Ms. Dorothy, M. Gunn, Clerk
    ~EC07
    ~
    Illinois Pollution Control Board
    James R. Thompson Center
    STATE OF ILLl~~d
    100 W. Randolph Street, Suite 11-5000
    poUutiOfl Contro
    Chicago, Il 60601
    Re:
    Docket Number R-04-021
    n ~
    Revisions to Radium Water Quality Standards
    \&~~
    Dear M. Gunn:
    Thank you for this opportunity to provide comments on the referenced issue. Please include
    them with the record of this docket.
    Radium is currently regulated under Sections 302.207. a and b of Illinois’ Water Quality
    Standards for general use waters. Paragraph a addresses gross beta concentration, and paragraph
    b limits radium 226.
    The USEPA has completed extensive research on the effects of pollutants in the environment.
    The Agency states on its
    Technology Transfer Network Air Toxics Website
    that “No information
    is available on the acute effects of uranium, radium, or radon in humans.” My review of
    available literature has failed to find any study identifying acute toxicity levels of radium for any
    animal, which would be translated into a water quality standard below the current gross beta
    WQS.
    Radium’s chronic effects on humans as well as wildlife can be documented, but the resultant
    water quality standards should not be based upon acute toxicity. The end result of a chronic
    versus acute toxicity loading is that the assumed stream flow associated with the calculated
    discharge limits of wastewater treatment plants. Typically, for most pollutants, wastewater
    treatment plant discharge limits are based upon the acute toxicity and the ten year seven day low
    flow. This is the appropriate way to protect wildlife from acute toxicity for pollutants such as
    ammonia, due to the fact that short term exposures to ammonium are toxic to wildlife. Radium,
    on the other hand, does not present similar acute environmental hazards. If a radium standard is
    to be met, then the NPDES limits should be based on annual average flows instead of ten year
    seven day low flows.
    If a water quality standard is to be based upon chronic effects of humans or wild and domestic
    animals, then the current level associated with drinking water standards would be appropriate.
    This level has been studied and documented to assure protection from the chronic effects of
    radium. The level is based upon long term consumption of the water at the 9S~percentile of
    water usage. Once again this limit is based on long term usage and chronic effects. Primary
    contact in surface waters would present a significantly lower health risk due to the limited
    amount of consumption and contact of the waters as compared to drinking water.
    Communities that have radium in sources for drinking water have a limited number of
    alternatives for reducing levels. Many of these alternatives generate recycle streams that are
    discharged to sanitary sewers. By requiring NPDES discharge limits be based on ten year seven
    day low flows and that the allowable level is only twenty percent of what is considered safe to
    drink, the cost effective method of addressing radium throughout the community will be
    affected.
    There is limited information on cost effective methods for removal of radium in wastewater
    treatment plants. Activated sludge processes have been found to remove between twenty to
    eighty percent of influent radium in waste sludge. While the literature on removal is scarce,
    apparently the mechanism for removal is either chemical precipitation or absorption into waste
    sludge. An oversimplified model may attribute the twenty percent base line removal as
    absorption and the remaining sixty percent to be dependant upon plant chemistry.
    USEPA research on the mater has identified barium sulfate and gypsum as possible coagulants
    for radium. Barium may be found in trace amounts in wastewater, but it probably is not present
    in sufficient quantities to account for radium removal. The components of gypsum (CaSO4
    2H20) are found in most wastewaters. How these components are allocated to different
    compounds is dependant upon many variables. Calcium is found in water hardness that may be
    used for nitrification. Sulfur compounds can be found in many forms that tend to depend on pH
    and dissolved oxygen of the sewage as it travels through the sewer system and treatment
    facilities.
    In order for either coagulant to assist in the removal of radium, the sulfur must be in the form of
    sulfate. Sulfates are removed from wastewaters when anaerobic conditions exist. Treatment
    plants designed to remove phosphorous biologically, are required to include anaerobic zones
    which will also remove the sulfates from the mixed liquor. Improvements that will result in the
    reduction of phosphorous to the waters of the State, may reduce POTW’s ability to remove
    radium.
    Treatment methods to further reduce radium levels at wastewater treatment facilities are
    essentially the same methods available for potable water treatment. Most of these methods result
    in a back wash stream relatively high in radium. These methods would not be feasible, because
    they could not be discharged to surface waters. The only methods that could be used to are those
    that remove the radium in a sludge or on a filter media that is concentrated and disposed of.
    The typical source of radium for communities is from the raw water from deep wells. If a
    community is to treat its source water to meet drinking water standards, then the cost effective
    method of reducing radium in wastewater treatment discharges will most likely be removal
    facilities for the raw water. This will also apply to those communities that currently meet
    drinking water standards, but have POTW discharges greater than the WQS. The allowable
    treatment methods will be limited to those that do not generate concentrated waste streams that
    will need to be treated as wastewater.
    Enforcement of the current water quality standard will have the effect of creating de facto
    drinking water standard that is not based upon the protection of human health, but on the
    wastewater treatment limits. Developing NPDES limits based on ten year seven day low flows
    in the stream will further magnify the discrepancy between the WQS and the drinking water
    limit. Communities that are including biological nutrient removal in the wastewater treatment
    process will be further penalized due to requirements associated with the process.
    Thank you for this opportunity to provide the Board with my comments.
    Sincerely,
    E
    Curtis A. Craigmile, P.E.
    11617 West
    194th
    Street
    Mokena, Ii 60448

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