WATER QUALITY AMENDMENTS TO
    35
    Iii. Adm. Code 302.208(e)-(g), 302.504(a)
    302.575(d),
    303.444, 309.141(h); and
    PROPOSED
    35
    Iii. Adm. Code 301.267
    301.313, 301.413, 304.120, and
    309.157.
    RECEIVED
    CT
    F~’S OFFICE
    APR 152002
    NOTICE OF FILING
    Dorothy Gunn, Clerk
    Illinois Pollution Control Board
    100. West Randolph Street
    Suite 11-500
    Chicago, Illinois 60601
    Matthew Dunn
    Illinois Attorney General’s Office
    Environmental Control Division
    James R. Thompson Center
    100 West Randolph Street
    Chicago, Illinois 60601
    Marie B. Tipsord
    Illinois Pollution Control Board
    100 West Randolph Street
    Suite 11-500
    Chicago, Illinois 60601
    Legal Service
    Illinois Department ofNatural Resources
    524 South Second Street
    Springfield, Illinois 62701-1787
    PLEASE TAKE NOTICE that I have today filed with the Office ofthe Clerk ofthe
    Pollution Control Board the WRITTEN COMMENT OF THE ILLINOIS ASSOCIATION OF
    WASTEWATER AGENCIES, a copy ofwhich is served upon you.
    ILLINOIS ASSOCIATION OF WASTEWATER AGENCIES,
    By:
    ‘bne ofIts Attorneys
    0
    Sheila H. Deely
    Roy M. Harsch
    GARDNER CARTON & DOUGLAS
    321 North Clark Street
    Chicago, Illinois 60610
    (312) 644-3000
    Dated: April
    15,
    2002
    IN THE MATTER OF:
    BEFORETHE ~
    ~èL~-I3F
    ~LLlNOIS
    Pollution Control Board
    )
    )
    )
    )
    )
    R02- 11
    Rulemaking-Water
    TIllS FILliNG
    PRINTED ON RECYCLED PAPER
    ~i~ECEIVED
    CT FRK’S OFFICE
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    APR 1
    5
    2002
    IN THE MATTER OF:
    Pollution
    S~ti~FEOF
    Control
    ILLINOIS
    Board
    WATER QUALITY AMENDMENTS TO
    )
    35 Ill. Adm. Code 302.208(e)-(g), 302.504(a)
    )
    R02-1 1
    302.575(d), 303.444, 309.141(h); and
    )
    Rulemaking-Water
    PROPOSED 35 Ill. Adm. Code 301.267
    )
    301.313, 301.413, 304.120, and 309.157.
    )
    WRITTEN COMMENT OF THE
    ILLINOIS ASSOCIATION OF WASTEWATER AGENCIES
    The Illinois Association ofWastewater Agencies (IAWA), submits this written comment
    to the Illinois Pollution Control Board (Board) in support ofa component ofthe proposal made
    by the Illinois Environmental Protection Agency (Agency) in PCB R02-11.
    The IAWA endorses the Agency’s reconmiendation to change the term designating the
    oxygen demand ofwastewater treatment effluents from the term five
    (5)
    day biochemical oxygen
    demand to five
    (5)
    day carbonaceous biochemical oxygen demand (CBODS5). Contrary to the
    assertions ofthe environmental groups at the second hearing in this matter, the IAWA believes
    that the change is not a mechanism to relax existing effluent standards. Rather, it is an attempt to
    more clearly define the wording and terminology ofthis existing regulation, in accordance with
    the Board’s historical intent. The accuracy ofthe BOD5 test has always been a problem because
    ofthe variable contribution ofthe nitrogenous BOD5, to the point that the BOD5 test is of limited
    value. From a performance measure, compliance measure, and from an historical regulatory
    perspective, CBOD5 is the appropriate test for wastewater discharges.
    IAWA urges the Board to adopt the rule as proposed. Concerns regarding ammonia
    toxicity are properly addressed by Sections 304.105 and 304. 122 ofthe Board’s regulations,
    which are currently the subject ofa rulemaking before the Board.
    See In the Matter ofProposed
    Amendments to the Ammonia Nitrogen Standards,
    35 Ill. Adm. Code 302.212, 302.213, 304.122,
    R02-19. As for concerns about ammonia from a nutrient standpoint, this should be addressed
    when the United States Environmental Protection Agency issues a new National Criteria
    Document and the Board is presented with consideration ofthe adoption ofa new standard.
    Finally, concerns with the individual impact on streams are properly addressed through the Total
    Maximum Daily Load process on stream reaches. This is not an appropriate issue in this
    proceeding.
    In the prior testimony ofMichael Callahan on behalfofIAWA concerning the change
    from BOD to CBOD, which was presented at the hearing on March 6, 2002, Mr. Callahan
    referenced testimony and other materials by Dr. John Pfeffer in the R71-14 proceeding. At that
    hearing, the Board asked IAWA if it could locate a copy ofthat material. After a thorough
    search by the Bloomington and Normal Water Reclamation District, counsel for IAWA Gardner
    Carton and Douglas, and other sources, IAWA has not been able to locate this material.
    IAWA also requests that the Board adopt the change to dissolved metals from the current
    total metals for the reasons presented by the Agency and as further supported by the Galesburg
    Sanitary District in the Testimony ofSteven E. Davis, District Superintendent ofthe Galesburg
    Sanitary District (GSD). As testified to by Mr. Davis, GSD, the DeKaib Sanitary District, and
    other publicly owned treatment works are currently experiencing difficulty in meeting the permit
    limits derived from the total metals discharge limitation, and are in need offinal adoption of
    these rules. Dissolved metals are a better representation ofthe biologically active portions of
    metal.
    The IAWA appreciates this opportunity to provide comment in this proceeding.
    CHO2/22 182997.1
    CERTIFICATE OF SERVICE
    The undersigned certifies that a copy of the foregoing WRITTEN COMMENT OF THE
    ILLINOIS ASSOCIATION OF WASTEWATER AGENCIES was filed by hand delivery with the
    Clerk of the Illinois Pollution Control Board and served upon the parties to whom said Notice is directed
    by first class mail, postage prepaid, by depositing in the U.S. Mail at 321 North Clark Street, Chicago,
    Illinois on Monday, April 15, 2002.
    CHO2/22183556.1
    Mike Callahan
    Bloomington Normal Water Reclamation District
    P.O. Box 3307
    Bloomington, IL 61702-3307
    Dennis Duffield
    Department ofPublic Works City ofJoliet
    921 E. Washington Street
    Joliet, IL 60433
    Lisa M. Frede
    Chemical Industry Council
    9801 W. Higgens Rd,
    -
    Suite
    515
    Rosemont, IL 60018
    James T. Harrington
    Ross &Hardies
    150 North MichiganAvenue
    Suite 2500
    Chicago, IL 60601
    Katherine Hodge
    Hodge Dwyer Zeman
    3150 Roland Avenue
    Springfield, IL 62705
    Robert A. Messina
    Illinois Environmental Regulatory Group
    215 East Adams Street
    Springfield, IL 62701
    Irwin Polls
    Metropolitan Water Reclamation District Of Chicago
    6001 West
    Cicero, IL 60804
    Marie Tipsord
    Attorney, Pollution Control Board
    100 West Randolph, Suite 11-500
    Chicago, IL 60601
    Larry Cox
    Downers Grove Sanitary District
    2710 Curtiss Street
    Downers Grove, IL 60515
    Albert Ettinger
    Environmental Law & Policy Center
    35 E. Wacker Drive
    -
    Suite 1300
    Chicago, IL 60601
    Dorothy Gunn
    Clerk, Pollution Control Board
    100 West Randolph
    -
    Suite 11-500
    Chicago, IL 60601
    Ron Hill
    Metropolitan Water Reclamation District
    100 East Erie
    Chicago, IL 60611
    Margaret P. Howard
    Hedinger & Howard
    1225 S. Sixth Street
    Springfield, IL 62703
    Tom Muth
    Fox Metro Water Reclamation District
    682 State Route 31
    Oswego, IL 60543
    Sanjay Sofat
    Illinois Environmental Protection Agency
    1021 North Grand Avenue East
    Springfield, IL 62794-9276
    R02-1 1 Service List
    Water Quality Triennial Review
    April 15, 2002
    CHO2/22183569.1

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