Most Honorable Board Members:~
Fox ~
Water Reclamation District
~
682 State Route 31
•
Oswego,
Illinois 60543-8500
T.F. Muth, District Manager
(630) 892-4378
•
FAX (630) 892-4394
D.C. Ingemunson, Attorney
G.V. Griffin, Engineer
March 01, 2002
RECEIVE~
Illinois Pollution Control Board
CLERK’S omcr
Attn: Dorothy Gunn, Clerk
James R. Thompson Center
MAR 4
2002
100 West Randolph Street
Suite 11-500
STATE OF IWNOIS
Chicago, Illinois 60601
Pollution Control
Board
re: Docket
R02-1
1
My name is Thomas F. Muth and I am the District Manager for the Fox Metro Water Reclamation District
(Fox Metro). I have worked for Fox Metro (formerly the Aurora Sanitary District) since July, 1987..~.
Over the years Fox Metro has relied heavily upon working with and making recommendations based upon
analytica ciata tnat is, preferably, both as accurate and reliable as possible. With this understanding in mind,
Fox Metro supports the Illinois Environmental Protection Agency (Agency) proposal to amend 35,111. Adm.
Cofle 304.120 by add~nq~ Paragraph (g) which specifies that the five (5) day carbonaceous biochemical
oxJq~~r
.i..~manc CDOD~~st ~sthe analytical method ~ohe used forthe rileasureireni of biochemical oxygen
demanc.. in wastewater ~fflu~nts.
The Agency p~o’~o~at~ssign~ticantbecause it elim!p3tes the ambIg~Htywherth~ya-~ot~iriallyless reliable test
the five (5~daj oio~hernica~oxygen demand (BOD5 might be usea to measure the above referenced and
important parameter of wastewater treatment plant pertormance Agency test’r’~ion~previously submitted
January 29 2002 has detaded how ammonia nitrogen can be a potential interference in the BOD5 test
Interferences in test methods can leadto inconsistent, inaccurat~and/or unreliable results. The CBOD5.test
eliminates the potential interference by ammonia nitrogen and leads to more reliable data upon which
wastewater treatment plant design, performance evaluation and process control decisions can more
confidently be made.
The argument that the effluent discharge limits for biochemical oxygen demand should be lowered if the
CBOD~test
is
specfied for t3 measurement is
flCOS~S~.Gl~
‘,~it~iea~on Trii~argument is seemingiy
test.basedlfthisweretrue,upon
the assumptionthen
itwouldthat
ammoniaalso
standnitrogento reasonwas
meantthatthereôrimpliedis
no needto
betotestorhavedischargemeasured as partof the BODlimits5
for ammonia nitrogen as that parameter would already be accounted for in the BOD5 testl This, of course,
is unreasonable.
For manyyears now waterquality business professionals- hay Leerrusirrg-CBO05 data upon which to design
wastewater treatment plants analyzetheir performanceand make process control decisions Now isthe time
to officially recognize what has t5een professionally undéistood for all these years~ti attfreQBQO5 test be
the specifi~ctmethod formeasuring thebiochemical oxygen dem
nrwete~frè~t~rt
~ar~teftient-s-
~
ip~ j~~Y
~
SioQa~ely,u.
~
Thomas F. Muth
‘,4~
District Manager
Fox Metro Water Reclamation District
