BEFORE THE
BOARD
~
F~6
1
52002
-,
iN THE MATTER OF:
~
lLI~I1VOIS
WATER QUALITY TRIENNIAL REVIEW
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R02-1 1
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AMENDMENTS TO
35
ILL. ADM. CODE
)
(Rulemaking-Water)
302.208(e)-(g),
302.504(a),
)
302.575(d), 303 .444, 309. 141(h);
)
AND PROPOSED 35 ILL. ADM. CODE
)
301.267, 301.313, 301.413,
)
304.120 AND
309.157
)
NOTICE OF FILING
TO:
SEE ATTACHED SERVICE LIST.
PLEASE TAKE NOTICE that on Tuesday, February 15, 2002, we filed the attached
Comments of the Metropolitan Water Reclamation District of Greater Chicago
with the Clerk
of the Pollution Control Board, a copy of which is herewith served upon you.
METROPOLITAN WATER RECLAMATION
DiSTRICT OF GREATER CHICAGO
BY:
~
Michael G. Rosenberg, its Attorney
Michael G. Rosenberg/Ronald M. Hill
Metropolitan Water Reclamation
District of Greater Chicago
100 East Erie Street
Chicago, IL 60611
(312) 751-6583
CERTIFICATE OF SERVICE
I,
(~J’~)2~~./J
JC1~f)~J)
being duly sworn on oath, certify that I caused a
copy of the attache~1
Comme~sof the Metropolitan Water Reclamation District of Greater
Chicago to be sent via first class U.S. Mail to the individuals identified on the attached service list
their addresses as shown, with proper postage prepaid, from 100 E. Erie Street, Chicago, Illinois, at
or nearthe hour of 4:00 p.m., this 15th day of Feb ary, 2002.
SUBSCRIBED and SWORN to before
c1~iA1/,
LI~r~)
me this 15th day ofFEBRUARY, 2002.
otary Public
RFI:me
“UFFiC~/L1SEAl’
~
RoSALIE BO1TARI
)
Notary
Public. State of Illinois
I
i
~
-~
WIll) 1(Y)
)
SERVICE LIST
RH:me
Ms. Dorothy M. Gunn
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Albert Ettinger
Environmental Law & Policy Center
35 East Wacker Drive, Suite 1300
Chicago, Illinois 60601
James T. Harrington
Ross & Hardies
150 North Michigan Avenue, Suite 2500
Chicago, Illinois 60601
Katherine Hodge
Hodge & Dwyer
3150 Roland Avenue
P.O. Box 5776
Springfield, Illinois 62705
Mane E. Tipsord
Hearing Officer
Illinois Pollution Control Board
100 West Randolph, Suite 11-500
Chicago, Illinois 60601
Dennis Duffleld
Department of Public Works
City ofJoliet
921 E. Washington
Joliet, Illinois 60433-1267
Tom Muth
Fox Metro Water Reclamation District
682 State Route 31
Oswego, Illinois 60543
Sanjay Sofat
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, IL 62794-9276
Margaret Howard
Hedinger and Howard
1225 South Sixth Street
Springfield, Illinois 62703
Robert Messina
Illinois Environmental Regulatory Group
215 East Adams Street
Springfield, Illinois 62701
Irwin Polls
Metropolitan WaterReclamation
District of Greater Chicago
6001 West Pershing Road
Cicero, Illinois 60804
Mike Callahan
Bloomington Normal Water
Reclamation District
P0 Box 3307
Bloomington, Illinois 61702-3307
Lisa Frede
Chemical Industry Council
9801 W. Higgins Rd., Suite 515
Rosemont, illinois 60018
Larry Cox
Downers Grove Sanitary District
2710 Curtiss Street
Downers Grove, Illinois 60515
2
IN THE MATTER OF:
WATER QUALITY TRIENNIAL REVIEW
AMENDMENTS TO
35
ILI.~,ADM. CODE
302.208(e)-(g),
302.504(a),
302.575(d), 303.444,
309.141(h);
AND PROPOSED 35 TLI..~.ADM. CODE
301.267,
301.3
13, 301.413,
304.120 AND 309.157
COMMENTS OF THE METROPOLITAN WATER
RECLAMATION DISTRICT OF GREATER CHICAGO
The Metropolitan Water 1. .eciamation District ofGreater Chicago (“District”) submits the
following comments in support of the proposed amendment to
35
111. Adm, Code 304,120. The
District reserves the right to submit additional comments on any of the amendments being con-
sidered herein at the close oftestimony in the event the Board authorizes such comments.
The Illinois Environmental Protection Agency (“Agency”) is proposing to amend 35 IlL
Adm. Code 304.120 of the Board regulations by adding a Paragraph (g) which specifies that
compliance with the 5-day biochemical oxygen demand (BOD5) numerical standards in Section
304.120 be determined by analysis of 5-day carbonaceous biochemical oxygen demand
(CBOD5).
The District supports this proposed amendment to Section 304.120. The generally ac-
cepted definition of the purpose of secondary treatment for municipal wastewater treatment
plants is to remove suspended solids and biodegradable organic matter (carbonaceous material)
from wastewater, to a specified level of quality. Historically, the BODc test was the accepted
measure of biodegradable organic matter in wastewater, and the concentration of BOD5 in an
effluent was the measure ofthe efficiency ofthe secondary treatment process.
test actuallyIn
recentrr.easuresyears,twoa significanttypes
ofdeoxygenatingbody
ofresearchwastes,has demonstratedcarbonaceousthatmaterialthe traditionaland
ammonia-
BOD5
BEFORE THE ILLINOiS POLLUTION CONTROL BOARD
CLERK’S OFFICE
FEB 1 5 2002
)
STATE OF
IWNOIS
)
Pollution Control Board
)
R02-1i
)
(Rul emaking-Water,)
)
)
)
)
)
nitrogen. The ammonia-nitrogen exerts a so-called nitrogenous demand (NOD) when it is bio-
logically converted to nitrate-nitrogen through bacterial action. Research has also conclusively
shown that this NOD contribution to the traditional BOD5 test can be highly variable depending
on a variety of circumstances regarding the wastewater sample and treatment plant operations.
This, in some cases. can result in the traditional BOD5 test producing results that do not accu-
rately reflect the true operation of the secondary treatment process. This can. .lead the treatment
plant operator to incorrectly assess the condition of his plant, and also can result in the Agency
incorrectiy assessing the operation ofthe plant relative to removal ofcarbonaceous material.
With this information in hand, researchers developed the CBOD5 test which allows the
oxygen demand due to carbonaceous material to be separated from the oxygen demand due to
ammonia-nitrogen. Th.e
CBOD5
test has been validated and accepted for use by Standard Meth-ET?1 w?462 470 m?536 470 l?S?BT?
ods for the Examination ofWater and Wastewater.
By formally recognizing the use ofthe CBOD5 test for measuring deoxygenating wastes
under Section 304.120, the Board will be unifying its regulations with the generally accepted
theories in the municipal wastewater treatment industry regarding the scientifically correct
method for assessing the removal of organic matter in the secondary treatment process.
Any concerns which the Board may have regarding the removal of--toxicity due to ammo-
nia-nitrogen from municipal waseewater are handled adequately under Sections
3
04.105 and
304,122 ofthe Board’s regulations.
Metropolitan Water Reclamation District
ofGreater chicago,
By:
~
Richard Lanyon, ~3rector ofR&D
February 15, 2002
Metropolitan Water Reclamation
District of Greater Chicago
100 East Erie
Chicago, Illinois 60611
312.751.5190
THIS FILING IS SUBMITTED ON RECYCLED PAPER
2
