BEFORE THE ILL1NOIS POLLUTION CONTROL BOARIcLERKS
RECEflFED
OFFICE
SEE ATTACHED SERVICE LIST
AUG 182005
STATE OF iLLINOIS
Pollution Control Board
PLEASE TAKE NOTICE that I have filed with the Office ofthe Pollution
Control Board the SECOND FIRST NOTICE COMMENTS OF THE ILLINOIS
ENVIRONMENTAL PORTECTION AGENCY on behalfofthe Illinois Environmental
Protection Agency, a copy of which is herewith served upon you.
Date: August
15,
2005
1021 North Grand Avenue East
P.O. Box 19276
Spring field, IL 62794-9276
217/782-5544
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
B2JM@L~
RiL
Deborah J. W. ams
Assistant Counsel
Division of Legal Counsel
THIS FILING IS SUBMITTED ON
RECYCLED PAPER
IN THE MATTER OF:
)
REVISIONS TO RADIIJM WATER QUALITY
STANDARDS: PROPOSED NEW 35 ILL. ADM.
CODE 302.307 AND AMENDMENTS TO
35 ILL. ADM. CODE 302.307 AND 302.525
NOTICE
TO:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
)
R0-21
)
(RuAlemaking
-
Water)
)
)
Amy Antoniolli, Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
1)
RECEIVEb
BEFORE THE ILLINOIS POLLUTION CONTROL BOAIfl~ERXSOFFICE
)
AU5182005
REVISIONS
TO
RADIUM WATER
)
STATE OF ILLINOIS
QUALITY STANDARDS:
PROPOSED
)
Pollution Control Board
NEW 35 ILL.ADM.CODE 302.307
)
R04-02l
AND AMENDMENTS TO 35 ILL.ADM.
)
Rulemaking
-
Water
CODE 302.207 AND 302.525
)
)
SECOND-FIRST NOTICE COMMENTS OF THE ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY
NOW COMES the ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
(“Illinois EPA” or “Agency”), by and through one ofits attorneys, Deborah J. Williams,
and hereby respectthlly submits to the Illinois Pollution Control Board (“Board”) its
Second First Notice Comments in the above-captioned regulatory proceeding. In support
thereof, the Illinois EPA states as follows:
BACKGROUND AND INTRODUCTION
The current General Use water quality standard for radium 226 (contained in 35
Ill. Adm. Code 302.207) is 1 picocurie per liter (“pCiIL”) and was adopted by the Board
in the initial set of Board regulations in 1972.
See,
R71-14. There is no existing standard
for radium 228. Under Section 303(c) ofthe Clean Water Act, the Illinois EPA has the
obligation to no less than every three years conduct reviews of its water quality standards
and update those standards where needed.
See,
33 U.S.C. 1313(c). As part ofthat
process, the Agency filed a proposal to update the water quality standards for Radium on
January 13, 2004. The Illinois EPA proposed eliminating the General Use and Lake
Michigan Basin radium 226 water quality standards and replacing them with a combined
radium 226 and 228 water quality standard of 5 pCiIL in the Board’s Public and Food
Processing Water Supply standards, found in Subpart C ofSubtitle C of the Board’s
Water Quality Standards Regulations.
See,
35 Ill. Adm. Code 302.301-302.306.
The Board issued a First Notice Opinion on July 8, 2004 that contained language
identical to the Agency’s proposal that was published in the Illinois Register on August 6,
2004. A total offour hearings over five separate days have been held on this matter and
after extensive post-hearing comments, the Board issued an opinion on April 7, 2005 in
which it decided to withdraw the First Notice proposal and issue a Second First Notice
proposal, which was published in the Illinois Register on April 29, 2005. Following a
Motion by the City ofJoliet for an extension ofthe comment period, the Board set a
deadline of August 15, 2005 for public comments on its Second First Notice proposal.
The Board’s proposal would replace the General Use Water quality standard of 1
pCi/L radium 226 with a combined radium 226 and 228 standard of 3.75 pCi/L. The
General Use standard would be 30 pCifL for 1 mile downstream from the discharge point
of a publicly owned treatment works (“POTW”) receiving discharges from public
drinking water supplies using high radium sourcewater (greater than 3.75 pCi/L). No
Public and Food Processing Water Supply Standard is found in the Board’s proposal.
The Board solicited comments from the public on its Second First Notice proposal and
particularly asked for input from commenters on whether its proposal will achieve the
stated goal of giving some relief to the regulated community in the radium belt of
Northern Illinois.
COMMENTS ON BOARD’S SECOND FIRST NOTICE PROPOSAL
The Illinois EPA bases these comments on three assumptions about the
underlying goals ofthe Board’s Second First Notice proposal. First, that the Board
2
intends for the proposal to assure protection ofthe most sensitive use of the waters ofthe
State. hi this case, the most sensitive use is assumed by a consensus ofthe stakehoider’s
to this proceeding to be reproductive impacts on riparian mammals from longlenn
exposure to radium in the rivers and streams they use for habitat. Second, the Board has
stated a goal ofavoiding the imposition of an unreasonable hardship on the POTWs in
the radium belt ofNorthern Illinois that receive discharges from public water supply
systems that must treat groundwater to achieve compliance with U.S. EPA’s maximum
contaminant level (“MCL”) for radium 226 and 228. It is assumed that the types of
hardships the Board is attempting to avoid are either requiring these communities to
cease use ofradium containing groundwater for drinking or requiring the use of
additional add on treatment technologies at individual POTWs. Finally, the Illinois EPA
assumes the Board also intends to protect downstream public water supply systems using
surface water as source water for drinking from future violations ofthe MCL.
The Agency’s comments will attempt to address the Board’s goals and expand on
some issues raised by Region V of the United States Environmental Protection Agency
(“U.S. EPA Region V”) in their comments filed on June 14, 2005. The Agency still
stands behind the proposal it filed with the Board in January 2004 and believes the Board
is mistaken in its reliance in its Second First Notice proposal on the technicalinThnnation
submitted by WRT Environmental. These comments will not repeat the Agency’s Post-
Hearing comments or hearing testimony, but will instead attempt to advise the Board of
the best way to achieve its goals within the framework established in its April 2005
Opinion and Order and the requirements of the Clean Water Act. These comments will
also identify one typographical error in the Board’s Second First Notice Opinion.
3
Discussion of Comments Filed by U.S. EPA Re2ion V
U.S. EPA raised several key points in their brief comments to the Board. The
Illinois EPA agrees with most ofthese points and would like to clarify and expand on one
of them. U.S. EPA points out that it has “no national criteria recommendations for
radium to protect aquatic life or wildlife, and there are insufficient data to support
derivation ofwater quality criteria for either ofthese endpoints using USEPA methods.”
Public Comment 41 at 1. These comments support the consistent position taken by the
Agency throughout this proceeding that studies do not currently exist which meet U.S.
EPA’s guidelines for development of Water Quality Standards. U.S. EPA’s comments
also indicate that a standard of3.75 pCi/L would be approvable, but they do not see
support in the record for the dual 3.75/30 pCi/L General Use and Lake Michigan radium
standard proposed by the Board. In fact, the implication from U.S. EPA’s comments is
that in all likelihood a General Use standard of30 pCi/L would be approvable as well.’
U.S. EPA appears primarily concerned about how to reconcile the two separate standards
proposed by the Board, rather than the numbers themselves.
The Board states that the 3.75 pCiIL standard proposed for all General Use
waters beyond one mile downstream from community sewage treatment plants and Lake
Michigan is based on a U.S. Department ofEnergy (“D.O.E.”) model and is purported to
be the concentration necessary forprotection of terrestrial wildlife inhabiting riparian
zones, i.e., habitat consisting ofstreams and the dry land immediately bordering streams.
Illinois EPA gave testimony refuting the appropriateness ofthe 3.75 pCi/L value and the
use of the D.O.E. model in developing a water quality standard during the hearings and in
As indicated by the Agency at hearing, U.S. EPA Region V had also expressed informal verbal approval
ofthe Agency’s initial regulatory proposal to eliminate a General Use water quality standard for radium
and replace it with a Public and Food Processing Water Supply standard.
4
its post-hearing comments. The Illinois EPA still strongly opposes the use ofthe D.O.E.
model for a purpose so far removed from the one it was developed to address. However,
for these Second First Notice comments, the Illinois EPA will offer the Board
constructive suggestions for improvement to the proposed General Use water quality
standard.
General Use Radium Water Quality Standard as a Long
Term Average
The one issue upon which the parties appeared to achieve consensus at the
hearings in this matter was that the available evidence shows that mammals living near
and obtaining their food source from streams (riparian mammals; e.g., musk rats, river
otters) are predicted to be the category of organisms most susceptible to harm. This harm
comes from cumulative exposure to radioactivity. The longer the exposure of the
mammals to radium in the stream water, the greater the chances for adverse effects on
reproduction over the individual’s lifetime.
Given the newly established mode of adverse impact for radium, it is not
appropriate to change the value ofthe standard (or to leave the standard as is) without
changing the exposure period under which the standard is applied. Under the existing
standard, and in the Board’s proposal, a certain concentration ofradium, either 1 pCi/L
radium 226 or 3.75 pCi/L radium 226 and 228 combined, must never be exceeded at any
time. Under these instantaneously applied standards, dischargers would be regulated
using 7Q10 stream flow conditions (the average minimum seven day low flow which is
predicted to occur once in ten years) as the basis for calculating the mixing that may be
allowed for dischargers with high radium sourcewater. In addition, POTWs that have
zero 7Q10 stream flows would not be entitled to a mixing zone under an instantaneously
5
applied General Use standard pursuant to Section 302.l02(b)(8) ofthe Board’s mixing
zone regulations.
See, 35
Ill.Adm.Code 302.l02(b)(8). The Board recognized this
problem and the hardship it would create for POTWs and attempted to address it through
the use of an alternative standard for 1 mile below the discharge point from impacted
POTWs. As stated in the Second First Notice Opinion:
The Board considered a number ofoptions for providing relief to POTWs,
including a blanket exemption from general use radium water quality standards,
setting effluent limits, and specifying mixing zones in accordance with 35 Ill.
Adm. Code 302.102. However, since the noncompliance issues are mostly
associated with POTWs discharging into low flow streams, the Board finds a
Section 302.102 mixing zone would not address POTW concerns. Instead, the
Board finds that specifying a zone ofmixing allowing a radium concentration
above the proposed general use standard better addresses the POTWs’ concerns.
*
.While the Board presently believes that a 1-mile segment of the stream should
provide an adequate mixing zone for POTW discharges to comply with the
proposed general use standard of 3.75 pCi/L, the Board invites comments from
the participants on this provision.
R04-21, Second First Notice Opion, Slip. Op. at 25. The Illinois EPA does not believe
the Board’s proposal succeeds in the goal ofproviding relief to POTW dischargers to low
flow streams. There is no evidence in the Record to suggest that radium would degrade
over the distance of 1-mile below the POTW discharge. The Agency also believes most
POTWs that would violate an instantaneous standard of 3.75 pCi/L at its discharge point
to a zero 7Q10 waterbody would rarely achieve sufficient dilution ofthe effluent 1-mile
downstream to achieve compliance with the instantaneous standard. In response to the
Board’s concerns, the Illinois EPA recommends that U.S. EPA’s suggestion ofutilization
oflong-term averaging for the radium water quality standard which incorporates the use
of long term flow values in developing mixing zones would more closely achieve the
Board’s stated goals.
6
The implementation method used for the majority ofthe Board’s acute and
chronic water quality standards relies on use of7Q10 values and was developed to
address substances that have a relatively short-term critical exposure period
—
days or
weeks of exposure leading to adverse impacts rather than years of exposure leading to
these impacts. The Illinois EPA agrees with U.S. EPA that a standard applied with a
short exposure period is inappropriate given the nature ofthe substance beingxegulated.
U.S. EPA points to the example ofthe implementation ofwildlife protection water
quality standards developed for the Great Lakes Water Quality Initiative (GLI). See, 35
Ill. Adm. Code 302.Subpart F (Lake Michigan Basin Water Quality Standards). In
Subtitle E ofthe Board’s regulations bioaccumulative substances such as PCBs or DDT
are regulated based on concentrations present during 90Q10 or higher stream-flow
conditions (the average minimum 90 day low flow which is predicted to occur once every
10 years).2 Using this flow condition acknowledges that discharged concentrations ofthe
substance will be diluted much ofthe time due to higher than 90Q10 conditions usually
being present in the waterbody. The 90Q10 stream flow values will be higher than 7Q10
values and many streams with a 7Q10 flow value ofzero would have a higher than zero
90Q10 value. The fish that affected wildlife (eagles, otters, etc.) eat will therefore not
bio-accumulate the substance at the highest rate all the time, therefore fish flesh
concentrations will remain acceptably low, and the wildlife species are protected.. Use of
2
The Illinois State Water Survey’s website explains the concept of7Q10 as follows: “A 7-day low flow
for a stream is the average flow measured during the 7 consecutive days of lowest flow durin~anygiven
year. The 7-day 10-year low flow (Q7,lO) is a statistical estimate of the lowest average flow that would be
experienced during a consecutive 7-day period with an average recurrence interval often years. Because it
is estimated to recur on average only once in 10 years it is usually an indicator of low flow conditions
during drought.” Simply substituting 90 for 7 would explain the meaning of the term 9OQlO.
7
the more conservative 7Q10 flow values in calculating permit limits was found by the
Board to be inappropriate for the type ofimpact being regulated for these parameters.
There are at least two other examples in the Board’s regulations that utilize a flow
value other than 7Q1 0. One example is the Human Nonthreshold Criterion of Subpart F
of Subtitle C ofthe Board’s water quality standards regulations which uses harmonic
mean flow values. Another example is an annual average used in the Human Health
Standard which is defined in 35 I11.Adm.Code 302.208(c) and is used for mercury and
benzene:
The human health standard (HHS).
. .
shall not be exceeded when the stream flow
is at or above the harmonic mean flow pursuant to Section 302.658 nor shall an
annual average, based on at least eight samples, collected in a manner
representative of the sampling period, exceed the HHS except as provided in
subsection (d).
Because radium affects wildlife primarily through simple exposure it is even more
important to establish a long term average under the radium water quality standard than
for the other substances regulated using long term average. Radium can be contrasted
with the PCBs and DDT-type chemicals regulated by the GLI wildlife protection
standards, mercury or benzene regulated under the BBS or substances regulated under
the Human Nonthreshold Criteria in Subpart F that impact organisms only through
bioaccumulation. For this reason, it makes even less sense to regulate radium based on
instantaneous (not-to-be-exceeded) standards. A standard that insists that radium never
exceed 3.75 pCi/L does not indicate whether undesirable exposure has occurred or not.
Therefore, the Illinois EPA is recommending that the Board adopt General Useandiake
Michigan Basin radium water quality standards that are based on an annual average
concentration in the water body. This means that a stream concentration above 3.75
8
pCi/L is allowable as long as at other times the concentration is lower resulting in an
annual average meeting the standard.
One additional justification for use of a long term average is the Board’s reliance
on the biota dose assessment of the DOE model in establishing the General Use water
quality standard at 3.75 pCi/L combined radium 226 and 228. As discussed in testimony
at the Board hearings, this screening model was designed to address contaminated sites
and detect a screening level at which additional tests and studies to determine potential
impacts to riparian wildlife should be conducted. The potential impacts being protected
for in this model are reproductive effects on riparian mammals that occur over a lifetime
ofexpose to radium concentrations in their environment. The exposure period
contemplated by the D.O.E. model is consistent with the annual average exposure period
recommended by the Illinois EPA. To attempt to use parts ofDOE’s model without
allowing for the use ofaveraging over a period oftime adds an unjustifiable levetof
conservatism upon an already conservative screening tool.
The annual average ofstream flow is a reasonable and easily calculated statistic
for establishing a meaningfUl implementation scenario. The U.S. Geological Survey
provides annual average flow values and, where necessary, it is believed that these values
can also be derived based on watershed and basin information. Communities discharging
radium to a receiving stream would receive radium permit limits (if a reasonable potential
to exceed the radium water quality standard in the stream existed) based on the dilution
provided to their sewage treatment plant effluent by the average annual flow ofthe
receiving stream. This exposure period and implementation strategy will protect riparian
mammals, while simultaneously minimizing the potential for economic hardship to
9
communities with radium in their water supply. Under this implementation method,
discharges ofradium-bearing effluent to lakes, a condition now not known to exist,
would be discouraged because lakes usually have no flow and thus no dilution would be
afforded. The Illinois EPA believes that an annual average is the most appropriate tool
available for the regulation of radium to protect the riparian mammal use ofthe General
Use and Lake Michigan waterbodies in the waters ofthe State of Illinois. As will be
explained below, it is also necessary for achieving the Board’s goal ofproviding relief to
the POTWs tributary to high radium sourcewater.
Protection of Drinkin Water Intakes
U.S. EPA also expressed concerns in its comments to the Board that a final
radium water quality standard must assure that drinking water intakes are protected. PC
41 at I. It can be argued that in one important respect the language of the Board’s
Second First Notice is less stringent that the Illinois EPA’s original proposal: the Board
has removed the use ofa Public and Food Processing Water Supply standard matching
the U.S. EPA’s MCL for radium hi drinking water. The Illinois EPA suggests to the
Board that a Public and Food Processing Water Supply standard is necessary for radium
and should be established at the
5
pCi/L drinking water standard to protect sources of
drinking water. The federal drinking water standard is an instantaneously applied
standard and therefore a Rublic and Food Processing Water Supply surface water intake
standard of
5
pCi/L should apply at all times. The Illinois EPA is not aware of any
existing or anticipated situations where an upstream discharge would cause a Public and
Food Processing Water Supply surface water intake to exceed 5 pCiIL, but such a
standard should be adopted as a safeguard from that scenario in the future.
10
Impact of Board’s Proposal on POTWs
The Board also solicited comments on whether its use ofa 30 pCi/L standard for
stream segments that are up to 1 mile downstream ofa POTW discharge using drinking
water that is greater than 3.75 pCi/L would address the concerns ofthe regulated
community of POTWs in the radium belt of Northern Illinois. As the Agency indicated
at the hearings, there is almost no effluent data available from these facilities and very
limited ambient stream concentration data. Even with so little ambient or effluent data
available, it seems clear that the Board’s proposal will not result in the intended relief to
the regulated community. An instantaneously applied value of 3.75 pCi/L would be
overly protective ofwildlife even under the D.O.E. model and even with the I mile
exemption it is unlikely to achieve the goal of achieving compliance for POTW point
source dischargers. On the other hand, an annual average value as recommended above
is both consistent with the D.O.E. model’s approach and would attain the Boardfs:goai~uf
providing relief to most ofthe radium belt POTWs.
The City ofJoliet has attempted to coordinate some efforts to fill the data gap
mentioned above. With the information currently available, the Agency can only make
some educated assumptions about the potential impact ofthe Board’s proposal as drafted
on these POTWs. These assumptions would be that many, if not most, ofthe impacted
POTWs would have difficulty with an instantaneously applied combined standard of 3.75
pCi/L even 1 mile below their discharge point as those standards are currently
implemented. Based on available information on sourcewater concentrations, it can also
be concluded that a General Use standard of30 pCi/L would be met by all known
dischargers. It is also anticipated that the majority ofdischargers would be able to
11
achieve compliance with an annual average radium water quality standard of 3.75 pCi/L.
The only exception to this might be a handful of POTWs that discharge to streams with
an average annual flow rate ofzero because the POTWs effluent represents the only flow
to the receiving stream. The Illinois EPA anticipates that the long term averaging as
proposed by U.S. EPA and with the recommendations suggested in these comments will
likely give relief to many of the impacted dischargers in a more defensible manner that is
protective ofthe most sensitive uses of all the waters ofthe State of illinois.
Proposed Regulatory Language
The following regulatory construction includes the suggestions contained above:
SUBPART B:
GENERAL
USE WATER QUALITY STANDARDS
Section 302.207
Radioactivity
a)
Gross beta (STORET number 03501) concentration shall not exceed 100
picocuries per liter (pCi/L).
b)
Concentrationc of radium 226 (STORET number 09501) and
sStrontium 90
(STORET number 13501) concentration must not exceed 1 and 2 picocuries
per liter (pCi/L) respectively.
c)
The annual average radium 226 and radium 228 (STORET number 11503’)
combined concentration must not exceed 3.75 picocuries per liter (pCi/L).
1) For purpose of this subsection, the requirement ofSection 302.102(b)(8)
ofthis Part that mixing is not allowed in receiving waters which have a
zero minimum seven day low flow which occurs once every ten years does
not
apply, and
2) Mixing zones for radium dischargers may be calculated using the annual
average stream flow present at the point of discharge.
SUBPART C: PUBLIC AND FOOD PROCESSING WATER SUPPLY STANDARDS
Section 302.307
Radium 226 and 228
Radium 226 and 228 (STORET number 11503) combined concentration must not exceed
5
picocuries per liter
(pCiIL)
at any time.
SUBPART E: LAKE MICHIGAN BASIN WATER QUALITY STANDARDS
Section 302.525
Radioactivity
12
Except as provided in Section 302.102, all waters ofthe Lake Michigan Basin must meet
the following concentrations in any oamplc:
a)
Gross beta (STORET number 03501) concentrations must not exceed 100
picocuries per liter (pCi/L).
b)
Concentrations ofradium 226 (STORET number 09501) and sStrontium 90
(STORET number 13501) concentration shall not exceed 1 and 2 picocuries
per liter (pCi/L) rcspcctivcly.
c)
The annual average radium 226 and 228 (STORET number 11503) combined
concentration must not exceed 3.75 picocuries per liter (pCi/L).
TypoEraphical Error in Second Notice Opinion
Finally, the Illinois EPA would simply like to bring a typographical error to the
Board’s attention from its April 7, 2005 opinion. On page 19 the Board states that
“Sludge containing between five and 15 pCi/g is also still acceptable...”. The figure
“15
pCi/g” should have been “50 pCi/g”. The Board’s Opinion correctly quotes from the
transcript page referenced (Tr.4 at 318), but this error (either in transcription or as a
misstatement by the hearing) does not correspond to the actual figures in the
Memorandum of Understanding between the Illinois EPA and the former Department of
Nuclear Safety. See, Exhibit
5,
Attachment 1A.
CONCLUSION
The Illinois EPA appreciates the resources the Board has dedicated to the resolution
ofthis regulatory proceeding and the opportunity the Board has granted all parties to the
proceeding to participate and present documents and testimony for the Board’s
consideration. The Agency praises the Board in its efforts to sort out a confusing
administrative record and to attempt to fill in scientific gaps with the most appropriate
standard possible with the information available. While the Agency strongly disputed
much ofthe testimony and many ofthe exhibits that were presented for the Board’s
13
consideration by WRT Environmental, some of which were incorporated by the Board in
its Second First Notice proposal, the Agency is nevertheless confident that the Board’s
proposal could provide a General Use water quality standard that is an improvement on
the existing standard if the comments of Illinois EPA and U.S. EPA regarding use ofa
long term average are taken into account and a Public and Food Processing Water Supply
standard is incorporated. The Board’s Second Notice Proposal does not succeed in
accomplishing its stated goals ofprotecting riparian mammals at the level of 3.75 pCiIL
or affording relief to the regulated community. The Illinois EPA is confident that its
recommendations regarding application of the General Use standard as an annual average
will allow the Board to continue to rely on the General Use water quality standard figure
it feels is necessary at this time while affording relief to the vast majority ofthe impacted
POTWs impacted by this rulemaking.
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
B~gp~i~
Deborah J. Williamy
Assistant Counsel C’
Division of Legal Counsel
August
15,
2005
1021 N. Grand Ave. E
P.O. Box 19276
Springfield, Illinois 62794-9276
14
STATE OF ILLINOIS
)
)SS.
COUNTY OF SANGAMON
)
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the attached Second First Notice
Comments ofthe Illinois Environmental Protection Agency upon the person to whom it is
directed, by placing it in an envelope addressed to:
TO:
Dorothy Gunn, Clerk
Amy Antoniolli, Hearing Officer
Illinois Pollution Control Board
Illinois Pollution Control Board
James R. Thompson Center
James R. Thompson Center
100W. Randolph Street, Suite 11-500
100W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
Chicago, Illinois 60601
SEE ATTACIIED SERVICE
LIST
and mailing it by First Class Mail from Springfield, Illinois on August 15, 2005, with sufficient
postage affixed.
SUBSCRIBED AND SWORN TO BEFORE ME
this
15th
day ofAugust, 2005
±
I
CYNTHIAOFFICIALL.WOLFESEAL
•1
:~:
~&~~~‘9t
Notary Public
THIS FILING IS SUBMITTED ON RECYCLED PAPER
R 04-21 SERVICE LIST
Roy M. Harsch
SashaM. Engle
Gardner Carton & Douglas
191 N. Wacker Drive, Suite 3700
Chicago, Illinois 60606-1698
Albert F. Ettinger
Environmental Law & Policy Center
35 East Wacker Drive, Suite 1300
Chicago, Illinois 60601
Matthew J. Dunn
Office ofthe Attorney General
Environmental Bureau
188 West Randolph,
20th
Floor
Chicago, Illinois 60601
Claire A. Manning
Posegate & Denes
111 N. Sixth Street
Springfield, Illinois 62701
Richard Lanyon
Metropolitan Water Reclamation District
100 East Erie Street
Chicago, Illinois 60611
Abdul Khalique
Metropolitan Water Reclamation District
Of Greater Chicago
6001 W. Pershing Road
Cicero, Illinois 60804
Dennis L. Duffield
City of Joliet
Department of Public Works & Utilities
921 E. Washington Street
Joliet, Illinois 60431
William Richardson
Illinois Department ofNatural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
RoseMarie Cazeau
Office of the Attorney General
Environmental Bureau
188 West Randolph,
20th
Floor
Chicago, Illinois 60601
William Seith
Total Environmental Solutions
631 E. Butterfield Road, Suite 315
Lombard, Illinois 60148
John McMahon
Wilkie & McMahon
8 East Main Street
Champaign, Illinois 61820
Lisa Frede
CICI
2250 E. Devon Avenue, Suite 239
Des Plaines, Illinois 60018
Jeffrey C.Fort
Letissa Carver Reid
Son.nenschein Nath & Rosenthal
8000 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6404
