2019-05-24_PERMIT FILE - M2019027 (2)

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Environmental Impacts of Water Treatment Chemicals at Industrial Sand Mines M C-43 BARR neurological symptoms reported by area residents. The centration of the water contained in the wet sand piles ATSDR, in conjunction with the New Jersey Department and filter cake. Between biodegradation and dilution, of Health and Senior Services, conducted an extensive the concentration of acrylamide monomer in the quarry study of the site, and concluded "the site poses no public pit will be virtually undetectable, based on the kinetic health hazard. Community health concerns (i.e. neuro- model. logical conditions and cancer) are unlikely to be associ- ated with exposures to site-related acrylamide"11 The acrylamide monomer readily biodegrades in water and soil (acrylic acid and ammonia are break down prod- conclusion ucts). As micro-organisms acclimate,they become more Polyacrylamide anionic flocculants and polyDADMAC efficient at removing acrylamide from soil and water. At cationic coagulants are two commonly used water treat- our modeled wet plant, we expect significant biodeg- ment chemicals used at industrial sand mines. Both radation of acrylamide to occur in the soil beneath the chemicals contain trace amounts of residual monomers wet sand piles and filter cake so that concentrations of resulting from their manufacture. acrylamide reaching groundwater will be insignificant. A monitoring program has been in affect at mines in The EPA classifies the acrylamide monomer as a prob- Chippewa County, Wisconsin,for over a year. To date, able human carcinogen and has established a de facto the acrylamide monomer has not been detected in any National Primary Drinking Water Regulation of 0.5 ug/L groundwater samples. for the acrylamide monomer. Because the DADMAC monomer is readily soluble in There are no federal or state DADMAC concentration water, and has poor adsorption to minerals and organic limits for either surface water or groundwater, presum- matter,the majority of the polyDADMAC coagulant will ably because there are fewer toxicity concerns. Conse- exit the clarifier/sand wash loop with the filter cake. A quently, very little chemical data are available to perform relatively small proportion of the coagulant consisting a detailed mass balance and risk evaluation. This leads of the DADMAC monomer will enter the clarifier/sand us to conclude that the compound is unlikely to result in wash loop and be recycled. We expect a steady state significant environmental effects. concentration to form in the clarifier and sand wash loop. This will be the same as the initial concentration of The acrylamide monomer is readily soluble in water, the water contained in the wet sand piles and filter cake. and has poor adsorption to minerals and organic matter. Thus, while the majority of the polyacrylamide floc- The DADMAC monomer readily biodegrades in water culant will exit the clarifier with the solids in the under- and soil. We expect significant biodegradation of DAD- flow, the vast majority of the acrylamide monomer will MAC to occur in the soil and groundwater beneath the flow through the clarifier and be recycled. We expect wet sand piles and filter cake. a steady state concentration to form in the clarifier and While no practical EPA-approved analytical method exists sand wash loop. This will be the same as the initial con- for acrylamide, a laboratory has been found that has 11 www.atsdr.cdc.gov/HAC/pha/BelvidereSandGravelSite/ developed a test method capable of analyzing for acryl- Belvidere_Sand_Gravel_Site%20HC%208-20-2008.pdf amide to the EPA's de facto drinking water standard. Page 6 © Barr Engineering Co.2013 Keenesburg Project—Limited Impact 110 Application_May 24,2019