BEFORE THE ILLINOIS POLLUTION CONTROL BOARDRECEIVED
CLERK'S OFFICE
MAY 0 3 2007
STATE OF ILLINOIS
IN THE MATTER OF :
)
Pollution Control Board
PROPOSED AMENDMENTS TO
)
R 2004-025
DISSOLVED OXYGEN STANDARD )
35 Ill . Adm
. Code 302.206
)
NOTICE OF FILING
See Attached Service List
PLEASE TAKE NOTICE that on Thursday May 3, 2007, we filed the attached
Comment Letter from Mr
. Streicher and Motion For Leave to File Comment Letter
Without Service of Attached Data with the Clerk of the Illinois Pollution Control Board, a
copy of which is herewith served upon you
.
Respectfully submitted,
ILLINOIS ASSOCIATION OF WASTEWATER
AGENCIES
Roy M. Harsch
DRINKER BIDDLE GARDNER CARTON
191 N. Wacker Drive -
Suite 3700
Chicago, Illinois
60606-1698
(312) 569-1440
:w
0
hd 1_
A_
THIS FILING IS BEING SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDCLERK'S
RECEIVEDOFFICE
IN THE MATTER OF :
)
MAY 0 3 2007
PROPOSED AMENDMENTS TO
)
R 04-25
STATE OF
Pollution
ControlControl
Board
DISSOLVED OXYGEN STANDARD )
35 111. Adm
. Code 302 .206
)
MOTION FOR LEAVE TO FILE COMMENT LETTER WITHOUT SERVICE OF
ATTACHED DATA
The Illinois Association of Wastewater Agencies ("IAWA"), by its attorneys Drinker
Biddle Gardner Carton, hereby request to file Mr
. Streicher's April 24, 2007 comment letter
without service of attached data
. In support, IAWA states as follows :
I .
On April 24, 2007 Mr
. Dennis Streicher of the IAWA submitted a comment letter
to the Illinois Pollution Control Board ("IPCB") in this matter
. Attached to Mr . Streicher's
comment letter was a letter from Dr
. Garvey of the IAWA along with the 2006 dissolved oxygen
monitoring results obtained from the Illinois Environmental Protection Agency
("IEPA").
(Copy attached herein)
.
2.
As a result of the voluminous amount of data contained in the 2006 dissolved
oxygen monitoring results, Mr
. Streicher submitted said results electronically to the IPCB as
posted on the IPCB website in this matter on April 24, 2007 .
3.
Due to the voluminous amount of data, IAWA requests that it not provide the
2006 dissolved oxygen monitoring results to those on the service list but, rather will provide it
electronically to anyone who requests such information and provides an e-mail address
.
Alternatively, said monitoring results are available on the IPCB website as provided in this
matter on April 24, 2007
.
Wherefore, the Illinois Association of Wastewater Agencies, respectfully requests
that the IPCB grant this Motion for Leave to File Mr
. Streicher's April 24, 2007 comment letter
without service of the attached data based on the above
.
Respectfully Submitted,
May 3, 2007
DRINKER
Roy M . HarschBIDDLE
GARDNER CARTON LLP
191 N
. Wacker Drive
- Suite 3700
Chicago, IL 60606
312-569-1441
0 ne of h Attorneys for Petitioner
CERTIFICATE OF SERVICE
The undersigned certifies that a copy of the foregoing
Motion For Leave To File
Comment Letter Without Service of Attached Data
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 191 North Wacker Drive, Chicago, Illinois
on Monday, May 3, 2007.
Service List
R2004-025
Fred L
. Hubbard
16 West Madison
P.O. Box 12
Danville, IL 61834-0012
Bernard Sawyer
Metropolitan Water Reclamation District
6001 W . Pershing Rd.
Cicero, IL 60650-4112
Claire A. Manning
Posegate & Denes, P.C.
111 N . Sixth Street
Springfield, IL 62705
Deborah J
. Williams
Stefanie N . Diers, Assistant Counsel
Illinois EPA
1021 North Grand Avenue
P.O
. Box 19276
Springfield, IL 62794-9276
Dorothy M
. Gunn
Illinois Pollution Control Board
100 W
. Randolph Street - Suite 11-500
Chicago, IL 60601
Frederick D
. Keady
Vermilion Coal
1979 Johns Drive
Glenview, IL 60025
Alex Messina
Illinois Environmental Regulatory Group
3150 Roland Avenue
Springfield, IL 62703
Charles W. Wesselhoft
Ross & Hardies
150 North Michigan Avenue
- Suite 2500
Chicago, IL 60601-7567
Connie L
. Tonsor
Illinois EPA
1021 North Grand Avenue
P
.O
. Box 19276
Springfield, IL 62794-9276
Dennis L. Duffield
City of Joliet
Department of Public Works and Utilities
921 E
. Washington Street
Joliet, IL 60431
Erika K. Powers
Barnes & Thomburg
1 N. Wacker - Suite 4400
Chicago, IL 60606
James L. Daugherty
Thom Creek Basin Sanitary District
700 West End Avenue
Chicago Heights, IL 60411
James T
. Harrington
Ross & Hardies
150 North Michigan Avenue - Suite 2500
Chicago, IL 60601-7567
John Donahue
City of Geneva
22 South First Street
Geneva, IL 60134-2203
Katherine D. Hodge
Hodge Dwyer Zeman
3150 Roland Avenue
P.O. Box 5776
Springfield, IL 62705-5776
Lisa Frede
Chemical Industry Council of Illinois
2250 E. Devon Avenue - Suite 239
Des Plaines, IL 60018-4509
Matthew J . Dunn
Office of the Attorney General
188 West Randolph -
20`h
Floor
Chicago, IL 60601
Mike Callahan
Bloomington Normal Water Reclamation Dist .
PO Box 3307
Bloomington, IL 61702-3307
Richard McGill
Illinois Pollution Control Board
100 W . Randolph Street - Suite 11-500
Chicago, IL 60601
Stephanie N . Diers
IEPA
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Joel J . Sternstein
Office of the Attorney General
188 West Randolph Street - 20`h Floor
Chicago, IL 60601
Stanley Yonkauski
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, IL 62702-1271
Larry Cox
Downers Grove Sanitary District
2710 Curtiss Street
Downers Grove, IL 60515
Margaret P . Howard
2601 South Fifth Street
Springfield, IL 62703
Michael G. Rosenberg, Esq .
Metropolitan Water Reclamation District
100 East Erie Street
Chicago, IL 60611
Richard Lanyon
Metropolitan Water Reclamation District
100 East Erie Street
Chicago, IL 60611
Sanjay K . Sofat
Illinois EPA
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Sue Schultz
Illinois American Water Company
300 North Water Works Drive
P.O. Box 24040
Belleville, IL 62223-9040
Susan M. Franzetti
10 South LaSalle Street - Suite 3600
Chicago, IL 60603
Vicky McKinley
Evanston Environment Board
233 Grey Avenue
Evanston, IL 60202
Edward Hammer
U.S
. Environmental Protection Agency
WQ-16J
77 West Jackson Boulevard
Chicago, IL 60604
Todd Main
Director of Policy and Planning
Friends of the Chicago River
407 S . Dearborn - Suite 1580
Chicago, IL 60605
N. LaDonner Driver
Illinois Environmental Regulatory Group
3150 Roland Avenue
Springfield, IL 62703
Marc Miller, Senior Policy Advisor
Michael J . Fischer, Policy Advisor
Office of Lt. Governor Pat Quinn
Room 214 State House
Springfield, IL 62706
CHOI/ 12509025 .1
Tom Muth
Fox Metro Water Reclamation District
682 State Route 31
Oswego, IL 60543
W.C
. Blanton
Blackwell Sanders Peper Martin LLP
2300 Main Street
- Suite 1000
Kansas City, MO 64108
Albert Ettinger
Senior Staff Attorney
Environmental & Law Policy Center
35 E. Wacker -Suite 1300
Chicago, IL 60601
Irwin Polls
Ecological Monitoring and Assessment
3206 Maple Leaf Drive
Glenview, IL 60025
Tracy Elzemeyer
Generdl Counsel
American Water Company
727 Craig Road
St. Louis, MO 63141
Dr. Thomas J . Murphy
2325 N. Clifton Street
Chicago, IL 60614
Illinois Association of Wastewater Agencies
241
SPRINGFIELD,
NORTH FIFTH
ILLINOISSTREET62701217.5231814
FAX: 21T-544-OW
Revlon!
STEVE
RocklordRock
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Reclamation Dismd
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CUFF WHITE
City d St Charles
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BRIAN
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Sa,ilay D'a&t
Manber-at Large
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DENNISSTREICHER
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of Elmhursr
.
Illinois
Ex-Oficu
STEVE DAVIS
The Galesburg Sanitary District
Galcsburg, Illinois
Electronic Filing, Received, Clerk's Office, April 24, 2007
********
PC #109 * * * * * * *
April 24, 2007
Pollution Control Board
Dorothy Gunn, Clerk
.I RTC
100 Randolph Street, Suite I 1-500
Chicago, Illinois 60601
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
(luring 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 continuntrs
ntoouorlng nicasurelnents pct-ciousl
y entcretl as exhiblt> in thus
Electronic Filing,
* * * * *
Received,
* * * PC #
Clerk's
109 * *
Office,
* * * *
April
*
24, 2007
2
proceeding
. According to Mr. Matthew Short ofIEPA 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 (luring 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 JAW\
:\ ill regards to establi,hing reasonable dissolved o .Ny_en
requirements 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 I'or dissolved oxygen and
it adheres to the advice of local experts in establishing the months oh late spawning and
protecting those early lire stages
.
The IAWA has acknowledged that some waters in Illinois could be identified as
requiring a different dissolved oxygen average or minima for certain least disturbed
waters . However, the IAWA adamantly opposes establishing such criteria without the
ground t uthing 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 aces of the rivers and waters in Illinois
.
I'd like to remind the Board the IEPA
and IDNIt tiled 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 IEPA .
Sincerely,
Electronic Filing,
* * * * *Received,
* *
. *
PC
Clerk's
#109 t *
Office,
* * * *
April
*
24, 2007
Dennis Streicher
Director of Water & Wastewater
Cc :
Richard McGill, Hearing Officer
Service list
_
. The Voice
of Wastewater Agencie! : in Illinois"
10 April 2007
Mr
. Dennis Slrcicher
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 Malt 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 TAWA . I summarized this approach
during the November 2006 IPCB hearing
. I evaluated the data relative to the proposed IAWA
standard and the IDNR/I EPA standard for enhanced DO surface waters . The enhanced stream
segments I evaluated are listed as
IEPA Segment Stream Name
BM-PS-C2
Sugar Creek
DAG-03
Hodges Creek
GB-08
DuPage
GB-18
DuPage
PQC-06
SB Kishwaukee
PQFD-01
Hampshire
PQFD-H-C3
Hampshire
Pal-10
EB Kishwaukee
PQI-H-CS
SB Kishwaukee
Electronic Filing, Received, Clerk's Office, April 24, 2007
******** PC#'109*******
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 I, 2). For the minimum criterion, ten and sixteen percent o f
observations across months and stream segments generated violations for the IAWA and
IDNR/IEPA proposed standards, respectively (Table 1)
. 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,
)1II,tiar\CV
A"ociali Direclor,\
Professor
I isherica ;inIll . .\qu .uIlllure ( mice . \thttlIn4III Iltmm t lnceniIN
;11IIondule
. 11 IN_')Il 1
Electronic Filing,
* * * * *
Received,
* * * PC#109
Clerk's*
* *
Office,
* * *
April
*
24, 2007
Table] .
Minimum criteria .
Proportion of dissolved oxygen concentration point estimates
(mg/I
.) 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
. : IA WA
: 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
POC-06
SB Kishwaukee June
0 .00
0
.00
August
0 .32
0 .35
POFD-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-CS
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, Clerk's Office, April 24, 2007
* * * * * * * * PC #109 * * * * * * *
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
BM-PS-C2_
Sugar Creek July
6 .02
5 .23
XIEPA
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
Juty
9 .54
5 .55
9 .23
5
.01
GB-18
DuPage
July
8 .79
6 .01
POC-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
7-d Means of daily means
: IEPA : Seven (lay averages must not be less than
6 . 15 mg /L
.
through July ; IAWA
: Seven day averages must not be less than 6 mgIL through June
.
h
7-d means of daily minima : IEPA
: Seven day averages must not he less than 4.5
mg/L
after July 31
; IAWA
: Seven day averages must not he less than 4 mg/L after hue 30 .
N/A = not applicable .
Electronic Filing, Received, Clerk's Office, April 24,
2007
********
PC #109 * * * * * * *
8
.93
7 .17
8 .86
7 .17
8 .86
7 .23
POI-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
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Electronic Filing,
* * * * *
Received,
* *
* PCClerk's
#109
*
Office,
* * * * *
April
*
24, 2007
.
STATIONS-HIGHLIGHTED IN YELLOW
AROEGEIVINTS SUGGESTED FOR
6
.2ojj DO STANDARD
SE-14
EMBARRAS RIVER
BI07BT7
INDIAN CREEK
BFT1
SUGAR CREEK
BFC-20
ROBINSON CREEK
MIAMI SuGAWCRSE
BP-03
Vgg"Ll
`:.ER:
BPJC-06
SALINE BRANCH
BPJCA-UC-D1 BONEYARD CREEK
BZK-01
RACCOON CREEK
C-09
LITTLE WABASH RIVER
C-33
LITTLE WABASH RIVER
DA-11
MACOUPIN CREEK
DAG-03
MCMG1FS%CRMK
DB-01
APPLE CREEK
DD-04
MAUVAISE TERRE CREEK
DE-01
MCKEE CREEK
DH-04
SUGAR
CREEK
GB-08
XURENGfY450
G548
GYMOG
BR..
HBD-04
THORN CREEK
HBDB-03
BUTTERFIELD CK
HCC-07
NORTH
BRANCH CHICAGO R
HCCB-05 W FK NORTH BRANCH
HCCC-02
MIDDLE FORK
HFT1
TINLEY
CREEK
PO-13
KISHWAUKEE
RIVER
PQC-06
PQC-13
SM-is WMAEOR
S BR KISHWAUKEE R
PQFD , 01
PQFD-114C3
PQI-10
BRANCH-'EAST
PQI-H-C5
SO" .
,
*6w
Electronic Filing,
********Received, PC#,109*******Clerk's
Office, April 24, 2007
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Electronic Flling,,Received,
Clerk's Office, April 24, 2007
*******.*
PC#109 * ** * * * *
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1N
10E
18
SE
38 .51842
-88.13199
3S
t0E
18
NE
38 .26991
-88.1377
1ON
6W
16
NW
39.316667
-89.773056
1ON
9W.. .
E
39.283842 -90.139167
11N
13W
28
NE
39 .3695
-90.54636
15N
12W
23
SW
39 .73139 -90.40736
3S
2W
8
SW
39 .81757
-90.65332
3N
1 W
22
NE
40 .2313889 -90.4927778
36N
9E; :.
NE
41 .5923
-88.22436
`9E-
41.5361111 -88.1813889
14E
34
. 41 .56821
-87.60782
_
14E13E
308
NW
4241.01237.53986
-87-87.64954.79554
12E
4
NE
42 .1383
-87.83478
42N
12E
3
42 .1526
-87.81833
37N
13E
32
NE
41 .64664 -87.76646
44N
6E
35
NW
42 .24784 -88.50644
42N
:3E . . . '17
42 .11029
-88)90053
4E
4
7,''
NW
41 .8925
42 .12222222
-88.7861111
6E=-
NW
-88.56888889
-88..6547
. "8E
-20
.-'NE
42 .1064
-88.49159
'GE
42 .21943
9E . .
12
s0
SE'
42 .1681
-88.4535
