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
35 111. Adm
.
Code Parts 301, 302
,
303 and
304
R08-9
(Rulemaking
- Water)
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER
CHICAGO'S PRE-FILED QUESTIONS TO THOMAS BAMONTE
1.
What safety protocols does your organization employ when inviting the public to use the
CAWS?
A.
Do you avoid certain areas due to barge and motorized boat traffic, absence of
safe entry and exit locations, and/or other
issues
incompatible with recreational
uses?
B.
Do you avoid certain times, such as during and following wet weather events?
C.
How
do you determine when wet weather effects have dissipated?
2.
Even if
the wastewater treatment plant effluent was disinfected
,
would you recommend
that people
,
particularly children
,
should avoid exposure
to the CAWS
due to pathogen
contributions from stormwater runoff and combined sewer overflows?
3.
What protocols do you personally employ to minimize the potential of illness due to
exposure to pathogens in the waterways in which you kayak?
4.
On page 4 of your testimony, you indicate that "[a]n unexpected boat wake or collision
with another kayak can result in loss of balance and capsize."
A.
Aside
from the increased risk of water ingestion, does capsizing pose other safety
related risks?
B.
Do you agree that kayaking in certain portions of the CAWS might be unsafe due
to barge traffic?
5.
On page 5 of your testimony, you state that, "the River is heavily used by novice paddlers
because it is more protected than Lake Michigan waters."
A.
Do you feel comfortable with the fact that these "novice" paddlers share the
waterways with a high number of barges, power boats and tour boats that cause
large wakes and take up a major portion of the waterway?
THIS FILING IS BEING SUBMITTED ON RECYCLED PAPER
Electronic Filing - Received, Clerk's Office, August 25, 2008
B.
Have you experienced the pull or suction of small hand-powered craft (and larger
boats for that matter) towards a barge when they pass through the center of a
waterway due to the huge volume of water they push? Do you feel confident that
novice kayakers would be able to navigate through this suctioning effect?
C.
Since
novice paddlers are more
likely
to capsize
, do you worry that if they do,
they may be
in an area
with
steep banks and no ability
to climb out of the water?
6.
On page 5, you state "I hope that the IPCB will establish water quality standards that
reflect the fact that recreational paddlers like kayakers have extensive bodily contact with
River water each and every time they paddle in the River."
A.
Are you familiar with the
reasons
cited by IEPA
explaining
why the primary
contact use is not even being considered in this rulemaking
due to its
inappropriateness
for the CAWS?
B.
Do you believe that the proposed technology-based standards requiring
disinfection to 400 fecal coliform counts per 100 milliliters for the secondary-
treated effluent from the three water reclamation plants will make the River safe
for recreational paddlers?
C.
To your knowledge, would "extensive bodily contact" with the River carry any
less risk with respect to pathogens if the District plants were to disinfect? Please
cite any evidence you have concerning this risk.
D.
Do you believe that the River will be safe at all times (in terms of limiting
paddlers' exposure to illness-causing pathogens) regardless of the existence of
other potential pathogen sources (excluding the secondary-treated effluent from
the water reclamation plants)?
E.
If there are lingering effects of combined sewer overflows and other wet weather
sources of potential illness-causing pathogens, do you believe that people should
know when the River water may not be safe?
F.
Or, if it is difficult to communicate this in a clear way, should people be warned,
in general, that the water may not be safe so they can take extra precautions?
G.
Given the concern you express in your testimony for water contact on the part of
kayakers, as President of the Chicago Area Sea Kayakers Association, does your
association take any action to inform recreational paddlers that the River water
currently is not safe due to "direct (e.g., hand in water)" or indirect "(e.g., water
on gear)" (p. 4) exposure to River water? If not, why?
7.
In the petition you filed on behalf of CASKA on April 18, 2008
,
you state that the Board
is urged to adopt rules that meet a General Use standard by 2016
(CASKA April
18, 2008
filing top of page 2).
A.
Is this what you are alluding to in the concluding remarks of your testimony?
2
Electronic Filing - Received, Clerk's Office, August 25, 2008
B.
If so, how do you propose that the Board structure a rule that would ensure that
the waterways meet General Use standards considering that wastewater effluent is
not the only source of bacteria and pathogens to the waterways?
Dated:
August 25, 2008
Respectfully submitted,
METROPOLITAN WATER RECLAMATION
DISTRICT-OF-GREATER CHICAGO
Fredric P. Andes
Fredric P. Andes
David T. Ballard
BARNES & THORNBURG LLP
Suite 4400
One North Wacker Drive
Chicago, Illinois 60606
(312) 357-1313
482452v1
3
Electronic Filing - Received, Clerk's Office, August 25, 2008
