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FOX RIVER WATER RECLAMATION DISTRICT

RAYMOND STREET & PURIFY DRNE / P.O . BOX

3 28 . ELGIN . I L 50121-0328/ PH

. (847) 742-20G8 FAX (B471 742 .0193

June 5, 2007

Ms

. Marie Tipsord

Illinois Pollution Control Board

James R

. Thompson Center

100 W. Randolph

-

Suite 11-500

Chicago, Illinois 60601

Dear Ms . Tipsord,

Please accept the attached sheet as written public comment for the proposed

changes to the Sulfate and Total Dissolved Solids Water Quality Standard on

behalf of the Illinois Association of Wastewater Agencies' (IAWA) Water

Quality Subcommittee . An original will follow by overnight delivery .

Please contact me if you have any questions

. Thank you for your time in

consideration of these comments

.

Sincerely,

Rick Manner, P .E .

IAWA Water Quality Subcommittee

BOARD MEMBERS

Bruce R . Can, Praeldang

James E. Tucker,

Vlos PrSderrt Sancta J . VsccMo, TnresumrCbnc,

Emest R . Ludwlg, Tmaree;

Kevin B

. Kelly, Tnrst

OFFICIALS

Roben P

. Truedood, General Menage.; Douglas J . Scho low,

Artansy

RE : R2007-009 Sulfate and TDS WQS Proposal

RECEIVED

CLERK'S OFFICE

JUN 0 7 2007

Pollution

STATE OF

Control

ILLINOIS

Board

---

TRIENNIAL REVIEW OF SULFATE AND TOTAL DISSOLVED SOLIDS WATERCI~IRAL$~ICE

RECEED

STANDARDS :

JUN 0 l 2007

IEPA (Illinois Environmental Protection Agency) should be compliment gT

MEOFILLINOIS

providing a strong scientific basis to a sulfate limit that was acknowled§*kO Lntrol Board

overly simplistic prior to this

. Their work is comprehensive and applicable to the

waters of the state of Illinois

. The proposed changes are supported by the Illinois

Association of Wastewater Agencies (IAWA) Water Quality Subcommittee

.

IEPA should be encouraged to assess and correct other limits that have not been

rigorously reviewed for decades

. Excessively lenient regulations hurt the

environment directly if dischargers exceed what the limit should be

. Excessively

strict limits harm the economy by wasting money in efforts towards monitoring and

control at an unnecessary level

. Such limits also harm the environment indirectly

by wasting natural resources, increasing waste production and/or wasting energy .

In that these indirect damages occur every day, their damage could exceed the

damage caused by any excessively lenient regulations

.

Eliminating the Total Dissolved Solids (TDS) standard is also supported

. Any given

pollutant which is demonstrated to cause damage should be regulated individually

to the extent necessary

. If there is a synergistic or antagonistic effect between

more than one pollutant that is demonstrated to occur in Illinois, that more complex

relationship should be regulated by individual permits or by State regulations

. This

is the case with the proposed limit on sulfate

. However, there is no demonstrable

damage to the environment caused by TDS at the concentrations found in Illinois'

waters

. Retaining the limit would mis-direct compliance efforts towards a standard

that has no rationale for existence .

The use of actual flow values for discharges that only occur during precipitation

events is strongly supported

. This recognizes reality and is protective of the

environment .

IEPA's retaining discretion for when their staff should use a particular dilution value

is also supported

. It is impossible to account for all possible scenarios when writing

regulations

. To attempt to do so would unnecessarily burden the Board and the

regulations with minutiae that would be subject to change at each permit cycle

.

IEPA's professional staff should be trained to enforce explicit standards in most

cases

. They should also be trained to understand the purpose of a regulation and

account for particular circumstances in selected situations

. This is appropriately

their responsibility and they should retain the authority to apply appropriate

discretion .

IEPA's decision to not propose standards for extremely high levels of sulfate and

hardness is an appropriate decision

. Similarly, not analyzing every possible

combination of pollutants and every possible synergistic effect of pollutants is also

appropriate

. These decisions properly conserve staff and research efforts, as well

as Pollution Control Board time for realistic situations for the State of Illinois

.

---

Fi1Wffl?

~s`

oRfGINAL

FOX

RAYMOND STREET

RIVER

d PURIFY DRIVE/

WATER

P .O

. BOX 328, ELGIN,

RECLAMATION

IL 60121-0328 / PH . [8471 742-2066

DISTRICT

FAX [84?) 742-D193

~ALiT}' ,S,~tfC~ ..~crT.taF

THIS IS PAGE 1 OF 3 PAGES

BEING TRANSMITTED

. IF

ANY PROBLEMS OCCUR, PLEASE CALL (847) 742-2068

.

SOAROMEMSERS

Bruce A . Cum .

Hesidenr, Jemea E Tucker, Vice President, Sandra J. Vecchio. TreasurerClerk

Ernesl R . Lu6mg . Tmeree ; Kevin B

. Kelly

. Trustee

OFFICIAL$

Poberl P . Trueblood, General Manager,

Douglas J . Schellow, Allomey

TELECOPIER COVER PAGE

RECEIVEDCLERK'S

OFFICE

FAX NO, (847) 742-0193

JUN 0 7 2007

To :

Pollution

STATE OF

Control

ILLINOISBoard

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