Louise Michels
Springfield, Illinois62704

{Date}

Page 1

{Date}

Louise Michels

Staff Attorney

Illinois Emergency Management Agency

1035 Outer Park Drive

Springfield, Illinois62704

Re:Public Comments to 32 Ill. Adm. Code 330.40

Dear Ms. Michels:

{Entity’s name} is writing to express its concern{or indicate that Entity is opposed to} with the Illinois Emergency Management Agency’s (“IEMA’s”) proposed modifications to 32 Ill. Adm. Code 330.40 and the negative impacts that such regulation will have on {Entity’s name}. {Include if applicable Entity’s dissatisfaction with the rulemaking process, need to incorporate communities’ and/or Illinois landfill operators’ concerns as any final rule, and/or comment on deficiencies concerning first publication (see Slide Numbers 29 & 30 from webinar presentation)}.

By way of background, the {Entity} is a {Municipality orOther} with a population of {insert number}. The {Entity} operates its own publicly owned wastewater treatment works (“POTW”) consisting of a {indicate specific information regarding its WWTP operations}. {Add information regarding recent expenditures that the agency may have incurred to improve its system or any other relevant information specific to entity’s current financial position}. The {Entity’s} water is sourced from deep well water which containshigh concentrations of radium. {Include information if available regarding the concentrations of radium in sludge or if entity does not know current concentrations of radium include how this rulemaking process has given it insufficient notice to test and determine specifics of how this rule will impact the Entity}. As a result, the POTW operations produce radium-containing sewage sludge. The {Entity} generates approximately {indicate amount} of sewage sludge on an annual basis. The {Specify whether Entity utilizes land application and if so amount} utilizes the resulting sewage sludge as biosolids that are applied to approximately {Number of Acres} acres of land.

Specifically, the biosolids program {Specify details regarding Entity’s biosolids program}. The {Entity}has been operating this program for {Specify time period} and has had great success{Give any examples of how program has been successful for farmers and/or Entity}. The {Specify how the Entity has ensured safety of its program by monitoring and/or other activities. Include some specific details of monitoring including frequency, inception date etc.,} has been monitoring biosolids for radium since {Date} per Illinois Environmental Protection Agency’s (“Illinois EPA”) request. However, this was never required by any conditions of our permit with Illinois EPA previously. {Include if this applies}. {Discuss whether entity has considered other alternatives and if these alternatives are cost-prohibitive for the entity.}

{Discuss economic and other implications of proposed rule to current biosolids program. Alternatively, an entity can discuss how it was not subject to the rule but now may be}. Discuss potential other implications. (i.e., landfill space, costs associated with landfill disposal and/or transportation etc.,)}

The {Entity}currently has a contract for land application of biosolids with pricing of {Discuss economics of current land application program and how many applications are done pursuant to such}

Discuss how the current regulation will have impact on reducing current site life. The proposed rule will also impact site use by reducing the current site life {from ___ to ____}. After {Years} of application the {Number} acres cannot be used and any future sites can only be applied on for{Years or specify other time period}. {Discuss how rule will increase competition for land and consequently, this will ultimately impact the distance the material has to be hauled and the related costs.}

Based on the above, the {Entity}would like to respectfully request that IEMA withdraw its proposed regulation or in the alternative that it adopt a program such as that of the State of Wisconsin that will be protective of human health and the environment while not unduly burdening the {Entity} and other similarly situated municipalities.

Respectfully submitted,

______

{Entity}