Layne-Western
    a division of Layne Christensen Company
    721 W. Illinois Avenue
    •
    Aurora, Illinois 60506
    •
    Phone: 630-897-6941
    •
    Fax: 630-897-6976
    August 15, 2005
    Ms. Amy Antoniolli
    Illinois Pollution Control Board
    100 W. Randolph, Suite 11-500
    Chicago, IL 60601
    SUBJECT:
    Proposed Radium Standard for Wastewater Discharges- R04-021
    Dear Ms. Antoniolli,
    With pending legislation for water utilities for radium compliance, it is not a good time to rush to change
    the standard for radium in wastewaters. The radium standard in drinking water took 20+ years of
    discussion before a safe level of combined radium 226 and radium 228 was determined. This has
    created an economic burden for utilities that will take a few years to recover from. Of course, they will
    have an improvement in the radium content of drinking water which should have long term benefits.
    This same approach should be used for determining discharge limits to our surface waters.
    For surface water discharges, the actual levels that are currently being discharged are poorly
    documented. The effects of radium on aquatic life should be studied further to document any
    deleterious influences on aquatic life. Since this data does not exist, we feel that rushing to a new
    standard would be premature and provide a solution that is not fully backed by facts.
    Some of the reasons that the standard should be investigated further before setting a new standard
    include:
    1.
    Why would the level in surface waters be higher than what is regulated in drinking water?
    2.
    No increases in discharges will result from setting the discharge limits higher.
    3.
    There is little or no data on the effect of radium concentrations on aquatic life or other
    wildlife. The cost of a low standard should show some commensurate improvement in the
    environment.
    4.
    There is little data on the actual levels of radium in water currently discharged from
    wastewater plants or on the dilution effect in surface waters.
    5.
    It has taken many years to determine the new drinking water regulations and there is an
    economic hardship to meet the new drinking water regulation. Any change to wastewater
    limits should be staged for after the drinking water regulations go into effect and actual levels
    in wastewater are better documented. The dilution effect in surface waters should be taken
    into account as well.
    6.
    Yes, a new standard needs to be developed because the 1 pCi/L radium 226 level cannot be
    met by dischargers and radium 226 and radium 228 need to regulated together.
    * * * * PC #49* * * *
    Thank you for the chance to comment on the water quality standard for radium.
    Sincerely,
    LAYNE-WESTERN
    a division of Layne Christensen Co.
    Jim Groose
    Water Treatment Specialist
    * * * * PC #49* * * *

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