N
THE MATTER OF:
)
)
REVISIONS TO READIUM WATER QUALITY
STANDARDS: PROPOSED NEW
35
ILL.
ADM. CODE 302.307 AND AMENDMENTS
TO
35
ILL.
ADM. CODE 302.207 AND 302.525
NOTICE OF FILING
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
Illinois Attorney General’s Office
Environmental
Bureau
188
West Randolph Street,
20th
Floor
Chicago, Illinois
60601
Amy Antonelli, Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois
60601
Jonathan Fun, General Counsel
Illinois Department ofNatural Resources
One Natural Resources
Way
Springfield,
Illinois
62702-127 1
Claire Manning, Posegate and 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
Lisa Frede
CICI
2250 E.
Devon Street, Suite 239
DesPlaines, Illinois
60018
Roy Harsch
Gardner,
Carton & Douglas
Suite
3700,
191
North Wacker
Chicago, Illinois
60606
Richard Lanyon
Metropolitan Water Reclamation District of
Greater Chicago
100 East Erie Street
Chicago, Illinois
60611
Bill
Seith
Total Environmental Solutions
631
W.
Butterfield Road,
Suite 315
Lombard, Illinois
60148
Joel Sternstein
Assistant Attorney General
Environmental Bureau North
188 W.
Randolph Street,
20th
Floor
Chicago, Illinois
60601
Deborah J. Williams
Assistant Counsel
Illinois Environmental Protection Agency
Division of Legal Counsel
Mail Code #21
1021 North Grand Avenue East
P.O. Box
19276
Springfield, Illinois
62794
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RE
CE
fiV ED
CLERK’S OFF! CE
APR
2 ~ 20t14
R
04-21
STATE OF ~LLlNOIS
)
(Rulemaking-Water)
Pollution Control Board
)
)
)
)
PLEASE TAKE NOTICE
that I have today filed with the Office of the Clerk ofthe
Pollution Control Board the
PRE-FILED TESTIMONY OF DENNIS L. DUFFIELD, P.E.
on behalfofthe City ofJoliet, a copy of which is
herewith served upon you.
CITY OF JOLIET
By:_______________
Dennis L. Duffield~.E.
City of Joliet
Director of Public Works and Utilities
DATED: April
22, 2004
City of Joliet
921
E. Washington Street
Joliet, Illinois
60433-1267
(815)
724-4230
THIS FILING
IS SUBMITTED
ON RECYCLED PAPER
RE CE
V ~
CLERK’S OFFICE
BEFORE
THE ILLINOIS POLLUTION CONTROL
BOARD
APR
252004
STATE OF ILLINOIS
Pollution
Control Board
N
THE MATTER OF:
)
)
R04-21
REVISIONS TO READIUM WATER QUALITY
)
(Rulemaking-Water)
STANDARDS: PROPOSED NEW
35
ILL.
)
ADM. CODE 302.307 AND AMENDMENTS
)
TO
35
ILL. ADM. CODE 302.207 AND 302.525
)
)
PRE-FILED TESTIMONY OF DENNIS DUFFIELD
My name
is
Dennis Duffield.
I am the Director of Public
Works and
Utilities for
the City of Joliet.
I am responsible
for the planning,
design,
construction
and
operations
of water
and wastewater systems
for Joliet.
I have worked for the City of Joliet
for approximately 24
years
and have been responsible for the water and
wastewater systems for
all
but the first four months of
the 24 years.
Prior to working at the City ofJoliet, I worked for the City of Virginia Beach, Virginia
for approximately
five
years with
responsibilities
for
the operations of the water
distribution
and
wastewater collection
systems.
Previous experience was in the Indian Health Program of the United
States
Public
Health Service.
I received
a
Bachelor of Science
in
Civil
Engineering
from Bradley
University in
1972.
I have been a Licensed Professional Engineer in the State ofIllinois since
1980.
Today
I
will testify
in
regards
to
the Illinois
Environmental Protection
Agency’s
(IEPA) proposed changes to the water quality standards
for radium and
the impact ofthis proposal
on the water supplies and wastewater treatment plants.
The
City
of Joliet
operates
a
public
water
supply
using
groundwater
containing
radium. After use by consumers, the water is
discharged to the two
wastewater treatment
plants that
the City of Joliet also operates.
Discharge from the plants is to Hickory Creek at the confluence with
the DesPlaines River and directly to the DesPlaines River.
Prefiled Testimony of Dennis Duffield
Page
1
The City
of Joliet’s
water supply
system
currently
consists of
15
deep
wells
that
produce water that exceeds the thinking water standard for combined radium 226
and radium 228 of
5.0 pico-curies per liter and
5
shallow wells that produce water that complies with the standard.
This
water
is currently supplied to consumers without treatment.
The wastewater from the community
is
collected
and
transported
to
two
wastewater
treatment
plants.
Since
no
radium
treatment
is
provided, the radium that enters the system arrives at the wastewater treatment plants.
Joliet
recently measured the concentration ofradium in the influent to
the treatment
plants.
The results area as follows:
Joliet Eastside Wastewater Treatment Plant
Date
Radium
226
pCi/liter
Radium 228
pCi/liter
Combined Radium 226 and 228,
pCi/liter
February 2004
3.0
5.3
8.3
March
8,
2004
1.9
4.3
6.2
Joliet Westside Wastewater Treatment Plant
Date
Radium 226
pCi/liter
Radium
228
pCi/liter
Combined Radium 226 and 228
pCi/liter
February 2004
2.9
5.1
8.0
March
8, 2004
3.9
6.1
10.0
These concentrations of radium arriving at the wastewater plants are very near to
the
10.4 pico-curies per liter
average concentration measured in Joliet’s deep wells.
Joliet
is
planning
to
remove radium from
the drinking water by
implementing
the
co-precipitation of radium with pre-formed hydrous manganese oxide.
In this process, a solution of
hydrous
manganese
oxide
is
mixed
with
the
well
water
and
forms a
precipitate.
The
radium
is
attached to the precipitate.
The precipitate is filtered from the water which removes the radium.
Prefiled Testimony ofDennis Duffield
Page 2
The filters collect the precipitate and begin to filter water at a slower rate.
The flow
ofwater is
then reversed and the precipitate
is washed from the filter and collected.
This stream is
known as the
“backwash”.
This wastewater from the water treatment process
is
then discharged to
the sanitary sewer.
This
wastewater contains the radium removed from the drinking water.
The backwash combines with discharge from homes and businesses in the sanitary
sewer and
becomes the influent to the wastewater treatment plants.
Since the radium is
removed and
subsequently recombined, there
is
no
change
in
the quantity of radium anticipated to
arrive
at the
wastewater treatment plants.
Measurements
of the
concentration
of radium
discharged
from
the
wastewater
treatment plants were also taken.
The results ofthe measurements are as follows:
Joliet Eastside Wastewater Treatment Plant
Date
Radium
226
pCi/liter
Radium 228
pCi/liter
Combined Radium 226 and 228,
pCi/liter
February 2004
1.2
3.9
5.1
March
8, 2004
2.6
3.5
6.1
Joliet Westside Wastewater Treatment Plant
Date
Radium 226
pCi/liter
Radium 228
pCi/liter
Combined Radium 226 and
228
pCi/liter
February
2.0
2.9
4.9
2004
March
8,
0.9
1.0
1.9
2004
All ofthe discharge results demonstrate that this proposed rule is necessary to allow
the continued
discharge from
existing
wastewater treatment
plants. The concentration
of radium in
the
treatment
plant
discharge
is
reduced
from
the
influent
concentration.
From
this
limited
information, the range of the removal for combined radium 226 and 228
is from 2
to 81.
Prefiled Testimony ofDennis Duffield
Page 3
The discharge
from
the Joliet
Eastside Wastewater Treatment Plant
is
to
Hickory
Creek at the confluence with the DesPlaines
River.
Joliet collected stream samples from
a location
upstream ofthe plant discharge on Hickory Creek and
a location downstream ofthe plant
discharge
on the DesPlaines River submitted for radium concentration
determinations.
The results of samples
collected March 8, 2004 are as follows:
Location
Radium 226
pCi/liter
Radium 228
pCi/liter
Combined Radium
226
and
228
pCi/liter
Upstream
0.1
1.3
1.3
Downstream
0.2
1.2
1.4
The specific sampling
locations are shown on the map below:
These sample results
show the impact ofthe discharge on the river is very limited.
Prefiled Testimony ofDennis Duffield
Page 4
Sample
Back to top
Upstream
Sample
Joliet has collected additional
influent
and effluent samples and is waiting for the laboratory results.
It is our intent to provide this information if it becomes available before the hearing record is closed.
The
proposed
rule
is
necessary
to
allow
the
water
supplies
to
proceed
with
construction of the required facilities
to
remove radium from
the drinking water and
to
be
assured
that the discharge of the backwash
or other return
flows
from
the radium removal
treatment system
can
be
discharged
to
the
sanitary
sewer without
causing
an
effluent
violation
for the
wastewater
treatment plant owner.
This
will
also allow the wastewater treatment plant owner to be
assured that
it will not be
necessary to
develop additional
standards for the discharge of water treatment
wastes
containing
radium
to
the
sanitary
sewer
system.
Joliet
currently
prohibits
the
discharge
of any
radioactive
wastes
of such concentrations that
will
cause
the
treatment
plant to
violate any
water
quality
standards.
Without the approval ofthe IEPA’s proposed rule, Joliet
would have to consider
other water treatment methods that do not discharge the water treatment waste stream containing the
radium to the sanitary sewers.
This
would be
required as the discharge ofradium bearing wastes to
the sanitary sewers could result in a violation of the existing water quality standards.
As
indicated in
the
testimony of Robert Mosher
at the
April
1,
2004
hearing, the
only
threat
to
human health
from
radium
is
through
ingesting
the radium
through
drinking
water.
The IEPA’s
proposed water quality standards
adequately address any potential problems with
food
processing
and public
water supply
intakes and allow the continuation of discharges by
wastewater
treatment facilities.
The City of Joliet
supports the implementation of the
water quality
standards
for
radium.
Prefiled Testimony ofDennis Duffield
Page 5
I would like to thank the Board for the opportunity to
submit pre-filed testimony.
I
will be pleased to
answer any additional
questions presented by the Board
or members of the public
regarding my testimony.
By:
~Z’~h4
~4~i&
Dennis L. DuW3jI, P.E.
City ofJoliet
Director of Public Works and Utilities
April 22, 2004
City ofJoliet
Department ofPublic Works and Utilities
921
E.
Washington
Joliet, Illinois
60433-1267
Prefiled Testimony of Dennis Duffield
Page 6