Anonymous public comment

I am a certified, licensed wastewater operator in the state of Illinois and have been for over 20 years. I actively participate in many of the regulated activities that are outlined in our permit. Having this first-hand knowledge, I feel like there may be a few changes that could be advantageous to the operators and plants, as well as the agency. Every permittee has several "pollutants" that they are responsible for monitoring as well as removing from the water they treat. Some of these pollutants are very serious while others have more passive effects on the environment. Many plants send daily or weekly samples away to certified laboratories while some plants perform their own testing. In addition to the regular testing to monitor and report to the EPA, plants that perform their own tests are also required to participate in a "quality assurance" program to prove that they are capable of performing those tests and proficient enough to deliver accurate results. This is a necessary step for the agency to ensure that these laboratories are reporting the correct information to satisfy their permit requirements. Some plants have more items to test for than others and, for a small municipality, it can certainly become costly, in respect to both time and cost. While I certainly understand the need to remove most or all of these pollutants in the water before their release into the surrounding environment, my comment would look not to remove the quality assurance tests or to halt the agency from assigning parameters to treatment plants. Instead, I would recommend that there be a less arduous process for disputing or completely eliminating certain "pollutants" from being included on a plant's permit. Some of these "pollutants" occur normally in nature without any intervention and in such insignificant quantities that they would not have an excessive effect on their surroundings. I believe that a treatment facility, especially one with a respectable record with little to no permit violations or reporting infractions, should be able to dispute a parameter with the agency, particularly when the existing parameter is for a "pollutant" that is not extraordinarily hazardous. I have had particular experience with this concerning one parameter that we treat at our facility. This specific "pollutant" enters our plant in such insignificant amounts that we then have to reduce even further, sometimes at great effort and cost. But to what substantial end? My experience in the field allows me to see the need for our permit system and the meticulously planned parameters that they include. I would just like to see a bit less complicated process for dispute or removal of a parameter of an insignificant amount. This could, eventually, help to relieve a bit of stress on our laboratories and municipalities that try so hard to ensure such an impeccable product is released into the environment. Thank you.