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 WILLIAM VAN BONN
1.
Are you familiar with the Chicago Area Waterway System (CAWS)? Please describe
your experience on the CAWS.
2.
On page 1 of your testimony, you state that the "massive influx of effluent from
wastewater treatment plants" is one of the notable human impacts on the CAWS. Yet
you also mention reversing the flow of the Chicago River. Did you consider the relative
wildlife impacts of the dramatic physical alterations to the CAWS, which also include
channelization and making reaches straighter, wider and/or deeper to accommodate
shipping and other commercial purposes?
3.
On page 2, paragraph
2, you state, "The proposed rules mandate that Metropolitan
Water Reclamation District of Greater Chicago (MWRD) dramatically reduce pathogens
that it discharges into our waters by disinfecting approximately 1.17 billion gallons of
effluent daily at its Calumet, Stickney and North Side wastewater treatment plants." Are
you aware that the proposed rule by IEPA mandates that MWRD disinfect to reduce the
number of fecal coliforms, which are fecal indicators and not pathogens?
4.
Are you aware of any pathogens that have been found in the final effluent from the
Calumet, Stickney, and North Side water reclamation plants (WRPs) that discharge to the
CAWS?
A.
If so, do you know the present level of pathogens in the final effluents from the
MWRD WRPs?
B.
If so, how do you know?
5.
On page 3, last sentence
you make the statement that "Natural systems are complex and
subject to multiple factors."
A.
Would
you explain what these factors are?
B.
How do these factors for a natural system compare to the factors for the man-
made canals
of the CAWS?
THIS FILING
IS BEING SUBMITTED
ON RECYCLED PAPER
Electronic Filing - Received, Clerk's Office, August 25, 2008
6.
On Page 4, paragraph 2, sentence
3, you state, "From this perspective, it is not hard to
appreciate how disinfecting wastewater will lead to a more natural, balanced, healthy
ecosystem."
A.
Explain how disinfecting treated wastewater at the North Side, Stickney, and
Calumet WRPs will lead to a more natural, balanced aquatic ecosystem in the
CAWS.
B.
How would the discharge of residuals from disinfectants and disinfectant by-
products impact the ability to achieve a more natural, balanced healthy
ecosystem?
C.
Are you
aware that response
of the
bacterial community to the post
-
disinfection
environment will be influenced by bacterial repair
,
recovery
,
and regrowth, and
that collectively
,
these processes may yield diminished water quality relative to a
situation in which disinfection is not practiced?
D.
How would the generation of energy required to support disinfection contribute to
further global climate change and impact local wildlife
of the CAWS?
7.
Page 4, paragraph 3 of your testimony references the Exxon Valdez event and its impact
on sea otters.
How were the sea otters negatively impacted: was it by bacterial pathogens
or by the oil?
8.
Page 3, paragraph 4.
A.
What are the studies that you reference regarding parasites from wastewater
treatment plant effluents as being the most common cause of disease and death in
sea otters off the California coasts?
B.
Were there any other causes?
C.
What level of treatment did the wastewater receive prior to being discharged to
the sea?
D.
Were these effects due to wastewater effluent discharge or to the now- banned
.
practice of ocean disposal of raw sludges?
E.
Do you have data showing which parasites were found in treated secondary
effluents as opposed to raw or partially treated sewage?
9.
Page 4, paragraph
5. Describe your experience on the CAWS and LDPR generally and
specifically as to river otters.
A.
You
state that river otters were indigenous to the
CAWS
. Much
of the CAWS are
man-made and had no previous indigenous aquatic life
.
Please provide scientific
evidence showing that rivers otters were indigenous
to the CAWS.
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Electronic Filing - Received, Clerk's Office, August 25, 2008
B.
What do river otters eat?
C.
Does the CAWS have adequate food sources for otters?
D.
On what data do you base this?
E.
What kind of hunting habitat do river otters require?
F.
What physical habitat is required for a successful population of river otters?
G.
Your testimony references a single sighting of a river otter in the CAWS.
Was
the person reporting this sighting a trained biologist who could correctly
distinguish a river otter from other mammals?
H.
Is there any confirmed population of river otters
in the CAWS?
10.
Page 4, paragraph
5.
You state "If we want otters and other native species to
successfully return to the area and once again be a part of our life experience, it is
important to understand what organisms threaten their health, and how we can avoid
needlessly tipping the balance in favor of those threats."
A.
Is it possible that something other than bacteria may be keeping river otters from
colonizing the CAWS?
B.
Have you seen a river otter in the CAWS?
C.
How many river otter sightings are you aware of in the last year?
D.
Are you aware of any river otter census performed in the CAWS ever?
E.
Are you
suggesting that river otters be introduced into the
CAWS
urban riparian
areas?
F.
If so,
please explain
why you think this
is a reasonable
,
sustainable action.
G.
Wouldn't introduction of river otters to the CAWS lead to incompatible
interactions with humans in an urban setting?
H.
There is presently a problem with overpopulation of white tailed deer in Cook
County Forest Preserves. Are you not running the same risk by introducing river
otters?
1.
What does the first word, Kimber, refer to in the second to last sentence? It is not
listed in the indicated reference.
11.
Page 5, paragraph
4.
Your testimony discusses toxoplasmosis, which is caused by a
parasite in cat feces.
You state that "cat feces in discarded litter has been found to
contaminate wastewater."
3
Electronic Filing - Received, Clerk's Office, August 25, 2008
A.
What is
the basis for this statement
,
and what scientific support can
you offer to
show
that the parasite is present in treated
effluent from
a municipal wastewater
treatment plant?
B.
What is basis for the statement that discarded cat litter has been found to
contaminate wastewater?
C.
Do you
know that according
to CDC,
'
Toxoplasmosis is a disease that can come
from cats, but people are more likely to get it from eating raw meat or from
gardening?
D.
Do you have any data which associates any Toxoplasmosis outbreak with treated
wastewater effluent?
12.
Page 6, paragraphs 3 and
4.
Your testimony about giardia and cryptosporidium
references studies on marine ecosystems.
A.
Are
you aware of any studies on river otters in fresh water ecosystems?
B.
What does it mean that giardia and cryptosporidium have been found in otter
feces?
C.
Can human sources of giardia and cryptosporidium be distinguished from other
sources, or could the source be from other wildlife?
13.
Pages 7
and 8
,
Bacteria
:
Salmonella
,
Streptococcus, and Mycobacteria-Tuberculosis.
A.
Several cases of otters in captivity or zoos having bacteria-associated problems
are cited. Is it correct that the sources of the bacteria were not wastewater
treatment effluents?
B.
Do you know that similar concentrations of Salmonella spp., protozoan parasites,
and enteric viruses measured in the CAWS downstream of MWRD WRP outfalls
were also detected upstream of the same MWRD WRP locations during dry
weather conditions? [The evidence is in the final risk assessment report z Tables
3-5a, 3-5b, 3-5c, 3-6 and 3-7.]
14.
On page 8, paragraph
3, you state that disease outbreaks are often associated with
contaminated water.
A.
Do you have data indicating any disease outbreaks associated with the discharge
of treated secondary effluent in fresh water systems?
http://www.cdc.gov/
toxoplasmosis/
' http://www.mwrdgc.
dst.il.us
/RD/UAA/GEOSYNTEC.RISKASSESS.%2OFinal.pdf
4
Electronic Filing - Received, Clerk's Office, August 25, 2008
15.
How could you prove that low concentrations of pathogens detected in the CAWS
locations both upstream and downstream of the District WRPs are viable and/or infective
pathogens likely to cause detectable health effects?
16.
How can you prove that the effluent disinfection will lead to effective control of
pathogens (viruses and protozoa)?
17.
You cite
an on-line 3 reference that is in context to microbial source
tracking.
A.
The article actually appears to indicate that the measurement of fecal indicator
bacteria neither defines what pathogens are present, nor defines the sources of
these bacteria. Is that correct?
B.
If so, aren't you misinterpreting the article in your testimony?
18.
Page 9 Conclusions.
A.
Considering the other sources of pathogen loading to the CAWS, such as
stormwater runoff and combined sewer overflows, do you think that disinfection
at the treatment plants would make a meaningful difference in wildlife exposure
to pathogens?
B.
Did you consider whether disinfection would result in reduced total pathogens in
the CAWS
, rather than only the indicator parameter fecal coliform?
19.
Page 5, paragraph
5.
You refer to a book by Dr Mark Jerome Walters on human
influence on the natural world and resulting diseases.
A.
What
are the six modern plagues?
B.
Would you associate these plagues with the water quality in the CAWS or some
other factors?
C.
While the risks associated with untreated sewage are well known
,
do you have
data or know of any reports of plagues being associated with treated secondary
effluent in the
CAWS
or anywhere else?
D.
Do you agree that manmade intervention such as "disinfection" will change the
natural CAWS environment and will breed tougher unnatural bugs-"microscopic
predators"?
3Yan, T. and M. J. Sadowsky. (2007) Determining sources of microorganisms in waterways.
Environmental Monitoring and Assessment.
Online first (DOI:10.1007/s10661-006-9426-z).
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Electronic Filing - Received, Clerk's Office, August 25, 2008
20.
On
page 9, last paragraph
,
you state that, "If effluent from wastewater treatment plants
is not disinfected, it will contain pathogens that potentially cause disease in both wildlife
and humans."
A.
What sorts of wildlife impacts would be caused by disinfection byproducts?
B.
Do you have any qualifications to speak to the effects of District effluent on
humans?
C.
How do you know that wastewater effluent that is not disinfected will cause
disease in wildlife and/or humans?
D.
Do you know of any scientific evidence that any current wildlife populations
within the
CAWS
are suffering from diseases caused by District effluent?
E.
Are
you aware of any toxicological
(
wildlife and
/
or humans
) field
studies
conducted in the
CAWS that
show that effluent from District
WRPs
that is not
disinfected will cause disease in wildlife and/or humans?
F.
Are you aware that a recent study (i.e. Blatchley et al. 2007)4 suggests that the
long-term affects of disinfection may actually be detrimental to water quality, in
terms of bacterial composition?
G.
Published research strongly suggests that conventional disinfection processes are
not effective for control of the risks of disease transmission, particularly those
associated with viral pathogens. A paper published in Australia (Razzell, WE.
The
Realities of Disinfection in Water and Wastewater Treatment,
1990)5 also
concluded that treatment of discharges of effluent from sewage treatment plants
having secondary treatment is a waste of resources and a threat to the
environment apart from being ineffective as practiced conventionally. Are you
aware that inactivation of indicator bacteria does not guarantee an acceptable
degree of inactivation among waterborne pathogens?
H.
What evidence do you have that disinfection as currently practiced will
dramatically reduce levels of pathogens in the CAWS?
I.
You
state that,
"Wastewater that is collected
,
concentrated
and discharged by the
billions of
gallons into
the CAWS artificially
tips the balance
in their favor. "
(1)
Do you believe that wastewater is concentrated before being discharged
into the CAWS?
4Blatchley, et al. (2007
).
Effects of
Wastewater Disinfection on Waterborne Bacteria and Viruses.
Water
Environment Research
,
Volume 79, Number 1, pp 89-91.
5 Razzel
,
WE,
The Realities of Disinfection in Water and Wastewater Treatment
.
Institute of Engineers, Australia,
1989. National conference publication.
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Electronic Filing - Received, Clerk's Office, August 25, 2008
(2)
Are you aware that wastewater treatment processes do not concentrate but
remove up to 99% of contaminants from raw wastewater?
Dated:
August 25, 2008
By:
Fredric P. Andes
David T. Ballard
BARNES & THORNBURG LLP
Suite 4400
One North Wacker Drive
Chicago, Illinois 60606
(312) 357-1313
482449v1
Respectfully submitted,
METROPOLITAN WATER RECLAMATION
DISTRICT OF GREATER CHICAGO
Fredric P. Andes
7
Electronic Filing - Received, Clerk's Office, August 25, 2008
