TRUSTEES

WHEATON

PLANT SUPERINTENDENT

CLEVE E. CARNEY

1 S 649

STEVE BOLLWEG

ROBERT A. HESTERMAN

JEFFREY R. WALKER

MAINTENANCE SUPERVISOR

BRUCE TUNAITIS

ENGINEER

AND

MANAGER

CHEMIST

ROBERTL. CLAVEL

ATTORNEY

FAX: 630-668-5536

PROJECT ENGINEER

ROGER RITZMAN

www.wsd.dst.iI.us

MOHAMMED HAQUE

February 28, 2002

RECEIVED

CLERK’S

OFFTC’~

Illinois Pollution Control Board

Attn: Dorothy Gunn, Clerk

MAR

12002

James R. Thompson Center

100 West Randolph Street — Suite 11-500

STATE OF IWNOIS

Chicago, IL 60601

Pollution Control Board

Re: Docket R02-1 I

The Wheaton Sanitary District would like to comment on the proposed amendments to 35 III. Adm. Code

304.120, currently before the Board under this Docket R02-1 1.

The District is specifically concerned over the issue that has been raised regarding the proposed change

from five-day biochemical oxygen demand (BOD5) to five-day carbonaceous biochemical oxygen demand

(CBOD5).

The District’s NPDES Permit No. ILOO3I 739 has required reporting effluent CBOD5 since 1988.

As the members of the Board are well aware, the CBOD5 test eliminates the effect of the nitrogenous

oxygen demand. This is a highly variable quantity depending on the extent to which nitrification has

occurred in the sample being tested. The CBOD5 test has historically been used to measure the removal

of organic matter in the treatment process and was never intended to control downstream dissolved

oxygen, as is apparently the objective of those who oppose this change. Numerous references can be

cited in the literature of the need to inhibit nitrification in the BOD5 analysis to obtain data that can be used

to compare results on different samples.

In any event, the use of BOD5 would not be meaningful since, in some cases, it could include none of the

nitrogenous demand and, in other cases, include a significant fraction of the nitrogenous demand, or

anywhere in between. What value is this highly variable parameter in determining the dissolved oxygen

effects from a plant effluent?

The Board’s rules already contain standards for ammonia-nitrogen, to control toxicity in a water body, and

dissolved oxygen. If toxicity or low dissolved oxygen is a concern, these are the proper parameters to be

used to insure that water quality is maintained.

The District supports the amendment to the rules as proposed by the Illinois Environmental Protection

Agency.

We appreciate the opportunity to provide our comments.

WHEATON SANITARY DISTRICT

Robert L. Clavel, P.E.

Engineer - Manager

PLANT: 630-668-1511

Protecting Public Health

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