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Seven organizations are filing additional comments regarding the IEPA’s effort to change radium
in water standards in Illinois. The groups include: Clean Water
Illinois, Des Plaines River
Valley Restoration Project, Citizens for Conservation, Illinois Audubon Society, Prairie Woods
Audubon Society. Citizens Against Ruining the Environment C.A.R.E., Illinois Division Izaak
Walton League of America
In additional two news articles from the Lake Zurich Couriers and the Washington Post are also
included. These articles speak to the heart ofthe radium in water matter.
DougDobrneyer
RECEWED
CLERK’S OFFICE
DEC 08 2004
STATE OF ILLINOIS
Pollution Control Board
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December 3, 2004
The Honorable Rod Blagojevich
Governor. State of Illinois
James R. Thompson Center, FL. 1 6
100 W. Randolph St.
Chicago, IL 60601
Dear Governor Blagojevich:
As a diverse group of organizations that champion different environmental issues, we would like
to express our disappointment in the Illinois Environmental Protection Agency’s (IEPA)
proposal to weaken radium water quality standards. As we understand it, the IEPA is proposing
to allow a virtually unlimited amount of radium, a cancer causing agent, to be
discharged into Illinois rivers, streams and lakes.
The proposed rule change raises many serious concerns. Lowering the water quality standards
would set a dangerous precedent, as it would significantly weaken the stat&s regulatory process
and pave the way for polluters to act without concern. Allowing more radium would contribute
to the already burgeoning pollution in the waterways, which amplifies the threat to animal and
plant life in our rivers, lakes and streams. Most important, relaxing state standards puts the
residents of Illinois at risk of developing cancer and other serious diseases.
The citizens of Illinois deserve to know whythe IEPA is aggressively pursuing a rule change that
compromises environmental security and public health. This action goes against all progressive
environmental thinking and we have yet to hear a compelling public interest rationale for
weakening the standards that keep our waterways clean.
We are counting on you to work in cooperation with policymakers to maintain the current water
quality regulations that have been integral in making Illinois a leader in sound environmental
policy. We respectfully request that you urge your agency to conduct a more thorough analysis
of this issue and explore cleaner alternatives that promote environmental safety now and in the
future.
We are also attaching two media articles pertaining to this issue. The first is from the
Lake
Zurich Courier
covering the issue of radium in sludge. A
Wcishingto;z
Post
article looks at the
issue of the discharge of radium tainted wastewater into the waterway system in Maryland. Both
ofthese issues are crucial to the discussions here in Illinois.
Sincerely,
Doug Dobmeyer
Clean Water
—
Illinois
P.O.
Box 268617 Chicago, Illinois 60626
773/33 8-98 25
Dave Lloyd, Volunteer Steward
Des Plaines River Valley Restoration Project
708/485-2296
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Karen Hunter
President
Citizens for Conservalion
847-382-7283
Marilyn F. Campbell
Executive Director
Illinois Audubon Society
P.O. Box 2418, Danville, IL 61834-2418
217/446-5085
Nancy Wedow,
Conservation Chair, Prairie Woods Audubon Society,
P0 Box 1065, Arlington Hts, Illinois 60006
847-359-3077
Ellen Rendulich
Director
Citizens Against Ruining the Environment C.A.R.E.
815-834-1611
P.O. Box 536
Lockport, IL 60441
Joseph F. Hyland
President, Illinois Division
Izaak Walton League of America
c/o
255
E. Cleburne
Bartlett, Ill., 60103
630-372-6919: home
630-363-6312: cell
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December 2, 2004
Lake Zurich Courier
Radioactive dirt
JEPA examines sewage processed into fertilizer at area plants
While municipalities concentrate on removing radium from drinking water, environmental agencies are taking a
closer look at how the radioactive leftovers are being handled.
Agencies responsible for sewage treatment and water treatment, including Lake in the Hills Sanitary District and the
village of \Vauconda, are getting more scrutiny from the Illinois Environmental Protection Agency concerning
radium that is removed from drinking water and later passes through the sewage treatment.
Other villages, such as Lake Zurich and Island Lake, rely on other sewage treatment agencies to dispose of radium
removed from drinking water.
Radium is a naturally occurring radioactive element found in deep wells. Radium breaks down into radon, a harmful
gas. Water treatment plants use water softeners to filter radium from drinking water, but that does not mean the
element disappears. Byproducts from the softening process, including radium, make their way through sanitary
sewers to sewage treatment plants.
Sludge, the organic solid remaining after sewage treatment, can contain radium removed from drinking water.
Sludge is often given or sold to farmers, who use the substance as fertilizer. No law restricts the amount of radium
that can be present in sludge, although some guidelines exist.
Treated water, or effluent, flowing from sewage treatment plants into rivers and lakes can also contain radium.
Radium contained in liquids is diluted by the volume of raw wastewater going into sewage plants and further diluted
when the treated effluent reaches rivers and lakes. Rivers and lakes are checked periodically to ensure that levels of
radium do not exceed safety standards.
As area municipalities reduce radium levels to make their drinking water safer, that has raised concerns regarding
radium content in sludge.
“It’s a two-edged sword,” said Toby Frevert, who manages the IEPA Division of Water Pollution Control. “Sludge is
very valuable (as fertilizer) for its nutrients, but it contains this other chemical. We need to figure out how to benefit
from the good.”
Health concerns
Concern over radium levels in sludge grew after the JEPA set a deadline of December 2003 for compliance to
standards reiterated in 2000. The standards had been in effect for some 30 years, but were not enforced in Illinois.
The U.S. Environmental Protection Agency looked in the 1990s at possibly raising the maximum reconnrrended
radium levels. A maximum level of radium appropriate for drinking water was identified in the mid-l 970s as below
5
picocuries per liter. A picocurie represents the radioactivity in I trillionth of a gram of radium. In 1991, the U.S.
EPA considered raising the maximum to 20 picocuries.
As municipalities began complying with the safety standards, more radium has been filtered out of drinking water
and winding up in sludge, which raises new health concerns.
Prolonged exposure to radium has been proven to cause bone cancer, said Larry Thomas, a vice president with
Crystal Lake-based Baxter and Woodman, an engineering consultant for many area municipalities on water and
sanitary issues.
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It is unclear, Thomas said, \vhether radium filtered out of water from deep wells
--
which later becomes a component
of sludge
--
is at a high enough level to create any health problems.
According to a joint agreement between the IEPA and Illinois Division of Nuclear Safety, the only existmg
guideline is that the radium level present in sludge cannot exceed by more than a 10th of a picocurie the existing
level of radioactivity in the field where it is being applied.
The IEPA is beginning to evaluate sludge content and to look into how much radium is actually present, Frevert
said.
Lake in the Hills
The Lake in the Hdls Sanitary District is one of the first to feel the effects ofthese new concerns.
Every five years, the Sanitary District must apply for a permit so that sludge from its plant can be spread on farm
fields. The permit allo\vs the district to contract with a private company, which the district pays to haul away the
sludge to give to farmers, accordmg to Sanitary District Manager Ross Nelson.
In 2003, the Sarutary District applied 707.5 metric tons of sludge on fields in McHenry, Kane, LaSalle, Boon and
DeKalb counties. It pays Synagro, a national waste solids handler based locally in Sugar Grove, between $30,000
and $40,000 a month to press and remove its sludge.
F
When re-applying this year for its land-use application permit, the Sanitary District learned the IEPA had new
permit guidelines. The new standards restrict the amount of any sludge that can be applied to any particular field.
According to Frevert, the single sludge sample the agency had for Lake hi the Hills was 12.7 picocuries of
radioactivity per gram. The IEPA analysis showed that at that level the sludge applied to land would hit the
minimum target within two years, meaning that sludge could be applied to the same farm field once a year for two
years. After that, there could be no more sludge applications on that farm field.
With only one sample available, the WPA set the bar higher as far as restricting the applications of sludge from die
Lake hi the Hills Sanitary District, Frevert said.
The Sanitary District recently conducted another test and is waiting for lab results, which should be back in early
December, Nelson said.
If the sample shows a lower radium content, the IEPA might reverse its decision, Frevert said. If not, it leaves the
sanitary district with a big question.
‘What do you do with the sludge?” Nelson asked. “It’s a problem finding farmers willing to accept it as it is. This is
a real hardship for the district. It will increase our operational costs.”
While waiting for the ruling, the Sanitary District will work with towns of Lake in the Hills and Huntley to find a
way to reduce the amount of radium entering the waste stream, Nelson said.
In September 2004, Lake in the Hills put 2.8 million gallons of wastewater into the sanitary district, according to
Lake in the Hills Water Supervisor Bob Krause. The village doesn’t normally test wastewater for radium, just the
softened drinking water, which is typically at 1 .5 picocuries per liter, which exceeds the safety standard of
5
picoeuries. But Krause said the village recently took a sample of its wastewater and is waiting for test results.
Lake Zurich
The Village of Lake Zurich in the process of adding radium removal systems to its drinking water. The village plans
to add radium removal systems to all six of its wells at a cost of $1
.5
million per well. So far, one well has the
technology. The village does not deal directly with sludge.
Robert Duprey, Lake Zurich’s assistant public works director, said the village uses an ion exchange radium removal
system, which works like a home water softener. The system filters 60 percent of the water coming into it and
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blends the filtered water with the remaining 40 percent of unfiltered water. This mixing process dilutes radioactive
particles to a level that meets the 5 pieocuries standard.
“The bottom line is with all the treatment we will be implementing. we will be treating at a level that will get us to 5
picocuries,” Duprey said.
Without treatment, the village water averages 6.8 picocuries, he said.
Lake Zurich discharges the byproduct of its water-filtering system into sanitary sewers. From there, the flow travels
to Lake County’s Des Plaines River Treatment Plant in Deerfield.
Phil Perna, who monitors water quality reports for Lake County Public Works, said county plant wastewater
undergoes regular treatment processes. Sludge is drawn from the wastewater, and a contractor hauls
it
away for use
on farmland. The county leaves radium testing to die contractor.
W7auconda
Four of Wauconda’s eight municipal wells are deep wells. Radiation in unfiltered water from the four deep wells
averages 13.8 picoeuries per liter, said Assistant Superintendent of Public Works Betty Hairison. After filtermg, the
radiation level in drinking water measures less than die required 5 picocuries per liter.
The liquid byproduct from the filtering process contains about 9 pieocuries of radiation per liter and is discharged
into the sanitary sewers. After processing at the Wauconda \‘Vastewater Treatment Plant, the radium ends up in
sludge, which is hauled away for use by area farms as fertdizer, and in the treated effluent that flows into Fiddle
Creek and eventually mto the Fox River.
Waueonda’s permit for land application expires Sept. 30, 2008.
Island Lake
The two deep wells in Island Lake average a combined radiation level of 8.8 picocuries. Almost all of that is filtered
out during treatment for drinking water, said Public Water Superintendent Neal Dc Young.
The liquid byproduct from the filtering goes to the Northern Moraine Wastewater Reclamation District in Island
Lake where it is processed with that of two other municipalities, said Dorothy Bangle, the district’s administrative
coordinator.
Treated effluent from the sewage treatment plant flows into the Fox River; sludge is hauled by an outside company
to area farmland for use as fertilizer.
The district’s permit is up for renewal Iuly 31, 2005.
Charles Drops Plan to Discharge Tainted Water Into Stream
By Joshua Partlow
Washington Post Staff Writer
Sunday, November 21, 2004; Page SMO6
Charles County officials headed off a potential confrontation over elevated levels of radiation in
a subdivision’s water supply with their decision last week against discharging the polonium-
tainted water into a nearby stream.
In March, residents of the 95-home Chapel Point Woods subdivision learned that the county
planned to install a reverse osmosis filtration system to remove naturally occurring polonium and
radium from their water supply. The level of radiation coming from three wells is about three
times the federal limit. But the question then became: Once the radiation is removed, where
should it go?
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The county initially wanted to dump a daily dose of 8,600 gallons and the radioactive materials
into a small stream that runs through the subdivision before emptying into the Port Tobacco
River. Some residents and members of the Port Tobacco River Conservancy adamantly opposed
the idea because they feared the highly toxic polonium could be dangerous to children playing in
the stream and to fish and other aquatic life.
But at a meeting with residents Tuesday night, officials said the county had decided not to
release the substances into a tributary of Wills Branch. The county will cancel its discharge
permit application with the Maryland Department of the Enviromnent. said Jerome Michael, the
county’s director of public utilities.
The change of heart came after a preliminary study by the Department of the Environment found
that the concentrations of polonium estimated in the discharge water
--
225 picocuries per liter
--
would exceed safe levels. Michael said. State officials at a public meeting in La Plata on Tuesday
night said they would not release the study until it was approved or specie’ what the safe levels
of polonium are.
“With the numbers they were talking about,” Michael said, “we’re not even close. Not even
close.”
Some of those gathered in La Plata found the news reassuring.
“This was a good decision,” said David Gardiner, the executive director of the Port Tobacco
River Conservancy. “There have been concerns by several people that the level of polonium
would be a very serious problem if it were released into the stream.”
The county must now find an alternative method of disposing of the polonium. Michael said one
possibility would be to truck the discharge water to the Mattawoman Wastewater Treatment
Plant offHawthorne Road near Mason Springs. It would be a more expensive option, he said, but
when diluted by the 15 million gallons of daily discharge at the plant, the radioactive substances
probably would not cause a problem in the Potomac River.
Installation of the Chapel Point Woods filtration system is scheduled for completion in the
summer, and the timeline will not be affected by changing the discharge plans, officials said. A
test ofthe system removed 97 percent of the polonium from the water, said Ben Movahed, an
engineer with Watek Engineering Corp., which is designing the filter.
In the late 1990s, hundreds of wells in Anne Arundel County were found to have elevated levels
of radium, an element that occurs in trace amounts in rocks and soil. Butthis case was the first
discovery of polonium in Maryland.
“This isn’t something we’ve come across in Maryland before,” said Steve Luckman of the permits
division of the Maryland Department of the Environment.
Officials did not know why the polonium was in the earth below these three wells, which
descend about 600 feet into the Patapsco aquifer. No other nearby wells outside the subdivision
have had elevated radiation levels, officials said. Residents of Chapel Point Woods, weary of
buying bottled water for drinking and cooking, want to be able to say the same soon.
“As long as they proceed with treating the water,” said Bruce McCormick, who has lived in the
neighborhood for 14 years. “That’s what matters to me.”
