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              Salt Creek TMDL- Appendix H
Draft Report for USEPA Approval 50 July 2004
Thank you for your willingness to work with any agency or organization to better manage and
apply deicer salt or other chemicals. In the near future the Agency will contact local
governmental agencies and others to suggest alternative means and possible funding options to
reduce road salt use, consistent with public safety limitations.
150. The Forest Preserve District of DuPage County (the “District”) fully supports the goal of the
TMDL program, which is to improve water quality in our lakes, streams and rivers. Organizationally,
many of the District’s policies emphasize the importance of controlling and eliminating pollution in
our waterways. Our Land Management Policy states “Rivers and streams within District boundaries
shall be left in a natural state. Winding courses, eddies, riffles, rapids or falls, shaded banks, vegetated
banks, oxbows and backwaters, all contribute to a diverse and healthy stream.” We have a Policy on
the Development, Preservation and Operation of Historic Structures, which states our support for the
preservation of “… structures connected with events important to the patterns of history; structures
connected with regionally important people; structures that represented community development or
were instrumental to settlement of an area; and structures that are essentially intact or undisturbed.”
The Graue Mill Dam at Fullersburg Woods Forest Preserve, which is owned by the District, clearly
falls into this category of being an important historic structure. A dam has existed at this site since at
least 1852, to supply a source of waterpower for a gristmill constructed by Frederick Graue, one of
DuPage County’s earliest settlers. The existing dam was constructed in 1934 by the Civilian
Conservation Corps, as part of the Works Progress Administration. The Graue Mill is a National
Historic Landmark, and one of DuPage County’s most popular tourist destinations. Visitors are able
to see the mill operate virtually the same way that it did 150 years ago. It is my understanding that the
Graue Mill has the only operable millrace powered waterwheel in the State of Illinois. So, admittedly,
the District has conflicting policies regarding the Graue Mill Dam at Fullersburg Woods. Without the
historic significance of the structure, and its critical importance in the overall operation and
interpretive programs at the Graue Mill, our existing policies would seem to lead us to support the
recommended removal of the dam. We agree that the dam does create some negative impacts on
water quality and the overall ecological health of Salt Creek. However, the historic importance of the
dam cannot be ignored, as the draft version of the TMDL report has done.
Thank you for giving a detailed background and history of the Graue Mill and Fullersburg
dam. The historic, cultural and economic value of this dam will be considered when a final plan
to bring Salt Creek in compliance with DO Water Quality Standards is implemented. Please
refer to our responses to comments #1 and #2 for our plan on accomplishing that goal.
151. It appears to us that the draft Salt Creek Watershed Implementation Plan offers two basic
alternatives with respect to the TMDL for dissolved oxygen: 1) Reduce the average monthly
allowable pollutant concentrations of CBDO5 and ammonia to 5.0 mg/L and 1.0 mg/L, respectively,
at the wastewater treatment plants within the Salt Creek watershed, or 2) remove the Graue Mill Dam
at Fullersburg Woods. If we understand the report correctly, the cost of the first alternative is
estimated to be $18 million, on a watershed-wide basis, while the cost for the dam removal option has
not been calculated.
The cost of dam removal was not estimated in the report due to the complex nature of the
project. If dam removal is adopted as a viable implementation strategy, removal estimates can
be made through cooperative interaction between stakeholders, in the form of a watershed
committee, and the Agency. This report, and its subsequent approval by USEPA, is the first
step in establishing load reductions and implementing pollution reduction strategies in the
watershed.