ILLINOIS POLLUTION CONTROL BOARD
February
7,
1980
VILLAGE
OF GLASFORD,
)
Petitioner,
V.
)
PCB 79—238
ENVIRONMENTAL
PROTECTION
AGENCY,
Respondent.
OPINION
AND
ORDER
OF
THE
BOARD
(by
Dr.
Satchell):
This
matter
comes
before
the
Board
upon
a
variance
petition
filed November 13,
1979
by
the
Village
of
Glasford
(Glasford)
The petition requests
a variance from the fluoride limitation of
Rule 304(B)
and the gross alpha particle and radium limitation
of Rule 304(C) (1)
of Chapter
6:
Public Water Supplies
(Rules)
On January 16,
1980 the Environmental Protection Agency
(Agency)
recommended that the variance be granted with conditions.
Glas-
ford waived its right to a hearing and the Board has received no
public comments,
Glasford operates a public water supply system in Peoria
County.
The supply serves 1100 residents with about 100,000
gallons of water per day.
The system draws from two 1700 foot
deep wells, each with
a capacity of approximately 200 gallons
per minute.
The system has a 50,000 gallon aerated storage
reservoir,
chlorination equipment and a 35,000 gallon water
tower.
Glasford also ooerates a sewage treatment plant which
discharges
to Dry Run Creek, a tributary of the Illinois River.
Rule 304(B) (4)
sets a limit of 2,0 mg/l fluoride in finished
water in public water supplies in Peoria County.
(This is
in
excess of the 1.8 mg/l limit for the southern counties.)
The
recommendation contains a suimraary of Agency sampling of the wells
and finished water.
All indicate violations of the fluoride
standard.
The finished water ranged from 2.7 to 3.7 mg/I with
an average of 3,0 mg/l in eight samples taken during the spring
of 1979,
Rule 304(C) (1)
sets maximum limits for radium-226, -228 and
gross alpha particle activity in public water supplies.
Combined
radium-226 and -228 may not exceed
5
pCi/l and gross
alpha
part-
icle activity may not exceed
15
pCi/i.
Rule
309(C)
(1)
provides
that compliance
is determined on the basis
of quarterly samples
averaged over a year.
The Agency has collected only one recent
37—341
—2—
sample.
This shows
55.4 ±11,9 pCi/l in the distribution system.
Apparently this
is gross alpha particle activity.
Although
quarterly samples are not yet available, the Agency believes this
is sufficiently beyond the present limit to indicate that a viola-
tion most probably exists.
Glasford offered two alternative compliance plans,
The first
involves drilling
a shallow well to provide water with a low
fluoride and radium content to blend with the deep well water to
provide
a satisfactory mix,
Glasford estimates that this would
cost $50,000,
The Agency estimates that another $50,000 will he
necessary to provide two miles
of six-inch main from the nearest
likely site for the well.
In the alternative Glasford proposed
to lower the fluoride level with an activated alumina filter and
the radium with a zeolite softener.
This was estimated to cost
$200,000 to construct.
The Agency opposes zeolite softening because it increases
the sodium content of the finished water and because it produces
as a side product liquid waste which would present disposal
difficulties.
The Agency also opposes activated alumina treatment
for fluoride because the technology
is expensive and uncertain.
The Agency recommends lime softening to treat both contaminants.
Although lime softening is not the most commàn method of treating
for fluoride, the United States Environmental Protection Agency
(USEPA)
Manual of Treatment Techniques states that excess lime
softening has been shown to remove fluoride from high magnesium
water by co-precipitation with magnesium hydroxide
(Rec., Ex,
D).
Apparently Glasford has high magnesium water.
The Agency esti-
mates the cost of lime softening at around $200,000,
the same as
Glasford~sestimates for its suggested treatment.
The standards for both fluoride and radium are mandated by
USEPA regulations.
Under the Safe Drinking Water Act variances
cannot extend beyond January
1,
1981.
However,
the Agency has
joined the Illinois Department of Public Health and other states
in recommending that USEPA raise the fluoride standard to four
times the optimum level,
that is to 4.0 mg/I.
The Agency believeE
that at Glasford~s level there should he little or no noticeable
fluorosis, or dental mottling.
Bills have been introduced in Congress to require suspension
of the radium standards until new studies of health effects have
been conducted.
The Agency tends
to agree with experts that the
radium standard is too stringent at present.
It has attached a
37—342
—3—
statement by Dr.
R.
E.
Rowland, Director, Radiological and
Environmental Research Division, ~rgonne National Laboratory
(Rec., Ex.
B).
A major part of the radium problem is that
it
can be incorporated into bone tissues
in place
of calcium which
is chemically similar to radium.
Among other things,
Dr. Row-
land contends that early studies on which the radium exposure
guidelines were based assumed that the body incorporated radium
at a rate ten times higher than presently estimated,
Based on
Dr. Rowland’s conclusions, the Agency believes that a standard
of 90 pCi/1 for gross alpha count may provide adequate protection
at a large savings over the present standard,
Glasford contends that its residents have been using deep
well water since 1947 with no aoparent ill effects.
The Aqency
does not recommend that Glasford be required to undertake epi-
demiological studies.
Glasford has offered to notify the con-
sumers of its water of the violations
on a three month basis by
direct mail, publication in the local newspaper and announcements
on the local radio and television stations.
The Board finds that it would impose an arbitrary and un-
reasonable hardship to require Glasford to undertake immediate
actions to reduce its fluoride and radium levels.
Glasford is
granted a variance through January
1,
1981 upon condition that
it submit to the Agency a compliance plan within 150 days of
the date of this Order,
The Agency will schedule a hearing on
the compliance plan to satisfy the requirements of the Safe
Drinking Water Act,
In the event Congress or the USEPA takes
actions which would allow a variance beyond this date, Glasford
may petition the Board for extension of this variance.
This Opinion constitutes the Board’s findings of fact and
conclusions of law in this matter,
ORDER
The Village of Glasford is granted a variance from the
fluoride limitation of Rule 304 (B)
,
from the combined radium-
226 and -228 limitation of Rule 304(C) (1) (a)
and from the gross
alpha particle activity limitation of Rule 304(C) (1) (b)
of
Chapter
6:
Public Water Supplies, subject to the following
conditions:
1.
This variance will expire on January
1,
1981,
37—343
—4—
2.
Petitoner shall undertake any reasonable measures
within the limitations of its existing equipment to
minimize the concentration of radium and fluoride in
its public water supply.
3.
Within thirty days of this Order, and at ninety day
intervals thereafter,
Petitioner shall notify the
consumers of its water that the water does not meet
the standards
for fluoride and radium.
4.
Within 150 days of the date of this Order Petitioner
shall submit to the
Agency a compliance plan detailing
its programs to come into eventual compliance with the
fluoride and radium standards,
5.
Within forty-five days of the date of this Order,
Petitoner
shall
execute
and
forward
to
the Illinois
Environmental Protection Agency, Variance Section,
2200 Churchill Road,
Springfield,
Illinois, 62706,
a
Certificate
of
Acceptance
and
Agreement
to be bound
to all terms and conditions of this variance.
This
forty-five day period shall be held in abeyance for
any period this matter
is being arpealed.
The form
of the Certificate shall he as
follows:
CERTIFICATION
I,
(We), __________________________________
having read and fully understanding the Order
in
PCB 79—238, hereby accept that Order and agree
to he
bound by all of its terms and conditions,
SIGNED
TITLE
DATE
IT IS SO ORDERED,
37—344
—5—
I,
Christan L. Moffett, Clerk of the Illinois Pollution
Control Board,
y ~he above Opinion
and Order were
adopted on the
1980 by a vote
of ~O
37—345
day
0
Illinois Polluti
Board