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GREATER PEORIA
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Illinois Pollution Control Board
Attn: Dorothy Gunn, Clerk, Docket R02-1 I
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Dear Board Members:
The Greater Peoria Sanitary and Sewage Disposal Districts supports the IEPAfiling to define the
BOD effluent standard specifically as carbonaceous BOD. This filing documents current practice
in applying the intent ofthe regulations to permits.
Effluent limits for carbonaceous oxygen demand have historically been interpreted and permitted
based on the CBOD test. The intent of this parameter is to determine and regulate treatment
plant performance in regards to carbonaceous oxygen demand. The BOD effluent parameter was
not intended to reflect any portion ofthe oxygen demand in converting ammonia nitrogen to
nitrate nitrogen. Effluent and water quality standard for all forms ofnitrogen are well
documented in other sections ofthe regulations.
The Illinois Environmental Protection Agency is commended fortheir initiative in filing this
document. Current permitting practicefollows the intent ofthe regulation and is well accepted by
the permitting, regulated and enforcement communities. This filing clearly defines current
interpretation ofthe intent ofthe regulation.
The Greater Peoria Sanitary and Sewage Disposal District requests your favorable consideration
ofthe Agencies filing.
Sincerely,
GREATER PEORIA SANITARY DISTRICT
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Stanton A. Browning
Executive Director
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February 28, 2002
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2002
STATE OF IWNOIS
Pollution Control Board
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2322 South Darst Street
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Peoria, Illinois 61607-2093
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Phone 637-3511
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Fax 637-6614