page 1
page 2
page 3
page 4
page 5
page 6
page 7

President

STEVE 

RockfordRock 

River 

.

(

IllinoisWater 

;RAC 

Reclamation 

EFTA

District

Vice President-Administrator

CLIFF WHITE

City

5t Charlesof 

St Charles

.                        Was

Vice President - Technical

BRIAN 

GurneeNorth 

Shore 

. Illinois

DORN

Sanitary Distict

Member-al-Large

MIKE 

UrbanaUrbana 

.

&

LIII'LE

IllinoisChampaign 

Sanitary District

Member-at-Large

NI('K 

Ikr,cncn(n

MENNINGAo

Sunilurs IJisl 'I

Uo,rncn (hr,yc, Illinois

Idei at Large

TOM MU rH

Us,vego, 

Fox Metro 

IllinoisWater 

Rmlumution District

Member-al-1-urge

City

DENNISSTREICHER

Elmhurst, 

of ElmhurstIllinois

Ex-Otiia

STEVE DAVIS

The Galesburg Sanitary District

Galesburg, Illinois

Electronic Filing, 

* * * * * 

Received, 

* * * PC 

Clerk's 

#109 * 

Office, 

* * * * * 

April 

*

24, 2007

Illinois Association of Wastewater Agencies

241

SPRINGFIELD, 

NORTH FIFTH 

ILLINOISSTREET

62701 217-523-1814 FAX 217-544-0086

\\' Lust I' P. .  .

RE:

Proposed Amendments to Dissolved Oxygen

Standard

35 ILL 

. ADM .CODE 302 

.206

Pollution Control Board Rule R04-25

The Illinois Association of Wastewater Agencies (IAWA) would

like to request that additional data be entered into the record of the

referenced petition . The data consists of continuous dissolved

oxygen (DO) measurements taken on a number of Illinois rivers

during the summer and early fall of 2006 

. This data was requested

from the Illinois Environmental Protection Agency (IEPA) before

the last hearing on this petition in November 2006 . The data has

only been made available to IAWA in late March 2007 . That data is

included with this letter. Please recall that during testimony much

was made of any data collected during 2005 because of the

widespread drought conditions that existed in Illinois that year 

. This

data was collected in 2006 which was a much more average year in

regards to rainfall totals .

While IEPA included a disclaimer stating that they will assume no

responsibility for the accuracy of the data . the data is consistent

with data that has been collected in numerous other continuous

monitoring measurements prev iously entered as exhibits in this

April 24, 2007

Pollution Control Board

Dorothy Gunn, Clerk

,1 RTC

100 Randolph Street, Suite 

11-500

Chicago, Illinois 60601

Electronic Filing, 

* * * * * 

Received, 

* * * PC #109 

Clerk's 

* *

Office, 

* * * *

April 24, 2007

proceeding

. According to Mr. Matthew Short of JEPA ten of the thirty-two river

segments on which measurements were taken are those that would have the proposed

higher average DO limits of 6 .25 mg/L applied as recommended in the Joint IEPA and

Illinois Department of Natural Resources (IDNR) proposal 

. According to IEPA and

IDNR, an enhanced DO limit is needed on selected Illinois river segments because the

agencies have determined that there are DO sensitive fish species present in those river

segments and that there is a need to maintain a higher average DO for a longer time into

the year

.

IAWA asked Dr 

. James Garvey to review the 2006 data ; especially the ten river

segments that are suggested to have the agencies enhanced DO standard applied and

therefore should have the assemblage of DO sensitive fish species . IAWA asked Dr .

Garvey to compare the IAWA proposed standard (both DO concentrations and

proposed dates) to the Joint IEPA-IDNR proposed concentration and dates and to

determine which standard would be a better fit . All of the 2006 data has been collected

with continuous DO recorders during a non-drought year . Included with this letter is

Dr. Garveys' response to that request . In summary, the 2006 data support Dr 

. Garvey

and Dr

. Whiles original suggested DO concentrations and dates for those concentrations

and closely follow those found in the USEPA National Criteria Document . The 2006

data further supports the IAWA proposed limits and in comparison are a better fit and

generate fewer violations than the proposed Joint IEPA-IDNR limits . That is true for

both the DO concentrations and the dates 

.

Interestingly, some of the segments would even appear to be DO impaired 

. They would

violate BOTH the IAWA and agency limits yet still are suggested to sustain a

population of the DO sensitive species proposed by the agencies 

. As was said many

times during testimony it once again calls into question the methods and assumptions

made by the agencies in determining which river segments should have the enhanced

DO limits imposed or which fish species are truly DO sensitive 

. The IAWA question

the validity of those methods 

.

The IAWA respectfully asks that the Board consider this additional 2006 data as further

evidence that the proposed Joint IEPA-IDNR Recommended Revisions to the Illinois

General Use Water-Quality Standard for Dissolved Oxygen 

be rejected as not supported

by all the data collected to date and made part of this review 

. The proposed joint

standard does not accurately represent natural dissolved oxygen conditions in Illinois

waters 

. As was stated in my previous letter to the board in December 2006, the IAWA

assessment of national and Illinois dissolved oxygen water quality criteria has withstood

the test of several years of evaluation and field measurements that have continued to

support the position of IA \\ A m regards to

establishing

reasonable dissolved oxygen

rcquiremcnes in Illinois 

.

The Voice of Wastewater 

Agencies in Illinois"

3

This new data further supports that position

. The seasonality of the proposed

concentrations has also held up to that test

. The IAWA proposed standard is more

conservative than the NCD in regards to establishing minimas for dissolved oxygen and

it adheres to the advice of local experts in establishing the months of late spawning and

protecting those early life stages

.

The IAWA has acknowledged that some waters in Illinois could he identified as

requiring a different dissolved oxygen average or minima lot certain least disturbed

waters

. However, the IAWA adamantly opposes establishing such criteria without the

ground truthmg data to support that designation

. The IAWA proposes to work closely

with IEPA and IDNR and other interested parties in establishing those criteria and

determining what are the attainable uses of the rivers and waters in Illinois 

.

I'd like to remind the Board the IEPA and IDNR filed no data to support their joint

proposal

. They further testified that they made no attempt to ground truth their proposal

against collected data

. The IAWA asks the board to adopt the IAWA petition in total

with previously agreed to inclusion of a 30-day average and the narrative provision as

proposed by [EPA 

.

Sincerely,

Electronic Filing, Received, Clerk's Office, April 24, 2007

* * * * * * * * PC #109 * * * * * * *

Dennis Streicher

Director of Water & Wastewater

Cc:

Richard McGill, Hearing Officer

Service list

. .              . .The Voice 

of Wastewater Agencies in 

Illinois"

10 April 2007

Mr

. Dennis Streicher

IAWA

Dear Dennis 

:

You recently forwarded to me some 2006 semi-continuous dissolved oxygen (DO) monitoring

data collected by the Illinois Environmental Protection Agency (IEPA)

. As noted by Matt Short's

e-mail to you, several of the segments are listed to receive enhanced status under the proposed

IDNR/IEPA standard before the Illinois Pollution Control Board (IPCB)

. I used the same

approach as I did when analyzing 2006 data collected by IAWA

. I summarized this approach

during the November 2006 IPCB hearing

. I evaluated the data relative to the proposed IAWA

standard and the IDNR/IEPA standard for enhanced DO surface waters

. The enhanced stream

segments I evaluated arc listed as

Electronic Filing, 

* * * * * 

Received, 

* * * PC #109 

Clerk's 

* *

Office, 

* * * *

April 24, 2007

IEPA 

Segment

BM-PS-C2

DAG-03

GB-08

GB-18

PQC-06

PQFD-01

PQFD-H-C3

POI-10

PQI-H-C5

_Stream Name

Sugar Creek

Hodges Creek

DuPage

DuPage

SB Kishwaukee

Hampshire

Hampshire

EB Kishwaukee

SB Kishwaukee

In summary, both proposed sets of standards generated similar results, with the exception of

Sugar Creek

. In Sugar Creek, the proposed IDNR/IEPA standard generated violations whereas

the IAWA standard did not (Tables 1, 2)

. For the minimum criterion, ten and sixteen percent of

observations across months and stream segments generated violations for the IAWA and

IDNR/IEPA proposed standards, respectively (Table I)

. Five of the nine segments did not meet

the IDNR/IEPA proposed standard (Tables 1, 2)

. The majority of these violations occurred in the

Kishwaukee drainage .

Let me know if you have questions or need additional information 

.

Sincerely,

Jim Uarnrv

A

. uciac Director & :1`suuule Prolessor

I fisheries rind II, Ayuarultnre Center 

. AoaIthUl] Illinois I nicerskr .  (

a1[ . . .

le. II . t,-")CII

Electronic Filing, 

* * * * * 

Received, 

* * * PC #109 

Clerk's 

* *

Office, 

* * * * 

April 

*

24, 2007

Table l . 

Minimum criteria .

Proportion of dissolved oxygen concentration point estimates

(mg/L) quantified at each "enhanced" river site and month that were less than the minimum acute

concentration proposed by IEPA and IAWA are listed 

. IEPA 

: Not less than 5 mg/L, through July

31 : IAWA

: Not less than 5 mg/L through June 30 

. For later months, IEPA 

: Not less than 4

mg/L 

; IAWA : Not less than 3 

.5 mg /L .

_Month _         

IAWA 

IEPA

BM-PS-C2  

Sugar Creek  

July              

0 .00   

0 .12

Sept           

0 .00   

0 .00

BP-03

Vermilion River July              

0

.00

0 .00

August          

0 .00   

0 .00

Sept

0 .00   

0 .00

DAG-03   

Hodges Creek July

0 .62   

1 .00

August           

1 .00   

1 .00

Sept           

0 .29   

0 .60

Oct

0.00   

0.10

GB-08    

DuPage    

July

0 .00   

0 .05

August          

0 .00   

0 .14

GB-18    

DuPage    

July              

0 .00   

0 .00

August

0 .00   

0

.00

PQC-06   

SB Kishwaukee 

June           

0 .00   

0

.00

August          

0 .32   

0 .35

PQFD-01  

Hampshire   

June

0 .00   

0 .00

August          

0 .00   

0 .00

Sept            

0 .00   

0 .00

PQFD-H-C3 Hampshire   

June

0 .00   

0 .00

August          

0

.00

0 .00

Sept

0 .00   

0 .00

PQI-10   

EB Kishwaukee June

0 .09   

0 .09

August           

0 .02   

0

.11

PQI-H-C5  

SB Kishwaukee 

June           

0

.18

0 .18

August          

0

.07

0 .19

Average         

0 .10   

0

.16

Proportion of

Observations       

0

.32

0 .48

Electronic Filing, 

* * * * * 

Received, 

* * * PC #109 

Clerk's 

* *

Office, 

* * * * 

April 

*

24, 2007

Table 2 

. Seven-day mean and 7-d minimum criteria 

.

Average 7-d mean values and

average 7-d minimum dissolved oxygen concentrations during each month 

.   Each value

within each month represents an average of the 7 preceding days 

(e.g., a month with two

values listed below had 14 contiguous days of readings available 

; three would have 21

days ; etc .) .

Month

7-d

mean 7-d min °

Violate

IAWA

Violate

IEPA

BM-PS-C2 Sugar Creek 

July     

6 .02    

5 .23         

X

5 .96    

5

.21

X

Sept    

7 .38   

6 .26

6 .91    

5 .96

BP-03

Vermilion

River      

July     

6 .96   

6 .71

6 .86    

6 .62

Sept    

7 .52   

6 .68

7 .51    

6 .68

7 .53   

6

.76

DAG-03  

Hodges Creek 

August   

1 .32   

0 .43 X     

X

Oct

4.12  

3.40 

X

X

4 .27   

3.57 X    

X

GB-08  

DuPage   

July     

9 .54   

5 .55

9 .23   

5 .01

GB-18  

DuPage   

July     

8 .79   

6 .01

PQC-06

SB

Kishwaukee  

June    

8 .47   

7 .47

8 .47   

7 .34

8 .38   

7 .30

August   

8.09  

2.64 X    

X

6 .48   

1.68  X    

X

PQFD-01 

Hampshire  

June    

8 .83   

6 .91

8 .79   

6 .85

8 .65   

6 .85

Sept    

7 .72   

6 .52

7 .71    

6 .52

7 .71    

6 .53

7 .55   

6 .51

7 .56    

6 .52

7 .51    

6 .60

PQFD-H-

C3

Hampshire  

June    

9 .03   

6 .90

9 .06   

6 .84

9 .06   

6

.86

Sept    

9 .10    

7 .77

9 .11    

7 .76

9 .11    

7 .77

8 .97   

7 .83

8 .97    

7 .11

Electronic Filing, Received, Clerk's Office, April 24, 2007

`7-d Means of daily means : I EPA 

: Seven day averages must not be less than 6

.25 mg/l,

through July : IAWA : Seven day averages must not be less than 6 

m.-/L 

through Tune.

7-d means of daily minima : IEPA : Seven day averages must not be less than 4 

.5 mg/L

after July 31 ; IAWA : Seven day averages must not be less than 4 mg/L after June 30 

.

N/A = not applicable .

* * * * * * * * PC #109 * * * * * * *

8 .93   

7 .17

8 .86   

7 .17

8

.86

7 .23

PQI-10

EB

Kishwaukee  June    

8 .41    

5 .13

7 .66   

4

.79

August   

9 .21    

4 .24         

X

8

.99

3.92 X    

X

8

.37

3.76 X     

X

PQI-H-CS

SB

Kishwaukee  June    

8 .44   

4

.76

7

.60

4 .37

7 .18   

4 .46

August   

7.50   

3.87 X    

X

6 .85   

3.54 X    

X

Electronic Filing,

********Received, PC#109*******Clerk's

Office, April 24, 2007

STATIONS HIGHLIGHTED IN YELLOW

ARE SEGEMNTS SUGGESTED FOR

STATIONS HIGHLIGHTED IN YELLOW

ARE SEGEMNTS SUGGESTED FOR

BM-PS-C2 SUGAR •CREEK-NORTH

,BPJCA-UC-D1 BONEYARD CREEK

NORTH BRANCH CHICAGO R

Office, April 24, 2007

(-BR W EDGE OF CAMARGO

IDOUGLAS

1 .5 MI S LAWRENCEVILLE AT RT 1 BR

LAWRENCE

0 .3 MI NE OF PALESTINE NEAR ICRR BR

CRAWFORD I

OLD RR BR NE ROBINSON 50YD UPS WWTP

CRAWFORD

US 150 BR., E'.EDGE OF PARIS AND 0 .9 MI . DNS PARIS SOUTH STP

EDGAR

VERMILION COUNTY FOREST PARK CANOE LAUNCH 4M1 E 0,5MI S WESTVILLE VERMILION

CO RD 24 B41 MI N MAYVIEW, 4 MI E URBANA

CHAMPAIGN

DNS OF US 150 NEAR SYCAMORE STREET URBANA

CHAMPAIGN

4 MI WSW FRANCISVILLE ON CO RD 050N

LAWRENCE

0.5 MI S BENNINGTON ON SALEM MT ERIE RD

EDWARDS

6 MI WNW GRAYVILLE

EDWARDS

2 MI SE OF STANDARD CITY ON COOPS MOUND RD

MACOUPIN

ICHISM RD BR 3:5 MINE OF ROCKBRIDGE

I RT 104 BR AT CHAMBERSBURG

PIKE

2 MI NW RAY

SCHUYLER

RENWICK RD SWPLAINFIELO

VIKILL=

2 MI N SHOREWOOD AT-SLACKRD BR

WILL

THORTON RD BRAT THORNTON, IL

DUNDEE RD BR NORTHBROOK

COOK

LAKE-COOK CO LINE RD BR AT DEERFIELD

COOK

[135TH ST BR NR CRESTWOOD

12 MI SW DEKALB AT GURLER RD

DEKALB

[2.6

;NWMAMPSHIRE AtWALKER ROAD

GHENRY

ALLEN RD BR, 1^ MI NW OFFHAMPSHIRE AND 1 MI DNS HAMPSHIRE WWTP

KANE'

2 MI SE' UNION

MGHENRY

MARENGORD -BR, 1.3 MI W OF HUNTLEY AND 2.9 MI DNS HUNTLEY WWTP

Clerk's Office, April 24, 2007

40.1170055 -88.201375

40.2313889 -90.4927778

41 .5923 -88 .22435

35N

9E .

41 .5361111 -88.1813889