~_~l—C4:2:
    2lPJ:~
    RECEIVED
    CLEFIK’S
    ~7742
    OFFICE
    AUG
    112004
    STATE OF ILLJNJOIS
    CITIZENS
    Wcb
    Si t~
    hL1p:iicar~1ockport.hon1e~acad.
    ccrnPOIIt~tionControlBoara
    AGAINST
    ~-M~i1
    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

    Back to top