ILLINOIS POLLUTION CONTROL BOARD
October 30,
1980
IN THE MATTER OF:
PETITION TO AMEND CHAPTER
6:
)
R78-8
PUBLIC WATER SUPPLY, RULE
305,
BY THE VILLAGE OF ORANGEVILLE
)
Final
Order of Dismissal:
OPINION AND ORDER OF THE BOARD
(by J.D. Dumelle):
The Village of Orangevilie (Orangevilie) proposed that the
Board exempt certain public water supplies from the mandatory
chlorination requirement of Rule 305 of the Pollution Control
Board
Rules and Regulations, Chapter
6:
Public Water Supplies
(Rule
305).
Public hearings were hold in
Freeport on December
19,
1978,
and in Springfield on January
9,
1979.
On January 23,
1980,
an Economic Impact Study
(EIS) was submitted to the Board
by the Illinois Institute of Natural Resources in compliance with
Public Law 79-790.
Thereafter,
two additional hearings were held
to consider the EIS.
One was held on February
8,
1980,
in
Oregon.
The other was held on February
22, 1980,
in Chicago.
Over eight hundred pages of testimony and eighty exhibits were
entered into the record.
In its present form Rule 305 requires all public water
supplies, except those purchasing treated water containing
adequate chlorine, to chlorinate
the water before it enters the
distribution system.
Residuals of chlorine must be maintained at
levels sufficient to provide adequate protection, as determined
by the Environmental Protection Agency (Agency).
Rule 305 was enacted in December of 1974.
Illinois,
and the
six other states which then required chlorination,
did so based
essentially on three factors:
1.
Existing engineering knowledge indicated chlorination
to he technically feasible and immediately adoptable;
2.
Technical reports
indicated overall effectiveness; and
3.
Chlorination was deemed to be the best available safety
measure against potential contaminants.
(EIS 1—2).
The requirement was enacted despite the awareness of the
potential hazard of carcinogens resulting from the reaction of
chlorine with waste hydrocarbons in the water systems.
At that
time the Board found
“that
chlorination
is needed to prevent very
dangerous water—borne diseases...
.
The Board feels that not to
require chlorination at this time would he turning its back on
a
known danger to protect against
a potential
one.”
—2—
However,
the Board went on to point out that it “is well aware of
its responsibility to change the regulation as more information
becomes available and will endeavor to do so”
(Opinion in R73—13,
15 PCB 145, January
3,
1975).
In an amended petition dated January
3,
1979, Orangeville
proposed a change to Rule 305, which has given the Board the
opportunity to look once more at the chlorination requirement.
The amended rule,
if adopted, would state that “Rule
305, may not
apply to public ground water supplies that have demonstrated the
ability to provide water that is safe for human consumption.”
The reasons for this change, and the subject of most of the
testimony at the hearings,
fell into three general areas of
impact:
economic, aesthetic,
and health.
Each of these areas is
discussed below.
Economic ~
The economic cost of chlorination is of considerable
importance in evaluating the proposed amendment to Rule 305.
It
is also an area of significant dispute.
The Economic Impact Study includes a detailed analysis of
the cost of chlorination based upon USEPA economic information
(EIS 48).
The total capital and operating cost of chlorination
was found to be 3.25~/1000gallons at a one million gallons per
day
(gpd)
design capacity (EIS 49).
This was the smallest system
considered,
and larger systems had lower unit costs.
Thus, based
upon an average daily usage of 100 gpd/person, the additional
cost per user for chlorination would be about $1.19/year.
This
figure corresponds with the testimony of Mr.
Isoe,
one of the
authors of the study, that the average increase in cost per user
would be in the range of one to three dollars per year
(R.580).
There
is some difficulty in applying these figures to the
communities most affected by the mandatory chlorination
requirement, however,
since 76 of the 99 communities presently
not chlorinating have fewer than 500 people
(R.698).
This
translates to approximately 50,000 gpd, considerably under the
lowest usage
level upon which the EIS figures are based.
Fortunately, the record includes considerable testimony
regarding the costs of small
systems.
Mr. Markwood, the Manager
of the Agency1s Division of Public Water Supplies, testified that
the capital cost of chlorination for a system designed for a
community of 500 people would be in the range of six or seven
hundred dollars
(R.188).
Mayor Bostian of Orangeville, however,
placed the costs considerably higher:
$1,000 for a separate
chlorination building,
$800 for engineering
fees, $500—$2,000 for
equipment (depending on whether gas or liquid chlorination is
used),
and $30—$50 for a home filter to remove the chlorine
(R.277—20).
Bradley Heights has apparently spent $1,500 on
engineering fees alone
(R.297-8),
Rock City,
a town of 250,
spent $4,000 for a complete system
(R.168—9).
—3—
These higher figures for small towns appear to be greater
than necessary for an effective system.
One reason for this is
that both Mayor Bostian and Mayor Welling of Rock City included
the cost of
a separate building, but that should not be necessary
for
a small system.
Liquid chlorination, using
a
hypochlorinator,
is generally recommended
for such systems and
does not require
a separate facility (R.698),
Quotes from
consulting engineer’s reports show total costs of $600—$2,000 for
hypochlorination systems (Ex.44).
It
is even possible (although
not recommended except for very small suppliers having difficulty
funding chlorination equipment)
to chlorinate using a Sears
Roebuck system which costs under $140 for everything that
is
needed (R.702 and Ex.
80).
Another reason for these higher costs may be some unusual
problem with the system.
The $1,500 engineering costs cited for
Bradley Heights may well result from this.
The Bradley Heights
distribution system is over 50 years old and has a substantial
build-up of nuisance bacteria which would be attacked by the
chlorine and slough off into the water
(R.677).
Because of this
they had to look into two proposals to clean out their system
prior to chlorination,
and this may be responsible for much of
the expense
(R.681—2).
The Board notes that where such unusual
costs are necessitated by a Board rule,
a variance may be
requested from that rule.
Such a request was,
in fact, made by
Bradley Heights and variance was granted on February
7,
1980,
in
PCB 80—107
(R.676).
Finally, many small communities do chlorinate their water
and have been able to afford the expense
(R.496).
Aesthetic ~act
Some of the reasons given for opposition to mandatory
chlorination relate to
the
aesthetic impact, centering on the
perceived bad taste and odor of chlorinated water.
In this
regard chlorination has both
a positive and a negative effect.
It removes some chemical compounds and kills taste—producing
algae, hut does impart a taste that some people find
objectionable (EIS
13 and R,17).
Mr. Wright, Chairman of the
Water and Sewer Committee in Leaf River, testified to receiving
thirty complaints about the taste and odor of the water when he
began chlorinating
(R.173, 177-8).
Mr.
Lewis,
an Agency Manager,
testified that these taste and odor problems of chlorinated
ground water result from iron bacteria being killed by the
chlorine
(R,466).
Most of the testimony,
however,
indicates that taste and
odor should not be much of a problem.
Mr.
Lewis continued his
testimony by explaining
that
the iron bacteria which may build up
in distribution systems which do not chlorinate will, after a two
to four month period of continuous chlorination, he eliminated
from the system.
The system should then stabilize and the taste
and odor problems should abate
(R.466—467).
This appears to have
been the case in Kansas,
Illinois, where six months after
—4—
chlorination began,
there was only one complaint (R.487).
This
lack of taste and odor problems should be most apparent in ground
water supplies, which are the supplies affected by the proposed
amendment,
in that such water is relatively constant
in its
chemical, mineral and organic content.
Chlorine levels can,
therefore,
be well controlled,
since the taste and odor problems
are most apparent when the chlorine level fluctuates
(R.468).
Other testimony countering the aesthetic problems of
chlorination included that of David Loveland, Director of Public
Works for the County of DuPage, who testified that chlorination
should actually improve the taste and odor of water by removing
hydrogen sulfide, iron bacteria, chloramines
and chlororganics
(R.857),
There was also testimony that the chlorinated water
in
Minier,
Illinois,
tastes
fine.
Finally,
99.7
of the Illinois population
is presently being
served with chlorinated water
(ElS
5), most for an extended
period of time,
and there has been no public outcry against its
tas~:eor odor.
HEALTH IMPACT
The most serious objection to mandatory chlorination is
based on the health impact.
In this regard,
the first question
that must he faced is whether chlorination
is an effective method
of insuring sanitary drinking water.
The record indicates
little
disagreement that it
is.
The first continuous chlorination system in the United
States was installed at the Bubbly Creek Filter plant of the
Union Stock Yards in Chicago
in 1908
(EIS
17).
Since that time
it has proven its effectiveness
in disinfecting public water
(EIS
6).
Enteric diseases such as typhoid, cholera, and the
dysenteries have been virtually eliminated since its general use
in the United States
(EIS 8).
In earlier times public water
systems were commonly responsible
for epidemics of waterborne
diseases,
Severe outbreaks of typhoid and cholera struck
Chicago,
London,
Pittsburgh,
Hamburg
(Germany),
Lausen (Switzer-
land),
Mankato
(Minnesota)
and numerous other cities
(EIS 16).
Rather than questioning the effectiveness of chlorination,
some of those opposing
it do so on the grounds that these
diseases are no longer a problem and,
therefore, that
chlorination
is no longer necessary.
Mayor Bostian testified
that “the big spreaders of disease are food and contact”; that
“common source epidemics are now infrequent;” that “cholera has
vanished from the United States;” and that “typhoid is a rare
disease”
(R.664—6 and
Ex,
42).
However, even if these statements
are generally true,
they are true in a society which chlorinates
most of its water.
As the Economic Impact Study points out
“chlorination of public water supplies..,
is so common
in the
U.S. that its importance
is often forgotten, while in the
remaining parts of the world many people die each year as a
result of waterborne diseases”
(EIS 17).
—5—
Mr.
Langtrop, Coordinator of the Communicable Disease
Program for the Illinois Department of Public
Health,
testified
that
E.
Coli,
shigella,
and salmonella bacteria can be
transported by water and can cause gastroenteritis,
typhoid,
septicemia fever, abdominal pain, and diarrhea
(R.383).
There
were 16,000 cases of salmonellosis contamination
in Riverside,
California,
in 1965 when the city did not have a chlorinated
water supply (R.386).
In the 1970’s there were 300 cases of
waterborne illness reported in two outbreaks in Illinois
(R.387).
These were a result of contamination of unchiorinated groundwater
supplies (R.392,
395).
Dorothy Bennett, who has worked for both the Department of
Public Health and the Division of Public Water Supplies of the
Agency,
testified that there are persons known to be carriers of
typhoid who could infect a public water supply in Illinois and
suspects that there are others who have not been identified
(R.518).
She feels that chlorination will help check the spread
of typhoid (R.520).
She also pointed out that once chlorine was
added to the water in Riverside,
California,
the outbreak ended
(R. 515).
Even assuming that waterborne disease continues to be a
health problem and that chlorination
is an effective means
of
insuring sanitary drinking water,
it is argued that if a public
water supply is safe prior to chlorination, no benefit
is added.
Several witnesses testified to
a lack of knowledge of any illness
caused by their unchlorinated ground water supplies
(R.19,
45,
139,143,161,293,365,423).
As Mayor Bostian concluded,
“water
down in a deep well which has been filtered by the soil and sand”
is pure
(R.17).
That is generally true,
hut
it
is not sufficient to insure
that safe drinking water reaches the consumer.
It overlooks the
fact that contamination may well occur at some point within the
distribution system.
Supporting this
is the testimony of other
witnesses who have known people to contract disease from
unchlorinated groundwater
supplies
(R.412,516,842).
This risk of
contamination is confirmed by a study of the causes of waterborne
disease
in the U.S.
from 1971-77 which shows that about half of
the reported outbreaks were caused by groundwater systems
(EIS
xviii and Gp.
Ex.
23).
While
some of the causes of these outbreaks may not be
applicable to a given ground water system,
there are so many
possible methods of contamination that
it
is difficult to
conceive of a system which would not be susceptible to one or
more of them.
Ira Markwood testified that contamination could
occur due to back siphonage, back pressure, repairs to the
system,
incorrect installation of water mains or hydrants,
or
defects
in
the
system
(R.181—3).
Back siphonage occurs when pressure in the water mains
is
reduced, which consequently allows “contamination to be sucked
—0—
in from any cross—connection or possibly from leaks, or by
any other path by which contamination could enter the system”
(R.181).
Such a loss of pressure could result from power
outages,
water main breaks, or an excessive demand, as when
fighting
a fire
(R.181,439).
Cross—connections in homes and factories can occur at
any time (R.105—8,129,180—3,227—8,542—3,735).
Even a regular
cross—connection elimination program cannot avoid all accidental
siphonage into a distribution system.
Mr. Markwood was challenged
to find a cross—connection in a factory which boasted of the
effectiveness of its program,
and he did
(R.543).
The USEPA
“Cross—Connection Manual”
includes diagrams of possible cross—
connections and case histories of contamination caused by them
(Ex.9).
Given the difficulty of eliminatinc cross-connections
in an environment as controlled and supervised as
a factory’s,
it is hard to conceive of a town insuring that none would exist.
If a homeowner simply leaves a hose on in a puddle of water,
contamination could result if there were a water main break
or if water was being used to fight a fire
(R.182).
Back pressure occurs when an outside water source is
connected to a public water supply
(e.g.
a well connected
to a house which is also served by a public supply)
and
the pressure of the outside source becomes greater than that
of the public supply.
There have been a number of cases of
contamination that resulted from this
(R.181).
Mr.
Schoena, an Agency engineer, testified concerning
several problems with distribution systems that have resulted
in contamination.
These included defective systems and a
contaminated replacement pump which
in turn contaminated the
well supply (R.441-60).
Only through chlorination were these
problems solved.
Chlorination can also serve as a safeguard
against operator mistakes and contamination through employee
contact with the water supply (R.482—3,
519—20).
Since chlorination can protect a public water supply
against all of these problems, the health benefits of it are
apparent.
However, these must be balanced against the possible
adverse impacts.
Testimony in the record concerning adverse health impacts
is considerable.
It includes a wide range of hazards such
as allergic reactions (R.800—811), heart disease
(R.345),
high blood pressure
(R.347), high cholesterol
(R.300),
and
cancer (R.190—3,203,220,340,361,535,704—7,715), among others
(R.348-50).
Many of these are also touched upon in various
exhibits (Ex.22,29,32,35,40,55,56,et al
.).
While the list is lengthy,
few,
if any,
of the claims
are well substantiated and of serious concern.
The most
researched of these claims appears to be the carcinogenic
potential of chlorinated water.
—7—
The possihilty that carcinogens
might
be
found
in
chlorinated
water
has
been
suspected
for
years,
hut
only
recently
has
gained national
and international attention.
In 1974
suspected
chlorine—related
carcinogens
were
reported
in
treated
drinking
water,
and
in
1976
a
study
by
Page,
et
al.,
attributed
15
to
20
percent
of
the
cancer
deaths
in
southern
Louisiana
to
the
use
of chlorinated Mississippi
River water
for
drinking water
(EIS
32—33).
However,
it
should
he
noted
that
these
are
surface
water
related
rather
than
ground water related, and studies in
Ohio
and
North
Carolina
confirm
that
surface
water
supplies
are
considerably
more
contaminated
than
groundwater supplies
(EIS
34).
Mr.
Markwood’s
testimony also supports this
(R.
191—2).
The
literature
suggests
that
the
most
detrimental
by—product
of
chlorinated
drinking
water
is
chloroform
(a
trihalomethane)
which
is
formed
by
a
reaction
of
the
free
chlorine
with
a
“precursor.”
The
precursor can be naturally present such as
humic
acid
(formed through the decay of plant material)
or
culturally introduced organic material
(EIS
35).
Studies have
found chloroform “capable of producing malignant and metastatic
neoplasms
(tumors)
in both rats and mice”
(EIS
37). Other studies
have shown some statistical
correlation between chloroform dose
and carcinogenic effect
(EIS 37).
These studies indicate a
potential carcinogenic risk to humans, and chloroform
is
presently classified as a possible carcinogen
(R.203).
However, the National Academy’s Safe Drinking Water
Committee estimates
(with a
C)5
percent confidence level)
that
a
2
liter per day lifetime consumption of drinking water with 0.02
mg/l chloroform will result in one excess death per 33,333 people
(EIS 37—8
and R.615).
Further,
since chloroform arises from a
combination of chlorine and an organic precursor,
it
is possible
to inhibit chloroform formation without eliminating the use
of
chlorination.
Much of the other testimony regarding health effects derives
from an article entitled “Learn to Live Without Chlorine,”
by
DeCrosta
(Ex.22).
That article, while raising several important
health
issues,
does not resolve those issues and admits that
there is disagreement among experts.
Other than cancer,
the
issues discussed include arteriosclerosis,
high blood pressure
and red blood cell problems (EIS 38—41).
DeCrosta cites an experiment by Dr.
Price
in which two
groups of 12—week old cockereis
(chickens)
were placed on
identical diets,
except that one group was given distilled water
and the other chlorinated water.
After seven months all of those
cockerels drinking chlorinated water developed arteriosclerosis,
while none of the control group had.
However, there is no
indication of what chlorine levels were used,
nor any indication
that the experiment has been replicated
(see
R.345).
DeCrosta also reported that Russian scientists
found that
men drinking water with
a 1.4 mg/i chlorine level showed higher
—8—
blood
pressures
than
those
drinking
water
containing
0.3-0.4
mg/i
(see
R.
347).
However,
the
record
indicates
that
a
chlorine
residual
of
0.2
mg/i
is
sufficient
to
destroy
contamination,
such
that
levels
of
1.4
mg/I are unnecessary
(R..450).
Another study reported by DeCrosta was undertaken by John
Eaton and seems to indicate that chlorine may have adverse
effects upon red blood cells.
However, Eaton is quoted
as
saying
“1 can’t say anything for sure now.
.
.
.More studies will have to
be
done,
as
there
were
conflicting results between individuals”
(see Ex.22 and EIS 41).
The above cited studies form the bulk of the substantiation
of
the
alleged
adverse
health
effects
from
chlorination,
and
much
of
the
testimony
in
the
record
appears
to
be
based
upon
them.
A
summary
of
these
studies
among
others,
is
given
in
Table
8
of
the
Economic Impact Study
(39-40).
One allegation not covered by the Study is that some people
have an allergic reaction to chlorine
(R.799—811).
Dr. Randolph
has, apparently, treated as many as 6700 people from around the
country for allergic reactions to chlorine since
1956
(R.806).
However, no studies have been made available to the Board, and
Dr. Randolph has, apparently,
been able to find waters
for his
patients that do not cause allergic reactions, though probably at
some expense and inconvenience.
OTHER
IMPACTS
There
are
several
other
allegedly
adverse
impacts
of
chlorination
that
were
brought
out
in
the
course
of
the
hearings.
These include the lack of detection of problems within the water
system
(R.140),
hazards
to
fish
(R.166,295),
hazards
to
plants
(R
295),
the
failure
of
donuts
and
breads
to
rise
(R.280),
and
the destruction of beneficial bacteria
(R.279).
None of these
problems appear to be significant.
While fish can be killed by chlorine,
“concentrations
necessary to affect
(sic) damages are not likely to exist as a
result of the treatment of drinking water” in a natural
environment
(EIS xiii).
Domestic fish will often be killed if
placed in chlorinated water, but “mitigating measures are simple,
efficient, and costs are insignificant”
(EIS xiii).
One such
measure is to simply let the water sit out for 2 days
(EIS 64).
Plants should not be harmed through contact with chlorinated
water since the chlorine will not be assimilated by them (EIS
65).
Chlorine in a domestic water supply is not considered to be
a problem in the making of donuts or yeast breads with the
exception that taste could be affected by over—chlorination (EIS
66).
—9—
Kenneth
Mayer,
Manager
of
the
Water
Department
of
Monroe,
qisconsin,
testified that hairline cracks in one of their
reservoirs would not have been detected if chlorination had
been used
(R.140).
After obtaining unsafe samples, he was
alerted to
the fact that there was some problem with the
system.
William Robinson,
a mechanical engineer, also
testified as to difficulties in discovering contamination
when the water
is chlorinated since there would not be bad
samples
arid the taste and odor of chlorine will cover up the
taste and odor of water that
“has gone bad”
(R.
323—329).
Mr. Robinson, however, apparently misunderstood the testing
procedures used in a chlorination program and finally stated
that he “would have to do some more homework on this
“
(R.327).
Mr. Markwood, on the other hand, testified convincingly
that the required daily testing of chlorine residual
levels
at various homes in the distribution system should function
as an effective “tracer” test for contamination (R.183—6).
Mr.
Plienes, Public Works Director of the Village of Minier,
also testified to this function (R.414—417).
If the chlorine
residual
is low or nonexistent, it follows that the chlorine
is being used up in attacking contamination, and that there
is some problem in the system.
This method of discovering
problems
in the system appears to be preferable
in that often
a problem will be found prior
to any adverse health effects
(R.185).
Whereas,
since small
systems are only required to
send one water sample per month for bacterial
testing,
a
considerable number of people could be subject to contamination
prior to discovery of the problem in
a non—chlorinating system
(R. 414,477).
The allegation that chlorination adversely affects water
treatment plants by destroying beneficial bacteria also appears
to be unfounded.
Bacteria are used
in treatment plants to
consume organic materials and change them into nutrients and
other innocuous by—products such as carbon dioxide and water.
There should, however,
be no deleterious effect from the chlorine
residual delivered at the tap because it would “either dissipate
or react with organic materials before it would enter the
treatment plant”
(EIS 11).
This is also discussed in the
testimony of Mr. Pleinis
(R.416).
Options Available
Under Procedural Rule 212, the Board
is not bound to
enact or dismiss the proposed regulations;
it may, after hearing,
“revise the proposed regulations before adoption in response
to suggestions made at the hearing and written submissions
received subsequent thereto.”
Thus,
there are essentially
three courses of action open to the Board:
1.
To
adopt
the regulation as proposed;
—10—
2.
To
enact
a regulation with alternatives to chlorination
such as other disinfection methods or more frequent
bacterial
tests
and/or
cross—connection inspections of
private
homes
and
other buildings by licensed plumbers;
or
3.
To
dismiss the proceeding and leave mandatory
chlorination in place.
These alternatives are discussed below.
Adoption
of
the
Regulation
as
Proposed
The
Board
declines
to
enact
the
regulation
as
proposed.
The
record clearly indicates the necessity of disinfection, or at the
very
least
a
stron9
inspection
and
sampling
program,
to
insure
the
safety
of
public
drinking
water.
The
present
sampling
regulations are tailored to a mandatory chlorination system and
are not adequate
to insure the safety of
a non-chlorinating
system.
Even if
a ground water supply is pure and remains so,
the numerous possibilities of contamination arising
in the
distribution system cannot be adequately protected against under
a system in which samples may be analyzed only once per month,
and
in which there is no requirement for
a cross—connection
inspection program.
Adoption of Modified Regulation
The Board also declines to adopt a modified regulation,
since neither requiring other forms of disinfection,
nor a strong
inspection regulation would be as effective and inexpensive as
chlorination.
The Economic Impact Study contains a detailed examination of
the various alternative disinfection technologies.
Its findings
are summarized in Table 24,
pp.
75—6
(see also 47—61 and 93—112).
A chloramine system is by far the least expensive, but its
biocidal activity
is considerably lower than the other systems
and would have
to be used in conjunction with another technology,
thus making the total cost considerably higher than the
alternatives
(R.54).
Ozone and ultraviolet technologies are also
considerably more expensive,
and ozone alone has been
unsatisfactory in Europe, thus increasing its expense even more
(R.196)..
Only bromine, which is very hard to handle and iodine,
which caused severe taste, odor,
and color problems, can maintain
an
adequate
residual
(R.
196),
The
high
cost
of
chlorine
dioxide
has resulted in limited use
(EIS 108).
An increase
in sampling and a strong cross—connection
elimination program would also be expensive.
Even if these
tasks
could
be
successfully
accomplished
through
the
hiring
of
one
additional employee at $10,000 in a town of 500 people, the cost
per user would increase $20/yr. which is
far in excess of the
—11—
cost of chlorination.
Even at that,
however, had samples would
remain an after—the—fact determination and many people could be
made ill before the problem was discovered.
Chlorination, on the
other
hand, provides constant insurance against such
contamination while acting as a “tracer” to discover problems.
Dismissal of the Regulatory Proceedi~
By balancing the benefits of mandatory chlorination against
its costs,
the Board finds
that the R78—8 proceedings should be
dismissed.
Based upon the record,
it
is clear that chlorination
is an effective method of insuring a safe water supply; that
the economic cost
is justified; that the aesthetic,
and other
non—health impacts are not sufficiently detrimental to warrant
the weakening of the mandatory chlorination requirement;
and, as
the Board found in R73—13,
that not requiring chlorination “would
be turning its back on a known danger
to protect against a
potential one.”
The Board is not overlooking the potential health dangers
presented by chlorination, which appear to be substantial,
especially with respect to the possible carcinogens produced
through chlorination.
The other potential adverse health
problems
(heart disease, arteriosclerosis,
high cholesterol and
high blood pressure) appear
to be highly speculative at this time
and have not been found to be
a problem by the American Heart
Association, American Medical Association,
or the American Public
Health Association
(R.
633).
The carcinogenic effect, on the other hand,
is becoming well
established as
a potential problem.
However, ceasing
chlorination is not the only solution to that problem.
Since
the
carcinogenic effect of chlorinated water has been traced to
chloroform and other trihalomethanes~ it is possible to reduce or
eliminate the problem by setting a trihalomethane standard to
adequately protect the public health.
This standard could be met
by removing the precursors
from the water supply to be
chlorinated.
A Federal standard for trihalomethanes will soon be
adopted by the Board as a “pass—through” regulation.
At that
time the Board can tighten the standard if it does not give
adequate protection.
Thus,
even this aspect of the health
problem fails to warrant changing the mandatory chlorination
requirement.
In dismissing this proceeding, the Board
is acting
in
accordance with recommendations of the vast majority of those who
testified who are responsible
for the safe operation of public
water supplies and who support chlorination
(R.235,
246,260,406,413,715,817,824,850,865).
JURISDICTION OF THE BOARD
During the course of the hearings Mayor Bostian and others
have questioned whether the Board has complied with Section 27(a)
on the Environmental Protection Act by imposing mandatory
—12—
chlorination on all, public water supplies in the State
(R.368,374,796).
That Section indicates that the Board shall
take into account the conditions of the areas involved and the
technical feasibility an~teconomic reasonableness of compliance
with the regulation.
It is alleged that the Board has not considered the
differences between various water supplies in the state, but that
is not,
in fact,
the case.
The Board is aware that many ground
water supplies provide “safer” water than surface supplies,
The
Board
is also aware that there are areas of the state where no
disease has been documented to be a result of contamination of
the public water supply.
However,
the Board is also aware that
cross—connections,
back siphonage and back pressure are problems
than can occur anywhere in the state at any time, and can cause
any system to become contaminated. Further, many cases of illness
are unreported and may not he linked to the water supply, even
if
they are a result of contamination.
Finally, travelers around
the state may be affected by bacteria in the water to which
local
residents may have built up an immunity (R,187,250,834),
Thus,
testimony by citizens, or even by doctors, that they
do not know of any disease being caused by their water supply
does not mean that none has been caused.
Further, despite
differences
in water supplies, possible contamination in the
distribution system is
a statewide problem, and travelers around
the state should have the assurance that any public water they
drink within the state will be safe.
Finally, the Board wishes to express its appreciation
to Mayor Bostian and others who testified and commented during
the course of these proceedings,
Their research and interest
in the mandatory chlorination regulation has resulted in a
detailed re—examination of that regulation.
The Board has
a continuing duty to protect the health and welfare of the
citizens of this state,
and the re—examination of regulations
in light of new evidence on the effects
of
them
is
part
of
that
duty.
ORDER
Proceedings in R78—8 are hereby
dismissed,
IT IS SO ORDERED.
I, Christan L; Moffett, Clerk of the
Illinois
Pollution
Control Board, hereby qertify that th~a~ove
Opinion
and
Order
was adopted on
the
~6~”
day of
~
1980 by a vote
of
_______
ok~L~
c~
~i
ChristanL.
M~~tT
Clerk
Illinois
Pollution Control Board
