RECEIVED

CLERK’S OF~1CE

MAR - 7 2002

Naperville

p~uon

Con

March

5,

2002

Illinois Pollution Control Board

~,

Attn: Dorothy Gunn, Clerk re Docket R02-1 1

James R. Thompson Center

100 W. Randolph Street

Suite 11-500

Chicago, IL 60601

Ladies and Gentlemen:

The City ofNaperville Department ofPublic Utilities requests that the following comments be

considered in support ofthe proposed amendment to

35

IL Adm. Code 304.120.

It was the original intent of the Illinois Control Board to regulate the carbonaceous BOD, rather

than total secondary wastewater treatment process. (This can be confirmed in the Board’s

records.) Total BUD measures only a small and variable component of nitrogenous oxygen

demand. The small portion it does measure, however, interferes with the universal application of

the test as a comparative measure ofthese processes.

In the 1970’s the USEPA required that secondary treatment processes be measured in total BUD

limits. The interference of nitrogenous oxygen demand has created-unresolvable problems with

such a use oftotal BOD. Consequently, in 1984 the USEPA authorized use of CBOD for

determination ofsecondary treatment process efficiency. At that time the IEPA began including

CBOD in Illinois NPDES permits and has continued to do so to date. The issue before the Board

is not intended to extend relief to discharges in the form ofa relaxed discharge standard. Rather,

the purpose is to eliminate the ambiguity associated with the existing terminology.

The City ofNaperville Department of Public Utilities urges the Board to proceed with this

proposed change to clarify this otherwise confusing regulation.

Sincerel

Allen

A

F. Panek, Assistant Director

Naperville Dept. of Public Utilities

ALP/gr305-02

CITY OF NAPERVILLE

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400 SOUTH EAGLE STREET

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P.O. BOX 3020

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NAPERVILLE, IL 60566-7020

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630/420-6111