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Trudy Krygsheld

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SANITARY DISTRICT

Dcccniher 19 .2006

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'RECEIVED

.

, ;,JV,

CLERK'S OFFICE

rncr_ek cStI

DEC

1 9 2006

STATE OF ILLINOIS

Pollution Control Board

Ms

. Dorothy Gunn . Clerk

Illinois Water Pollution Control Board

JRTC

100 Randolph Street, Suite 1

1-500

Chicago. I L 60601

ORIGINAL

RE:

Proposed Amendments to Dissolved Oxygen Standard

35 ILL. ADM

. CODE 302.206

Pollution Control Board Rule R04-25

Dear Ms. Gunn :

The Thorn Creek Basin Sanitary District supports the adoption of the

petition as

originally submitted by the Illinois Association of Wastewater Agencies (IAWA)

in

the proceeding R04-25

. Thorn Creek has been on the service list for the

subject

proceeding and has reviewed the submittals by IAWA and all other parties in

the

matter

. Thorn Creek believes that the IAWA proposal would establish

a dissolved

oxygen water quality standard that is protective of the state's

surface waters and

biological resources

. The petition is founded in good science and is attainable

in the

water resources throughout the state

. IAWA has stated and no one has disagreed that

the current dissolved oxygen water quality standard is not science-based

. IAWA's

proposal is based on the US EPA National Criteria Document, and is in fact, more

protective than suggested in the National Document

.

The Illinois Environmental Protection Agency and the Illinois Department of Natural

Resources have offered counter proposals in this matter

. They should not be accepted

for two reasons

:

1 .

They have not provided scientific data that supports the derivation of their

alternate limits .

2.

There is no scientific evidence supporting the proposed enhanced standards

for certain stream segments, including the requirement for higher dissolved

oxygen standards

. In fact, data provided by IAWA shows that the higher

oxygen levels are not always present in the stream segments they

report as

having sensitive aquatic life

.

X11

---

.

;s. Ikuodiv (; ,u n

1I :IrIUI ; ~i'I r P"' ILOLOA ( _q 'Vi Illlaru

December 19.2(106

Pace -2-

Thorn Creek appreciates this opportunity to offer comments in relationship to R04-

25 . Adoption of the original petition as submitted by IAA% A is encouraged

.

Very truly yours,

James L . Daughem

District Manager

JLD:pm

cc

:

See Service List

---

TO :

Clerk's Office

I!linois Water Pollution Control Board

FAX '

1-312-814-3669

FRONT

: James L . Daugherty

DAFI, : December 19 . 2006

RE:

Public Comments on the

Proposed Amendments to Dissolved Oxygen Standard

35 ILL. ADM . CODE 302206

Pollution Control Board Rule R04-25

FAX

THORN CREEK BASIN SANITARY DISTRICT

700 West End Ac c ., Chicago Heights, 11 . 60411

Phone : 708-754-0525

Fax

:708-754-3940

Attached please find my public comments on the above subject . I understand a fax copy is acceptable for

submittal -

Thank vou .

James L. Daugherty

District Manager

IF ALL PAGES ARE NOT RECEIVED, PLEASE CALL (708) 754-0525 X21