RECEIVED

CLERK’S OFFICE

BEFORE THE ILLiNOIS POLLUTION CONTROL BOARD

JUN 202005

STATE OF ILUNOIS

Pollution Control Board

IN THE MATTER OF:

)

)

INTERIM PHOSPHORUS

EFFLUENT

)

R4-26

STANDARD, PROPOSED

35

ILL. ADM.

)

(Rulemaking

-

Water)

304.123 (G-K)

)

)

)

TO:

See Attached Service List

PLEASE

TAKE

NOTICE that on Monday, June 20, 2005, we filed the

attached

Comments ofthe Illinois Association of Wastewater Agencies

with the Clerk ofthe Illinois

Pollution Control Board, a copy ofwhich is herewith served upon you.

Respectfully submitted,

ILLINOIS ASSOCIATION OF WASTEWATER

//

.1

One ofIt

ttome

s

Roy M. Harsch

GARDNER CARTON & DOUGLAS LLP

191

N. Wacker Drive

-

Suite 3700

Chicago, Illinois

60606-1698

(312) 569-1441

THISFILING IS SUBMITTED ON RECYCLED PAPER

---

RECEIVED

CLERK S OFF~C~

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

JUN 202

5

STATE OF ILLINOIS

IN THE

MATTER

OF:

)

POII~ti~~

Control Board

)

INTERIM PHOSPHORUS EFFLUENT

)

R4-26

STANDARD, PROPOSED 35

ILL. ADM.

)

(Rulemaking

—

Water)

304.123 (G-K)

)

)

)

COMMENTS OF

THE

ILLINOIS ASSOCIATION OF WASTEWATER AGENCIES

Introduction

The Illinois Association ofWastewater Agencies (“lAWN’) appreciates the opportunity to

comment on the Illinois

Pollution Control Board’s (“Board’s”) proposed rule establishing a state-

wide effluent phosphorus standard.

IAWA has reviewed the Board’s discussion ofthe proposed

rule.

IAWA continues to oppose the rule for the reasons listed below.

Insufficient Justification for a State-wide Effluent Standard

IAWA believes that the record fails to provide sufficient justification for promulgation of a state-

wide phosphorus effluent standard.

The Board’s authority to promulgate effluent standards is

limited to known pollutants and must be coupled with a demonstration that economic treatment

technology is

available.

IAWA does not believe that the record in the matter contains evidence

that phosphorus is causing widespread pollution problems in the state of Illinois, or that

promulgation ofthe proposed phosphorus effluent standard will have a measurable impact on

eutrophication.

The record does contain discussion ofthe role ofphosphorus as one ofthe two major nutrients in

the aquatic environment.

When phosphorus is present in excess and a number ofother

conditions are present, eutrophic conditions can develop.

Eutrophic conditions may or maynot

be an environmental problem depending on the presence or absence ofother conditions, such as

low reaerationrates.

No one in this proceeding has provided evidence defining the extent that

elevated levels ofphosphorus are causing environmental problems.

The Illinois Water Quality Report

(“305(b)

Report”) as prepared by the Illinois Environmental

Protection Agency (“Agency”) does list many stream segments as being impaired due to

phosphorus.

This listing

is not based on an onsite determination ofcause and effect.

It is based

on statistical guideline that was set at the

85th

percentile ofstatewide Ambient Water Quality

Monitoring Network (“AWQMN”) data.

Any stream segment that has a few sample results

above this concentration will be listed as impaired due to phosphorus. While the approach has

---

some value in identifying streams where phosphorus may be a concern, it can not be considered

evidence that these elevated levels ofphosphorus are causing environmental problems.

Therefore, the 305(b) Report can not be used asjustification for a state-wide phosphorus effluent

standard.

No Need to Shortcut a Science-Based Approach

It seems that all parties in this matter agree that the proposed phosphorus effluent

standard is not

science-based.

The Agency with the Illinois Nutrient Work Group is in the midst ofa multi-year

undertaking to develop science-based water quality standards.

IAWA does not believe the

record in this matter documents an urgent need to short cut the science-based approach that is

already under way.

Proposed Phosphorus

Reductions are Insii~nificant

The proposed rule will have very limited impact on the total amount ofphosphorus entering the

aquatic environment.

Agricultural sources are also major dischargers ofphosphorus.

In many

areas there are also

significant natural sources of phosphorus in Illinois soils.

On a regional or

statewide basis the proposed interim effluent standard will not noticeably reduce phosphorus

concentrations in Illinois streams.

No Daily Maximum Limit

Ifthe Board does proceed with establishing a phosphorus effluent standard, it should exempt the

standard from the Averaging Rule

(35

JAC 304.104

(a) (2)

& (3)).

The proposed effluent

standard of 1.0 mg/I will be implemented as a monthly average limit in NPDES permits.

The

Averaging Rulewill also require the Agency to place in NPDES permits

a daily maximum limit

of2.0 mg/l.

A daily maximum limit is both unnecessary and undesirable.

A daily maximum limit is not needed sincephosphorus is not a toxic parameter.

Daily

maximum effluent limits are typically related to acute toxicity levels ofpollutants.

They are

designed to prevent short term discharges ofhigh levels ofpollutants that would lead to acute

toxicity in the aquatic environment.

While this is appropriate for toxic pollutants, it is not

appropriate forphosphorus.

Phosphorus is a nutrient and is not toxic.

Ifthe intent ofthis rule it

to

force the use ofwhat the Board considers to be available technology, a monthly average

effluent limit, without a daily maximum limit, will accomplish that end.

A daily maximum limit is undesirable as it will discourage the use ofbiological phosphorus

removal technology (“BPR”).

BPR is a complex biological process that relies on a sequence of

conditions to encourage the luxury uptake ofphosphorus.

Ifany number ofconditions are not

present, the process will not function at optimum levels.

As a result, this process produces a

more variable effluent.

2

---

The Board should encourage the use ofBPR over chemical phosphorus removal.

Chemical

phosphorus removal is a more resource intensive process.

It requires the manufacture ofa

chemical and transportation ofthe chemical to

treatment facilities. It also leads to the creation of

additional sludge, which must be processed and then transported to the final disposal site.

Each

ofthese additional functions are energy intensive; energy consumption has both air and water

quality consequences and requiring such should be carefully evaluated.

The State of Wisconsin has allowed an exemption even to the monthly average limit forplants

using BPR.

See Wisconsin Administrative Code NR2 17.04 (2) included as Attachment

1.

Note

that the State ofWisconsin has never proposed a daily maximum limit, even for Great Lakes

dischargers.

The presence ofa daily maximum phosphorus limit will discourage the use ofthe most

environmentally favorable option formeeting the phosphorus effluent standards.

Ifthe Board

decides to promulgate a phosphorus effluent standard, IAWA recommends the following

addition to the rule since phosphorus is not a toxicant:

g) (4) Monthly average permit limits established under this subsection (g) are not subject

to the averaging rules under subsections (a)(2) and (a)(3) ofSection 304.104.

Economic Reasonableness

IAWA believes the economic impact ofthe proposed rule has been seriously underestimated.

We have obtained construction cost estimates for two recent plant improvement projects that

included the upgrade to phosphorus removal.

The Village ofBeecher is expanding its plant to

1.2 million gallons per day (“MGD”).

The cost

of chemical phosphorus removal includes a chemical

feed building, equipment, electrical and

controls for a total of$288,000.

This does not include the cost to handle the increased sludge

production, which is estimated to comprise 20

ofthe total sludge volume

for this plant.

The

cost for sludge handling (digester, storage building modifications

and belt press) is $892,800.

The 20

attributable to phosphorus removal is $178,600.

This makes the total capital cost for

phosphorus removal $466,600

for a 1.2 MGD plant.

The City of McHenry’s South plant

is expanding to

1.5

MGD. This expansion is one ofthe first

projects affected by the anticipation ofthe proposed rule, and has now entered the construction

phase.

The cost ofthe chemical feed equipment and building, including electrical and controls,

reflected

in the engineer’s pre-bid estimate, was $350,000, which is in line with the cost at

Beecher. The engineer’s total pre-bid estimate for the expansion project was 3 percent above the

lowest bid received in April 2005. The impact on sludge processing at McHenry has not been

established and is not reflected in the above figure. Furthermore, the chemical storage capacity

and the size ofthe chemical feed building were governed by the capacity ofchemical delivery

trucks,

not by the projected consumption ofthe chemical. Consequently, the McHenry South

estimate provides an indication ofthe capital cost ofadding chemical phosphorus removal to

the

smallest plants in the range targeted by the proposed rule when a new chemical feed building is

required but sludge processing capacity is sufficient.

3

---

Based on recent facilities planning at a 30 mgd Lexington, Kentucky WWTP, the total costs for

BPR and chemical phosphorus removal (“CPR”), including the impact on sludge processing and

anticipating a

1

mg/L phosphorus limit, were as follows based on a 20 year presentworth

analysis:

BPR

CPR

Initial Capital Costs

$10,092,000

$4,286,000

Operation and Maintenance Costs

$1,625,000

$11,455,000

Equipment Replacement Costs

$457,000

$205,000

Total Present Worth

12,174,000

$15,946,000

Costs for several Wisconsin facilities studied during the Rock River phosphorus total maximum

daily load pilot project (2000) have been updated to 2005 costs and are presented in the attached

graphs.

The capital costs presented above for Beecher, McHenry and Lexington are consistent

with the attached graph.

These costs are dramatically different from those referenced by the

Board.

The Board’s decision was erroneously based upon an estimate ofthe capital cost forphosphorus

removal of$35,000 as quoted in the First Notice Opinion.

Based on the information presented in

these comments, the actual costs will be ten times that amount forplants in the one to five MGD

range and four times that amount forplants above 30 MGD.

For CPR, the capital cost is only a

fraction ofthe total 20

year present worth cost.

Forplants with a capacity ofone ortwo MGD

using CPR, it appears that the 20 year presentworth including sludge processing and disposal

will be $600,000 to $1,000,000.

Conclusion

JAWA continues to oppose the proposed interim phosphorus effluent standard.

In our opinion,

the record in this matter does not support the establishment ofa state-wide effluent standard for

phosphorus for the following reasons:

•

A demonstration has not been made ofa state-wide water pollution problem due to

phosphorus induced eutrophication.

•

There is no need to shortcut a science-based water quality standard for phosphorus

currently underway.

•

The proposed rule will only decrease ambient levels ofphosphorus an insignificant

amount.

•

The anticipated costs ofcomplying with the proposed rule are unreasonable

in light ofthe

magnitude ofprojected benefits.

•

The cited costs ofcomplying with the proposed rule understate the actual costs by

between a factor of4 to

10 times.

4

---

ATTACHMENT

NO.

1

---

150—3

NIL

NR 217.04

Unofficial

Text (See Printed Volume).

Current through date and

Register shown

on

Chapter NR 217

EFFLUENT STANDARDS AND LIMITATIONS

NR 217.01

Purpose.

NR 217.02

Applicability.

MR 217.03

Definitions.

NR 217.04

Effluent standards and limitations forphosphorus.

Note:

Effluent standards are beingcreated

for phosphorus at this time.

Effluent

standards

forother pollutants may be added to this chapterat later dates.

Note:

Corrections made under s.

13.93

(2m) (b) 7.,

Stats., Registei

August,

1997,

No.

500.

NR 217.01

Purpose.

The

purpose of this chapter is to re-

duce

the

amountof pollutants dischargedto surface waters by

es-

tablishing effluent standards and limitations for pollutants

in

ef-

fluentdischarged

to

surfacewaters of

the

state. Effluent standards

and limitations are adopted pursuant to ch.

283,

stats.

History:

Cr. Register, November,

1992, No.

443, efl~

12—1—92.

NR 217.02

Applicability.

This

chapter

is

applicable

to

point sourceswhichdischarge wastewaterto

the

surface waters of

the

state.

History:

Cr. Register, November,

1992, No.

443, eff.

12—1—92.

NR

217.03

Definitions.

Defmitions

of

terms and

the

meaningofabbreviationsused inthis chapterareas definedinchs.

NR 102,

106,

205,

210

and 243. In addition:”effluent standard”

means any requirement

for a specific pollutant

applicable to a

category or class of point sourceswhich are more stringent than

the requirements under s. 283.13 (1) to (4), Stats.

History:

Cr. Register,

November,

1992, No. 443, e11

12—1—92.

NR

217.04

Effluent

standards

and

limitations

for

phosphorus.

(1)

GENERAL.

Effluent

limitations

fortotal

phos-

phorus

shall

be

imposed in WPDES permits for wastewatersdis-

charged to surfacewaters as

specified

in this section.

(a)

An

effluentstandard for totalphosphorus shall applyas fol-

lows:

1. Aneffluentlimitation equal

to

I mg/L totalphosphorus as

amonthly averageshall applyto publicly ownedtreatmentworks

and privately owned domestic

sewage works subject to

ch. NR

210

which

discharge

wastewater

containing

more

than

150

pounds oftotal phosphorusper month, unless an alternative limi-

tation is providedunder sub. (2).

2. Aneffluentlimitation equal to

1 mg/L total phosphorus as

a monthly

average shall

apply in cases where the discharge of

wastewater from all outfalls of afacility other than those subject

to ch. NR 210 containsacumulative totalof more than 60 pounds

of total phosphorus per month, unless an alternativelimitation is

providedunder sub. (2). Outfalls consisting ofnoncontact cooling

water without phosphorus

containing additives

may

not be in-

cluded in the calculation of the cumulative total of phosphorus

discharged from thefacility. Compliance with

theconcentration

limit shall be determined as a rolling 12 month averageas deter-

mined by thetotalphosphorus from all outfalls subjectto theefflu-

ent limitation for the most recent 12 months divided by the total

flow for all those outfalls for thesame period.

3.

Effluent limitations for phosphorus

equal

to

1

mg/L

as a

monthly average containedin permits on December 1,

1992 shall

remain in effect.

4.

Effluent limitations for phosphorus equal

to

85

removal

of influent concentrations of phosphorus containedin permits on

December 1,

1992 shall be modified

to

1

mgJL total phosphorus

as amonthly

averageupon reissuance ofthe permit unless anal-

ternative limitation is provided under sub. (2).

5.

Runoff

to

surface waters

from animal feeding operations

shallbe controlledusing bestmanagementpracticesto achievethe

purpose ofthis chapter pertaining to phosphorus.

6.

The

department shall determineifapermittee is discharg-

ing more than the applicable threshold valuespecified in subd.

1.

or 2. by examiningavailabledataon orrequiringmonitoringofthe

amount of phosphoruscontainedin the wastewater effluent. Such

data

shall

be

representative of the amount

of phosphorus con-

tained in the wastewater effluent during periods of discharge or

operation.

Note:

The threshold valuesofthis section will beapplied at thetime ofWPDES

permit reiseuance orpermit

modification which may

occurdue to changes in waste

characteristics.

Note:

See NR 102.06 in reference to water quality standards.

(2)

ALTERNATIVE

EFFLUENT

LIMITATIONS

TO

THE

EFFLUENT

STANDARD FOR PHOSPHORUS.

(a)

Permitteessubject to sub. (1) (a)

1., 2., or 4. may requestan alternativeeffluent limitation for total

phosphorus ifone or more of the following apply:

1.

A perniitteemay requestan alternative effluentlimitation

in cases where achieving the I

mg/L total phosphorus

effluent

standard is notpractically achievable.

a.

A permittee requesting an

alternative effluent limitation

under this subdivision shall provide, as apart oftheWPDES per-

mit process, information whichdemonstrates thatthe 1

mg/L total

phosphorus effluentstandard is notpracticallyachievable andin-

formationnecessary for thedepartmentto establishan alternative

effluentlimitation. Theinformation provided shallinclude butnot

be limited to the following: theresults ofacomprehensive phos-

phorus mislimi7ation study to determine the sourcesof phospho-

rusto thewastewater, an evaluation ofpossiblemethods toreduce

thesourcesof phosphorus

to

the wastewater, adescriptionof ac-

tions

implemented to

reduce the

sources of phosphorus

to the

wastewater. In addition, the permittee shall provide data on

the

phosphorus concentrations intheinfluent

to

andeffluentfrom the

wastewater treatment facilities which areachievable after phos-

phorus

minimization steps

have been implemented,

alternative

treatment technologies whichmay

be employed to achieve the

1

mg/L effluentstandard, andtheir associated removal efficiencies

and costs and therequested alternativeeffluent limitation.

b. Thedepartment shall review requests andtheinformation

providedby permitteesandmay establishalternative effluentlim-

itations to theeffluent standard imposed under sub. (1) (a)

1., 2.

or 4. wherethis standard, in thebest professionaljudgment ofthe

department, is not practically achievable. For these cases, thede-

partment shall establish an alternative eflluent limitation consid-

ering the effluentquality achievable with theapplicationof treat-

ment

technologies,

process

changes,

and

phosphorus

minimization

steps

to

reduce the amount of phosphorus to

the

maximum extentpractically achievable taking into accountener-

gy, economic andenvironmental impacts.

2.

A permitteemay requestan alternative effluentlimitation

in cases wheretheoperationof specificbiological phosphorus re-

moval technologies will achieve a level ofperformance equiva-

lent to a 1 mg/L effluentstandard. Systems whichemploy biologi-

cal phosphorus removal technology shall result in theremoval of

not less than 90

of thephosphorus whichwould be removed by

achieving the

1

mg/L

total phosphorus effluent standard

based

upon a mass determination.

Register, August, 1997, No. 500

---

NR217.04

WISCONSINADMINISTRATIVE CODE

150—4

Unofficial Text (See Printed Volume).

Current through date and Register shown on Title Page.

a.

A pennittee requesting

an alternative effluent limitation

under this

subdivision shall, as a part ofthe WPDES permit ap-

plication process, provide

information

whichdemonstrates that

achieving therequested alternative effluentlimitation using bio-

logical phosphorusremoval willachieve thisrequirement. Thein-

formation shall include dataon thetotal mass of phosphorus dis-

charged

using

biological

removal

with

and without

chemical

polishing andthetotal mass ofphosphorus dischargedusing treat-

ment technologies to achieve the

1 mg/L effluentstandard andthe

information necessary for thedepartment to establish an alterna-

tive effluent limitation.

b.

The departmentshall review requests and theinformation

providedbypermittees andmay establish alternativeeffluentlim-

itations to theeffluent standard imposed under sub. (1) (a)

1., 2.,

or 4. wherethe alternativelimitation, inthe best professionaljudg-

ment ofthedepartment, will resultin insignificant differences in

theamount ofphosphorus discharged, on amass basis, compared

to themass whichwould be dischargedby achievingthe I mg/L

total phosphorus effluent standard. For

these

cases,

the depart-

ment shall establish an alternativeeffluent limitation considering

theeffluent quality

achievable with the applicationof biological

phosphorus

removal

technologies, taking

into

account the total

phosphorus removal performanceon amassbasis. Thealternative

effluent limitation established by the department under this sub-

paragraph may not exceed2 mgILas amonthly average.

3.

A permitteemay request an alternativeeffluent limitation

in cases wherephosphorus—deficient wastewaters necessitatethe

addition ofphosphorus to abiological treatmentsystem

to

assure

efficientoperationandcompliance withother effluentlimitations.

a.

A permittee requesting

an

alternative effluent limitation

under this subdivision shall, as apart of the WPDES application

process, provide information which demonstrates that achieving

the I mgfLtotal phosphorus effluent standard is not practically

achievable andtheinformation necessaryfor thedepartment to es-

tablish

an

alternative effluent limitation.

The information pro-

videdshall include but not be limited to the following: theresults

ofa comprehensive phosphorus minimization study to minimize

theamountofphosphorus dischargedwhileallowing efficientop-

eration of the wastewater treatment system, a description of ac-

tions

implemented

to

reduce

the

amount

of phosphorus

dis-

charged, thephosphorus effluentconcentrations achievable after

phosphorus minimi7~tionsteps have been implemented, the re-

moval efficiencies andcosts associatedwith alternativetreatment

technologies

whichwould be necessary

to

achieve the

1

mg/L ef-

fluentstandard andthe requested alternative limitation.

b.

Thedepartment shall review requests and theinformation

provided by thepermittee and may establish alternative effluent

limitations to theeffluent standard imposed under sub. (1) (a) 2.

where this standard, in thebest professional judgment of the de-

partment, is not practicallyachievable. The department shall es-

tablish an alternativeeffluentlimitationconsideringtheminimum

phosphorus

effluent quality

achievable

while allowing

efficient

operationof thewastewater treatmentsystem. Thealternativeef-

fluentlimitation establishedby thedepartmentunder this subdivi-

sion may not exceed 2 mgIL as amonthly average.

(b)

Permittees subject

to

sub.

(1) (a)

1. or 2. whichdo not dis-

charge their effluent into the basins oftheGreat Lakes or theFox

(Illinois) river may request an alternative effluent limitation

for

total phosphorus according to theprovision

ofthis paragraph.

1.

A permitteemay request an alternativeeffluentlimitation

under thisparagraph in cases whereachievingthe

1

mg/L effluent

standard

would not result in an environmentally significant im-

provement in water quality andmaterial progress towards theat-

tainment and maintenance of

associated surface

water quality

standardsfor the receiving wateras established in chs. NR

102 to

104.

2.

A permittee requesting an alternative effluent limitation

under this paragraphshall propose for thedepartment’sapproval

astudy plan to identify thereceiving waters affected orpotentially

affected by the discharge, describe how information

will be ob-

tained

to

justify an alternativeeffluent limitation under this para-

graph, and provide the informationnecessary to establish interim

and alternative

effluent limitations under

this

paragraph.

This

study plan shall be submitted as a partoftheWPDES permit ap-

plication process. Theresults ofthe study shall include an evalua-

tion of all point and non—point sources of phosphorus in the wa-

tersheds

and

the

impacts

of the phosphorus

contributions

on

biological andchemical waterquality conditions. Uponreviewof

thestudy plan, the departmentmay require additional information

as deemed necessary andmay expand the study to include other

watersheds or portions thereofthatmay be significantly impacted

by the permittee’sdischarge of phosphorus.

3. The department may establish an alternativeeffluent find-

tation where, in the best professionaljudgmentof the department

and based upon the information provided

by

the permittee pur-

suant

to

the study plan and otherrelevant information, achieving

theeffluentstandard under sub. (1) (a)

1. or 2. would notresultin

an environmentally significantimprovement inwaterquality and

material

progress

towards the attainment of associated surface

waterquality standards for thereceiving waterbody as established

inchs.NRlO2to

104.

4. Aninterim effluentlimitation andcompliance schedule for

completing thestudy shall beimposed in apermituntil therequest

for an exemption from the

1

mg/L effluent standard is approved

or denied. Theinterim effluentlimitation shall be equal to therep-

resentative concentration oftotal phosphorus as a monthly aver-

age in theeffluent based on the information provided by theper-

mittee as apart of theWPDES permit application process.

5.

Alternative effluentlimitations established underthis para-

graph may not exceedthe interim effluent limitation established

under subd.

4.

(3)

ANALYTICAL

METHODS

AND

LABORATORY

PROCEDURES.

Methods used

for analysis of influent andeffluent samples shall

be as described in ch. NR 219 unless alternativemethods arespe-

cified in theWPDES

discharge permit.

(4)

COMPLIANCE.

Thedepartment shall determineandspecify

areasonable compliance schedule in thepermittee’sWPDES per-

mit ifthe facility isunable tomeet the effluent standard or limita-

tions determined according to this section at the timeofpermitis-

suance or reissuance.

Thedate for compliance with

this section

may not extendbeyond 3

years from the date ofpermit issuance

or

reissuance,

unless

the department

determines

that circum-

stances beyond thepermittee’s control, such as an environmental

impact statement, require additional time for compliance. In such

circumstances, thedate for compliance with this section may not

extendbeyond

5

years from the date of permit issuance or reis-

suance.

(5)

DEPARTMENT

DETERMINATIONS.

Effluent

standards

and

limitations established under subs. (1) (a) and (2) arenot subject

to

thevariance procedure under s. 283.15, Stats.

History:

Cr. Register,

November, 1992, No. 443, eff.

12—1—92.

Register, August, 1997, No.

500

---

ATTACHMENT

NO.

2

---

Attachment 2

—

Cost graphs for Wisconsin facilities studied as part ofthe Rock River

phosphorus pilot project, 2000.

$10,000,000

$1,000,000

$100,000

$10,000

Case

History P

Removal Capital

Costs

0.1

POTW DAF,

mgd

.CPR1

•

BPR

Case History P Removal O,M&R Costs

0

5

10

15

20

References:

RockRiver POTWWatershed Group Summary of Watershed Studies

by Earth Tech

and Strand Associates, Inc., 2000;

and

To BPR orNot To BPR,

That is the Question: A

10

0

0

c~1

U)

0

C.)

U)

0.

U)

C.)

1

10

100

$300,000

~

$250,000

0

~

$200,000

$150,000

~

$100,000

o

$50,000

$0

I.

CPR~

• BPR

POTW

DAF,

mgd

---

Comprehensive Comparison ofPhosphorusRemoval Technologies

presented to the Central

States Water Environment Association Annual Meeting by Troy A. Larson, Strand

Associates, Inc., May 2005.

---

CERTIFICATE OF SERVICE

The undersigned certifies that a copy of

the foregoing Comments of the Illinois

Association ofWastewater Agencies were

filed by hand delivery with the Clerkofthe Illinois

PollutionControl Board and served uponthe parties towhom saidNotice is directed by firstclass mail,

postage prepaid, by depositing in the U.S. Mail at

191 NorthWacker Drive, Chicago, Illinois on

Monday, June 20, 2005.

SEE ATTACHED SERVICE

LIST

---

SERVICE

LIST

Sanjay K. Sofat

Assistant Counsel

1021 North Grand Avenue East

P.O. Box

19276

Springfield, IL

62794-9276

Matthew J. Dunn, Chief

Office ofthe Attorney General

Environmental Bureau

188 West Randolph Street

20th

Floor

Chicago, IL

60601

Robert A. Messina

General Counsel

Environmental Law &

Policy Center

3150

Roland Avenue

Springfield,

IL

62703

Albert F. Ettinger

Environmental Law &

Policy Center

35

East Wacker Drive

Suite 1330

Chicago, IL

60601

John McMahon

Wilkie

& McMahon

1

East Main Street #214

Champaign,

IL

61820-3615

William Richardson,

General Counsel

Department ofNatural

Resources

One Natural Resources Way

Springfield,

IL

62702-1271

Richard Lanyon

Director ofResearch

& Development

Michael G. Rosenberg

Metropolitan Water Reclamation

of Greater Chicago

100

E. Erie

Chicago, IL

60611

David Horn

Asst. Prof., Biology

Aurora University

347 GladstoneAvenue

Aurora, IL

60506

Darin Boyer

City ofPiano

17 E. Main Street

Piano, IL

60545-1521

Dorothy M. Gunn

Illinois Pollution Control Board

100 W. Randolph St.

Suite 11-500

Chicago, IL

60601

R04-26