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RECEIVED
CLEFIK’S
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OFFICE
AUG
112004
STATE OF ILLJNJOIS
CITIZENS
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hL1p:iicar~1ockport.hon1e~acad.
ccrnPOIIt~tionControlBoara
AGAINST
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c~rc1ockport@usa,cCm
RUINING the
ENVIRONMENT
P.O. Box 536
Lockport, IL 60441
August
10, 2004
Ms. Amy Antoniolli
Illinois Pollution Control Board
100 W. Randolph Suite 11-500
Chicago, II. 60601
Re: Revisions to Radium Water Quality Standards: Proposed New
35
Iil.Adm. Code
302.307
and amendments to
35
fll.Adm.Cod.e 302.207 and
302525
R04-021 Rulemaking —Water
Before the Illinois Pollution Control Board
Dear Ms. Antoniolli:
Citizens Against Ruining the Environment-C.AR.E. is located in Will County. We
understand as part of tb.e Water rulemaking process before the Illinois Pollution Control
Board, a change is being consideredwhich would involve the increase from 1. Pico curie
to
5
PIco curie’s per
liter
and apply these standards specifically to surface waters used for
public and food processing water supplies.
Last year the sprcading of Sludge
—
biosolids
-
was brought to our attention. We
investigated this issue, and found out that this contaminated sludge has been used on Will
County Farmland for over thirty years. We are fer iiizing with. byizoducts ofindustrial
and human sewage.
Environmental Science
defines sludge as a “viscous, semisolid mixture ofbacteria-and
virus-laden organic n~atter, toxic metals, synthetic organic chemicals & settled solids
removed from domestic & industrial. waste water at sewage treatment plants.~’
C.A..R.E. is extremely concerned. with the proper treatment ofthis sludge prior to bein~
applied to land. We believe that sludge farming is only transferring pollutants from thie
treatment plant to the soil, air and ~ound water f~ornthe disposal site.
~—l’~—Ci4;2:~’IPM
~i~T7~243E:~
Many of us arc residents in Lockport. Until last year, the water in our area had
dangerously high levels ofradium. Th.i.s originally came to our attention approximately 4
years ago because one ofus read the small pri.n.t on. the back ofour water bills, and
discovered that a. few dollars had been collected on each residents monthly
water
bill that
went into a “radium bond fund.” The back ofthe bill also stated that:
A dose ofthc
5
pci/L ingested o~em an ext~n~ed~ei~d ‘d~i’tirt~~emay result in the
development ofbone cancer in a very si-nail, portion ofthe population...” This
information alone would be alarming to most people. however, farther investigation
indicated, that these outrageously high levels ofradium were known of and allowed for
over two decades. We also discovered that the verbiage used by the City of Lockport to
explain the radium situation, was flawed. The recommendation. submitted by the LEPA for
municipalities with high radium levels stated that: “At the levels ofradium detected the
short term risk is minimal and no special precautions need to be taken by the consumer
____________________ We have questioned the C.ity as well as thc Agency a.s to what they
consider an “extended period oftime” to be, but no one has given. us any answers.
Back i,n 1998 an EPA Regulatory Manager was quoted in a Chicago Tribune Article that
“...Radium does damage to the cells...” an,d “..there are molecular similarities to
calcium
“
Since a portion of the radium ingested retrains in tb.e bone, is it safe to
consume and bath in this water for
5
years? Ten? The Illinois Pollution ControlBoard
had originally ruled on the clean up ofradium,,., over a decade ago. They instructed
Lockport to institute certain changes in a “timely maimer.” Loc.kport instead pleaded
hardship, and proclaimed that they needed an extension on more then one occasion due to
the ~-owth in the area, and the capital imnprovements that they had to implement due to
this development.
We would appreciate your comments tp the questions below:
-Many pathogens cause diseases that sicken, cripple and kill humans. What type ofpre-
treatment is in place for viruses, bacteria, protozoa and fungi. etc.?
-What type of testing is currently in pace for heavy metals prior to land fanning?
-
Does this sludge contain: dioxin, PCBs such, as DOT, nickel, asbestos or lead? What
other types ofpollutants are in this sludge?
-What process is being utilized for testing areas that have been land farmed for several
years? I-low often are the areas tested?
-Radium is a known carcinogen. Should water quality standards allow a known
carcinogen to be discharged into Illinoi.s waterways at advanced levels?
-Has the effect ofradium on aquatic/wildlife been established, at the revised levels?
-Has anyone presented studies that show radium at these levels to be safe for aquatic or
human life?
1
~
2
L~.
.,.
t.
-We already face the prospect ofnever being able to consume fish in Illinois due to the
mercury dispersed from
Coal Fired Power
Plants.
Do
we wish. to add radium
to
the mix?
-Should. cost even be considered,
when we are talking about protection oflife forms?
-Shouldn’t
the
safety and welfare ofthe illinois Residents be the main priority?
As there are many unanswered questions re: sludge pollutants and radium standards in
water that should be addressed. prior to making any recommendations, Citizens Against
Ruinin.g the Environment requests that additional investigation into the sludge and
radium discharging, and land spreading be completed prior to changing any pico curie
limits.
.
Sincerely,
iDirectors
Carol Stark
Ellen Reridulich
Sandy Burcenski
Wendy Viacak
838-1483
834-1611
838-1442
838-0622