Former Carnotite Reduction Company Frequently Asked Questions
1. GENERAL REMEDIATION PROJECT QUESTIONS
1.A Why is the remediation occurring now?
1.B How long will the remediation take to complete?
1.C What time of day will work be conducted?
1.D Who is conducting the remediation and how are they being selected?
.1E What are the clean-up levels for the site?
1.F What will happen to the site after remediation is complete?
1.G How will the excavation and utilities be affected during winter?
1.H Will a Rodent Control Program be implemented during excavation?
1.I What work is going on at the site now?
2.A How will the public be informed of the remediation progress?
2.B Will minority-owned businesses have opportunities to work on this project?
2.C Will this project hurt area property values?
3. TRANSPORTATION AND ACCESS TO AREA FACILITIES
3.A How will access to the Metra 27th Street station be impacted?
3.B What transportation route will be used by trucks?
3.C How will soil in the trucks be covered during transportation?
4. SAFETY AND MONITORING PROCEDURES
4.A What site safety precautions are being implemented?
4.B Is this contamination a health hazard now?
4.C Who is overseeing the remediation?
4.D What measures will be taken to control dust exposure?
4.E How will public dust exposure be monitored?
4.F Will other types of monitoring be conducted?
4.G Could a circus-type tent over the area be used during excavation?
4.H How will compliance by the remediation contractor with local, state, and federal regulations be enforced?
4.I During excavation, how much radiation will area residents be exposed to daily?
4.J What actions can area residents take to minimize their dust exposure during excavation?
5. DRINKING WATER PROTECTION AND STORMWATER PROTECTION
5.A How will stormwater be managed?
5.B Is the drinking water supply to the area safe?
1. GENERAL REMEDIATION PROJECT QUESTIONS
1.A Why is the remediation occurring now?
The remediation is occurring now after years of planning, coordinating, and permitting with the Illinois Emergency Management Agency (IEMA). When IEMA first issued the City’s radioactive material license in 2015, they triggered the need for the removal of the radioactive material. Before progressing to the removal phase, the remediation plan (also referred to as the decommissioning plan), required IEMA approval. This approval was received from IEMA in February 2021.
1.B How long will the remediation take to complete?
Construction activities are expected to take approximately 13 to 15 months to complete from the excavation contractor mobilization to the site during the summer of 2021.
1.C What time of day will work be conducted and will the construction be very loud?
Although certain activities may begin earlier, every effort will be made to conduct significant noise-generating activities between 8 am to 8 pm. While large earth-moving equipment will be used, this project does not involve high noise generation from demolition activities such as building tear downs. Some concrete and asphalt from within the excavation footprint will be removed as the excavation progresses. The concrete and asphalt will be broken down with a jack hammer or hydraulic breaker attachment to an excavator.
1.D Who is conducting the remediation and how were they selected?
The remediation is being conducted by F.H.Paschen. F.H. Paschen has retained Arcadis, Tecnica Environmental Services, and Griffin Dewatering to assist with the environmental aspects, earthwork, and dewatering and groundwater treatment for the project, respectively. Tecnica is a City of Chicago minority-owned business.
The Department of Assets, Information and Services (AIS) with City of Chicago prepared construction bid documents to procure a remediation contractor. The City advertised the bid in late fall 2020 and expects to begin field work in summer 2021. The bid documents identify the health and safety, related project experience, and radiological licensing requirements that contractors must have to perform the project. Prior to the award, the City conducted a vetting process to determine if the selected Contractor meets City requirements and has not violated any City or sister agency policy, codes, state, federal, or local laws, rules or regulations and have not been subject to any debarment, suspension or other disciplinary action by any government agency.
1.E What are the clean-up levels for the site?
The site is contaminated with Radium-226, Uranium and Thorium-230. IEMA set the site-specific soil clean-up levels in the City’s radioactive material license, which are provided below.
- Radium-226 - 5.9 picocuries per gram (pCi/g)
- Total uranium (U-234, U-235, and U-238) – 22 pCi/g to a depth of 5 meters (approx. 16 feet) and 52 pCi/g below a depth of 5 meters
- Thorium-230 – 5.5 pCi/g
These clean-up levels factor in the presence of background concentrations as radium, uranium, and thorium are all naturally occurring elements and are based on IEMA, US Environmental Protection Agency (USEPA) and/or Nuclear Regulatory Commission guidance.
1.F What will happen to the site after remediation is complete?
The excavated area will be backfilled with clean stone or soil and the site will remain fenced off until redevelopment occurs. Although the radiological contamination associated with Carnotite will have been addressed, other portions of the site including the green space still contain more traditional contaminants typical of urban settings, including lead and polynuclear aromatics (PNAs). This contamination will be addressed during site redevelopment.
1.G How will the excavation and utilities be affected during winter?
Utilities in the excavation area have already been abandoned and will not be affected. The excavation will continue through the winter season.
1.H Will a Rodent Control Program be implemented during excavation?
Prior to the start of construction, AIS will work closely with the Department of Streets and Sanitation and F.H. Paschen to identify potential rodent issues that may be caused by the disturbance from the excavation. The identified rodent issues will be addressed with a Rodent Control Program, with an emphasis on protecting adjacent private property.
1.I What work is going on at the site now?
Excavation of the radiologically contaminated soil will not begin until IEMA has reviewed and approved the construction plans and procedures and authorizes work to start. Prior to this authorization, certain site preparation activities are allowed and occurring now, such as utility abandonment and installation, addition of fencing, clearing and grubbing, and installation of support facilities. These activities are conducted in accordance with the City’s Radiation Monitoring Ordinance (Section 11-4-1100). More details on procedures required for underground work in the Carnotite area are provided here: Carnotite Underground Work.
2.A How will the public be informed of the remediation progress?
Prior to the start of construction, the City held a community meeting on June 1, 2021. The City will provide regular progress updates to the project website (www.chicago.gov/carnotite) during construction. These updates will include all air monitoring results and excavation progress. Contact information for questions or concerns will be made available on the website. In addition, the City is continually updating the mailing list for the project to ensure area residents and businesses are informed about community meetings and other updates.
The City is providing a live video feed from an on-site video camera on the Carnotite website during site remediation.
Throughout the remediation, the City will continue to answer questions through email (AIS_EHS_Notifications@cityofchicago.com) and its outreach telephone number (312-744-0500). Residents without computer or internet access may request information including dust monitoring data be mailed to them by calling the outreach telephone number listed above.
2.B Will minority-owned businesses have opportunities to work on this project?
On November 13, 2020, AIS held a virtual meet and greet for MBE contractors to present their company qualifications to other non-MBEs. A significant portion of the work is not available to MBEs due to the specific technical requirements of the work. However, the site remediation contractor will hold a minimum of two job fairs to discuss the types of subcontracting work available for this project. The site remediation contractor will also work closely with community organizations and the Alderman’s office to increase hiring opportunities for community members. While the City cannot direct the contractor in hiring procedures, they can work with the contractor to meet with the Alderman’s office to explore community hiring options.
F.H. Paschen will be holding a virtual job fair through Microsoft Teams on July 28, 2021 from 11:00 a.m. to 12:30 p.m. A second job fair will be held in December 2021 or early 2022. F.H. Paschen will be posting information on their social media accounts as well as sending flyers for distribution through Alderman Sophia King’s office and F.H. Paschen’s Workforce Partners.
2.C Will this project hurt area property values?
Cook County is the property tax collection agency for homeowners in the City of Chicago. The City of Chicago is not able to offer tax relief or incentives. The remediation project provides removal of radioactive soil followed by a large development. This improvement may result in increased property values in the area around the site. AIS has asked the Cook County Assessor’s Office to review this question along with information about the remediation project. The FAQs will be updated when the Assessor’s office provides information regarding this question.
3. TRANSPORTATION AND ACCESS TO AREA FACILITIES
3.A How will access to the Metra 27th Street station be impacted?
Two pedestrian walkways provide access to the station, one from the north (26th Street) and one from south (Vernon Avenue/Ellis Avenue). On July 26, 2021, the north walkway was permanently closed. The station is now accessible only from the south walkway. Prior to closure, pedestrian wayfinding signage was installed. These walkways are depicted in the Project Fact Sheet.
3.B What transportation route will be used by trucks?
During construction, it is expected that trucks will enter and leave the site at 27th Street and Ellis Avenue and travel through the former Michael Reese Hospital site via S Cottage Grove Ave or S Lake Park Ave to access Lake Shore Drive from 31st Street. Flaggers and barriers will be provided at truck crossings to provide pedestrians with safe access to the Metra Station from the south walkway. Trucks will be decontaminated, run through a wheel wash system, and prior to leaving the site.
It is expected that one lane is always open on the 31st bridge to accommodate truck traffic. However, if the 31st Street bridge is under construction and cannot accommodate trucks, the alternative route could include 31st Street west to Dr. Martin Luther King Jr. Drive north to Interstate 55.
3.C How will soil be loaded and transported to the disposal facility?
Our current plan (pending IEMA approval) is to transport and dispose a majority of the radioactive waste at the Waste Control Specialists (WCS) radioactive waste licensed landfill in Texas. The waste will be placed in specially constructed radioactive waste bags (IP-1 bags) that will be packaged and sealed onsite before off-site transportation. An example of an IP-1 bag from another radioactive waste remediation site in Illinois is shown in this photograph.
The bags will be stored in a protected area until they are ready for loading and transport by trucks. The sealed bags will be secured on trucks and transported to railcars at an off-site intermodal yard to WCS in Texas for disposal. Non-radioactive waste will be transported in tarped trucks to a local landfill.
Each truck will pass through an automated wheel wash and be subject to thorough inspection by the on-site transportation and disposal coordinator prior to leaving the site to ensure no loose soil is adhering to the truck. If spills occur, the contractor will clean up off-site spills or dirt tracked onto City rights-of-way or streets within an hour of notification of the spill. In addition, significant spills while transporting the material will be cleaned up by the transportation company.
4. SAFETY AND MONITORING PROCEDURES
4.A What site safety precautions are being implemented?
All personnel on the site will be adhering to health and safety plans approved by the Illinois Emergency Management Agency. Site safety briefings will occur every day work is being conducted at the site. As needed, additional meetings will be held to immediately address safety concerns (unsafe acts, near misses, stop work condition) or a change in scope. Weekly progress meetings will be conducted to facilitate communication of short-term and long-term planning, including work sequencing and associated staffing and safety requirements.
All personnel have the authority to “STOP WORK” if they see an unsafe act or condition. Work conditions will be discussed in safety briefing immediately after stopping work. All necessary changes will be made before resuming work to ensure safe working conditions.
Additional precautions include dust monitoring in the work area and site perimeter and radiological air particulates along the site perimeter. Please refer to FAQs 4D, 4E, and 4F for additional details on these dust mitigation and air monitoring efforts.
Area pedestrians will be protected through extensive site signage, construction flaggers, barricades and construction fencing.
4.B Is this contamination a health hazard now?
No. In 1979, the State of Illinois Department of Health, Division of Radiological Health (a predecessor to the Illinois Emergency Management Agency (IEMA), in cooperation with the U.S. Environmental Protection Agency (EPA), conducted a radiological surface survey of the northern portion of the Michael Reese property near 26th Street, and concluded that the contamination did not pose an immediate health hazard but should be removed prior to any future construction. Most impacted material is limited to the top 5 feet below ground surface (bgs) but extends to approximately 14 feet bgs within one area in the northwest portion of the Site.
4.C Who is overseeing the remediation?
IEMA is the regulatory agency that will be overseeing the remediation activities at this site. The remediation work is being completed under an IEMA-issued decommissioning license and in accordance with an IEMA-approved decommissioning plan. Prior to starting work, the contractor’s work plans will be submitted to AIS and IEMA for review and approval. IEMA will conduct routine site inspections for the duration of the project.
The City (department of AIS) will be managing the remediation project and has also retained an independent remediation oversight and construction management consultant to oversee work performed by the remediation contractor. AIS’ oversight representatives, including a radiation safety officer, have successfully conducted radiation-contaminated soil remediation and monitoring at multiple sites throughout the U.S. Examples of this experience include three of the Ottawa, Illinois, Radiation Areas and many sublocations associated with the Lindsay Light Superfund sites. AIS’ oversight representatives are applying that experience to the Carnotite site. Depending on the number of activities and work each day during construction, 2 to 4 oversight personnel will be on site monitoring activities.
These oversight services will include providing a Radiation Safety Officer (RSO) to monitor for radiation safety, providing an on-site presence for all license-related activities, monitoring for the remediation contractor’s compliance with bid document including dust control requirements, performing air monitoring, conducting field surveys and sampling, and preparing weekly progress reports. The City’s RSO will have the authority to stop all work activities if radiation monitoring detects concentrations above action levels.
4.D What measures will be taken to control dust exposure?
The primary measure currently proposed (pending IEMA approval) to control dust exposure is to eliminate or minimize operational activities that contribute to dust generation, such as on-site staging and blending of soil. In the proposed approach, the contractor will direct-load a majority of the waste into radioactive waste bags (IP-1 bags) that will be packaged and sealed onsite before off-site transportation to the Waste Control Specialists (WCS) radioactive waste licensed landfill in Texas.
Based on experience at similar sites, other sources of dust generation are from on-site truck and vehicle traffic. The contractor will be required to implement dust suppression measures to minimize dust generation from activities such as excavation, stockpiling, loading, and on-site truck traffic. The contractor will be required to cease dust-generating activities during periods of adverse weather (e.g., sustained winds exceeding 20 miles per hour averaged over a 10-minute period). Any time visible dust is observed at the site, the contractor will be required to take actions within 20 minutes to stop the generation of visible dust. Keeping a clean haul roadway, misting water on site roadways as needed and routing trucks through the wheel wash prior to leaving the site will minimize dust generation at the site. General dust control actions may include water misting, covers, crusting agent, or equivalent as well as regulating equipment speeds and limiting traffic volume.
A third measure will include use of shade cloth on perimeter fencing, which is 8 to 10 feet in height, and covering inactive soil stockpiles with plastic sheeting, which will further assist in minimizing dust levels at the site.
All of the measures discussed above have been used at multiple remediation sites and shown to be effective in controlling dust generation at sites. For example, Tetra Tech regularly uses these dust control measures at the Ottawa Radiation site in Ottawa, Illinois, to control dust generation during remediation. The contractor’s construction plans and procedures for dust control are currently being prepared. Additional details will be shared once approved by IEMA.
4.E How will public dust exposure be monitored?
Dust monitoring requirements will be included in the Health and Safety Plan/Radiation Protection Plan (HASP/RPP) and Field Sampling Plan prepared for the project that will be reviewed and approved by IEMA prior to starting work. These plans specify a dust action level for public exposure at the site perimeter based on the U.S. Environmental Protection Agency National Ambient Air Quality Standards for particulate pollution from Title 40 of the Code of Federal Regulations (CFR) Part 50.6, which are set to be protective of human health. The site-specific action level is 150 micrograms per cubic meter (μg/m3) per 24 hours based on respirable particles, with diameters that are generally 10 micrometers and smaller.
However, additional separate radiological monitoring is required as dust monitoring data alone cannot be used to determine radiation concentrations. This is because dust potentially generated from the site will not always contain radioactive particulates and a correlation is not possible. Please refer to FAQs 4F for additional details on the required separate radiological monitoring.
The site-specific dust action level of 150 μg/m3 is utilized as an early warning sign of dust control issues. During construction, dust suppression measures such as water misting will be actively applied to minimize dust generation. However, if site action levels are exceeded, work will be stopped, and dust suppression measures will continue until dust levels are below the established action level.
Dust monitors will be run continuously along the site perimeter (fence line monitoring), including during non-working hours. Monitoring will be reviewed in real time and alarms are set to notify the oversight contractor if the site action level is exceeded. Each evening, the dust monitoring results for the previous working hours will be downloaded and converted into a format that is easy to understand and posted on the project website.
At a minimum, the City’s remediation oversight consultant will perform dust monitoring activities in two areas 1) within the active work area, and 2) along the site perimeter. The details on dust monitoring performed by the oversight consultant in the work area and at the fence line are presented below.
- Work area monitoring- conducted by use of continuous, real-time, direct-read particulate monitors capable of measuring respirable dust particles. The dust monitors will be placed on tripods to sample air at the breathing zone. They will be run continuously each day during excavation and soil management activities and be relocated within the work area as necessary to collect the most representative sample near work activities.
- Site perimeter monitoring– conducted by use of four continuous, real-time, direct-read dust monitors deployed at the site perimeter and placed approximately in cardinal directions. Locations of perimeter air monitoring stations may be adjusted as necessary to ensure at least one dust monitor is upwind of the site and one dust monitor is downwind of excavation and soil management activities at the site. The dust monitors will be used in conjunction with a telemetry system to continuously record and monitor dust levels in breathing zone ambient air at the site perimeter.
4.F Will other types of monitoring be conducted?
In addition to dust monitoring, the City’s remediation oversight consultant will perform radiological air particulate monitoring at the site perimeter. The radiological air particulate monitoring will be conducted using continuous low-volume particulate air samplers and real-time dose rate survey meters. Perimeter monitoring will begin prior to the start of construction and continue during construction to monitor potential airborne concentrations of radium, uranium, and thorium. The samples will be collected and screened for anomalies on a weekly basis as well as composited for a quarterly average to demonstrate compliance with IEMA’s public radiation dose limits. The frequency of dose rate surveys will be determined by IEMA prior to the start of construction.
The City’s remediation oversight consultant will also sample the discharge effluent from the groundwater treatment system to monitor compliance with the Metropolitan Water Reclamation District of Greater Chicago (MWRDGC) discharge criteria. Groundwater samples from on-site monitoring wells and stormwater samples may also be collected if required by IEMA or Illinois Environmental Protection Agency.
4.G Could a circus-type tent or tarp over the area be used during excavation?
A circus tent (sprung structure) is a large undertaking and is typically used for environmental remediation for soil containing volatile contaminants like benzene. These contaminants cannot be seen and are more difficult to control. Dust from excavations, including dust with radioactive materials, is not volatile and may be effectively controlled through water spraying and stopping work under adverse wind conditions.
Tarps over an excavation will be difficult to secure and may become airborne and potentially migrate offsite, which would pose hazards to the community. Please refer to 4D for dust control measures that will be implemented throughout construction.
4.H How will compliance by the remediation contractor with local, state, and federal regulations be enforced?
Regulatory agencies will be performing inspections on a routine basis. As the lead regulatory agency, IEMA will conduct site inspections throughout the duration of the project to monitor compliance with all application regulations including dust control. If compliance issues are identified, IEMA may issue a notice of violation and/or require work stoppage until the issues are resolved to their satisfaction.
The Chicago Department of Public Health (CDPH) will also conduct site inspections for compliance with local regulations, including the City’s Construction Site Cleanliness Ordinance (Section 13-32-125). AIS will work with CDPH to ensure that regular site inspections are conducted.
Please refer to FAQs 4E and 4F for additional monitoring activities that will be conducted during remediation.
4.I During excavation, how much radiation will area residents be exposed to daily?
Air particulate monitoring and direct gamma radiation measurements at the site perimeter will be used to demonstrate that radiation levels are well below the public dose limits set by IEMA. These dose limits and methods for demonstrating compliance can be found in 32 Illinois Administrative Code (IAC) 340.310 and 320. The site radioactive materials license requires that these measurements and calculations be submitted quarterly to the regulators for review and approval. The results will be posted on the Carnotite website upon regulatory approval.
Under the site radioactive material license, IEMA set radium, uranium, and thorium air particulate action levels for site perimeter monitoring equal to the Nuclear Regulatory Commission air effluent concentrations listed in 10 CFR 20, Appendix B, Table 2. These limits are 9.00 E-13 microcuries per milliliter (µCi/ml) for radium-226, 9.00 E-14 µCi/ml for uranium, and 2.00 E-14 µCi/ml for thorium-230. These action levels are equivalent to the concentration that, if inhaled or ingested continuously over the course of a year, would produce a total effective dose equivalent of 50 millirem (mRem), which is approximately equivalent to 5 chest x-rays per U.S. Nuclear Regulatory Commission guidance (link is provided below). This action level is conservative because the IEMA required annual public total effective dose limit in 32 IAC 340.310 is 100 mRem. The conservative air particulate action levels will ensure that the public is not exposed to radiation levels in excess of dose limits set by IEMA to ensure public health and safety.
For general information regarding radiation, including natural radiation sources, see the following information from the EPA and NRC:
4.J What actions can local residents take to minimize their dust exposure during excavation?
While dust is not expected to be a problem for local residents during remediation, there are a number of ways everyone can reduce their exposure to regularly-occurring dust in the area and make their homes healthier.
- Regularly clean your floors and wipe down any counters and surfaces to keep them free of dust, since dust may settle on floors and surfaces in your home.
- Make sure all family members remove their shoes before entering your home to help keep dust outside.
- You may wish to keep windows closed on very dry and windy days when dust is visible.
Within the City of Chicago there are many potential uncontrolled sources of non-radiologically contaminated dust. Radiological air particulate monitoring at the site perimeter will be conducted continuously to demonstrate radiation levels are well below the public dose limits set by IEMA.
5. DRINKING WATER PROTECTION AND STORMWATER PROTECTION
5.A How will stormwater be managed?
The Contractor will be required to implement a Stormwater Pollution Prevention Plan (SWPPP). The SWPPP will include soil and erosion control measures within the work area to prevent stormwater runoff from coming into contact with disturbed areas that may be contaminated. Control measures will include silt fencing, stormwater drain inlet protection, and berms and coverings for any soil stockpiles. Stormwater that comes into contact with excavation areas will be either treated onsite in a treatment system prior to discharge to the sanitary sewer as permitted by the Metropolitan Water Reclamation District of Greater Chicago (MWRDGC) or containerized and disposed of off-site at an approved disposal facility.
5.B Is the drinking water supply to the area safe?
Yes. The water supply mains providing drinking water from Lake Michigan are located west of the contaminated areas at the site and do not cross the contaminated areas. Water mains are also under pressure. Any cracks in the pipes will result in water exiting the pipe. The pressure inside the pipe also prevents surrounding materials (soil or groundwater) from infiltrating the pipe.