December 15, 2006

Illinois Pollution Control Board

Attention

: Clerk

100 W

.Randolph

James R . Thompson Center

Suite 11-500

Chicago, Illinois 60601

and via fax 312-814-3669 ; 2pages

Re:

I . .

CB 06-

RECEIVED

CLERK'S OFFICE

DEC 1

:_ _7005

STATE OF ILLINOIS

Pollution Control Board

is C mment on American Bottom Conservancy Appeal ofNPDES Permit

Horseshoe Lake / Canteen Lake, Madison County, Illinois

Since moving to Madison County nearly twenty years ago, I have frequented Horseshoe

Lake State Park for a variety of purposes

. Recently, I have observed increased access to

the Lake via the bike trail that actually runs on an abandoned railroad right-of-way

through GCS's facility property .

Several years ago, I was involved as an environmental consultant in the acquisition of

Canteen Lake by a private party . The surface waters of the two lakes are interconnected

.

The State had interest in acquiring the property but decided that it was too

"contaminated" and throughout the environmental assessment process was the concern of

GCS's wastewater discharges into the Lakes' water system

. While I am happy for my

clients in acquiring the property, fact is, Illinois citizens lost access to this unique

resource.

Over the years, I have been involved with the preparation and review of National

Pollutant Discharge Elimination System (NPDES) permits

. In recent years, I have

noticed that the principle purpose of the permit, to

eliminate the discharge of pollutants,

is seemingly being lost .

Rather than leading toward the elimination of pollutant

discharges, they are being manipulated as an accepted manner to dispose of wastes into

the waters of the State

.

One way this is done is to use connected water resource units (surface water and/or

groundwater) to in effect dilute the wastes to meet NPDES standards

. In some cases, the

prEmary use of the water resources becomes the dilution of wastes, before the wastes are

discharged back into the connected water resources units

. Dilution is not an accepted

environmental management of wastes

. Usually, this management involves some sort of

"passive treatment" of wastewater, identified as a friendly sounding "artificial wetlands

."

But little of the wastes' pollutants are actually removed from the environment

. Rather,

the holding of the wastes allows the wastes to be diluted before being discharged to

surface waters or leaching into the underlying groundwater .

Typically, NPDES permits are reviewed looking at the concentrations of pollutants being

discharged into the waters "mixing zone" This is a concept of diluting wastewaters and

---

Horseshoe

NPDES Permit

Lake,

Public

Madison

CommentCounty,

Illinois

PCB 06-171

DcXentlx

Page 2 o[2:r

15 . 2006

is evident even to the casual observer

. To properly evaluate the permit, the "treatment"

of the wastewaters needs to be considered as to whether the

elimination of pollutant

discharges to (connected) water resources is being promoted by the permit

.

Another element, that I believe is particular to this NPDES permit, is the discharge of

pollutant types into a water resource of pollutants that would not normally be expected in

the receiving waters which comes from the mixing of dissimilar wastewater streams,

during or after 'treatment' and prior to discharge .

All too often, common sense public comments regarding environmental matters are

responded to by saying, "we've considered the comment and decided to ignore it," to the

detriment of our environmental resources as a whole.

Every time I observe from public access property the industrial wastewaters related to

this permit, I question to myself the reasonableness of its management in the

environment. I believe a great many of those who utilize not only the water resources of

Horseshoe Lake itself and connected water resources, but also of environmental resources

surrounding the state park, would attend a Public Hearing on NPDES discharges into the

Lake, particularly if there is a proper public outreach effort toward them .

Sincerely,

Robert L. Johnson, PE

Senior Environmental Consultant

8 Cypress Point

Cpllinsville, Illinois

618/530-6604

MAY 0,011344 e'01