October 20, 2004
RECE
CLERK’S
WED
OFFICE
Mr. John C. Knittle
OCT 20 2004
Illinois Pollution Control Board
James R. Thompson Center
STATE OF ILLINOIS
100 W. Randolph - Suite 11-500
Pollution Control Board
Chicago, Illinois 60601
RE: R2004-021 Radium WQS Proposal
Dear Mr. Knittle,
~p~4~-1O
Please accept the attached letter as a written public comment for the proposed
changes to the Radium Water Quality Standard on behalf of the Illinois Association
of Wastewater Agencies’ Water Quality is Subcommittee. An original and copies will
be available for distribution at tomorrow’s hearing.
Please contact me if you have any questions. I thank you for your time in
consideration of these comments.
Sincerely,
Rick Manner, P.E.
IAWA Water Quality Subcommittee - Chairman
ILLINOIS ASSOCIATION OF WASTEWATER AGENCIES WATER QUALITY
SUBCOMMITTEE COMMENTS TO PROPOSED ADDITIONS AND REVISIONS TO
RADIUM WATER QUALITY STANDARDS
General support:
To be effective public servants, Publicly Owned Treatment Works (POTW)
employees have two primary purposes. We must both protect the
environment and also be good stewards of their ratepayers’ money. Some
people see a conflict between these two goals, however by using good
science we are able to decide when and where additional resources are
actually necessary. We use this good science to convince our governing
bodies and ultimately the public of the necessity of some changes.
For this reason, our primary interest in the Illinois Pollution Control Board
(IPCB) rule-making process is to be assured that limits are based upon the
best scientific studies available. In this case the Illinois Environmental
Protection Agency (IEPA) has demonstrated that the current limit of 1 pCi/L
was based upon an outdated, best guess. IEPA has also demonstrated that
since that time, the primary concern that is demonstrated with radium is
human exposure via ingestion. Next, they have demonstrated that the
national limit for ingestion is 5 pCi/L. With that limit in mind, IEPA has
proposed updating the water quality standard with a well-reasoned proposal
that appropriately addresses the demonstrated concern. The Illinois
Association of Wastewater Agencies (IAWA) Water Quality Subcommittee
supports the proposed change.
Burden primarily placed upon small drinking water utilities:
The testimony by IEPA shows that the current water quality standard has
little affect on dischargers to larger water-bodies. Smaller publicly owned
wastewater treatment utilities are more common dischargers to low-flow
streams, where the current 1 pCi/L limit is most problematic. If there is an
issue in terms of discharging in conformance with a water quality based
effluent limit, the POTW will naturally turn to the source of the radium, which
is likely to be an equally small drinking water supplier. This supplier will
often be the same municipality that operates the POTW plant. That supplier
is now faced with potentially meeting a discharge limit that is 5 times as
strict as the national drinking water standard at the same time they are
faced with installing treatment to comply with the drinking water standard.
Without the revision of the current lpCi/L standard, they must either
abandon the wells in the radium-bearing strata or buy a WRT-styled system.
If they choose the latter, they will need to run their system with a much
lower target concentration and the frequency of changing of media will
increase substantially relative to a target of 5 pCi/L, discussed with the
Board. With revision of the current 1 pCi/L standard, they will be free to
chose whatever system is best suited to their needs and will not be
mandated to buy a specific system.
Non-water quality issues should be addressed elsewhere:
IPCB’s rule-making process for water quality standards should be based
upon the best science about water quality issues. Similarly, limits regarding
worker safety should be based upon the best information about worker
safety. However, the venue to impose safety regulations in not a.water
quality standard. In the discussion about the radium water quality standard,
the IEPA has provided a demonstration that it has done a review of water
quality issues. Consequently, it has proposed a rule change that is as
protective for water quality issues as any in the rest of the country.
Nonetheless, if there is a desire to address worker safety at POTW’s in this
procedure, it should be noted that the primary concern is exposure to
radium after ingestion or, to a lesser extent, exposure to radon after
inhalation. Common sense and current safety practices adequately address
these issues. Ingestion of sewage and biosolids is not a serious problem and
ventilation is already required wherever process wastes are contained in a
building.
Other exposure routes are mediated by the nature of sewage treatment and
the ease of interception of alpha emissions. Many times the flow is within a
pipe or tank or there is an odor control curtain between workers and sewage
or workers and biosolids. Also, the clothing that is worn by workers will act
as a barrier. All of these are effective at resolving alpha emitters.
Scientific basis is necessary:
There must be a scientific basis to the regulations proposed. Lacking this,
the public will not have confidence that their money is being spent wisely to
protect the environment. Failure to do so will result is a lack of support
when there is a demonstrated need for lower limits in other areas.
The idea that any lower limit for a pollutant is inherently superior to a higher
limit, regardless of economics or other factors, leads one to the unattainable
conclusion that all pollutants must be limited to zero. While that could be a
laudable goal, this is an irrational way to set binding numerical regulations.
This thought process does not support 1 pCi/L, or any value above another,
since all numbers have an infinite number of values that are smaller than
themselves.
Illegal discharges not affected by standards:
The anecdotes of problems with radioisotopes at POTW’s in Ohio and
Pennsylvania involve illegal discharges that would not be thwarted by a lower
radium standard. These illegal activities were not averted by the other
regulations that were broken by the dischargers. It is noteworthy that all of
the illegal discharges that were discussed were investigated and prosecuted
by POTW’s in defense of their own interests and none of the discharges were
based upon toxicity of radium to any aquatic species. Illinois’ POTW’s can
be expected to protect their interests equally well and these non-aquatic
issues have no bearing upon what is a good water quality standard for
radium.
Residual sources regardless of treatment chosen:
There is a misconception in the testimony presented that if radium is
removed from the drinking water plant’s backwash flow, with a WRT system
for example, there will be none arriving at the POTW, so that the POTW can
safely assume the issue is permanently resolved. The reality is that there is
some residual radium in the drinking water sent to the homeowners and that
fraction can be quite high. For example, if a drinking water utility uses an
aquifer with 8 pCi/L of radium, and they choose to target 4.5 pCi/L for their
product water, more than half of the radium will be sent to homeowners and
ultimately the POTW. For these reasons POTW’s cannot feel relieved if a
WRT system is installed. While 4.5 pCi/L is less than 8 pCi/L, the difference
is not sufficient to allow POTW’s to ignore the issue.
In addition, even if the radium were removed from the equation, there is still
naturally occurring radiation and minor uses from the medical profession or
others. Also, the experiences in Ohio and Pennsylvania demonstrate that all
POTW’s must be vigilant in protecting their workers and the environment
from unanticipated discharges. A demonstration of that commitment is that
the national sampling initiatives cited in the testimony were the result of
POTW-driven efforts. We must continue to review all potential threats to
make the workplace as safe as possible.
