VILLAGE
    OF
    NAHON
    24555
    S. NAVAJO DRIVE. CHANNAHON, ILLINOIS 604 10-3334
    (815) 467-6644
    •
    FAX 467-9774 swww.channahonPC~~V~D
    CLERK’S
    OF~I~
    August 12, 2004
    6 2U04
    STATE OF ILL1~Oi~’
    ~l1ut1onControi~o~-~j
    Ms. Dorothy M. Gunn, Clerk
    Illinois Pollution Control Board
    James R. Thompson Center
    100 West Randolph Street Suite 11-500
    Chicago, Illinois 60601
    Re.
    Docket R04-21
    ~-pC~
    Revisions to Radium Water Quality Standards: Proposed New 35 ILL.
    Adm. Code 302.307 and Amendments to 35 ILL. Adm. Code 302.207 and
    302.525
    Dear Ms. Gunn:
    The Village of Channahon would like to submit the following comments in support
    of the above proposed rulemaking, which would amend the water quality
    standard for radium from 1 picocurie per liter to 5 picocuries per liter and change
    its applicability to only public and food processing water supplies. The Village of
    Channahon owns and operates a public water supply system and a public
    wastewater treatment system. The source water for the public water supply is
    groundwater pumped from shallow and deep aquifers. The water pumped from
    the deep aquifer currently exceeds the maximum contaminant level (MCL) for
    combined radium 226 and radium 228. Channahon currently uses two methods
    to treat its potable water to comply with the MCL: blending with low radium
    content water and coprecipitation with hydrous manganese oxide (HMO) followed
    by filtration. Both of these methods were identified in the Village’s Compliance
    Commitment Report submitted to the IEPA. The HMO plant is currently in use
    after receiving an operating permit from the IEPA.
    While the Village does not have any data on the radium levels currently in its
    effluent from the wastewater treatment plant, it is generally believed radium
    entering the treatment plant is partially deposited in the sludge and partially
    released in the effluent. It is important to note that the amount of radium
    reaching the wastewater treatment plant after bringing the potable water supply
    into compliance with the radium MCL is expected to be the same as it was before
    Page 2
    Ms. Gunn
    August 12, 2004
    treatment of the potable water for radium removal. The source water has not
    changed and therefore the radium levels should remain as before. The only
    difference from what occurred before treatment for radium is that the radium is
    removed before entering the distribution system and then recombined with
    domestic sewage in the wastewater stream. The blended water continues to
    contain radium below the MCL of 5 picocuries per liter, but quite possibly higher
    than the existing rule for discharge to surface waters of I picocurie per liter.
    This revision is necessary to allow us, and other similarly affected water
    treatment facilities, to operate without violation. Also, it would allow potable
    water treatment methods for radium removal approved by the IEPA to exist
    without the unintended consequence of requiring the wastewater treatment
    facility to treat for radium in its effluent or not accept waste containing low levels
    of radium at all. Additionally, it is unclear if any danger exists from the discharge
    of radium to water other than public water supplies or food processing.
    According to information obtained from the Illinois Department of Public Health,
    radium is only a danger when ingested. Radiation received externally is
    insignificant since the skin blocks the alpha radiation. Again, the Village of
    Channahon supports the IEPA’s proposal to revise the current radium water
    quality standards.
    Sincerely,
    Edward S. Dolezal,
    Director of Public Works
    cc:
    Joe Cook, Village President
    Village Board of Trustees
    David Johnson, Village Administrator

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