ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY

RECEIVED

1021

NORTH

GRAND

AVENUE

EAST,

P.O.

Box 19276,

SPRINGFIELD,

ILLINOIS

~

OFFICE

THOMAS

V.

SKINNER,

DIRECTOR

SEP

0

7

2001

STATE OF ILUNOIS

Pollution

Control

Board

August 27,

2001

Dorothy

M. Gunn, Clerk

Illinois Pollution Control

Board

100W. Randolph,

Suite 11-500

7

~‘.

Chicago, IL 60601

Re: Illinois Environmental Protection Agency Comments for Docket ROl -20 Radionuclides

Dear Ms. Gunn:

Please find

enclosed

comments

pertinent to Docket R01-20, which contains

Identical in

Substance drinking water regulations for public water supplies.

The Agency very much

appreciates the opportunity to comment, and hopes thatyou will take these comments into

consideration when

promulgating the final

rule.

The Board has requested comment on several items within the regulatory proposal.

The

Agencyoffers the attached comments on the regulation

proposed bythe Board, andwould

like to

commend

the

Board on

its

proposal, and

in

specific,

Mike McCambridge,

on the

timely and excellent work he has done to prepare the proposal and to address the needs

of Region

5 USEPA so that they can participate in the Board’s comment process.

These

regulations have been long-awaited by many Illinois public water supplies as a result of a

prolonged rule making

effort at the federal level.

The prompt proposal and adoption of

these regulations by the Board will assist those supplies in working toward compliance in

a timely manner.

Should you have any questions or find that this information is not clear, please contact me

for clarification.

Sincerely,

Ms. Lou Allyn Byus

Assistant Manager

-

Field Operations

Division of Public Water Supplies

Enclosure

GEORGE

H.

RYAN,

GOVERNOR

PRINfE p

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SEP

0

7

2001

STATE OF ILLINOIS

Pollution Control Board

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY COMMENTS

.

REGARDING R01-20

NPDWR for Radiolonuclides

—

Page

7 of the Opinion of the

Board

Sections 611.130,

611.330, 611.331, 611.720, 611.731

and Appendices A, G

and

H

The Agency concurs with

the

Board’s interpretation of “variance” and “exemption” as the

federal definitions

apply

to

Illinois rules.

The Agency

appreciates

the

inclusion

of the

reverse osmosis limitations note for clarityto the regulated community, and the discussion

of effective dates, which will also assist the

regulated community.

Spelling of Exceedence or Exceedance

—

Page 8 of the Opinion of the Board

The English

language

is

a compilation of rules

with

a great many exceptions,

many of

which do not support the

Latin derivation.

(Example:

“i” before “e” except after

‘c”

—

yet

we spell neighbor, weight,

neither, either, eight, and many other words

in contradiction.)

TheAgency supportsthe spelling “exceedance”, as it is found in the Encarta World English

Dictionary.

This spelling

is

most

commonly

used

in

many existing

federal

rules

and

guidance

manuals,

and has

been

used frequently

in training materials prepared

for the

drinking water program.

Please change all

spellings of “exceedance” to be consistent.

Doubled Article

—

Page

9 of the Opinion of the Board

The Agency concurs with

removal

ofthe double article.

Subsection Cross-References

—

Page 9 of the Opinion of the

Board

The

Agency concurs with

the

Board’s

proposal to

change all

references

of “below” or

“above” to “of this

Section”, as it does

provide clarity to the

regulated community when

interpreting

complex and lengthy regulations.

SDelling of Antimony

—

Page

10 of the Opinion of the

Board

The Agency concurs with

the Board’s proposal to correct the spelling of “antimony”.