ILLINOIS SECTION
AMERICAN WATER
WORKS
ASSOCIATION
RECEIVED.
CLERK’S OFFICE
DEC 162004
STATE OF ILLINOIS
PolIut(on Control Board
December 14, 2004
Reply to: Illinois Section
AWWA
535
Yorkshire Drive
Dekalb,IL 60115
Ms. Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street Suite 11-500
Chicago, IL 60601
VIA FAX# 312-814-3669 and USPS
RE:.DocketNo. R-04~021...
Revisions to Ra’~T~~VaterQuality Standards
Dear Ms. Gunn:
The Illinois Water Utility Council was formed by the Illinois Section ofthe
American Water Works Association to evaluate and comment on legislative, regulatory
and other matters, which directly affect waterutilities. The pending proposal ofthe
Illinois Environmental Protection Agency to modif~’the water quality standard for
radium directly affects water utilities in Illinois.
The proposal ofthe Illinois Environmental Protection Agency recognizes that
radium has been discharged to surface waters for decades. Many ofthe utilities that are
members ofthe American Waterworks Association have been providing drinking water
to their communities for over 100 years. Any water supply using water from the deep
aquifer has been discharging radium for that same time period.
The proposal ofthe Illinois Environmental Protection Agency had been
characterized as the de-regulation ofradium: This is not.true. IEPAhas recognized that
the allowable concentratiouinstreams and rivers in Illinois is two orders ofmagnitude
greater than the current standard and the highest concentration ofradium measured in
well water in Illinois. The establishment ofa numerical limit that is two orders of
magnitude higher than any concentration measured from wells in Illinois would not have
any different impact on the waters than the current proposal.
The Water Utility Council is concerned that a specific treatment technique may be
required for radium if the current standard is left in place. Water utilities have
responsibilities to theircustomers to select a treatment method that best meets the needs
oftheir system. Funds received from the public will be spent to comply with the
established rules and these funds should be spent wisely. The installation ofequipment
to meet a water quality standard of 1.0 pico curies per liter ofradium 226 is unrealistic
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 consumption with
radium levels up to 5.0 pico curies that is in full compliance with all drinking water
regulations. There is no scientific basis to indicate the need for removal of radium levels
below
5.0
pico curies from wastewater discharged to the environment. The Illinois
Section American Water Works AssociatiOn sUpports the EPA Proposal.
The Illinois Water Utility Council appreciates the opportunity to provide
comment on this very important issue to water utilities in Illinois.
Very truly yours,
F. Edward Glatfelter
Chair
ISAWWA Water Utility Council
Executive Director
Central Lake County
Joint Action Water Agency
