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ASSOCIATION

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December 14, 2004

Reply to: Illinois Sectio AW~VA

S35YorkshireDrive

Dekalb,IL 60115

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Ms. Dorothy M. Gurm, Clerk

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Illinois Pollution Control Board

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James R. Thompson Center

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100 West Randolph Street Suite 11-500

Chicago, IL 60601

VIA FAX# 312-814-3669 and USPS

RE: Docket No. R-04-021

Revisions to Radium Water Quality Standards

Dear Ms. Gunn:

The Illinois Water Utility COuncil was formed by the Illinois Section:

1

the

American Water Works Association to evaluate and comment on legislative~.egulatory

arid other matters, which directly affect water utilities. The pending proposal ofthe

Illinois Environmental Protection Agency to modify the water quality stand d for

radium directly affects water utilities in Illinois.

The proposal of the Illinois Environmental Protection Agency recogri

zes

that

radium has been discharged to surface waters for decades. Many of the utilit es that are

members ofthe American Waterworks Association have been providing dri ing water

to theircommunities for over 100 years. Any water supply using water from the deep

aquiferhas been discharging radium for that same time period.

The proposal ofthe Illinois Environmental Protection Agency had be n

characterized as the de-regulation of radium. This is not true. IEPA has rec gnized that

the allowable concentration in streams and rivers in Illinois is two orders of~agnitude

greater than the current standard and the highest concentration ofradium me sured in

well water in Illinois. The establishment of a numerical limit that is two ord s of

magnitude higher than any concentration measured from wells in Illinois wo id not have

any different impact on the waters than the current proposal.

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The Water Utility Council is concerned that a specific treatment technique in y be

required for radium if the current standard is left in place. Water utilities ha e

responsibilities to their customers to select a treatment method that best meet the needs

oftheir system. Funds received from the public will be spent to comply wi the

established rules and these funds should be spent wisely. The installation of quipment

to meet a water quality standard of1.0 pico curies per liter ofradium 226 is

ealistic

when the current standard for water delivered to people is

5.0

pico curies per liter of

combined radium 226 and radium 228.

Public water supplies provide potable drinking water for human

COflS:

ption with

radium levels up to 5.0 pico curics that is in full compliance with all drinkin water

regulations. There is no scientific basis to indicate the need for removal ofr dium levels

below 5.0 pico curies from wastewater discharged to the environment. The I linois

Section American Water Works Association supports the IEPA Proposal.

The Illinois Water Utility Council appreciates the opportunity to prov de

comment on this very important issue to water utilities in Illinois.

Very truly yours,

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F. Edward Glatfelter

Chair

ISAWWA Water Utility Counci

Executive Director

Central Lake County

Joint Action Water Agency