NOTICE OF FILING
me this 23rd day ofAugust, 2004.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RADIUM WATER QUALITY STANDARDS

BEFORE THE ILLINOIS POLLUTION CONTROL

BOARD

iN THE MATTER OF:

REVISIONS TO RADIUM WATER QUALITY

STANDARDS: PROPOSED NEW

ILL.ADM.

CODE 302.307 and AMENDMENTS TO

ILL. ADM. CODE 302.207 and

302.525

)

REC~VED

CLERK’S OFFICE

AUG

232004

STATE OF ILLINOIS

Pollution Control Board

)

R04-21

)

(Rulemaking

Water)

NOTICE OF FILING

TO:

SEE ATTACHED SERVICE LIST.

PLEASE TAKE NOTICE that on Monday, August 23, 2004, we filed the attached

Metropolitan Water Reclamation District’s Comments to Proposed Additions

and Revisions to

Radium Water Quality Standards with the Clerk ofthe Pollution Control Board, a copy of which

is herewith served upon you.

Michael G. Rosenberg/Ronald M. Hill

Metropolitan Water Reclamation

District of Greater Chicago

100 East Erie Street

Chicago, IL 60611

(312)

751-6583

METROPOLITAN WATER RECLAMATION

DISTRICT OF GREATER CHICAGO

BY:

Michael G. Rosenberg, its Attorney

CERTIFICATE OF SERVICE

I, J ~-~b

ii-1

PI~

Lfl1~b~

being duly sworn on oath, certif~rthat I caused a

copy of the attached Metropolitan Water Reclamation District’s Comments to Proposed

Additions and Revisions to Radium Water Quality Standards to be sent via first class U.S. Mail

to the individuals identified on the attached service list their addresses as shown, with proper postage

prepaid, from 100 E. Erie Street, Chicago, Illinois, at or near the hour of 4:00 p.m., this 23rd day of

August, 2004.

SUBSCRIBED and SWORN to before

me this 23rd day ofAugust, 2004.

Rosalie Bottari

Notary

Public

Notary

Commission

public, State

Exp. 04/10/2006

of Illinois

RH:me

THIS

FILING

IS SUBMITTED ON RECYCLED PAPER

Printable Notice List

Page lof 1

~rdner Cgr1Qn~

j~Q~

Interested Party

Qffice of thI~i1F~V

General

Petitioner

100 East Erie

Street

Chicago

Richard Lanyon, Director of Research and Development

1021 North

Grand Avenue East Springfield

P.O. Box 19276

IL 62794-9276

Deborah

J. Williams”

Stefanie N. Diers, Assistant Counsel

-“

191 N. Wacker

Drive

Chicago

Suite 3700

IL 60606-1698

Roy M. Harsch -

__________

Sasha M. Engle—

SonnenscheinNath

8000 Sears Tower

Interested

Rosenthal

Party

233 South

Wacker Drive

Jeffrey C.

Fort-’

Letissa Carver Reid

Environmental Bureau

Chicago

186 West

Randolph, 20th

Floor IL 60601

Joel

J. Sternstein, Assistant Attorney Genera ‘

______

Matthew J. Dunn, Division Chief

East Main Street

Champaign

IL 61820

John

McMahon

100W.

Randolph St.

Chicago

Suite

11-500

IL 60601

DorothyM.

Gunn, Clerk of the

Board

Amy Antoniolli, Hearing Officer

One Natural Resources Way

Springfield

IL 62702-1271

Jonathan Furr, General Counsel

2250 E. Devon Ave.

Suite

239

Des PIaii~

IL 60018

Lisa Frede

631 E.

Butterfield Rd.

Lombard

Suite 315

60148

William Seith

Abdul Khalique, Radiation Chemist

Total

number

participants:

Party Name

Metrop~lltanWater

Reclamation District

Interested Party

Role

IEPA

Petitioner

City & State

Phone/Fax

312/751-6583

312/751-6598

217/782-5544

217/782-9807

312/569/1000

312/569-3000

Chicago

IL 60606-6404

312/876-8000

312/876-7934

Wilkie & McMahon

Ihterested Party

Control Board

Interested Party

312/814-2550

312/814-2347

Illinois Department of

Natural Resources

Interested Party

217/359-2115

217/359-2754

CICI

Interested Party

3128143956

Total Environmental

~QEUllQJ1S

Interested Party

217/782-1809

217/524-9640

~tr~QiIt~flW~te1

Reclamation District

PiateL~hiQagQ

Interested Party

847-544-5995

Cicero

6001 W.

Pershing Road

60804

6309693300

6309693303

708-588-4071

http://www.ipcb .state.il.us/coollexternal/casenotify.asp?caseid=6285&notifytype=Service

8/20/2004

RECEW~WCLERK’S

OFFICE

AUG 23

200k

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

STATE OF ILUNOIS

INREVISIONSTHE MATTERTO RADIUMOF:

WATER QUALITY

)))

R04-21

rOiiU

ion Control Board

STANDARDS: PROPOSED NEW

ILL.ADM.

)

(Rulemaking

Water)

CODE 302.307 and AMENDMENTS TO

)

ILL. ADM. CODE 302.207 and 302.525

)

METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER

CHICAGO’S COMMENTS TO PROPOSED ADDITIONS

AND

REVISIONS TO

RADIUM WATER QUALITY STANDARDS

The Metropolitan Water Reclamation District of Greater Chicago (“District”),

submits the following comments in support of the proposed addition of 35 Ill. Adm. Code

Part 302.307, and amendments to 35 Ill. Adm. Code 302.207 and 302.525.

My name is Richard Lanyon. I am the Director ofResearch and Development

for the Metropolitan Water Reclamation District of Greater Chicago. I am submitting the

following statement on behalf of the District in support of the proposed additions and

amendments to the standard for radium.

The District is a unit of local government created by the state legislature for

the purpose ofcollecting and disposing of sewerage, reducing pollution ofthe waterways and

preventing flooding. 70 ILCS

2605/1, et seq.

(“District Act”). The District’s service area is

most of Cook County. In its capacity as a water reclamation district, the District operates

seven treatment facilities in its service area, serves five million residents and treats an

average of 1.4 billion gallons of sewage daily. The District has seven wastewater treatment

plant NPDES permits issued by the Illinois Environmental Protection Agency (“IEPA”).

The District has reviewed the revisions to the Radium Water Quality Stan-

dards: Proposed 35 Ill. Adm. Code 302.307 and amendments to 35 Ill. Adm. Code 302.207

and 302.525, and agrees with the Illinois Environmental Protection Agency’s (“Agency”)

proposal as delineated in the Board’s First Notice for the following reasons:

A. The only known documented exposure pathway that poses significant risk to hu-

man health or the environment for radium-226 is human exposure to drinking water.

The Agency conducted a literature survey for radium impacts to aquatic life and

found no scientific papers or other information on this subject. United States Envi-

ronmental Protection Agency-Region V water quality standards staff also found no

indication that radium poses risk in pathways other than the human drinking water

pathway.

The current water quality standard for radium-226 in General Use water

(302.207) and the Lake Michigan Basin

(302.525)

is 1 pCiIL, whereas the federal

drinking water maximum contaminant level for radium-226 plus radium-228 is

pCi/L. The General Use water and Lake Michigan Basin standards are more stringent

than drinking water standards and there is currently no scientific basis for this.

Therefore, there is no reason to regulate radium-226 in General Use water or the Lake

Michigan Basin at such a low concentration.

Because consumption ofdrinking water is the only pathway currently sufficiently

documented to pose significant risk, the Agency is justified in moving the standards

from General Use water quality to the Public and Food Processing water supply. The

Agency is also correct in deleting the standard from General Use waters and the Lake

Michigan Basin until such time as sufficient information is generated to demonstrate

that radium-226 in these waters poses an environmental risk.

D. Adoption of the proposed revisions will relieve point source discharger such as

POTWs of an unnecessary burden ofbeing subjected to possible effluent limitations

on radium-226. Such limitations would not have any environmental benefit, but

could place a financial burden on the POTW community.

In summary, the proposed rule as published in the Illinois Register brings Illinois ra-

dium water quality standards in line with federal radium drinking water standards and re-

lieves the POTW community from unnecessaryregulatory burdens.

August

23,

2004

Metropolitan Water Reclamation

District of Greater Chicago

100 East Erie

Chicago, Illinois 60611

312.751.5190

Metropolitan Water Reclamation District

ofGreater Chicago,

By:

~irorofR&b

Richard Lan

THIS FILING IS SUBMITTED ON RECYCLED PAPER