Wednesday, September 12, 2012

Radioactive Iodine in Sludge May Contaminate Environment and Drinking Water

Majia here:  This is another post covering Ret. Capt. Clyde Stagner's analyses of radiation contamination in the Phoenix area caused by the Palo Verde nuclear plant in Maricopa County, AZ. 

Capt. Stagner is author of Hidden Tritium and has had a long, distinguished career, including military experience, monitoring radiation. Please see his most recent post.

Maricopa Association of Governments                             Memorial Day, 2012

Dear Ladies and Gentlemen,

    Phoenix treats 250 million gallons of wastewater each day. More than 90% of Phoenix 's waste water is highly treated and reused for crops ,turf irrigation, and power generation. Twenty billion gallons of sewage effluent is used annually as cooling water by the Palo Verde Nuclear Generating Station (PVNGS) from Phoenix, Scottsdale, Tempe, Glendale, and Tolleson, Az. The cooling water is transported approximately 37 miles by pipeline from the Phoenix 91st av Wastewater Treatment Plant(WWTP) to the utility's Water Reclamation Facility (WRF) located adjacent to the cooling towers of the generating station.

    NRC requires  PVNGS to control the quantity of contaminants from  the WRF influent prior to its use as cooling water.  In 2006, the utility sampled  the influent weekly for a composite which yielded forty seven samples with Iodine-131 concentrations ranging from 11 to 96 pCi/L. Wet samples of sludge were obtained weekly from the WFR centrifuge with  I-131 in all fifty one samples and concentrations ranging from 351-2460 pCi/kg.

    I-131 is a radioactive isotope with a half life of eight days. A low dose is most damaging to children because high doses kill cancerous thyroids. Perchlorates in drinking water, or food, with I-131 cause accumulative damage to the thyroid, especially in young children.

    The use and disposal of wastewater and reclaimed water within Maricopa County is governed by the rules and regulations of the Maricopa County Environmental Health Code, Chapter2, Section 1,Regulation 2. Subsection B of the code requires all releases of wastewater, or reclaimed water, to be considered spills which must be reported to the Maricopa County Environmental Services Department. Environmental nuisances are defined in Arizona Revised Statutes .Maricopa County ,EHC, Chapter49-141-144. Maricopa County EHC Chapter 11 defines nuisances as:
        6. The pollution or contamination of any domestic waters.
        9. Water which contains deleterious or foreign substances
  In 2010, the utility  found I-131 in 44 of 48 samples of WRF influent from the Phoenix 91st Av WWTP with concentrations ranging from 12pCi/L to  85 pCi/L(Table 8.00 Surface Water). Forty six samples of wet sludge from the WRF centrifuge had oncentrations ranging from 367to 2743 pCi/kg( Table 8.11 Sludge Sediment.  

The Phoenix 2011 annual Water Quality Report showed no monitoring for 1-131 in drinking water. A 2006 deduction attributed the 1-131to pharmaceutical sources in Phoenix.

The Arizona department of Environmental Quality (ADEQ), under the provisions of ARS Title 49-10 A, shall (3) conduct research;(4) Provide information and advice on request of private persons, and others and (10) Provide for the prevention and abatement of all water pollution including that related to radiation. Under the provision of ARS Title 36-1692A, the Department shall establish an environmental exposure risk assessment program which shall:2. Provide for different strategies to reduce or prevent public health risk from environmental exposure. Effluent generated from the 23 Av WWTP is used to irrigate crops in the Roosevelt Irrigation District. Effluent from Chandler and Mesa WWTPs is used for irrigation on the Gila River Indian Reservation.

 The Arizona Department of Health Services is responsible for providing the names of certified laboratories ,capable of providing required laboratory tests on wastewater effluents or biosolids, for entities licensed by the Arizona Department of Environmental Quality. Liquid biosolids are essentially 94 to 97% water which can be removed to 30% remaining (Ref:40CFr Part 503). Phoenix liquid biosolids were cited as having a solids concentration ranging from 12 to 14% (REF: WEFTEC .05). Phoenix WWTPS  must dry sludge to 40 % solids to meet the contract with the sludge haulers(Ref: Brown Digested sludge is removed by contract hauler,SYNAGEO to local farms for agricultural land for application Treated biosolids can be produced in cake, granular, pellet, or solid/ form.

   There are two classes of biosolids: Class A reduces bacteria and is typically dried and pasteurized; Class B includes all sludge not classified as A. Both classes may contain radioactive waste (Ref: The Free Encyclopedia Wikipedia). Treated effluent is discharged
for either inedible crops, irrigation (primarily the Buckeye Irrigation District), replenish
 nature habitats, or cooling water for PVNGS.  

Some of the effluent discharged into the Salt River from the 23 Ave or 91stAve WWTPs may percolate into groundwater. In  addition to receiving some groundwater, storm water flows into the 91 Ave WWTP. According to ADEQ there were 124  biosolids land application sites registered in Arizona. 

As of April 2011,the total number of acres registered, the number of these that receive biosolids annually, and solid,or slurry, and whether Class A or Class B is being applied to Arizona agricultural land has not been made available to the public by ADEQ(Ref: Biosolids Land USE in Arizona ,Janick F. Artiola,PHD,revised 4/11).
 ADEQ published the 2124 "Permitted POTWS and TWTDS with Biosolids Disposal Requirement," with an annual biosolids production of 74,141 dry tons. The Phoenix 91st Ave. WWTP  produced 41,025 dry tons with the 23 d Ave. WWTP producing the next largest amount of 8,692 dry tons. Maricopa County produced 56,702 dry tons of biosolids. ADEQ did not include the year date this biosolid production occurred.
 According to ADEQ 's  September 2003 publication, "Biosolids/Sewage Sludge Management Program Description," all information, except confidential information, will be available to the public by ADEQ.
 On 28 April, an email was sent to the Deputy Director, Work Program Div, ADEQ, requesting the wet tons of biosolids produced for the same year annual production of dry tons were produced for which no year was given. The Deputy Director referred the request to the Manager, Water Quality Utility Field Service Unit, who replied they were not a POTWS or and TWTDS and,"feel free to contact me at 602-771-4612." On April 30, the Manager emailed citing confusion about the information request. An email to the Deputy Director on 13 May, 2012 again requested a response or notification if censorship  was in effect at ADEQ.

 ADEQ requires testing of selected biosolid contents by licensed recipients: testing for radioactive content is not included. Radiation Safety Engineering, Inc was certified on March 28, 2012 to test for Iodine (EPA 901.1). Information can be released by the Az. Dept. of Health Services in accordance with the AZ. Public Records Act. Information can be released by the Dept.of  Health Services in accordance  with the Az. Public Records Act.

 General requirements, or management practices, are needed to protect human health  and the environment from any reasonable anticipated adverse effect that may occur from any pollutant in the bulk sewage sludge ( Ref: 40 CFR 503.0 (b) (2)). Nothing precludes a state from imposing requirements, for the use or disposal of sewage sludge, more stringent than the requirements of 40 CFR when necessary to protect public health and environment for the use or disposal of sludge ( Ref: 40 CFR 503.5). 

 The concentration of 1-131 discharged from secondary treatment system liquid waste, Phoenix 91st Ave WWTP, to the circulatory water system of PVNGS is limited to 1 x 10^-6 uCi/ml which is the NRC water effluent concentration applicable to public exposure( 10 CFR, Part 20, Appendix B, Table 2). PVNGS has continually met its responsibility,  year after year, in cleaning the Phoenix 91 st Ave WWTP secondary effluent of its high concentrations of I-131.  

How many WWTPs are discharging I-131into Phoenix, Maricopa county, and the remainder of Arizona? Tritium also accompanies the I-131 in its transition from the 91st Ave WWTP,via pipeline, to PVNGS.

Sincerely, Clyde H. Stagner

   Water Services Dept. Phoenix
   Professor Doctor Majia Nadesan

Capt. Clyde Stagner's book, Hidden Tritium, can be found at
EPA Censorship and a Failure of Transparency in Government
Hidden Tritium
Environmental Activism

Phoenix Radiation Increases

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