December 15, 2006
Illinois Pollution Control Board
Attention: Clerk
100 W . Randolph
James R
. Thompson Center
Suite 11-500
Chicago, Illinois 60601
and via fax 312-814-3669 ; 2pages
ORIGINAL
. .
Re:
PCB 06-17
Public Comment on American Bottom Conservancy Appeal of NPDES Permit
Horseshoe Lake / Canteen Lake, Madison County, Illinois
Since moving to Madison County nearly twenty years ago, I have frequented Horseshoe
Lake State Park for a variety of purposes .
Recently, I have observed increased access to
the Lake via the bike trail that actually runs on an abandoned
railroad right-of-way
through GCS's facility property .
Several years ago, I was involved as an environmental consultant in the acquisition of
Canteen Lake by a private party . The surface waters of the two lakes are interconnected
.
The State had interest in acquiring the property but decided that it was too
'contaminated" and throughout the environmental assessment process was the concern of
GCS's wastewater discharges into the Lakes' water system.
While I am happy for my
clients in acquiring the property, fact is, Illinois citizens lost access to this unique
resource.
Over the years, I have been involved with the preparation and
review of National
Pollutant Discharge Elimination System (NPDES) permits .
In recent years, I have
noticed that the principle purpose of the permit, to
eliminate the discharge of pollutants,
is seemingly being lost. Rather than leading toward the elimination
of pollutant
discharges, they are being manipulated as an accepted manner to dispose of wastes into
the waters of the State .
One way this is done is to use connected water resource units (surface water and/or
groundwater) to in effect dilute the wastes to meet NPDES standards
. In some cases, the
primary use of the water resources becomes the dilution of wastes, before the wastes are
discharged back into the connected water resources units .
Dilution
is
not an accepted
environmental management of wastes .
Usually, this management involves some sort of
"passive treatment" of wastewater, identified as a friendly sounding "artificial wetlands
."
But little of the wastes' pollutants are actually removed from the environment
. Rather,
the holding of the wastes allows the wastes to be diluted before being discharged
to
surface waters or leaching into the underlying groundwater
.
Typically, NPDES permits are reviewed looking at the concentrations of pollutants being
discharged into the waters "mixing zone ."
This is a concept of diluting wastewaters and
RSCEIVED
CLERK'S
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Horseshoe Lake, Madison County, Illinois
NPDES Permit Public Comment
PCB 06-171
December 15, 2006
Page 2 of 2
is evident even to the casual observer . To properly evaluate the permit, the "treatment"
of the wastewaters needs to be considered as to whether the
elimination of pollutant
discharges to (connected) water resources is being promoted by the permit
.
Another element, that I believe is particular to this NPDES permit, is the discharge of
pollutant types into a water resource of pollutants that would not normally be expected in
the receiving waters which comes from the mixing of dissimilar wastewater streams,
during or after `treatment' and prior to discharge .
All too often, common sense public comments regarding environmental matters are
responded to by saying, "we've considered the comment and decided to ignore it," to the
detriment of our environmental resources as a whole .
Every time I observe from public access property the industrial wastewaters related to
this permit, I question to myself the reasonableness of its management in the
environment . I believe a great many of those who utilize not only the water resources of
Horseshoe Lake itself and connected water resources, but also of environmental resources
surrounding the state park, would attend a Public Hearing on NPDES discharges into the
Lake, particularly if there is a proper public outreach effort toward them
.
Sincerely,
Robert L . Johnson, PE
Senior Environmental Consultant
8 Cypress Point
Collinsville, Illinois
618/530-6604
