BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
WATER QUALITY STANDARDS AND
EFFLUENT LIMITATIONS FOR THE
CHICAGO AREA WATERWAY SYSTEM
AND THE LOWER DES PLAINES
RIVER: PROPOSED AMENDMENTS TO
35 Ill. Adm. Code
Parts
301, 302,
303 and
304
R08-9
(Rulemaking
-
Water)
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER
CHICAGO'S PRE-FILED QUESTIONS TO MARC GORELICK
1.
Page 1 - Paragraph 2, lines 7-9 state: "Disinfection is nearly universal in major cities in
the United States and prevalent in most smaller communities, for the simple reason that it
is
widely recognized as necessary to protect public health." Do you believe that the
historical practice of wastewater disinfection in the United States is justified when:
A.
More current published research (Blatchley et.al., 2007)1, strongly suggests that
conventional wastewater treatment disinfection processes are not effective for
control of risks of disease transmission?
B.
A paper published in Australia (Razzell, WE.
The Realities of Disinfection in
Water and Wastewater Treatment,
1990)2 also concluded that treatment of
discharges of effluent from sewage treatment plants having secondary treatment is
a waste of resources and a threat to the environment apart from being ineffective
as practiced conventionally?
2.
Are you aware of any reports of disease outbreaks associated with secondary treated
wastewater effluents?
3.
Do you have any data similar to that for drinking water that suggests wastewater
disinfection as currently practiced in the United States is necessary to protect public
health?
4.
Page 1 - Paragraph 2, lines 11-13 states: "...a single study of this nature is simply not a
sound basis for bucking that vast consensus and allowing a heavy pathogen load in
recreational waters." It is important not to confuse the discharge of fecal indicators with
the discharge of a "heavy pathogen load". For example, isn't it true that the actual
measured concentrations of pathogenic microorganisms ranged from no-detect (<O.1) to
very low numbers? (Dry and Wet Weather Risk Assessment of Human Health Impacts of
'
Blatchley, et al. (2007
).
Effects of
Wastewater Disinfection on Waterborne Bacteria and Viruses.
Water
Environment Research
,
Volume 79, Number 1, pp 89-91.
' Razzel,
WE, The Realities
of Disinfection
in
Water and Wastewater Treatment
.
Institute of Engineers
,
Australia,
1989. National conference publication.
THIS
FILING
IS BEING SUBMITTED
ON RECYCLED PAPER
Electronic Filing - Received, Clerk's Office, August 25, 2008
Disinfection Vs. No Disinfection of the Chicago Area Waterways System, Geosyntec
Consultants, 2008; Tables 3-5a, 3-5b, 3-5c, 3-6 and 3-7).
5.
A paper you co-authored and referenced in your testimony entitled,
Pediatric Emergency
Department Visits for Diarrheal Illness Increased After Release of Undertreated Sewage
states, "Contamination of local waterways by untreated or partially treated sewage may
affect public health through dissemination of waterborne pathogens. In the process
known as secondary bypass, or blending, sewage proceeds to primary treatment where
solids, hydrophobic compounds, and sediment are removed. From there up to 20% of the
sewage stream bypasses the usual secondary treatment with biological agents (where
most pathogens are removed) and is directly diverted to the final step in the process ...and
then disinfecting agents such as chlorine are added, and the partially treated or "blended"
sewage is discharged into local watershed
areas."
A.
In this paper, you acknowledge that secondary treatment processes remove most
of the pathogens from the raw sewage prior to disinfection and discharge into the
receiving stream. Given that the District VWs are all secondary treatment
facilities,
what data do you have to indicate that the District is discharging a
heavy pathogen load into the CAWS?
6.
Page 1-Paragraph 2, linel3 states:
"Simply put, we do not need further study to know that
germs in the water can make people sick. "
Can you provide references for any past
epidemiological studies of risks of illness due to fishing, boating, rowing, canoeing and
kayaking, which are the types of incidental contact activities taking place on the CAWS?
7.
Page 1, Last paragraph states: "I urge the Board to be very cautious in its approach to the
epidemiological study, because placing excessive and undeserved weight on it could set a
dangerous precedent for other communities around the nation."
A.
Since epidemiological studies provide relevant scientific information for
evaluating risk from water recreation and for making decisions concerning
protection of recreators exposed to water, why would consideration of this
epidemiological study in formulating a basis for these decisions as they pertain to
the CAWS be "setting a dangerous precedent for other communities around the
nation"?
B.
Further, you state that the epidemiological study would, "potentially encourage
communities to discontinue a basic health precaution that they have, appropriately
been taking for decades."
What is the basis for this statement?
8.
Page 3, last 3 sentences states: "Some of the worst plagues in history have been caused
by untreated sewage being discharged into water sources used by humans..." While the
risks associated with untreated sewage are well known, do you have data or know of any
reports of plagues being associated with treated secondary effluent?
9.
Page 4, lines 1-2 states: "Although modern primary and secondary sewage treatment
remove many pollutants and solids from sewage, the pathogens will remain in the final
discharged effluent unless the sewage is disinfected."
2
Electronic Filing - Received, Clerk's Office, August 25, 2008
A.
Was your
statement meant to imply that secondary sewage treatment does not
remove pathogens?
B.
Are you aware that the statement contradicts your report referenced above in
which you state that most pathogens are removed during secondary treatment
prior to disinfection?
C.
Are you familiar with the report entitled, Public Health Risks Associated with
Wastewater Blending (Katonek and Rose-November 17, 2003)3, which states that
activated sludge is a common form of secondary treatment in the United States?
D.
Do you agree with the report's findings that activated sludge consisting of
bacteria, protozoa, and metazoan is vital for the removal of viruses and for a
significant reduction in E. coli 0:157-phage and that during aerobic wastewater
treatment, Cryptosporidium and Giardia can be reduced by approximately 99.9%
and Clostridium perfringens total counts can be reduced by approximately
99.97% all without disinfection?
E.
In several places throughout your testimony you use the term "sewage-
contaminated water."
While you have indicated in your testimony the risks of
serious illness from contact with sewage-contaminated water, how have you
compared the difference in risks between sewage-contaminated water and treated
effluent dominated waterways like the CAWS?
F.
Are you aware that the Cryptosporidium outbreak in Milwaukee was a drinking
water outbreak, not a recreational water outbreak?
G.
The Wisconsin Division of Health and the Wisconsin Department of Natural
Resources reports that this outbreak was not associated with the treated effluent
from the Milwaukee Metropolitan Sewage District, but was a result of
uncommonly heavy rains on frozen and ice-covered ground (particularly where
manure had been spread), barnyard runoff, raw sewage overflows, slaughterhouse
effluent, removal of a Milwaukee River dam and/or changes in filtration practices
at the drinking water plants.4 Do you have any data which associates any such
outbreak with treated wastewater effluent?
10.
Page 4-Last paragraph, Lines 1-2 states: "In preparation for my testimony, I have
reviewed a summary of indicator pathogen sampling data collected by MWRD and
posted to its website http://www.mwrdgc.dst.il.us/."
A.
What do you mean by the term "indicator pathogen"?
B.
Did you review the pathogen data or the indicator data or both?
3
Katonak, R. and Rose, J.B.,
Public Health Risks Associated with Wastewater Blending,
Final Report, Michigan
State University, November 17, 2003.
4
Archer, J.R. et al.
Gyptosporidium spp. Oocyst and Giardia spp. Cyst Occurrence, Concentrations and
Distribution in Wisconsin Water,
Publication WR 420-95, Wisconsin Department of Natural Resources 1995.
3
Electronic Filing - Received, Clerk's Office, August 25, 2008
11.
In your review of the data on the District's website, were you able to associate high levels
of fecal indicators with high levels of pathogens?
12.
How have the levels of indicator organisms in this data indicated the likely levels of these
pathogens?
13.
Do you have data which correlates the levels of indicators to the levels of pathogens in
any secondary treated wastewater effluent?
14.
Page 5, Paragraph 2, lines 8-10 states: "Several of the water samples in
the CAWS have
levels of E. coli that, if found in a urine sample of an infant, would be considered a sign
of a urinary tract infection requiring antibiotic treatment."
A.
Would these same levels of E. coli found in a fecal sample of an infant be of
concern?
B.
Please explain how levels of E. coli in urine are relevant to concerns about levels
of E. coli in the waterways.
C.
Do you know that each of us are excreting vast numbers of non-pathogenic E. coli
every day?
D.
Do you agree that the human health hazards associated with E. coli strains present
in environmental water are not well known and that the relationship between
pathogenic and non-pathogenic E. coli highly depends on the nature of the
watershed and the source of pollution?
15.
Page 5, Last paragraph, lines 2-4 states:
"It is unlikely on the other hand, that one would
find high levels of indicator bacteria correlated with low levels of viruses because the
latter tend to persist in the environment for longer periods of time. "
A.
Do you have data which correlates the levels of indicator bacteria with the levels
of viruses in treated wastewater effluents?
B.
Do you have data which
suggests
that high levels of indicator bacteria equals high
levels of viruses?
16.
Page 5 - Last paragraph, lines 8-11 to Page 6, lines 1-2 states: "Finally, as a general
matter, even low levels of any human pathogen can be dangerous for sensitive
populations - children, the elderly, and persons with compromised immune systems
(such as people in chemotherapy). Thus, an overall low level of indicator organisms
cannot be interpreted to mean that the level of waterborne pathogens is safe for sensitive
populations."
Given that current research suggests that disinfection is only effective in
lowering the levels of indicator bacteria and may not be effective against pathogens that
may be in the effluent, and given that monitoring results indicate that at times levels of
pathogens are higher upstream suggesting other sources of these pathogens:
4
Electronic Filing - Received, Clerk's Office, August 25, 2008
A.
What level of waterborne pathogens in incidental or secondary contact water is
safe for the sensitive population?
B.
Do you have data to show that disinfection of the wastewater effluents will reduce
the level of pathogens in the CAWS to that level?
C.
Did you know that although their symptoms may be more severe, it does not take
a lower dose of pathogens to infect children, the elderly, and persons with
compromised immune systems?
17.
Do you believe the proposed fecal coliform limit for the wastewater reclamation plants
will sufficiently protect the general public?
18.
Do you think the proposed effluent limits would make the waterways safe for sensitive
populations, even with a very high level of treatment at the plants?
19.
If the proposed effluent limits won't make the waterways safe for the public, including
sensitive populations, wouldn't it be better to let the public know that the waterways
should not be used for primary contact recreation?
20.
Wouldn't it be best to warn sensitive populations that the waterways would not be safe
even if very low levels of indicator organisms were present?
21.
Page 6, Paragraph 3, Lines 4-6 states: "Since epidemiological study populations are not
isolated from the general population or otherwise tightly controlled in their behavior and
exposures, it can be extremely difficult to isolate the factor that is causing any observed
effect calling into question the strength of the evidence."
A.
In your testimony you reference your "peer-reviewed study of diarrheal illness
rates in children following a release of undertreated sewage (which found a
positive correlation, i.e. more children in the exposed group of children were
sickened by a statistically significant margin)".
Who were the peer-reviewers of
the study and what were their credentials?
B.
How did you account for these same epidemiological study limitations in your
study on children in such a way that you can confidently state that you found a
positive correlation by a statistically significant margin?
C.
The UIC School of Public Health's epidemiological study design was developed
by a multi-disciplinary team of experienced researchers, with backgrounds in
infectious disease medicine, environmental medicine, epidemiology, biostatistics,
industrial hygiene and environmental science, and has been evaluated by a panel
of recognized leaders in the field of water microbiology and health (including US
Centers for Disease Control and Prevention, US EPA and other universities).
What elements does your study contain that contribute to its validity that the UIC
School of Public Health's epidemiological study does not have?
5
Electronic Filing - Received, Clerk's Office, August 25, 2008
D.
Some of the events in your study achieved statistical significance for "Lake
Michigan," none for "Non-Lake Michigan." However the sample size was 4
times larger for Lake Michigan.
What was the power of the study for Non-Lake
vs. Lake Michigan?
E.
The September 1, 2003 and May 14, 2004 events had similar amounts of sewage
diverted. The September 1, 2003 event had 4.2 times more Giardia cysts
measured in the effluent, however, the correlated effect is quite different. Can you
explain this?
F.
For the May 30 and September 1, 2003 events, did you have any data about
whether those children visiting the ER could have been exposed to the blended
effluent by recreating in Lake Michigan in areas affected by the effluent?
G.
In Table 2, did you define "winter" as the two events in December 10, 2003 and
March 26-28, 2004? For the winter grouping, are the illness rates for both the
Lake Michigan and the non-Lake Michigan drinking water zip codes statistically
significant?
H.
How does that support your overall conclusion that there is a relation between
blending events, Lake Michigan drinking water sources, and increased incidences
of diarrhea?
I.
In terms of the zip codes that were not within the Lake Michigan drinking water
source, do you know what treatment was provided to the source water?
J.
Do you have any evidence that the drinking water treatment provided to the
source water for those living in the Lake Michigan supply area was inadequate to
protect against waterborne pathogens?
K.
How do you support your conclusion "[w]e have observed an association between
the release of partially treated sewage into a drinking-water source in a
metropolitan area and subsequent child ER visits for diarrheal illness"?
L.
In the conclusion, the article states "Although these results are preliminary and
cannot themselves demonstrate a causal relationship, they suggest a need for
additional study in this area to inform ongoing policy debate."
What is meant by
preliminary? Isn't it possible that the results don't support a causal relationship?
M.
In reference to your study, a letter from the Milwaukee Health Department
(MHD) to the Milwaukee Journal Sentinel dated on April 28, 2006 states, "There
currently is no evidence of drinking water quality degradation at MWW [drinking
water] treatment plants as a result of secondary sewage bypasses at the
wastewater treatment plant. Furthermore, MHD's surveillance data reveals no
evidence that secondary sewage bypasses are directly related to increases in
disease occurrence with the community."
What evidence do you have that the
diarrheal illnesses you reported in children were directly related to drinking water
contaminated with sewage bypasses?
6
Electronic Filing - Received, Clerk's Office, August 25, 2008
22.
Page 7, Paragraph 2, lines 7-10 states: "Simply put, we already know that germs are bad
for people, and MWRD WWTPs are putting those germs in the water. That, standing
alone, is sufficient information on which to base a requirement that WWTPs disinfect
their effluent..."
A.
Have you read the testimony of Ernest Blatchley?
B.
On page 4 of his testimony, Dr. Blatchley states "A common impression among
the lay public is that a wastewater effluent that has been "disinfected" (i.e., is in
compliance with an effluent discharge limitation for coliform bacteria) is "safe",
in terms of potential exposure to waterborne microbial pathogens. However,
systems that are in compliance with coliform limitations similar to those that have
been proposed for the District's facilities may still contain viable and/or infective
microbial pathogens." Do you agree or disagree with these statements, and why?
C.
On page 6 of his testimony, Dr. Blatchley states "For example, in most countries
of western Europe, wastewater disinfection is practiced only at facilities where
effluent discharge is to a public swimming area, or where other opportunities for
direct human contact are likely (e.g., shellfish breeding grounds). Despite the fact
that effluent disinfection is uncommon in Europe, the incidence of diseases
associated with waterborne pathogens among the residents of these countries does
not appear to be substantially different than in the U.S." Have you compared this
information to what you found in your study of increases in emergency
department visits due to the supposed effect of blending events on Lake Michigan
drinking water?
23.
Page 8-Paragraph 4, lines 1-2 states:
"All these issues with sample size appear to be
present in the CHEERS epidemiological study ... "
A.
Are you aware that survey research - such as surveys of how the public feels
about the economy or the presidential race - generally samples less than 1/100 of
I% of the population?
B.
If the CHEERS research study enrolls 5 or 10% of CAWS users, wouldn't you
expect that to be representative of the population of interest?
C.
If the percent of users enrolled in the research is very high compared to most
research studies, wouldn't that make the results to be an unusually good reflection
of the risks of the actual population of CAWS recreators?
24.
Page 8-Last paragraph, lines 2-6 states: "The study is enrolling those engaged in all
manner of secondary contact use - including kayaking, canoeing, rowing, fishing, and
other activities that do not involve full-body contact. These activities differ greatly in the
likelihood that a participant will end up swallowing a mouthful of contaminated water,
which is the primary exposure pathway for waterborne pathogens."
7
Electronic Filing - Received, Clerk's Office, August 25, 2008
A.
The presence of pathogens would increase the risk of gastrointestinal disease if
people swallow the water. Do you know of any study published in the peer-
reviewed literature that estimated how much water people swallow when
recreating?
B.
If no such study has been done, why should we think that sufficient quantities of
water are swallowed by fisherman, boaters and rowers to produce illness?
25.
Page 11, Paragraph 2 states: "It is important to note that when the risk under study can be
changed by the individual, and it is known or suspected to be hazardous, the magnitude
of that risk is likely to be underestimated in an epidemiological study because people may
conduct themselves more cautiously in hazardous conditions and self-limit their risk..."
A.
Is the implication of this statement that disinfection will yield a substantial
reduction in the risks associated with waterborne microbial pathogens?
B.
Are you implying that users of the CAWS have modified their behavior because
of the perception of risk associated with the CAWS, in their current condition?
C.
What is the basis for these implications that the behavior patterns of users of the
CAWS will change (i.e., these people will be less conservative in their behavior)
if disinfection is implemented?
D.
How can you demonstrate that the cautious behavior you assume is exhibited now
may change if disinfection is implemented?
E.
If users become less cautious as a result of implementation of disinfection, isn't it
conceivable that the risk of disease transmission could increase?
26.
Page 12, lines 4
-
7 states: "Rather
,
the problem of waterborne pathogens
in the CAWS
needs to be understood as a situation that we know is inherently dangerous
,
and that is
bound over time to result in severe injury to someone even if that injury cannot be
captured in the narrow window of a scientific study."
A.
Are you aware that in many of the waterborne disease outbreaks in the United
States, most of the outbreaks are associated with "treated water" (swimming
pools, spas, wading pools, interactive fountains, etc.) (CDC, 2006, p. 6)5. Do you
think that swimming in treated water "is bound over time to result in severe injury
to someone"?
B.
Should people stop swimming in treated water venues because it is inherently
dangerous?
27.
Page 12, Last 2 lines states:
"I believe that sound science and public
health policy call
for promptly disinfecting WWTP effluent as IEPA proposed... "
5
Centers for Disease Control and Prevention
(CDC) (2006).
Surveillance for Waterborne Diseases and Outbreaks
Associated with Recreational Water - United States.
8
Electronic Filing - Received, Clerk's Office, August 25, 2008
A.
Are you aware that research by Blatchley et.al. (2007) strongly suggests that
wastewater disinfection processes cause a decrease in water quality and may not
be effective for control of risks of disease transmission as once thought?
B.
Are you aware that research published in Australia by Razzell, WE (1990)
concluded that treatment of discharges of effluent from sewage treatment plants
having secondary treatment is a waste of resources and a threat to the
environment?
C.
Are you aware that research presented to the Illinois Pollution Control Board by
MWRD demonstrated that water quality in the receiving waters downstream of
the Districts Ar"s was the same or better when disinfection was terminated than
it
was when disinfection was practiced?6
D.
If the MWRD were to disinfect, it would take years before the disinfection
processes would be built. If the risk is such as you describe, would you
recommend banning all recreation on the CAWS until that time?
E.
Even if the wastewater treatment plant effluent was disinfected, would you still be
concerned about recreational exposure to the CAWS due to pathogen
contributions from stormwater runoff and combined sewer overflows?
Dated:
August 25, 2008
Respectfully submitted,
METROPOLITAN WATER RECLAMATION
DIST
REATER CHICAGO
By:
Fredric P. Andes
Fredric P. Andes
David T. Ballard
BARNES & THORNBURG LLP
Suite 4400
One North Wacker Drive
Chicago, Illinois 60606
(312) 357-1313
482438v1
6
Haas, C. et al.,
Effects of discontinuing disinfection on a receiving water.
Journal Water Pollution Control
Federation, Washington, D.C. 20037 (1988).
9
Electronic Filing - Received, Clerk's Office, August 25, 2008
