ORIGINAL

1

POLLUTION

CONTROL

BOARD

2

3

4

IN THE MATTER

OF:

5

REVISIONS

TO RADIUM

WATER

)

R04-21

6

QUALITY

STANDARDS:

PROPOSED

)

RULEMAKING

-

WATER

7

NEW

35

ILL

ADM

CODE

302.307

AND AMENDMENTS

TO

35

ILL

ADM

)

8

CODE

302.207

AND

302.525

9

10

11

DATE:

Wednesday,

Thursday,

May

6,

2004

12

TIME:

2:30

PM

13

PLACE:

Illinois

Pollution

Control

Board

14

Hearing

Room

1021

N.

Grand

Avenue

East.

15

Springfield,

Illinois

16

17

18

19

20

Kimberly

A.

Ganz,

CSR,

RPR,

RMR,

CRR

IL

Lic.

#084-001691

21

MO Lic.

#721

22

23

24

JO ELAINE

FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

2

APPEARANCES:

2

MS.

AMY

C.

ANTONIOLLI

HEARING

OFFICER

3

ATTORNEY

ILLINOIS

POLLUTION

CONTROL

BOARD

4

100

W.

Randolph

Street

James

R.

Thompson

Center,

Ste.

11-500

5

Chicago,

IL

60601

6

MR.

NICHOLAS

J.

MELAS

7

BOARD

MEMBER

ILLINOIS

POLLUTION

CONTROL

BOARD

8

100

W.

Randolph

Street

James

R.

Thompson

Center,

Ste.

11-500

9

Chicago,

IL

60601

10

MS.

DEBORAH

J.

WILLIAMS

11

ASSISTANT

COUNSEL

ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY

12

1021

N.

Grand

Ave

East

Springfield,

IL

62794-9276

13

14

MR.

ALAN

KELLER

ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY

15

1021

N.

Grand

Ave

East

Springfield,

IL

62794-9276

16

17

18

19

20

21

22

23

24

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

3

MS.

WILLIAMS:

Good

afternoon.

Welcome

to the Illinois

Pollution

Control

Board.

My name

is Amy Antoniolli

and I’m

the hearing

officer

assigned

to this

rulemaking.

The board has captioned

this

proceeding

in

the matter

of revisions

to

radium water quality

standards

proposed

new

Illinois

Administrative

Code,

302.307

and

amendments

to

35 Illinois

Administrative

Code 302.207

and 302.525 which

the board

has docketed

as

RO4-21.

In this proceeding

the agency

is

seeking

to

amend

the board’s

water

quality,

radium quality

standards.

This

rulemaking

was filed

on January

13,

2004,

by the

Illinois

Environmental

Protection

Agency.

The board accepted

the proposal

for hearing

on January

22,

2004.

This

is the second

The first

hearing

took place

on

2004,

in the James

R.

Thompson

n Chicago.

To my left

is member

Melas,

the board member who

is

to this

matter,

and also present

board’s

technical

unit

are Anand

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

hearing.

April

1,

Center

i

Nicholas

assigned

from the

---

4

1

Rao

and Lisa

Liu.

2

Today’s

hearing

is governed

by the

3

board’s procedural

rules

for regulatory

4

proceedings.

All

information

that

is

5

relevant

and not repetitious

or privileged

6

will

be entered

into

the record.

All

7

witnesses

will

be

sworn and subject

to

8

cross

questioning.

9

The purpose

of today’s

hearing

is two

10

fold.

First,

this rulemaking

is subject

to

11

section

273

of

the Environmental

Protection

12

Act.

Section

273

of

the act requires

the

13

board

to request

the Department

of Commerce

14

and Economic

Opportunity

or the DCEO

to

15

conduct

an economic

impact

study

on certain

16

proposed

rules prior

to

their

adoption.

17

The board must

make

the

impact

study

or

the

18

DCEO explanation

of why

it won’t

conduct

19

the

study

available

to the public

at

least

20

20

days before

the public hearing

on the

21

economic

impact proposed

rules.

The board

22

requested

by letter

in this rulemaking

23

dated

February

18,

2004,

that

the DCEO

24

conduct

an economic

impact

study

of this

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

5

1

rulemaking.

2

On April

2,

2004,

a letter

from the

3

DCEO

explains

that

the DCEO will

not

4

perform

an economic

impact

study

for

this

5

rulemaking.

Due

to physical

constraints,

6

we’ve

made

that letter available

on the

7

table

at the

side

of the

room today

or it’s

8

also available

on the board’s

website

and

9

has been

since

it was

filed with

the board.

10

The second purpose

of this

rulemaking

today

11

is

to allow members

of the public

the

12

opportunity

to testify

and to

ask questions

13

of

the proponents.

14

Mr.

Dennis

Duffield,

Director

of

15

Public

Works

and Utilities

of

the City

of

16

Joliet

has prefiled

testimony

for today’s

17

hearing.

We will

start

today with

a brief

18

summary

of

the proposal

by the agency and

19

then allow

Mr.

Duffield

to give

an oral

20

summary

of

his testimony

or

if he chooses

21

to read his prefiled

testimony

into

the

22

record.

Finally

we will

have

a questioning

23

period and when we get

to

the questioning

24

period,

anyone

can ask

a question

but for

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

6

1

the Reporter,

please

speak up and try not

2

to

speak

over each other

so that

the

3

transcript

comes

out

clear.

Please note

4

that

the questions,

any questions

asked by

5

Member Melas

or any member

of

the

staff

are

6

intended

to help build

a complete

record

7

for the board’s

decision

and not

to

8

expression

any preconceived

notion

or bias.

9

Also

at

the

side

of

the room

today

10

I’ve made

copies

available

of

the board’s

11

order

accepting

this matter

for hearing,

12

the notice

of hearings,

the agency’s

13

proposal,

the prefiled

testimony

both by

14

Mr.

Duffield

and by the agency,

and at

this

15

time

I will

ask Member Melas

if you would

16

like

to add anything.

17

MR.

MELAS:

No.

I

just welcome

18

everybody

here

to

this hearing.

19

HEARING

OFFICER:

So,

we will

turn

it

20

over

to the agency

now.

21

MS.

WILLIAMS:

Thank

you.

Good

22

afternoon,

my name

is Debra Williams

and

23

I’m assistant

counsel

before

the Bureau

of

24

Water

at

the

Illinois

EPA and

as requested

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

7

1

by the Hearing

Officer,

I will

now provide

2

a brief

introduction

to the agency’s

3

rulemaking

proposal

in this matter which

4

was presented

in detail

at

the April

1

5

hearing

in Chicago.

6

Under

Section

303C

of the

Clean Water

7

Act,

the

Illinois

EPA has the obligation

to

8

no less

than every

three

years

conduct

9

reviews

of

its water quality

standards

and

10

update

those

standards

where

needed.

As

11

part

of

that ongoing process.

The agency

12

has proposed

this update

to the water

13

quality

standards

for rating.

Currently

14

the standard

applicable

to all general

use

15

waterways

in the

state

of Illinois

is

a

16

radium

226 standard

of

one pico-curie

per

17

liter.

U.S.

EPA has established

a maximum

18

contaminant

level

or MCL

of

5 pico-curies

19

per liter

for radium

226

and radium

228

20

combined.

Research

by the agency has

21

concluded

that

the technical

basis

for

the

22

radium water quality

standard

was

23

protection

of human health

from consumption

24

of radium

in drinking

water

and that

5

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

8

1

pico-curies

per liter

is clearly

the

level

2

protective

of

that use as established

under

3

the

Safe Drinking

Water

Act.

Therefore,

4

the agency

has proposed

changing

the

5

standard

to

5 pico-curies

per

liter and

6

placing

that standard

in the board’s

public

7

and food processing

water

supply standard

8

thereby making

the standard

applicable

only

9

in drinking

water

supply

intake.

10

The new standard

is proposed

to be

11

placed

in section

302.307

of subpart

C of

12

part

302

of

the board’s

regulations.

The

13

agency has also proposed

to repeal

the

14

general

use standard

in section 302.207

of

15

subpart

C and the Lake Michigan basin

16

standard

of Section

302.525

in subpart

E.

17

I have

with me

today

several

agency

18

staff

members

who are again available

to

19

answer

any additional

questions

by the

20

board

or members

of

the public.

To my left

21

is Bob Mosher

of the Bureau

of Water

22

Standard

Unit,

and to my right

is Jerry

23

Kuhn

of

the Division

of Public Water

24

Supplies,

both

of whom

attended

the first

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

9

1

hearing,

and

to my far right

is Al

Keller,

2

the permit

section manager who will

stand

3

in for Blake

Kinsley

of the industrial

unit

4

who was

not able

to attend this week’s

5

hearing.

Thank you for this opportunity

to

6

summarize

the proposal

and for thanking

the

7

board

in advance

for consideration

of our

8

proposal.

9

HEARING

OFFICER:

Thank you,

Miss

10

Williams.

At this

time

we could

go ahead

11

and have

Mr.

Duffield

sworn

in,

then he can

12

choose

to either give

a summary

of his

13

prefiled

testimony

or go ahead and read the

14

testimony

into

the record.

15

(Mr.

Duffield

is sworn.)

16

HEARING

OFFICER:

Thank you.

17

MR.

DUFFIELD:

My name

is Dennis

18

Duffield,

I am the Director

of Public Works

19

and Utilities

for

the City

of Joliet

and

I

20

would

like

to summarize

my testimony

as

21

I’ve

already prefiled.

22

The Joliet public water

supply

has

23

radium

in

it that exceeds

the drinking

24

water

standard.

We also operate

two

JO ELAINE FOSTER & ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

10

1

wastewater

treatment

plants

that receive

2

the wastewater

from this water

supply which

3

results

in radium

as an influent

to the

4

treatment

plants.

On

a numerical

average,

5

Joliet

has about

10.4 pico-curies

of

6

combined

radium

226 and

228

in its water

7

supply.

That

ranges throughout

the system

8

based

on actual

wells

that

are operated.

9

Of that,

between

the range

of

6.2

and

10.0

10

pico-curies

per liter arise

as influent

to

11

the two treatment

plants.

The treatment

12

plants

off

of

the two

samples

we’ve

13

analyzed remove

somewhere

between

2

and

81

14

percent

of the radium and have discharged

15

radium

in the

effluent

in the plants

at

a

16

range

of

1.9

to

6.1 pico-curies

per liter.

17

Our east

side plant

discharges

into

18

Hickory

Creek

at

the confluence

with

the

19

Des

Plaines

River.

We sample upstream

and

20

downstream

of our discharge

point

and have

21

found

that

the upstream

radium

22

concentration

is 1.3 pico-curies

per

liter

23

of combined

radium

226 and

228

and the

24

downstream

which

is essentially

within

the

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

11

1

Des

Plaines

River

is

1.4 pico-curies

per

2

liter,

or almost

no change.

3

Joliet believes

the proposed

rule

is

4

necessary

to allow Joliet

to complete

our

5

plans

to treat

for radium

in

the water

6

supply system using

the hydrous

manganese

7

oxide

treatment

method which results

in the

8

discharge

of radium

to the sanitary

sewer

9

as

it’s currently

discharged

and then

10

ultimately

to the Des Plaines

River and

11

Hickory

Creek

and we would

like

to do

so

12

without

a water quality

standard

violation.

13

We’ve noted

that

in testimony

provided

14

by Bob Mosher

of

the

Illinois

EPA

that

the

15

original

standard

for radium was

16

established

based

on problems

with people

17

ingesting

radium.

The proposed

rule

18

provided by the agency addresses

this by

19

establishing

a standard

for public water

20

supply

intakes

and food processing

21

facilities.

We support

the implementation

22

of this

rule.

That

summarizes

my

23

testimony.

24

HEARING

OFFICER:

Very good.

Thank

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

12

1

you,

Mr.

Duffield,

for your

testimony.

If

2

there

is no objection,

I have

a copy

of

the

3

prefiled

testimony

in front

of me

and

I

4

will move

to enter

that

as Exhibit

No.

1.

5

Seeing

no objection,

I

enter

this exhibit.

6

Does

anyone

here have

any questions

for

7

Mr.

Duffield?

Go ahead.

8

MR.

KELLER:

You’re building

a new

9

treatment

plant

on the

far west

side

of

10

Joliet

and would

that treatment

plant

have

11

similar

type problems

with radium

or not.

12

MR.

DUFFIELD:

I expect

that

it would,

13

that

it would be

the same because

at that

14

location,

we have

all

deep wells.

We won’t

15

have

any shallow

wells

so

the incoming

16

radium concentration

might

be higher

at

17

that plant.

18

HEARING

OFFICER:

And

I have

a

19

question

out

of curiosity.

Have

you or

20

your

staff

investigated

other

methods

of

21

removing

the radium from

the drinking

water

22

besides

the

co- precipitation

of radium?

23

MR.

DUFFIELD:

Yes,

we have

analyzed

24

two other

methods.

One method does

not

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

13

1

discharge

to

the sanitary

sewer.

That

2

method concentrates

the radium and ships

it

3

off to

a low level

hazard,

radium waste

4

disposal

site which

we think

has other

5

problems

and

so out

of cost analysis

and

a

6

risk

to our customers,

we have

selected

the

7

hydrous

manganese

oxide process

and will

be

8

submitting

that

as

a part

of our design

9

report

for review.

10

HEARING

OFFICER:

At this

time,

is

11

there

anyone

else

or any questions

for the

12

witnesses

from the agency?

Okay.

We thank

13

everyone

who

is here

for being here

today

14

and for the testimony

that you have

15

provided.

For

the record,

the board will

16

accept public

comments

in this

rulemaking

17

to be included

in the first

notice

18

opinionated

order

until

June

3,

2004.

19

There

will

be an additional

public

comment

20

period after

the board adopts

these

rules

21

for first

notice

45 days after

the first

22

notice

appears

in the environmental

23

register.

24

Today’s

hearing

concludes

the hearings

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

14

1

scheduled by the board

in this

matter but

2

any party may request

an additional

hearing

3

pursuant

to Section

102.14l2B

of

the

4

board’s procedural

rules.

5

We hope

to have

the transcript

for

6

today’s

hearing within

10

days and that

7

transcript

will

be available

on the board’s

8

website which

is www.ipcb.state.il.us.

9

There

the transcriptsw

as well

as

the

10

agency’s

proposal

and all

of

the boards

11

orders throughout

this proceeding

will

be

12

viewable

and downloadable

at no charge.

13

Alternatively

you may order

a copy

of

the

14

transcript

from the clerk

of the board

at

15

75 cents

per page.

Anyone

can file

a

16

public

comment

with

the clerk

of the board

17

but please note

when

filing

a public

18

comment

you must

serve

all

the people

on

19

the

service

list with

a copy

of

the public

20

comment.

Again,

copies

of the current

21

service

list

are available

at

the

side

of

22

the

room or you may call

the board

at

any

23

time

to request

the most current

and

24

up-to-date

copy.

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

15

1

If there

is nothing

further,

I want

to

2

thank you

all

again

for your

comments

and

3

testimony

and this hearing

is adjourned.

4

Thank

you.

5

6

HEARING

ADJOURNED:

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

JO ELAINE FOSTER

& ASSOCIATES,

P.C

(618)

877-7016

F:

(618)

655-0660

---

16

1

STATE

OF

ILLINOIS

)

sS

2

COUNTY

OF

WASHINGTON)

3

4

I,

KIMBERLY

A.

GANZ,

Lic.

No.

084-

5

1691,

a

Certified

Shorthand

Reporter

in

and

6

for

the

County

of

Washington,

State

of

7

Illinois,

DO

HEREBY

CERTIFY

that

the

8

foregoing

transcript

was

taken

down

in

9

shorthand

by

me

and

afterwards

transcribed

10

under

my

direction

by

computer

11

transcription

and

said

transcript

is

12

herewith

returned.

13

IN

WITNESS

WHEREOF,

I

have

hereunto

14

set

my

hand

and

affixed

my

Seal

this

13th

15

day

of

May,

200

18

Certified

Shorthand

Reporter

19

f~PICIALSEXt~1

20

~

Kimberly A. Ganz

~

Notary Public, State of

Illinois

21

My Commission Exp. 03/26/2008

22

23

24

JO ELAINE FOSTER

& ASSOCIATES,

P.C.

(618)

877-7016

F:

(618)

655-0660

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

(

IN 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

)

)

R04-21

)

(Rulemaking-Water)

)

)

)

)

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

188 West Randolph Street,

20th

Chicago, Illinois

60601

Amy Antonelli, Hearing Officer

fl

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

62702-1271

Claire Manning, Posegate

and

Denes

111 N.

6th

Springfield, Illinois

6001

Cicero, Illinois

Lisa Frede

2250

E. Devon Street, Suite 239

DesPlaines,

Illinois

60018

Roy Harsch

Gardner,

Carton & Douglas

Suite 3700,

191

North Wacker

Chicago,

Illinois

60606

Richard Lanyon

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

Chicago, Illinois

60601

Deborah J.

Williams

Assistant Counsel

Illinois Environmental Protection Agency

Mail

Code #21

1021 North Grand Avenue East

P.O. Box

Springfield, Illinois

62794

/

---

PLEASE

TAKE

NOTICE

that I have today filed with the Office ofthe Clerk ofthe

Pollution ControlBoard

the PRE-FILED TESTIMONY OF DENNIS L. DUFFIELD, P.E.

on behalfofthe City of Joliet, a copy of which is herewith served upon you.

CITY OF JOLIET

By:

~

Dennis L. Duffie1~.E.

City ofJoliet

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

---

BEFORE

THE ILLINOIS POLLUTION CONTROL

BOARD

IN THE MATTER OF:

)

)

R04-2l

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 ofJoliet

for approximately

24

years

and have been responsible for the water and

wastewater systems

for all

but the first four months of

9

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 of this 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

Q

the DesPlaines River and directly to the DesPlaines

River.

Prefiled Testimony ofDennis Duffield

Page

1

---

The City

of Joliet’s

water supply

system

currently

consists

of

15

deep

wells

that

produce water that exceeds the drinking 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 of radium 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

pCi/liter

and 228,

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

pCi/liter

and 228

February 2004

2.9

5.1

8.0

March8, 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 of Dennis Duffield

Page 2

0

o~

---

The filters collect the precipitate and begin to filter water at a slower rate.

The flow

of water 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

2004

2.0

2.9

4.9

~

March 8,

2004

0.9

1.0

1.9

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

0

information, the range ofthe removal for combined radium226 and 228

is from 2

to 81.

Prefiled Testimony ofDennis Duffield

Page3

---

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 ofsamples

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

0

Sample

Upstream

Sample

0

---

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 of the 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 ofthe 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 of Dennis 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:

DDQ/114~

Q~)1~.~k

Dennis L. Duf~3~,

P.E.

City ofJoliet

Directorof Public Works and Utilities

April 22, 2004

City ofJoliet

Department ofPublic Worksand Utilities

921

E. Washington

Joliet, Illinois

60433-1267

Prefiled Testimony ofDennis Duffield

Page 6