Board of’Trustees
Donald E. Eckmann
Downers Grove
President
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Staff
Lawrence C. Cox
General
Manager
Ralph E. Smith, Jr.
Operations Director
Sheila K. Henschel
Administrative
Services
Director
Wallace D. Van Buren
Vice
President
David J. Morrill
Clerk
March
5,
2002
Mane Tipsord, Attorney
Hearing Officer
Illinois Pollution Control Board
100 West Randolph, Suite 11-500
Chicago, IL 60601
Re: R02-11
Water Quality Triennial Review
Dear Ms. Tipsord:
The Downers Grove Sanitary Distnct submits the following comments in support ofthe
proposed amendment to
35
Ill Adm Code 304 120 The Illinois Environmental Protection
Agency has proposed to amend
35
Iii Adm Code 304 120 by adding a new paragraph (g) which
states that compliance with the 5-day biochemical oxygen demand (BOD5) standards in this
section will be determined by the analysis of5-day carbonaceous biochemical oxygen demand
(CBOD5). The District supports this proposed amendment and the written testimony ofMichael
Callahan, filedwith the Illinois Pollution Control Board on behalfofthe Illinois Association of
Wastewater Agencies, on this proposed amendment. As stated in Mr. Callahan’s testimony, this
amendment does not represent a relaxation ofeffluent standards but rather updates the
terminology in this regulation to reflect the current use ofthe CBOD5 test to measure the
performance and compliance oftoday’s wastewater treatment facilities.
The use of CBOD5 effluent limits was a topic of considerable controversy when it was
first proposed by the United States Environmental Protection Agency nearly twenty years ago. It
has now become the accepted compliance and performance measure in the wastewater industry.
The Downers Grove Sanitary District offers the following observations in support ofthis
statement.
The CBOD5 effluent limits first appeared in the District’s NPDES Permit No 1L0028380
issued by the Illinois Environmental Protection Agency on October 9, 1986, and it has appeared
in every permit issued since that date It is ourunderstanding that the United States
Environmental Protection Agency Region V has reviewed the NPDES permits issued to the
District, as the District is considered a major discharger. Prior to the issuance ofthe District’s
most recent permit on December 31, 2001, the Sierra Club submitted a letter to the Illinois
Member Illinois Association of Wastewater Agencies
Printed on Recycled Paper
MAR 112002
STATE OF IWNOIS
Pollution Control Board
Downers Grove,
IL 60515-0703
Phone: 630-969-0664
Fax: 630-969-0827
Providing
a
Better Environment for South Central DuPage County
Legal
Counsel
CLERK’S OFFfCE
Environmental Protection Agency concerning nutrient contributions and the detection limit for
cadmium. There was no reference in this letter to the CBOD5 effluent limits.
A search ofthe Illinois Pollution Control Board website for the term ‘CBOD’ resulted in
34 matches. Seven ofthose matches pertain to the current proceeding. Seventeen ofthose
matches involved provisional variance orders issued by the Board. Every one ofthese orders
involved CBOD effluent limits and the term CBOD was often used in the same sentence as the
reference to 35 Ill. Adm. Code 304.120.
The Downers Grove Sanitary District urges the Illinois Pollution Control Board to adopt
the proposed amendment to 35 Ill. Adm. Code 304.120(g).
Respectfully,
DOWNERS GROVE SANITARY DISTRICT
C’,
Lawrence C. Cox
General Manager
LCC/skh
