FOX RIVER WATER

FRWRDS

RECLAMATION DISTRICT

RA’AIDND STREEr &

PURIFY

DRIVE / P.O. Box 328, ELGIN, IL 60121-0328/PH. (847) 742-2O8R~ff4X(847J :742-01 3$

RECEIVED

Au~ust15,2005

~t’.1.

:.:.H.

.,.CLERK’s OFFICE

Ms. Amy Antoniolli

AUG 182005

Illinois Pollution Control Board

STATE OF ILLINOS

James R. Thompson Center

Pollution Control Board

100 W. Randolph - Suite 11-500

Chicago, Illinois 60601

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RE: R2004-021 Radium WQS Proposal

Dear Ms. Antoniolli,

Please accept the attached sheets as a written public comment for the

proposed changes to the Radium Water Quality Standard. These comments

are presented on behalf of the Illinois Association of Wastewater Agencies’

(IAWA) Water Quality Subcommittee.

Please contact me if you have any questions. I thank you for your time in

consideration of these comments.

Sincerely,

Rick Manner, P.E.

IAWA Water Quality Subcommittee - Chairman

BOARD MEMBERS

Bruce

R. Corn,

President.

James E. Tucker,

Vice President

Sandra J.

Vecchio,

Tmasumr.Cledc

Ernest R. Ludwig,

Trustee;

Kevin B. Kelly,

Trustee

OFFICIALS

Gregory

Hergenroeder, P.E., Geneml

Menegec

Douglas J.

Scheflow,

Attorney

ILLINOIS ASSOCIATION OF WASTEWATER AGENCIES’

WATER QUALITY SUBCOMMITTEE COMMENTS REGARDING PROPOSED

ADDITIONS AND REVISIONS TO RADIUM WATER QUALITY STANDARDS

From a water quality standpoint, there are literally millions of toxins that could be

present in waterways that could, in some theoretical concentration, present a

problem for some species in our state. The Illinois Pollution Control Board (IPCB)

has appropriately chosen to save the taxpayers the expense of preparing a

detailed study and associated rulemaking on each of these toxins.

Radium should be added to that list of pollutants that are not specifically

regulated, by removing the current, unsupported, water quality standard, except

where drinking water is at risk. Not having a limit for each of these toxins does

not invite uncontrolled discharge of all of these pollutants. Similarly, removing

radium from the list of explicitly-limited pollutants does not invite increased

discharges.

If there were significant sources of radium, or significant affects of radium in the

environment, radium would warrant the time and attention of a complex rule, one

that balances risks, costs and benefits. That is not the case here. With radium in

the picocuries per liter range, you have:

• one primary source (drinking water plants),

• one primary risk (human health from ingestion),

• one primary set of people paying for any solution (drinking water

ratepayers), and

• no real environmental threat from the levels found in the source.

This calls for a reasonable limit that protects the drinking water consumers from

a health standpoint, but also from a financial standpoint. Very simply and

efficiently, the Illinois Environmental Protection Agency’s (IEPA) original proposal

does that. If it ever comes to pass that this simple analysis is no longer accurate,

the IEPA is employed to bring this to the attention of the IPCB. Further action

would be appropriate at that time.

Please recall that at the start of this process, IEPA was in the unenviable position

of knowing that there was no technical basis for the current standard of 1 pCi/L

for radium 226. Further, they correctly recognized that several drinking water

supplies would either be in direct violation of the standard, or would put their

wastewater treatment plant in violation of this water quality standard.

Unfortunately, 1 pCi/L is still the enforceable limit today. Inaction today will

continue this situation, causing utilities facing the need to fix radium issues for

their drinking water supply, to also spend even more money to come into

compliance with a water quality standard that has no technical basis. It is

appropriate to change the limit, because the public expects their money to be

spent in efforts that actually improve the environment in a meaningful way.

IEPA’s initial proposal was a laudable attempt to fix this problem. They

performed an exhaustive search for data. They found no data, that meets Unites

States Environmental Protection Agency (USEPA) standards, to support

developing a standard to protect aquatic systems. They proposed to join USEPA

in not having a numeric water quality standard for radium, for much of the state.

IEPA did decide to retain a locally applied standard, to protect those water bodies

that are used as drinking water supplies. They proposed a 5 pCi/L standard for

those waters, using the conservative assumption that a drinking water plant

which must meet 5 pCi/L for their product, will not add any radium to the water.

Lacking any other evidence, that is an appropriately conservative design.

In summary, IEPA proposed a standard that would address human ingestion of

radium, the only demonstrable risk present. USEPA agrees that from an aquatic

habitat standpoint, there are insufficient data to support either a limit significantly

below or above that level (3.75 or 30 pCi/L). This implies that there would be a

similar lack of data to support any particular number, from an aquatic habitat

standpoint. USEPA also points out that any numerical limit above 5 pCi/L would

be less protective of drinking water supplies. IEPA’s original proposal addresses

these issues.

Because it addresses all of the meaningful concerns for radium in the waters of

Illinois, the IPCB should adopt the original proposal from IEPA.

Even with the relief provided by the IPCB’s proposed rule of 3.75 pCi/L, with

30 pCi/L for the first mile downstream of some wastewater plants, there will be

both drinking water suppliers and wastewater treatment plants that cause a

violation of the water quality standard. Maintaining this set of limits results in

some utilities being out of compliance with a limit, for which IEPA and USEPA

agree there is insufficient support.

If the IPCB requires any instantaneous limit that is less than 30 pCi/L of total

radium, it assures that some systems will be in violation of it from time to time.

If there were a demonstrable risk of harm to the environment, it would be

appropriate to impose such a limit and the financial burden of compliance would

be met by the sources of radium. That is not the case here, so the financial

burden is excessive.

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FOX RIVER

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FRWRDS

RECLAMATION

DISTRICT

AAYMOND STREET &

PURIFY Q~IV~

/ P.O. SUX 328. ELG~N,IL 60121-0328/ Ph. C847J 742-2068

RECEIVED

FAX

CLERK’S

(847) 742-0193

OFFICE

AUG 1~2005

FOX RIVER WATER ~ECLANATION DISTRICT

TELECOPIER COVER PAGE

FAX tqc. ie47)

712—0193

STATE OF ILLINOIS

Pollution Control Board

TO:

CON PA NY:

FROM:

DATE:

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RE:

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REMARKS:

THIS IS PAGE 1 OF 

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PROBLEMS OCCUR, PLEASE CALL 

(847) 742—269.

SOARD MEMBERS

Bruce P. Corn,

President;

James

E, Tucker.

Vice President;

Sandra ,J, Vocchlo.

Treesurer-CIs,k,

Ernest

Ludwig,

Trustee:

Kevin B. Kelly, Thnte.

OFFICIALS

Gre~oiyHergenroeder, P.E., General

M.nager

Dougles J.

Scheflow,

Attorney