NORTH SHORE SANiTARY DISTRICT
BOARD OF TRUSTEES
KOEPSEL DR., GURNEE, ILLINOIS 60031
PRESIDENT JAMES E. SVVARTHOUT LAKE FOREST
TDD 847/623-6091
VICE PRESIDENT JOHN R. PAXTON, ZION
TREASURER
JOSEPH H. PASQUESI, LAKE FOREST
TRUSTEE MARK F HAWIS, WAUKEGAN
RE CE
kV ED
TRUSTEE
EDDIE WASHINGTON, WAUKEGAN
Cl ERR’S OFPCF
GENERAL MANAGER BRIAN JENSEN, PE.
SECRETARY DOROTHYA.BAKER
MAR 6
2002
ATTORNEY MURRAY H. CONZELMAN
STATE OF IWNOIS
March 5, 2002
pollution
Control Board
Illinois Pollution Control Board
Attn: Dorothy Gunn, Clerk, re Docket R02-1 I
James R. Thompson Center
100 West Randolph Street
Chicago, IL 60601
Re: Support for IEPA carbonaceous BOD proposal
To Whom It May Concern:
The North Shore Sanitary District (NSSD) appreciates this opportunity to submit the following
comments in support of the proposed amendment to 35 ILL. Adm. Code 304.120. The Illinois
Environmental Protection Agency (IEPA) is proposing to amend the regulations to specifically
recognize carbonaceous BOD (CBOD) as the effluent limit, which should be applied to NPDES
permits issued in Illinois
The CBOD test method was developed to eliminate the interference caused by ammonia
nitrogen within the standard BOD test Ammonia nitrogen when present, interferes by exerting
a nitrogenous oxygen demand when it is biologically converted to nitrate nitrogen by specific
bacteria. The CBOD method calls for the addition of a nitrification inhibitor, which prevents this
conversion from occurring within the test. The CBOD test is universally applied and is an
approved method supported by Standard Methods for the Examination of Water and
Wastewater.
The amendment as proposed would not extend relief to dischargers in the form of relaxed
standards because CBOD has been applied to NPDES permits within the State of Illinois for
over 10 years. The intent of this action is to remove the confusion resulting from the terms total
BOD and carbonaceous BOD (CBOD).
The proposed change would update the regulation to current terminology and practices
employed within this area of science. The inclusion of the total BOD test within NPDES dates
back to the 1970’s as a means for documenting secondary treatment plant efficiency. The
CBOD test evolved from the original BOO method in the mid-i 980’s, when the effects of the
interference were recognized. This timeframe was marked by the development of biological
nutrient removal technology within the wastewater treatment process field. The same forms of
ammonia converting bacteria utilized within the biological nutrient removal processes are
responsible for the nitrogenous oxygen demand within the BOO test The presence of the
ammonia converting bacteria within the treated effluents resulted in elevated total BOD test
results, which incorrectly indicated a loss of secondary treatment plant removal efficiency.
Therefore CBOD became the industry standard for the measure of efficiency of the secondary
treatment process.
WATER POLLUTION CONTROL FOR THE LAKE MICHIGAN AREA OF LAKE COUNTY, ILLINOIS
Potential concerns over ammonia nitrogen levels present within a wastewater treatment
process effluent are addressed elsewhere within the NPDES program under ammonia nitrogen
based limits and/or bioassay monitoring that encompasses ammonia toxicity.
Thank you for this opportunity to comment in support of the IEPA’s proposed amendments on
carbonaceous BOD. The District reserves the right to submit additional comments on any of
the amendments being considered herein at the close of testimony in the event the Board
authorizes such comments. The District appreciates your consideration of these comments
prior to make a decision.
Sincerely
7T
Brian Jensen
General Manager
NORTH SHORE SANITARY DISTRICT
WATER POLLUTION CONTROL FOR THE LAKE MICHIGAN AREA OF LAKE COUNTY, ILLINOIS
