1. RECEIVED

3017 North Eighth Street
Springfield, Illinois 62707
217-528-0491
TEL
217-528-0497
FAX
springcrek@aol.com E-MAIL
Board of Trustees
Lowell H. Fraim
President
Richard T. Ciotti
Vice President
Patrick A. Noonan
Clerk
James H. McGrath
Trustee
Darryl W. Harris
Trustee
Bruce Stratton
Attorney
Robert A. Alvey
Director/Engineer
Nancy S. Wimmer
Office Supervisor
Paul Ed Vehovic
Treasurer
0
MEMBER
IllinoiS Association of
Wastewater Agencies
RECEIVED
CLERK’S
OFP~
MAR 4
2002
-
STATE OF
LWNOLS
Pollution
Control Board
February 27, 2002
Illinois Pollution Control Board
Attn: Dorothy Gunn, Clerk, re: Docket R02-11
James R. Thompson Center
100 W. Randolph St.
Suite 11-500
Chicago, Illinois 60601
COMMENTS OF THE SPRINGFIELD METRO
SANITARY DISTRICT
The Illinois Environmental Protection Agency is proposing to
amend 35 Ill. Adm. Code 304.120 of the Board’s regulations by adding
a Paragraph (g) which specifies that compliance with the 5-day
biochemical oxygen demand (BUD5) numerical standard in Section
304.120 be determined by analysis of 5—day carbonaceous biochemical
oxygen demand.
The Sanitary District is in support of this proposed amendment
for the following reasons:
1. Historically the intent of all the regulations were based
Upon the measure of carbonaceous oxygen demand.
2. The BUD parameter is used as a measure of the efficiency
of wastewater treatment and was not intended to measure
the organic loading on the receiving stream.
3. The carbonaceous biochemical oxygen demand test as presented
in the Standard Methods for the Examination of Water and
Wastewater is the accepted norm used by most wastewater
agencies.
4. By accepting this amendment, there will be no relief or
relaxation of any standardof the Illinois Pollution Control
Board. This is just a clarification of what is being done
and reported at the present time.
SPRINGFIELD METRO SANITARY
DISTRICT
~p
Robert A. Alvey
~
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Director/Engineer

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