BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
WATER QUALITY STANDARDS AND
EFFLUENT LIMITATIONS FOR THE
CHICAGO AREA WATERWAY SYSTEM
AND THE LOWER DES PLAINES
RIVER:
PROPOSED
AMENDMENTS TO
35 Ill. Adm
.
Code
Parts 301, 302
,
303 and
304
R08-9
(Rulemaking
-
Water)
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER
CHICAGO'
S PRE
-FILED QUESTIONS TO VICTOR CRIVELLO
1.
You indicate in your testimony that you recreate in the Calumet River System three or
more weekends per month.
A.
Have you
gotten
sick from
recreating in these waters?
B.
If so, how many times over how many years?
2.
You have observed a great deal of recreation in the Calumet area. Have you ever heard of
a documented disease outbreak resulting from all of this recreation?
3.
On page 2, paragraph 1, in sentence 1, you stated that there has always been a large
boating community on the Calumet Waterways.
A.
Please define what you mean by "a large boating community."
B.
Does a large boating community imply only private pleasure craft?
C.
Do you have any survey data showing the number of recreational boats using the
Calumet Waterways during a given year?
4.
On page 2 of your testimony, you indicate that you have "primarily observed waterway
uses from Ashland Ave. east along the Grand Calumet River."
A.
Could you provide a map or otherwise clarify the location you are referring to, as
Ashland Avenue crosses over both the Cal-Sag Channel and the Little Calumet
River, but not the Grand Calumet River?
B.
How frequently do you observe jet skiing, water skiing, and swimming between
Ashland Avenue and the Calumet Water Reclamation Plant?
C.
Would
you be surprised
if you
were told that people should not swim near a
wastewater treatment plant discharge
,
even if the plant was routinely meeting the
THIS
FILING
IS BEING
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Electronic Filing - Received, Clerk's Office, August 25, 2008
proposed technology-based limit or even performing much better than the
proposed fecal coliform limit?
5.
On page 2, paragraph 1, in sentence 5, you stated that you observed swimming and tubing
in the Calumet River System.
A.
In which waterways did you
observe swimming and tubing?
B.
What was the frequency of swimming and tubing you observed in the Calumet
River System?
C.
Do you have any survey data showing the number of occurrences of swimming
and tubing in the Calumet River System during a given year?
6.
On page 2, paragraph 1 of your testimony, you state that "[t]he Cal-Sag River
[sic]
is also
an area with heavy recreational uses. Even though occasional barge traffic does exist,
there is always more than enough room to pass in a safe way."
A.
What is the basis for this statement? Did you record these observations?
B.
Is this statement based on any field surveys or data collected on recreational uses
on the Cal-Sag Channel or is the statement your personal opinion?
C.
Do you have any survey data showing the number of recreational users on the
Cal-Sag Channel?
D.
Does the type and frequency of the recreational uses that you have observed on
the Cal-Sag Channel differ east of Ashland Avenue?
E.
Do you have any survey data showing the number of barges that pass through the
Cal-Sag Channel?
F.
Are you familiar with
USACE
data identifying between 4000-8000 commercial
barge lockages through the O'Brien Lock and Dam annually?
G.
Does that change your opinion concerning whether it is safe for recreational uses
in the Cal-Sag Channel?
7.
On page 3, paragraph 1, you state "Disinfection of the waters will be vital to the success
of this plan."
A.
What is
the basis for this statement?
B.
Do you know that the proposed IEPA rule requires disinfecting the effluent of the
Calumet Water Reclamation plant, which discharges to the Little Calumet River
near 128th Street, Chicago, Illinois, rather than the waters in the river itself?
C.
If you knew that the water quality in the east portion of the Little Calumet River,
Grand Calumet River, Calumet River and the entire Lake Calumet area would not
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Electronic Filing - Received, Clerk's Office, August 25, 2008
be improved, even if disinfection is implemented at the Calumet Water
Reclamation Plant, would your opinion concerning disinfection change?
D.
If you knew that, despite disinfection, more than half of the time, bacteria levels
would be much higher than 400 fecal coliform counts per 100 milliliters, would
that affect your conclusion about how vital disinfection is to the Calumet Area
Vision plan?
E.
If disinfection did not result in reduced risk to recreational users, would you still
believe that it should be required for the Calumet Vision Plan?
F.
Are you aware of the risk
assessment
and epidemiology studies performed by the
District?
G.
To your knowledge, what were the conclusions of the microbial risk assessment
study?
H.
Are
you aware of other sources of bacteria
in the CAWS?
I.
Have you conducted or are you aware of any study on the sources of
contamination to the area that the Calumet Vision Plan covers with respect to
bacteria and pathogens?
J.
How would the Calumet Vision Plan be affected if significant sources of bacteria
other than the WRP discharge, such as stormwater runoff and bird droppings, are
not addressed?
8.
According to your testimony, there are currently a large number of private boats that use
the Calumet Waterways for recreational boating.
A.
Is disinfection of the treated effluent from the Calumet WRP necessary for
recreational boating in the Calumet Waterways?
B.
Can you explain why?
9.
On page 4, paragraph 1, you contend that "continuing unsafe water conditions of the
Calumet waterways will have a negative affect on these activities."
A.
Explain what
is an unsafe water condition?
B.
Please describe the evidence you have that these waterways are unsafe for their
proposed designated uses (non-primary contact uses).
C.
Please describe your understanding
of how
the "unsafe" conditions
in the CAWS
would change if the plants disinfected.
D.
What bacterial level would you consider "safe" in the Calumet waterways?
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Electronic Filing - Received, Clerk's Office, August 25, 2008
E.
Do you know what bacteria levels would remain from combined sewer overflows
and nonpoint sources in the Calumet waterways after the proposed disinfection
requirements are implemented?
10.
On Page 4, the first
sentence
of the 2°d paragraph, "I strongly support the disinfection of
the Calumet waterways."
A.
How much do you believe the recreational risk level will decrease in the Cal-Sag
Channel, downstream of the Calumet WRP after disinfection, if other significant
sources of bacteria are not addressed?
B.
If you knew that the disinfection at the Calumet Water Reclamation Plant, as
proposed in this rule making, would not improve the water quality in the Little
Calumet River east of 128th Street, the Grand Calumet River, the Calumet River
and the entire Lake Calumet area, would that change your opinion?
11.
On page 4 you
state that
, "
Jet skiing
,
waterskiing
,
and tubing are activities
where water
contact is unavoidable."
A.
Do you
consider these activities to be included within the incidental contact
recreational use being proposed for these waterbodies?
B.
To your
knowledge
,
are primary contact activities being proposed as an attainable
use for the
CAWS during
this rulemaking?
12.
What protocols do you personally employ to minimize the potential of illness due to
exposure to pathogens in the waterways in which you recreate?
13.
What safety protocols would you recommend to the public when recreating in the
CAWS?
14.
Should certain areas be avoided due to barge and motorized boat traffic, absence of safe
entry and exit locations, and/or other issues incompatible with recreational uses?
15.
Do you avoid contact with the CAWS during certain times, such as during and following
wet weather events?
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Electronic Filing - Received, Clerk's Office, August 25, 2008
16.
Even if the wastewater treatment plant effluent was disinfected, would you recommend
that people, particularly children, should avoid exposure
to the CAWS
due to pathogen
contributions from stormwater runoff and combined sewer overflows?
Dated: August 25, 2008
Respectfully submitted,
METROPOLITAN WATER RECLAMATION
DIS
T OF GREATER CHICAGO
By:
Fredric P. Andes
Fredric P. Andes
David T.
Ballard
BARNES
&
THORNBURG LLP
Suite 4400
One North Wacker Drive
Chicago, Illinois 60606
(312) 357-1313
482127v1
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Electronic Filing - Received, Clerk's Office, August 25, 2008
