IN THE MATTER
OF:
)
REVISIONS TO RADIUM WATER QUALITY
STANDARDS:
PROPOSED NEW
35
ILL.
ADM. CODE 302.307
AND
AMENDMENTS
TO
35
ILL. ADM.
CODE 302.207 AND
304.525
)
NOTICE OF FILING
RECEWE
D
CLERK’S OFFICE
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
Matthew Dunn, Division Chief
flhinoi~
Attorney General’s Office
Environmental Bureau
188 West Randolph Street,
20th
Floor
Chicago, Illinois 60601
Amy Antoniolli, Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph
Street, Suite
11-500
Chicago, Illinois 60601
Johnathan Fun, Chief Legal Counsel
Illinois Department ofNatural Resources
One
NaturalResources Way
Springfield, Illinois
62702-1271
Claire Manning, Posegate & Denes
111 N.
6th
Street
Springfield, Illinois 62701
Abdul Khalique, Radiation Chemist
Metropolitan Water ReclamationDistrict of
Greater Chicago
6001
W. Pershing Road
Cicero, Illinois 60804
PLEASE TAKE
NOTICE
that I have today filed with the
Office ofthe Clerk of the Pollution
Control Boardthe
PRE-FILED TESTIMONY OF
JERRY
KUHN, ROBERT MOSHER and
BLAINE
KINSLEY
on behalfof the Illinois Environmental Protection Agency, a copy of which is
herewith served upon you.
DATED:
March 18, 2004
Illinois Environmental Protection Agency
1021 North Grand Avenue East
PostOffice Box
19276
Springfield,
Illinois 62794-9276
(217)
782-5544
ENVIRONMENTAL PROTECTION AGENCY
OF THE
STATE OF ILLINOIS
By:
~‘~)1M1
~
Deborah
.
Williams
Assistant Counsel
Division of Legal Counsel
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD
MAR
19
2OO~
STATE OF ILLINOIS
Pollution Control Board
)
R04-21
)
(Rulemaking-Water)
)
)
THIS FILING IS SUBMITTED
ON RECYCLED PAPER
RECE~VED
CLERK’S OFFICE
MAR
192004
BEFORE THE
ILLINOIS POLLUTION CONTROL BOA1~ATE
OF ILLINOIS
~-‘uIiution
Control Board
IN THE MATTER OF:
)
)
R04-21
REVISIONS TO RADIUM WATER QUALITY
)
(Rulemaking-Water)
STANDARDS:
PROPOSED NEW
35 ILL.
)
ADM. CODE 302.307
AND AMENDMENTS
)
TO
35
ILL. ADM. CODE
3 02.207 AND
304.525
)
)
PRE-FILED
TESTIMONY OF
JERRY
KUHN
My name is Jerry Kuhn. I am the manager ofthe Permit Section for the Division
ofPublic Water
Supplies ofthe Illinois Environmental Protection Agency (“Illinois
EPA”) and have held that position since October of2000.
The Permit
Section is
responsible for the review ofconstruction permit applications by community water
supplies.
A construction permit is required by the Illinois EPA for construction ofany
new community water supply and for changes or modifications to an existing community
water supply including water main extensions and water treatment plant modifications.
I
have worked for the Illinois EPA for approximately 21 years,
including eleven years in
the Division ofWater Pollution Control Permit Section and eight years in the Bureau of
Land as the RCRA Unit Manager in the Permit Section.
Prior to my time at the Illinois
EPA, Iworked for a consulting engineering firm.
I received a Bachelor ofScience in
•
Engineering
degree from Bradley University in 1975
and a Master ofScience in Thermal
and Environmental Engineering Degree from Southern Illinois University at Carbondale
in
1985.
I have been an Illinois Licensed Professional Engineer since 1980.
Today I will testif~r
in regards to the Illinois EPA’s proposed changes to the water
quality standards for radium and theproposal’s impact on Illinois community water
supply systems.
Regulations for radionuclides in drinking water were first promulgated
in 1976 as interim regulations under the authority ofthe Safe Drinking Water Act of
1974.
The standard was proposed for revision upward to 20 pCi/L in 1991, but
eventuallyit was determined that the original
5
pCilL should remain the MCL standard.
On December 7, 2000, U.S.EPA finalizedrevisions to
the 1976 radionuclide regulations,
which have since been adopted by the Illinois Pollution Control Board.
The Board’s
regulations were finalized on October 4, 2001
in rulemaking docket R01-20.
These
regulations retained the existing Maximum Contaminant Level (or “MCL”) of
5
picocuries per liter (“pCi/L”) for Radium 226 and 228 combined
and 15 pCi/L for gross
particle activity.
The rule became effective on December
8, 2003.
Entities regulated by this rule are public water systems that are c1as~ified
as
communitywater systems.
Communitywater systems provide water for human
consumption through pipes
or other constructed
conveyances to at least 15
service
connections or serve an average ofat least 25 people year-round.
Over 100 community
water supplies in Illinois are impacted by these regulations, due to the presence of
radionuclides in their source water used for drinking at concentrations higher than the
MCL.
The radionuclides found in Illinois groundwater wells are naturally occurring and
located primarily in deep bedrock aquifers.
Communitywater supplies that exceed the MCL for radionuclides have three
basic options to
lower their radium levels:
(1) blend theirwater with a source ofwater
with no or low amounts of radium to
meet the MCL,
(2) acquire another source for their
drinking waterwith radium below the MCL, or (3) install treatment for their source
water.
2
Under the
Safe Drinking Water Act, U.S. EPA must specify best available
technologies for treatment ofeach MCL.
In regards to treatment for removal of
radionuclides, U.S. EPA considers ion exchange, reverse osmosis and
lime softening to
be the best available technology. Additionally,
small system (serving less than 10,000
people) compliance technologies include green sand filtration, hydrous manganese oxide
filtration and enhanced coagulation/filtration.
All ofthese radionuclide removal
technologies produceresidual waste streams that must be dealt with.
Anywhere from
five to twenty-five percent ofthe water obtained
from well sources and treated by one of
~heradium removal technologies ends up as wastewater containing radionuclides
removed from the source water and discharged to the local wastewatertreatment plant.
Depending on the initial groundwater concentration, removal efficiency in the wastewater
treatment plant and the dilution available in the receiving stream, communities with
radionuclides in the source oftheir drinking water have or will have, once they
implement a radium removal technology, a problem with violations ofthe existing
radium water quality standard as it applies to most the waters ofthe state.
It is my opinion that the Agency’s proposed changes to the Board’s water quality
standards forradium will assist community water supplies in coming into compliance
with the Safe Drinking Water Act and prevent their efforts to reduce radium in drinking
water from becoming an issue of non-compliance with surface water quality standards for
publicly owned treatment works while still protecting surface water quality.
Finally, I would like
to thank the Board forthe opportunity to
submit this pre-
3
filed testimony and forits consideration of the Agency’s rulemaking proposal.
March 18, 2004
11
I/~
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
P.E.
4
lEO
MAR
19
2004
STATE
OFj
LINO
BEFORE THE ILLINOIS POLLUTION CONTROL BO~I~ttOfl
Control Board
IN THE MATTER OF:
)
)
R04-21
REVISIONS TO RADIUM WATER QUALITY
)
(Rulemaking-Water)
STANDARDS:
P1~OPOSED
NEW
35
ILL.
)
ADM. CODE 302.307 AND AMENDMENTS
)
TO
35 ILL. ADM. CODE 302.207 AND 304.525
)
)
PRE-FILED TESTIMONY OF ROBERT MOSHER
Background and Qualifications
My
name is Bob Mosher and I have been employed by the Illinois Environmental
Protection Agency (“Illinois EPA”) for over 18 years with more than
16 years experience
in the Water Quality Standards Unit.
I am an aquatic biologist by training with a
specialization in stream ecology and laboratory aquatic life toxicity studies.
Most
recently I have been involved in the development ofwater quality standards
for nutrients,
radium and sulfates for eventual adoption by the Illinois Pollution Control Board
(“Board”) as well as water quality standards implementation support for the Permit and
401
Water Quality Certification Sections of the Bureau ofWater.
I have a Bachelor of
Science degree in environmental biology and zoology from Eastern Illinois University
and a Master of Science degree in zoology also
from Eastern Illinois University.
My pre-
filed testimony in this matter will address the history and background ofthe Board’s
current radium water quality standards and thejustification for the Illinois EPA’s
proposed changes to those standards.
Introduction: Radium 226 and 228
Radium
is a naturally occurring radioactive metal that exists in several isotopes.
Radium forms when two other radioactive metals, uranium and thorium, decay.
These
substances are naturally found in rocks and therefore radium is ubiquitous in the
environment.
Radium
is usuallymeasured in picocuries per liter (“pCi/L”).
A picocurie
is
a very small amount ofradioactivity.
One picocurie is
associated with about one
trillionth of a gram ofradium.
Radium 226 emits alpha radiation and radium 228 emits
betaradiation.
The half-life ofradium 226
is
1,600 years while radium 228 has a half-life
of5.7 years.
There are two other natural isotopes ofradium that have half-lives ofjust a
few days.
Radium may exist in small Illinois streams below sewage treatment plants serving
communities that utilize high radium groundwater as drinking water at levels exceeding
the existing general use water quality standard of
1
pCi/L.
Discharges to
larger streams
probably receive sufficient dilution to meet the standard.
Recent stream concentrations
measured in the Fox Riverwere under
1
pCi/L.
The Fox River flows through
a region
where many communities depend on high radium groundwater, illustrating that ambient
river water is very low in radium and that the overall effect ofdischargers is minor.
The
vast majority ofIllinois community water supply facilities with high concentrations of
radionuclides in their source water (all groundwater) are located in the northern halfof
the State and in a region that stretches from Henderson County in the west to Cook and
Lake Counties in the northeast.
Sewage treatment plant discharges to very small streams
where no dilution wateris present have the potential to contain as much as
5
to 10 pCi/L
2
ofradium depending on concentrations in the groundwater and efficiency of treatment in
removing radium to the sewage sludge.
History of the Existing
General Use and Lake Michigan Basin
Water Quality Standards
The existing General Use water quality standard for radium 226 is
1 pCi/L and
is
found in 35
Ill. Adm. Code
3 02.207.
This standard was adopted by the Board as part of
its initial set ofwater quality regulations first promulgated in
1972 in docket R7 1-14.
An
identical standard first appeared in the regulations for the Lake Michigan Basin in
1997
due to a change in the format ofhow Lake Michigan standards were presented.
This
~tandardhas been continuously applicable in Lake Michigan since 1972,
however.
The
Board’s 1972 opinion accompanying adoption ofthe radium standard mentioned that the
new regulation “retains existing radioactivity levels” which implies that this standard
existed prior to
1972 in the Sanitary Water Board (the precursor to the Agency and
Board) regulations.
A justification document that appears to have accompanied the
rulemaking also simply says that the radioactivity standards “retains
existing
radioactivity levels.”
We now have reason to
believe that the Board’s 1972 radium 226
standard did not preserve a then existing state standard but rather was derived from a.
federal suggested value current at that time.
The Illinois
Sanitary Water Board had numerous regional water quality standards
•
in place by 1966 and these included
either a radium 226 standard or an “alpha omitters”
(presumablythe Sanitary Water Board meant “alpha
emitters”)
standard depending on
the region.
This may have been due to the fact that standards for interstate waters
reflected the neighboring state’s preference, some choosing to regulate radium 226 and
some alpha emitters.
The numeric value was the same for either parameter and for all
3
regions,
3 pCi/L.
Thhis standard was found in the Public Water Supply Intakes category
and it was noted that these standards were intended to protect “river quality at the point at
which water is withdrawn for treatment.”
This is consistent with the intent underlying
the Public
and Food Processing Water Supply Standards (Subpart C) in the current Board
regulations.
It is
aiso interesting to note that the standard for strontium 90 was
10 pCiIL
and gross beta concentration was
1,000 pCi/L
in these Sanitary Water Board standards
while the existing General Use water quality standards for strontium 90 and gross beta
are 2 pCi/L and
100 pCi/L respectively and are found in 35
Iii. Adm. Code 302.207.
In looking to the origin ofthe Sanitary Water Board’s standards, a federal source
called the Public Health Service Drinking Water Standards published by the U.S.
Department of Health, Education and Welfare in
1962 (and also
cited in the Agency’s
rulemaking proposal) is implicated.
In the
1962 document, finished drinking water
standards are given:
3 pCi/L for radium 226,
10 pCiIL for strontium 90 and 1,000 pCiIL
for gross beta radiation.
These are the exact values adopted by the Sanitary Water Board
for raw water being used as a public water supply.
In a later federal source, the Green Book (formally referred to
as the Report ofthe
Committee on Water Quality Criteria dated April
1,
1968 and cited in the Agency’s
proposal) a table is
given in the section on public water supply standards which gives two
values for each parameter, a “permissible” value and
a “desirable” value.
The
permissible value is
3 pCi/L for radium 226 while the desirable value is 1
pCifL.
For
strontium
90 these values are
10 and 2
and
for gross beta 1,000 and 100
pCi/L,
respectively.
The Green Book cites the
1962 Public Health Service document as the
source ofits “permissible” criteria but it seems that the “desirable” criteria are its own
4
invention.
The Green Book specifically states that these values applynot to finished
water but “can be used in setting standards for raw water quality only” which implies that
these were intended to be point of intake standards.
Taking a finished water standard and
applying it as a raw water standard adds conservatism, since any treatment provided by
the community water supply would reduce concentrations.
It appears that the Green
Book took this liberty with the
1962 drinking water standards.
The Green Book appears to be the source for the Pollution Control Board General
Use water quality standards of 1972.
The Sanitary Water Board
adopted their standards
before publication ofthe Green Book and interpreted the
1962 Public Health Service
values as point ofintake standards for public water
supplies.
The Pollution Control
Board apparently changed two things, making these standards general in ap~licabilityand
taking the more stringent Green Book “desirable” value as the standard, simply dropping
the””
sign.
The record indicating that the Board said it “preserved the existing
standard” may therefore mean that it was the 1968
Green Book “desirable”
recommendationrather than the standard applicable to
Illinois at that time (adopted by
the Sanitary Water Board) that was being preserved.
It seems certain that the ultimate
origin ofthe Sanitary Water Board’s radioactivity water quality standards was the federal
Public Health Service documents of 1962 while the Pollution Control Board’s source was
the Green Book.
For reasons ofconcentration (1 pCi/L instead of3 pCi/L) and
applicability (General Use instead ofPublic
and Food Processing Water Supply) the
present radium standard, and the radioactivity standards in general, are more conservative
than ever intended by the original source.
5
As
explained in Jerry Kuhn’s pre-filed testimony, the current U.S. Environmental
Protection Agency finished drinking waterMaximum Contaminant Level (or “MCL”) for
radium 226 plus radium 228
is
5
pCiIL.
This standard is based on the fact that radium is
a carcinogen.
Persons drinkingwater over a lifetime will theoretically be protected from
cancer at an
acceptable risk level (106 to
l0~’)if the concentration ofradium in drinking
water is less than or equal to
5
pCi/L.
Since the MCL is
a finished water standard, this
makes the previous federal standard of3 pCi/L applicable at the point ofintake (which
applies to raw water) upon which the Sanitary Water Board standard was based,
very
conservative.
Protecting nearly all waters at
1 pCi/L (IPCB) is excessively stringent.
This level ofprotection is undocumented and is unwarranted.
Proposed Radium
226
Plus
228 Public
and Food
Processing Water Supply Standard
Radium is a recognized carcinogen and therefore standards protecting sources of
drinking water are necessary and important.
However,
as far as maybe determined, no
otheruses ofwater are known to be adversely impacted by radium.
The Illinois EPA
conducted a literature search for radium impacts to aquatic life and found no scientific
papers or other information on this subject.
Consultation with USEPA Region V water
quality standards staff also found no indication that radium is anything but a threat to
human health via drinking water.
Other states regulate radium in a similar manner to that proposed by the Agency.
Oklahoma has a standard of
5
pCi/L at the point ofintake forpublic water supplies.
The
Ohio River Sanitation Commission (referred to
as “ORSANCO”) has a water quality
standard for the Ohio River of4 pCiIL applicable everywhere in the river outside of
mixing zones.
ORSANCO considers the entire Ohio River to be a public water supply.
6
Indiana has an intake raw water standard of3 pCi/L, which may be an artifact ofthe old
Green Book standard.
Several other states were contacted including California, Utah and
Arizona, Western states that have had hard rock mining issues.
Even these states have no
aquatic life water quality standards for radium.
Illinois appears to be unique in this
regard.
-
The Agency’s proposal to remove the General Use and Lake Michigan standards
and establish a Public and Food Processing Water Supply standard at the federal MCL for
radium 226 and 228
is protective ofall uses that maybe impacted by radium.
Radium
would
thenbe
regulated in a manner similar to other substances that may cause problems
in drinking water yet do not have to be regulated as stringently for other uses.
These
substances are those listed under 35
Ill. Adm.
Code
3 02.304.
For example, chloride is
regulated at 250 milligrams per liter under
3 02.304 to protect drinking water intakes from
excess salts.
There is no reason to regulate General Use waters at this low level since
other uses ofwaters are protected at higher chloride concentrations.
The existing General
Use standard regulates radium unnecessarily and
causes compliance issues at
communities struggling with drinking waterproblems.
While there is no data forradium to
indicate what the threshold concentration
would be to protect aquatic life, the Illinois EPA is confident that it is much higher than
the
5
pCi/L level given the lack ofconcern for this exposure route by the scientific
community,
the extremely low mass per volume concentration that this standard~
represents and the fact that barium, a much more common metal related chemically to
radium, is not toxic to aquatic life at the low part per million level.
Presently, the known
sources ofradium to the surface water environment are public water supplies that utilize
7
high radium groundwater.
These are typically no higher in concentration than the
groundwater,
and as explained in Blame Kinsley’s pre-filed testimony, usually somewhat
lower.
Even direct discharges ofwastewater resulting from treatment ofhigh radium
groundwater (should these ever occur) constitute only .about double the radium loading
expected from a sewage treatment plant.
Other types ofdischarges are unknown.
Should
a new source ofradium be proposed, the antidegradation standard would be imposed to
require the new source to justifythe radium discharge, which would include studies of
treatment alternatives and steps to
minimize any necessary radium discharges.
It is apparent from our investigation into the scientific information and the lack of
concern in other states and at the federal level that drinkingwater protection is the only
beneficial use classification of Illinois streams and lakes that warrants a radium water
quality standard.
This conclusion is based on concentrations existing or expected to be
realized in Illinois surface waters from either naturally occurring conditions or those
resulting from water treatment plant wastes or their affiliated publicly owned treatment
works in those parts ofthe state that rely on radium-containing groundwater as their
potable raw water source.
The proposed changes to the General Use and Lake Michigan Basin water quality
standards removes the radium standard and replaces it with a standard that protects
surface water intakes for raw drinking water at the established finished drinking water
MCL standard.
This change is protective ofthe sensitive designated use of Illinois
waters to radium and provides a framework in the regulations for a sensible approach to
radium in surface waters.
Radium will now be regulated as a combination ofradium 226
8
and 228 at Public and Food Processing Water Supply intakes at a concentration of
5
pCi/L.
I would like to thank the Board for the opportunity to
submit this pre-filed
testimony and for its consideration ofthe Agency’s rulemaking proposal.
I will be
pleased to answer any additional questions presented by the Board or members ofthe
public regarding the Agency’s rulemaking proposal.
By:___
RobertMosher
March
18, 2004
Illinois Environmental Protection Agency
1021
North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
9
MAR
192004
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARI~-
‘ATE
OF
ILLINOI5
OIIUt~OnControl
Board
IN THE MATTER OF:
)
)
R04-21
REVISIONS TO RADIUM WATER QUALITY
)
(Rulemaking-Water)
STANDARDS:
PROPOSED NEW
35 ILL.
)
ADM. CODE 302.307 AND AMENDMENTS
)
TO 35 ILL. ADM. CODE 302.207 AND 304.525
)
)
PRE-FILED TESTIMONY OF BLAINE KINSLEY
My name is Blame Kinsley.
I am the manager ofthe Industrial Unit in the
Division of Water Pollution Control, Permit Section.
I have been in that position since
December of2002.
The Industrial Unit is responsible for application reviewand issuance
ofNational Pollutant Discharge Elimination System (also referred to as “NPDES”)
permits and State Construction permits for industrial facilities including backwash
discharges from public water supply facilities.
I have worked for the Illinois
Environmental Protection Agency (“Illinois EPA”) for nine years, all
ofwhich have been
spent in the Industrial Unit.
Before coming
to the Illinois EPA, I worked for a consulting
engineering firm in Louisville, Kentucky.
I received a Bachelor ofScience degree in
Geological Engineering from the University ofMissouri-Rolla in 1994.
I have been an
Illinois Licensed Professional Engineer since 2001.
My testimony today will focus on the fate ofradium in publicly owned treatment
works (which I will refer to as “POTWs”).
The specific concerns I will discuss are in my~
testimony are how much radium can be expected to be removed in the various types of
treatment
systems and whether the affected systems will be able to meet the existing
water quality standard for radium 226.
There is little published information available on the fate ofradium 226 in
POTWs.
The State ofWisconsin probably has more experience with radium than any of
the states in U.S. EPA’s Region V (which is the region that includes Illinois).
A
1985
report by the Wisconsin Department of Natural Resources studied five Wisconsin
communities with varying degrees ofradium 226 and 228 in theirwastewater.
That
study concluded that biological sludges, both fixed media and
suspended growth, adsorb
soluble radium and that insoluble radium is also removed in wastewater treatment
processes by either physical settling or biological uptake.
All ofthe communities
studied
had either activated sludge or Rotating Biological Contactor (“RBC”) treatment
processes.
Removal efficiencies, based on influent versus effluent concentrations, ranged
from a low of29 percent to
a high of 97 percent.
For the purpose ofcomparison and to address the lack ofexisting treatment
efficiency or effluent data, the Agency used the fate of barium in a POTW to estimate the
removal efficiencies forradium by the same wastewater treatment facilities.
Both radium
and barium are Group IIA metals on the Periodic Table of Elements which means they
have similar chemical properties.
Influent and effluent sampling data for barium does
exist for some POTWs in Illinois especially those with approved pretreatment programs.
The influent concentrations of barium at a sampling ofthese POTWs were well below the
anticipated concentrations ofradium.
Removal
efficiencies, based on influent versus
effluent sampling, ranged from 25 percent to
62 percent.
Four ofthe five POTWs
reviewed utilized activated sludge
and one usedtrickling filters.
There did not appear to
2
be a correlation between the types oftreatment and the removal efficiencies based on the
limited number facilities where the data was available.
The Illinois EPA is in the process of requiring radium sampling ofsludge at
POTWs where high levels ofradium are found in the community’s source water.
In
addition, new State Construction permits for the discharge ofradium backwashes to
POTWs require influent and effluent sampling at the affected POTW.
This requirement.
is necessary to ascertain the percent removal ofradium in the treatment processes and to
gage the number offacilities that may have problems meeting the
1 picocurie per liter
(pCi/L) water quality standard for radium 226.
To
date, the Illinois EPA has received
only very limited data from this type of sampling.
Based on the data submitted by one
discharger with two wastewater treatment plants, the radium removal efficiencies are
between 31 percent and 60 percent.
Both ofthese wastewatertreatment plants employ an
activated sludge treatment process.
The difference between the two plants is that the
plant with a 60 percent removal efficiency receives much more of its influent from
combined sewer flows.
The combined sewer flows would act to
dilute the radium
concentration coming to plant which would increase its
apparent removal efficiency.
Considering typical raw water concentrations and expected removal efficiencies,
it is anticipated that many POTWs discharging to
streams with little orno continuous
flow may have trouble meeting the existing radium water quality standard.
The changes
proposed by the Agency would assist these communities in remaining in compliance with
water quality standards while still protecting all existing and future uses of the State’s
lakes and streams.
3
Finally, I would like to thank the Board forthe opportunity to
submit this pre-
filed testimony and for its consideration ofthe Agency’s rulemaking proposal.
By:___
-
Blame Kinsley, P.E.
March
18, 2004
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
4
STATE OF ILLINOIS
)
COUNTY OF SANGAMON
)SS.
)
PROOF OF SERVICE
I, the undersigned, on oath state that I have
served
the attached Pre-Filed Testimony ofJeny
Kuhn, Robert Moser and~Blaine
Kinsley upon the person to whom
it is directed, by placing it in
an
envelope addressed to:
TO:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
Johnathan Fun, Chief Legal Counsel
illinois DepartmentofNatural Resources
One Natural Resources Way
Springfield,
Illinois 62702-1271
Matthew Dunn, Division Chief
Illinois Attorney General’s Office
Environmental Bureau
188 West Randolph Street, ~
Floor
Chicago, Illinois
60601
Amy Antoniolli, Hearing Officer
Illinois Pollution Control Board
James
R. Thompson Center
100
W. Randolph Street, Suite
11-500
Chicago, Illinois
60601
Claire Manning, Posegate & Denes
111 N.
6th
Street
Springfield, Illinois 62701
-
Abdul Khalique, Radiation Chemist
Metropolitan Water Reclamation District of
Greater Chicago
6001 W. Pershing Road
Cicero, illinois 60804
and mailing itby First
Class Mail from Springfield,
Illinois
on March
18, 2004, with sufficient postage
affixed.
SUBSCRIBED AND SWORN TO
BEFORE ME
this
18th
day ofMarch, 2004
~Od~Lr
Notary Public
OFFICIAL
SEAL
BRENDA BOEHNER
NOTARY
PUBLIC,
STATE
OF
ILLINOIS
•:•~y
COMMISSION
EXPIRES
i~.i42OO~
THIS FILING
IS SUBMITTED ON RECYCLED PAPER
