:
Since the regulation is now effective, the IRWA is unsure how to recommend affected water systems should proceed. The Executive Director of the IRWA is attempting to reach the Illinois EMA for guidance and has contacted the Illinois EPA for their assistance. Specifically, water systems need to know:
- Does the Illinois EMA have an implementation strategy?
- When will the promised guidance documents be issued? and
- Will this Regulation be administered by the Illinois EPA or EMA?
- If Illinois EMA, what will their inspection frequency and protocols look like?
Suggested actions starting today:
- Make sure that everyone at your facility (including you political leaders) are aware of this new Regulation.
- Update your wastewater treatment facility personnel (if they are different than your potable water treatment staff).
- If you are doing any “projects,” in the near future, that will involve “residuals,” contact the Illinois EMA for advice.
- Rodney Pitchford, Health Physicist, Radiological Field Services Section, Manager
Office of Nuclear Safety, Illinois Emergency Management Agency and Office of Homeland Security, 1301 Knotts Street, Springfield, IL 62703; Rodney.Pitchford@illinois.gov
- Stay tuned for additional updates and training opportunities from the IRWA and Illinois EMA.
