April 13, 2007
City of Salem
)
Petitioner,
)
V .
)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent .
)
Re:
Provisional Variance From Limits for Carbonaceous Biochemical Oxygen
Demand (CBOD), Total Suspended Solids (TSS), and Ammonia Nitrogen
Of NPDES Permit IL0023264
Dear Mr. Besalke :
The Illinois Environmental Protection Agency (Agency) has completed its technical
review of the attached provisional variance request (Attachment A) submitted by the City
of Salem on April 12, 2007
. The City is undergoing improvements to its wastewater
treatment plant
. The City is requesting this provisional variance so that it can take the
North Oxidation Ditch No
. 1 out of service while the oxidation ditch walls are being
raised and new equipment is installed in the oxidation ditch
. Based on its review, the
Agency GRANTS a provisional variance subject to the specific conditions set forth
below
.
Background
The City of Salem owns and operates a wastewater treatment facility located at 801 East
Lake Street in Salem, Illinois
. This treatment facility consists of an oxidation ditch mode
activated sludge plant designed to treat 1
.672 million gallons per day (MGD) design
average flow and 3
.762 MGD design maximum flow
. The treatment system consists of
screening, dual oxidation ditches, clarification, and sand filtration
. The facility's main
outfall, Outfall 001, discharges to Town Creek
.
In order to complete the improvements to the wastewater treatment plant, the City will
need to take the North Oxidation Ditch No
. 1 out of service while the oxidation ditch
walls are raised and new equipment is installed in the oxidation ditch
. During this
construction period the City will have one oxidation ditch in service, instead of two,
resulting in twice as much wastewater being treated by the remaining oxidation ditch
.
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
REC
CLERK'S
DIVED
OFFICE
APR i . E 2007
Pollution
STATEOFControl
ILLINOISBoard
IEPA - 07-14
(Provisional Variance-Water)
On March 7, 2007, the Agency granted a provisional variance to the City so that it could
take the South Oxidation Ditch No
. 2 out of service to have the walls raised and new
equipment installed in that oxidation ditch
. This earlier provisional variance started on
March 12, and will end on April 25, 2007 or when the South Oxidation Ditch No
. 2 is
returned to service, whichever occurs earlier
.
Relief Requested
The City requests a provisional variance from the permit limits contained in NPDES
Permit IL0023264 for CBOD, TSS and ammonia nitrogen (Attachment B)
. This permit
requires the City to meet a monthly average limit of 10 mg/I for CBOD and 12 mg/l for
TSS, a daily maximum limit of 20 mg/l for CBOD and 24 mg/l for TSS, and the
following limits for ammonia nitrogen
:
Agency Determinations
The Agency has reviewed the requested provisional variance and has concluded the
following :
1 .
The environmental impact from the requested relief is predicted to be minimal
;
2 .
No reasonable alternatives appear available ;
3 .
No public water supplies should be affected
;
4.
No federal regulations will preclude the granting of this request
; and
5 .
The City will face an arbitrary and unreasonable hardship if the request is not
granted.
Conditions
The Agency hereby GRANTS the City of Salem a provisional variance from the CBOD,
TSS and ammonia nitrogen limits of NPDES Permit IL0023264, subject to the following
conditions:
A.
The provisional variance shall begin in April 2007, on the date that the City
contacts Barb Conner of the Agency by telephone, and shall continue for no more
than 45 days after that date, during which time the City does not have to meet the
Month
Monthly Avg . (mg/1)
Daily Max
. (mg/1)
April-Oct .
1 .5
3 .0
Nov .-March
3 .9
7 .0
CBOD, TSS, and ammonia nitrogen effluent limits specified in NPDES permit
IL0023264
.
B .
The City shall operate its system to produce the best effluent possible, and at no
time shall the effluent exceed the limits of 45 mg/I for CBOD, 45 mg/I for TSS,
and 15 mg/I for ammonia nitrogen
. All other requirements of NPDES permit
IL0023264 will be maintained during the variance period .
C.
The City shall notify Barb Conner of the Agency by telephone at 217/782-9720
when the improvements on the North Oxidation Ditch No . I begin and it is taken
out of service and again when repairs are complete and the North Oxidation Ditch
No. 1 is returned to service
. Written confirmation of each notice shall be sent
within five days to the following address :
Illinois Environmental Protection Agency
Bureau of Water - Water Pollution Control
Attention: Barb Conner
1021 North Grand Avenue East, MC #19
Springfield, Illinois 62794-9276
G.
The City shall sign a certificate of acceptance of this provisional variance and
forward that certificate to Barb Conner at the address indicated above within one
day of the date of this order . The certification should take the following form
:
I (We) , hereby accept and agree to be bound by all terms
and conditions of the provisional variance granted by the Agency in
Petitioner
dated
Authorized Agent
Title
Date
The City shall continue to monitor and maintain compliance with all other parameters
and conditions specified in its NPDES Permit No. IL0023264 .
Conclusion
The Agency grants this provisional variance in accordance with its authority contained in
Sections 35(b), 36 (c), and 37(b) of the Illinois Environmental Protection Act (415 ILCS
5/35(b), 36(c), and 37(b) (2004). The decision to grant this provisional variance is not
intended to address compliance with any other applicable laws or regulations .
Robert A . Messina
Chief Legal Counsel
c :
Marcia Willhite
Barb Conner
Vera Herst
Leonard Ferguson, Mayor of the City of Salem
Consulting Engineers
April 12, 2007
Roger Calloway
Illinois Environmental Protection Agency
Bureau of Water
Division of Water Pollution Control
Compliance Assurance Section
1021 North Grand Avenue East
P .O. Box 19276
Springfield, IL 62794-9276
Re:
City of Salem
North Oxidation Ditch No . I
Wastewater Treatment Plant Improvements
Request for Provisional Variance from NPDES Permit Limits
& Pollution Control Board Regulations
Dear Mr . Calloway
:
We have previously been corresponding with Barb Conner, who is apparently on
vacation . She has requested that we direct this request to your attention in her absence .
A Provisional Variance was previously granted for the South Oxidation Ditch No
. 2
. This
request for a Provisional Variance is due to the work being conducted on the other
oxidation ditch, North Oxidation Ditch No . 1 .
Pursuant to our meeting of April 8, 2005 and correspondence of May 12, 2006 we are
requesting that the City of Salem be granted a provisional variance from their NPDES
Permit limits (Permit No
. 1L0023264) while improvements are made to their wastewater
treatment plant .
Per the Agency's request we are responding to the following 13 items :
1)
A statement identifying the regulations, Board Order, or permt
requirements from which the variance is requested ;
A variance is requested from the City of Salem's NPDES Permit limits .
Specifically, we request that the requirements for CBOD, TSS and
ammonia are increased as follows :
CBOD
45 mg/L
TSS
45 mg/L
Ammonia
15 mg/L
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2)
A
description of the business or activity for which the variance is
requested, including pertinent data on location, size, and the population
and geographic area affected by the applicant's operations ;
The City is undergoing improvements to their wastewater treatment plant
that involve many different facets of their treatment process including
upgrading their existing oxidation ditches and constructing new secondary
clarifiers . The construction will require taking North Oxidation Ditch No . 1
out of service and raising the oxidation ditch walls, which will increase the
volume
. In addition, new oxidation ditch equipment will be installed
.
While
these improvements are being constructed the City will have only
one oxidation ditch in service instead of two, resulting in twice as much
wastewater being treated by one oxidation ditch .
3)
The quantity and types of materials used in the process or activity for
which the variance is requested, as appropriate
;
This involves oxidation ditches and secondary clarifiers used in the City's
wastewater treatment process .
4)
The quantity, types and nature of materials or emissions to be
discharged, deposited or emitted under this variance, and the
identification of the receiving waterway or land, or the closest receiving
Class A and Class B land use, as appropriate
;
The materials to be discharged in excess of NPDES permit limits are
CBOD, TSS
and ammonia from secondary effluent at the
City's
wastewater treatment plant .
5)
The quantity and types of materials in drinking water exceeding the
allowable content, or other pertinent facts concerning variances from th3
Board's public water supply regulations;
Not applicable .
6)
An assessment of any adverse environmental impacts which the variance
may produce;
Minimal adverse environmental impacts are anticipated
during the
variance period
. If the requested work cannot be done and a mechanical
breakdown occurs, severe environmental impacts could occur .
7)
A statement explaining why compliance with the Act, regulations or Board
Order imposes arbitrary and unreasonable hardship ;
The City must make these improvements to ensure compliance is
maintained in the future
.
Without this variance these improvements
cannot be made, which could result in non-compliance and a hardship on
the City .
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8)
A description of the proposed methods to achieve compliance with the
Act, regulations or Board Order, and a timetable for achieving such
compliance;
During the interim, while the City is operating its wastewater treatment
plant with one oxidation ditch the City will make every attempt to
maximize performance of the equipment in operation and construct the
proposed improvements as quickly as the City's contractor can construct
the improvements . The City will complete all of the necessary
improvements within 45 days.
9)
A discussion of
alternate methods of compliance and of the factors
influencing the choice ofapplying
for a provisional variance;
The upgrades that are being constructed that require the oxidation
ditches to be taken out of service are necessary due to the increased
flows to the existing plant. The City is in a position where it has to expand
the capacity of its existing wastewater treatment plant and it is
rehabilitating and increasing the capacity of its existing oxidation ditches .
In order to reuse and rehabilitate the existing oxidation ditches there are
no other alternatives available .
10)
A statement of the period, not to
exceed 45 days, for which the variance
is requested;
As previously discussed, the date for the proposed modifications to the
Oxidation Ditch No
. 1 is April 2007 . Because the exact date that each of
the Oxidation Ditches will be taken out of service cannot be determined in
advance, we recommend that the variance be granted with the official
date of the beginning of the variance be coordinated with IEPA personnel,
The variance would begin when the City of Salem contacts the IEPA and
would end when the improvements to the oxidation ditch are completed
and the City of Salem contacts the IEPA . In no case will this provisional
variance exceed 45 days .
11)
A statement of whether the applicant has been granted any provisional
variances within the calendar year, and the terms and duration of such
variances;
A Provisional Variance for 45 days was previously issued to the City of
Salem for taking the South Oxidation Ditch No . 2 out of service . The
request for the Provisional Variance for the South Oxidation Ditch No
. 2
was requested by Crawford, Murphy & Tilly, Inc . on behalf of the City of
Salem in a letter to the IEPA dated February 15, 2007
. The Provisional
Variance was granted by the IEPA
. The date of the Provisional Variance
is March 7, 2007 . The date that the 45 day period began is March 12 .
2007 .
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12)
A statement regarding the applicant's current permit status as related to
the subject matter of the variance request;
As previously discussed with the IEPA during a November 30, 2006
phone conversation, the City of Salem has an excellent history of meeting
its NPDES permit requirements
.
13)
Any Board orders in effect
regarding the applicant's activities and any
matters currently before the Board in which the applicant is a party .
None.
We appreciate your assistance with this matter
. Should you have any questions
regarding this matter, please don't hesitate to contact the undersigned at 572-1050 .
Sincerely,
CRAWFORD, MUR
ILLY, INC .
c:
City of Salem
C
. UUS/UU5
217/782-0610
August 24, 2005
City of Salem
101 South Broadway
i- t
Salem, Illinois 62881-1699
3021 NORTH C.ueNO AvENUF LASI,
P O . Box 19276
. SPRING,HELO, ILLINOIS 62794 .9276 - (21 7) 782
3397
)AMLS R
1HOMPSON CENTER, 100 WtST RANDULPH, SUITE
11-300, CHICAGO, IL 60601 -(312) 814 6026
Roo R . BLACOIEVICr1, GOVERNOR
DOUGLAS P . SCOTT, DIRECTOR
ILLINOIS
E-NVIRONMEN PAL PRO I1C-ION AGENCY
PC
City of Salem
Sewage Treatment Plant
NPDES IL0023264
Modification of NPDES Permit (Without Public Notice)
Dear Sir or Madam
The Illinois Environmental Protection Agency has reviewed your NPDES permit and discovered an error
in the daily maximum concentration limit for CBOD 5 on Page 2 of the permit . We have modified the
permit as follows
the daily maximum concentration limit for CBOD
5
on Page 2 of the permit was revised from 12 mg/L to
20 mg/t,
Enclosed is a copy of the modified Permit . Because the change made in the permit was minor, no formal
Public Notice of the modification will be issued .
Should you have questions or comments, please contact Landon Niedringhaus of my staff
Sincerely,
Alan
rIL4,
Kelley, P-E-
/ji, j
~/a
V
Manager, Permit Section
Division of Water Pollution Control
SAY, ELN J \niedxing\files\Salem NPDES Modification
Enclosure Modified Permit
cc-
CMT
Records Unit
CAS
Collinsville Regional Office
US EPA
ROO(foRO-4302 Nosh Main Street, Rockford, IL 61103-(815) 987-7760
DES PLnwes-9571 W
. Harrison St, I)es PI aines, IL 60016 -(847) 294-40D0
OcIN-595 South State, Elgin, IL 60123-1847) 608-3131
PEORIA-5415 N . Univernty St, Peoria, IL 61614-(309) 6935463
BUREAU or LAND- PEORIA -7620 N . University St ., Peoria, IL 61614-(309) 693-5462
• CHAMPAION-2125 South first Street, Champ a, gm IL 61820-(217) 278-5800
SINNC(iELD-4500 S Sixth Street Rd ., Springfield, IL 62706-(217) 786-6892
COLLINSVrLLE-2009 Mall Street, Colllnseitle, IL 62214-(618) 346-5120
MARION-2309 W
. Main St ., Suite 1' 6, Marion, IL 62959 -(618) 993-7200
Attachment B
C. rtV'
NPDES Permit No IL0023264
Illinois Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
Modified (NPDES) Permit
Expiration Date. September 30, 2010
Issue Date : March 10, 2005
Effective Date : October 1, 2005
Modification Date. August 24, 2005
Name and Address of Permittee
:
Facility Name and Address
:
City of Salern
Salem STP
101 South Broadway
801 East Lake Street
Salem, Illinois 62881
Salem, Illinois
(Marion County)
Receiving Waters
: Town Creek
In compliance with the provisions of the Illinois Environmental Protection Act, Title 35 of the III . Adm Code, Subtitle C, Chapter I, and the
Clean WaterAct(CWA), the above-named Permittee is hereby authorized to discharge at the
above location to the above-named receiving
stream in accordance with the standard conditions and attachments herein
.
Permittee is not authorized to discharge after the above expiration date . In order to receive authorization to discharge beyond the
expiration date, the Permittee shall submit the proper application as required by the Illinois Environmental Protection Agency (]EPA) riot
later than 180 days prior to the expiration date .
Alan Keller, P
.E .
Manager, Permit Section
Division of Water Pollution Control
SAK .ELN :04122101 dlk
Paye 2
Modiicatlon Dale
: August 2a, 2005
NPDES Permit No . ILU023264
Effluent Limitations,
. Monitoring, and Reporting
FINAL
Discharge Number(s) and Name(s)
. 001 STP Outfall
Load limits computed based on a design average flow (DAF) of 1
.672 MGD (design maximum flow (DMF) of 3
.762 MGD)_
Excess flow facilities (if applicable) shall not be utilized until the main treatment facility is receiving its maximum practical
flow .
From the effective date of this Permit until the attainment of operational level of the expanded facility, the effluent of the above discharge(s)
shall be monitored and limited at all times as follows
:
*Load limits based on design maximum now shall apply only when
flow exceeds design average flow_
"Carbonaceous BOD E (CBOD 5 )
testing shall be In accordance with 40 CFR 136
***See Special Condition 7
.
Flow shall be reported on the Discharge Monitoring Report (DMR) as monthly average and daily maximum
.
pH shall be reported on the DMR as a minimum and a maximum
.
For flow up to and including 3
.762 MGD discharges from Discharge Number 001 shall be monitored at a point representative of the
discharges from Discharge Number001 CBOD
5 ,
Suspended Solids, and Ammonia Nitrogen shall be monitored at a point representative
of the discharge but prior to admixture with the excess
flow discharge (A01)
LOAD LIMITS lbs/day
CONCENTRATION
DAF (DMF)"
LIMITS MG/L
Parameter
Flow (MGD)
Monthly
Average
Weekly
Average
Daily
Maximum
Monthly
Weekly
Average
Average
Daily
Maximum
Sample
Frequency
Continuous
Sample Type
CBOD s"
139 (314)
219 (628)
10
20
1 Day/Week
Composite
Suspended Solids
167 (377)
335 (753)
12
24
1 Day/Week
Composite
pH
Shall be in the range of 6 to 9 Standard Units
1 Day/Week
Grab
Chlorine Residual"'
0 .05
1 Day/Week
Grab
Ammonia Nitrogen
as (N)
April-October
21 (47)
42 (94)
November-March
54 (122)
1
.5
3
.0
1 Day/Week
Composite
98 (220)
3 .9
7 .0
1 Day/Week
Composite
Page 3
Modification Date. August 24, 2005
NPDES Permit No
. IL0023264
Effluent Limitations Monitornq, and Reporting
FINAL
Discharge Number(s) and Narne(s) . 001 STP Outfall
Load limits computed based on a design average flow (DAF) of 2
.508 MGD (design maximum flow (DMF) of 7_023 MGD)
.
Excess flow facilities (if applicable) shall not be utilized until the main treatment facility is receiving its maximum practical flow
.
From the attainment of operational level of the expanded facility until the expiration date, the effluent of the above discharge(s) shall he
monitored and limited at all times as follows :
*Load limits based on design maximum flow shall apply only when flow exceeds design average flow
.
"Carbonaceous BOD 3 (CBOD 5
) testing shall be in accordance with 40 CFR 136
.
"'See Special Condition 7 .
Flow shall be reported on the Discharge Monitoring Report (DMR) as monthly average and daily maximum
.
pH
,,halt be reported on the DMR as a minimum and a maximum .
Dissolved oxygen shall be reported on DMR as minimum .
For flow up to and including 7
.023 MGD discharges from Discharge Number 001 shall be monitored at a point representative of the
discharges from Discharge Number 001 . CBOD 3 ,
Suspended Solids, and Ammonia Nitrogen shall be monitored at a point representative
of the discharge but prior to admixture with the excess flow discharge (A01) .
LOAD LIMITS Ibs/day
-
DAF (DMF)'
CONCENTRATION
LIMITS MG/L__
Parameter
Flow (MGD)
Monthly
Average
Weekly
Average
Daily
Maximum
Monthly
Weekly
Average
Average
Daily
Maximum
Sample
Frequency
Continuous
Sample Type
CBOD 3 "'
209 (586)
418 (1171)
10
20
3 Days/Week
Composite
Suspended Solids
251 (703)
502 (1406)
12
24
3 Days/Week
Composite
Dissolved Oxygen
Shall not be less than 6 mg/L
3 Days/Week
Grab
pH
Shall be in the range of 6 to 9 Standard Units
3 Days/Week
Grab
Fecal Coliform
Chlorine Residual
See Special Condition 8
.
0 .05
3 Days/Week
Grab
Ammonia Nitrogen
as (N)
April-October
31 (88)
63 (176)
November-February
82 (228)
1 .5
3 .0
3 Days/Week
Composite
146 (410)
March
73 (205)
3 .9
7
.0
3 Days/Week Composite
146 (410)
3 .5
7 .0
3 Days/Week
Composite
Phosphorus
21 (59)
42(117)
1 .0
2 .0
3 Days/Week Composite
Page 4
Modification Date. August 24, 2005
NPDES Permit No . IL0023264
Effluent Limitations, onitoring, and Reporting
FINAL
Discharge Numbers) and Name(s) : A01
These flow facilities shall not be utilized until the main treatment facility is receiving its maximum practical now .
From the effective date of this Permit until the expiration date, the effluent of the above discharge(s) shall be monitored and limited at all
times as follows :
Total flow in million gallons shall be reported on the Discharge Monitoring Report (DMR) in the quantity maximum column
Report the number of days of discharge in the comments section of the DMR .
Fecal Coliform shall be reported on the DMR as daily maximum .
Chlorine Residual shall be reported on the DMR as a monthly average concentration .
pH shall be reported on the DMR as a minimum and a maximum .
BOD5 and Suspended Solids shall be reported on the DMR as a monthly average concentration_
CONCENTRATION
LIMITS mq/L
Parameter
Monthly Average
Sample Frequency
Sample Type
Total Flow (MG)
See Below
Daily When Discharging
Continuous
BODS
30
Daily When Discharging
Grab
Suspended Solids
30
Daily When Discharging
Grab
Fecal Coliform
Daily Maximum Shall Not Exceed 400 per 100 mL
Daily When Discharging
Grab
pH
Shall be in the range of 6 to 9 Standard Units
Daily When Discharging
Grab
Chlorine Residual
0 .75
Daily When Discharging
Grab
Page 5
Modification Date : August 24, "2005
NPDES Permit No . 11 .0023264
Influent Monitoring, and Reporting
I he influent to the plant shall be monitored as follows
.
Parameter
Sample Frequency
Sample Type
Flow (MGD)
BOD,'
1 Day/Week
Composite
Suspended Solids`
I Day/Week
Composite
Influent samples shall be taken at a point representative of the influent
-
Flow (MGD) shall be reported on the Discharge Monitoring Report (DMR) as monthly average and daily maximum_
BOD, and Suspended Solids shall be reported on the DMR as a monthly average concentration_
'Influent sampling shall be 3 days/week upon attainment of operational level of the expanded facility
Page
u
NP DES Perrmt No . IL0023264
Special Conditions
SPECIAL CONDITION
1 This Permit may be modified to include different final effluent limitations or requirements which are consistent
with applicable laws, regulations, or judicial orders The IEPA will public notice the permit modification
SPECIAL CONDITION 2
The use or operation of this facility shall be by or under the supervision of a Certified Class 1 operator
.
SPECIAL CONDITION 3 .
The IEPA may request in writing submittal of operational information in a specified form and at a required
frequency at any time during the effective period of this Permit .
SPECIAL CONDITION
4- The IEPA may request more frequent monitoring by permit modification pursuant to 40 CFR § 122 63 and
Without Public Notice in the event of operational, maintenance or other problems resulting in possible effluent deterioration .
SPECIAL CONDITION 5
. The effluent, alone or in combination with other sources, shall not cause a violation of any applicable water
quality standard outlined in 35 III . Adm . Code 302 .
SPECIAL CONDITION
6- Samples taken in compliance with the effluent monitoring requirements shall he taken .
A . For Discharge Number 001
- During dry weather flows (no excess flow discharge), samples shall be taken at a point representative
of the flows but prior to entry into the receiving stream
. Duringg periods of excess flow discharge, CBOD 5 , Suspended Solids, and
Ammonia Nitrogen, if Ammonia Nitrogen monitoring and sampling is required on the Effluent Limitations, Monitoring, and Reporting
Page of this Permit, shall be monitored at a point representative of the discharge but prior to admixture with the excess flow- It Fecal
Collform limits are different for Discharge Numbers 001 and A01, sampling shall occur at a point representative of the discharge and
prior to admixture, if hardware allows- Other parameters may be sampled after admixture but prior to entry into the receiving stream-
B . For Discharge Number A01
- Samples for all parameters shall be taken at a point representative of the discharge but prior to entry
into the receiving stream
. If Fecal Coliform limits are different for Discharge Numbers 001 and A01, sampling shall occur at a point
representative of the discharge and prior to admixture, if hardware allows . The sampling point for other parameters may be at a point
after admixture with the dry weather flows .
SPECIAL CONDITION 7- For Discharge No
. 001, any use of chlorine to control slime growths, odors or as an operational control, etc . shall
not exceed the limit of 0-05 mg/L (daily maximum) total residual chlorine in the effluent
. Sampling is required on a daily grab basis during
the chlorination process . Reporting shall be submitted on the DMR's on a monthly basis .
SPECIAL CONDITION 8- For Discharge No
. 001, the Permittee shall initiate sampling for fecal coliform after the revised facility has
reached stable operation, but not later than six (6) months after start up . Sampling shall be a minimum of four (4) grab samples, at a
minimum of seven (7) day intervals in order to verify the original assumptions made in the modeling used to grant the disinfection
exemption- The four (4) results, expressed in terms of fecal coliform per 100 mL of sample ("too numerous to count" results cannot he
accepted), shall be reported to the IEPA within seven (7) days of the final sample being analyzed and submitted to the following address .
Illinois Environmental Protection Agency
Division of Water Pollution Control, Water Quality Standards Unit
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
SPECIAL CONDITION 9 . The Permittee shall monitor the effluent and report concentrations (in mg/L) of the following listed parameters
eighteen (18) months prior to the expiration date and again at twelve (12) months .prior to the expiration date . The sample shall be a 24-
hour effluent composite except as otherwise specifically provided below and the results shall be submitted on Discharge Monitoring Report
Forms to IEPA unless otherwise specified by the IEPA . The parameters to be sampled and the minimum detection limits to be attained
are as follows :
Modification Date
. August 24, 2005
STORET
Minimum
CODE
PARAMETER
detection limit
01002
Arsenic
0 .05 mg/L
01007
Barium
0-5 mg/L
01027
Cadmium
0 .001 mg/L
01032
Chromium (hexavalent)
.(grab)
0-01 mg/L
Page /
Modification Date . August 24, 2005
Unless otherwise indicated, concentrations refer to the total amount of the constituent present in all phases, whether solid, suspended or
dissolved, elemental or combined, including all oxidation states
.
* 1 0 ng/L = I part per trillion .
SPECIAL CONDITION 10 .
The Permittee shall monitorthe effluentforthe following parameters monthly fora period of six (6) consecutive
months, beginning three (3) months from the date that stable operation of the expanded plant is achieved_ This Permit may be modified
with public notice to establish effluent limitations if appropriate, based on information obtained through sampling
. The sample shall be a
24-hour effluent composite except as otherwise
specifically
provided below and the results shall be submitted on the DMR's to IEPA . The
parameters to be sampled and the minimum detection limits to be attained are as follows
.
STORET
Minimum
CODE
PARAMETER
detection limit
01092
Zinc
0-025 mg/L
Unless otherwise indicated, concentrations referto the total amount of the constituent present in all phases, whether solid, suspended or
dissolved, elemental or combined, including all
oxidation states .
SPECIAL CONDITION
11 The Permittee may collect data in support of developing a site-specific metals translator for zinc Total and
dissolved metals for a minimum of twelve weekly samples need to be collected from the effluent and at a downstream location indicative
of complete mixing between the effluent and the receiving water to determine a metal translator for these parameters
. The IEPA will review
submitted sample data and may reopen and modify this Permit to eliminate or include revised effluent limitations for these parameters
based on the metal translator determined from the collected data .
SPECIAL CONDITION 12
. The Permittee has undergone a Monitoring Reduction review and the influent and effluent sample frequency
has been reduced for BOD, CBOD, Suspended Solids, Ammonia & pH due to sustained compliance . The IEPA will require that the influent
and effluent sampling frequency for these parameters be increased to 3 days/week if effluent deterioration occurs due to increased
wasteload, operational, maintenance or other problems . The increased monitoring will be required
Without Public Notice when a permit
modification is received by the Permittee from the IEPA .
SPECIAL CONDITION 13 . During January of each
year the Permittee shall submit annual fiscal data regarding sewerage system
operations to the Illinois Environmental Protection Agency/Division of Water Pollution Control/Compliance Assurance Section . The
Permittee may use any fiscal year period provided the period ends within twelve (12) months of the submission date .
Submission shall be on forms provided by IEPA titled "Fiscal Report Form For NPDES Permlttees'"
.
SPECIAL CONDITION 14
. The Permittee shall prepare a preliminary plan for biomonitoring and submit the plan to IEPA for review and
NPDES Permit No IL0023264
Special Conditions
STORET
CODE_
PARAMETER
Minimum
detection limit
01034
Chromium (total)
0 05
mg/_
01042
Copper
0 005 mg/L
00718
Cyanide (grab) (weak acid dissociable)
5 .0 ug/L
00720
Cyanide (grab not to exceed 24 hours) (total)
5 0 ug/L
00951
Fluoride
0 .1 mg/L
01045
Iron (total)
0 .5 mg/L
01046
Iron (Dissolved)
0-5 mg/L
01051
Lead
0 .05 mg/L
01055
Manganese
0 .5 mg/L
71900
Mercury (grab) (using USEPA Method 1631 or equivalent)
1 .0 ng/L'
01067
Nickel
0-005 mg/L
00556
Oil (hexane soluble or equivalent) (Grab Sample only)
5 0 mg/L
32730
Phenols (grab)
0 005 mg/L
01147
Selenium
0 .005 mg/L
01077
Silver (total)
0-003 mg/L
01092
Zinc
0 .025 mg/L
Page 8
Modification Date. August 24, 2005
NODES Permit No
. IL0023264
Special Conditions
approval within ninety (90) days of the start of operation of the expanded plant The Permittee shall begin biomonitoring of the effluent
discharge within ninety (90) days after approval of the biomonitoring plan or other such date as contained in the
[EPA's
notification letter .
Biomonitorinq
Acute Toxicity -
Standard definitive acute toxicity tests shall be run on at least two (2) trophic levels of aquatic species (fish,
invertebrate) representative of the aquatic community of the receiving stream
. Testing must be consistent with
Methods for M easuring
the
shall
Acute
be reported
Toxicity
in
of
accordance
Effluents and
with
Receiving
Section 12
Waters
Unless
to
substitute
Freshwater
tests
and Marine
are pre-approvedOrganisms
;
Fifth
the following
Ed
.)EPA-821-R-02-012tests
are required
. Results
Fish -
96 hour static or static renewal LC,o
Bioassay using 1- to 14-day old fathead minnows (Pimephales promelas)
.
b
Invertebrate 48-hour static LC,, Bioassay using Ceriodaphnia
Testing Frequency -
The above tests shall be conducted on a monthly basis for six (6) months within ninety (90) days following
performed
approval of
using
the biomonitoring
24-hour composite
plan
effluent
or other
samples
such date
unless
as contained
otherwise
in
authorized
the IEPA's
by
notification
the IEPA
.
(approval)
Results shall
letterbe
submitted
. Tests shall
to IEPAbe
within one (1) week of becoming available to the Permittee
.
Should the results of two (2) months of sampling indicate toxicity for each month, the Permittee may wish to contact the IEPA to
request the discontinuance of further sampling at which time the IEPA may require the Permittee to begin the toxicity reduction
evaluation and identification as outlined below .
Toxicity Assessment
- Should the review of the results of the biomonitoring program identify toxicity, the IEPA may require that the
Permittee prepare a plan for toxicity reduction evaluation and identification
. This plan shall be developed in accordance with Toxicity
Reduction Evaluation Guidon -
e for Municipal Wastewater Treatment Plants,
EPA/8338-99/002, and shall include an evaluation to
determine which chemicals have a potential for being discharged in the plant wastewater, a monitoring program to determine their
presence orabsence and to identify other compounds which are not being removed by treatment, and othermeasures as appropriate
The Permittee shall submit to the IEPA its plan for toxicity reduction evaluation within ninety (90) days following notification by the
IEPA
. The Permittee shall implement the plan within ninety (90) days or other such date as contained in a notification letter received
from the IEPA .
The IEPA may modify this Permit during its term to incorporate additional requirements or limitations based on the results of the
biomonitoring
. In addition, after review of the monitoring results, the IEPA may modify this Permit to include numerical limitations
for specific toxic pollutants
. Modifications under this condition shall follow public notice and opportunity for hearing
.
SPECIAL CONDITION 15 .
The Permittee shall conduct biomonitoring of the effluent from Discharge Number(s) 001
Biomonitorinq
1 .
Acute Toxicity- Standarddefnitiveacutetoxicitytestsshallberunonatleasttwotrophiclevelsofaquaticspecies(fsh,invertebrate)
representative of the aquatic community of the receiving stream
. Testing must be consistent with Methods for Measuring the Acute
Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms (Fifth Ed-) EPA/821-R-02-012 .
Unless substitute
tests are pre-approved ; the following tests are required
:
a .
Fish
- 96 hour static LC,, Bioassay using fathead minnows (Pimephales promelas)
.
b .
Invertebrate 48-hour static
LC,,, Bioassay using Ceriodaphnia .
Testing Frequency- The above tests shall be conducted using 24-hour composite samples unless otherwise authorized by the IEPA
.
Samples must he collected in the 18th, 15th, 12th, and 9th month prior to the expiration date of this Permit
.
Reporting -
Results shall be reported according to EPA/821-R-02-012, Section 12, Report Preparation, and shall be submitted to
IEPA, Bureau of Water, Compliance Assurance Section within one week of receipt from the laboratory
. Reports are due to the IEPA
no later than the 16th, 13th, 10th, and 7th month prior to the expiration date of this Permit
.
Page 9
Modification Date. August 24, 2005
NPDES Permit No
. IL0023264
Special Conditions
Toxicity Reduction Evaluation -
Should the results of the biomonitoring program identify toxicity, the IEPA may require that the
Reduction
Permittee prepare
Evaluation
a plan
Guidance
for toxicity
for Municipal
reduction evaluation
Wastewater
and
Treatment
identificationPlants,
. This
EPAB33B-99/002,
plan shall be
and
developed
shall
in
include
accordance
an evaluation
with
Toxicityto
determine which chemicals have a potential for being discharged in the plant wastewater, a monitoring program to determine their
presence or absence and to identify other compounds which are not being removed by treatment, and other measures as appropriate
.
The Permittee shall submit to the IEPA its plan for toxicity reduction evaluation within ninety (90) days following notification by the
IEPA- The Permittee shall implement the plan within ninety (90) days or other such date as contained in a notification letter received
from the IEPA .
The IEPA may modify this Permit during its term to incorporate additional requirements or limitations based on the results of the
hiomoniloring
. In addition, after review of the monitoring results, the IEPA may modify this Permit to include numerical limitations
for specific toxic pollutants
. Modifications under this condition shall follow public notice and opportunity for hearing .
SPECIAL CONDITION 16 .
For the duration of this Permit, the Permittee shall determine the quantity of sludge produced by the treatment
facility in dry tons or gallons with average percent total solids analysis
. The Permittee shall maintain adequate records of the quantities
of sludge produced and have said records available for IEPA inspection
. The Permittee shall submit to the IEPA, at a minimum, a semi-
annual summary report of the quantities of sludge generated and disposed of, in units of dry tons or gallons (average total percent solids)
by different disposal methods including but not limited to application on farmland, application on reclamation land, landflling, public
distribution, dedicated land disposal, sod farms, storagee lagoons or any other specified disposal method
. Said reports shall be submitted
to the IEPA by January 31 and July 31 of each year reporting the preceding January thru June and July lhru December interval of sludge
disposal operations .
Duty to Mitigate
. The Permittee shall take all reasonable steps to minimize any sludge use or disposal in violation of this Permit
.
Sludge monitoring must be conducted according to test procedures approved under 40 CFR 136 unless otherwise specified in 40 GFR
503, unless other test procedures have been specified in this Permit
.
Planned Changes
. The Permittee shall give notice to the IEPA on the semi-annual report of any changes in sludge use and disposal .
The Permittee shall retain records of all sludge monitoring, and reports required by the Sludge Permit as referenced in Standard Condition
23 for a period of at least five (5) years from the date of this Permit
.
If the Permittee monitors any pollutant more frequently than required by the Sludge Permit, the results of this monitoring shall be included
in the reporting of data submitted to the IEPA
.
Monitoring reports for sludge shall be reported on the form titled "Sludge Management Reports" to the following address
:
Illinois Environmental Protection Agency
Bureau of Water
Compliance Assurance Section
Mail Code #19
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
SPECIAL CONDITION 17 .
The Permittee shall notify the IEPA in writing once the treatment plant expansion has been completed
. A letter
stating the date that the expansion was completed shall be sent to the following address within fourteen (14) days of the expansion
becoming operational.
Illinois Environmental Protection Agency
Bureau of Water
Compliance Assurance Section, Mail Code #19
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
Page 10
Modification Date
. August 24, 2005
NPDES Permit No . IL0023264
Special Conditons
SPECIAL CONDITION 18
.
The Permittee shall record monitoring results on Discharge Monitoring Report (DMR) Forms using one such
form for each outfall each month .
In the event that an outfall does not discharge during a monthly reporting period, the DMR Form shall be submitted with no discharge
indicated
.
The Permittee may choose to submit electronic DMRs (eDMRs) instead of mailing paper DMRs to the IEPA- More information, including
registration information for the eDMR program, can be obtained on the IEPA websile,
h ttp ://www
epa state
i
l .us/water/edmr/inde x html
The completed Discharge Monitoring Report forms shall be submitted to IEPA no later than the 15th day of the following month, unless
otherwise specified by the permitting authority .
Permittees not using eDMRs shall mail Discharge Monitoring Reports with an original signature to the IEPA at the following address
:
Illinois Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
Attention
. Compliance Assurance Section, Mail Code # 19
SPECIAL CONDITION 19 .
This Permit may be modified to include requirements for the Permittee on a continuing basis to evaluate and
detail its efforts to effectively control sources of infiltration and inflow into the sewer system and to submit reports to the [EPA if necessary
.
AnACNMENT as
D..WWSVw
IM Il r n Emwomwnoa PlCrceon Act Cn 11 1 1 7 11, 1, 51.I-
Sec 1001
ar.reoe w.ewly
olad.Ypa Lim ton 17 day a.
.,eg.I
r.enq .
of dmly oocnalgs ne a ca
m e hyena snow_ .
cam
tie
ureo Oun,g a calernv wee . dnd.d by m. mrmowlof
holly
um r an du bldnrnarget
,na1Beat I.
.AMenegenwant
peptace. IBMPtI
one ., .rab
1
ena a gnceounf and o
schedules of tmtw
. ommduon of
Mnag .mw,l p .cnc an to oreyenl or,
.the
plluoon ofa((
o f "we
Sub .
Bayou t
1-1-bas
n, Iymrrren2
•od
tu,n9
poceouref . and preCnc
conmN on, an mMh . ,pulp. or Sofa., sludge Or .onto
01.00W. o dretnega iron raw
,
melanr
.lore,..
Awsuct men • sample of weal O
mpyaly
used Id male . d a IoW .,now"
Gross Saps
. mere en ,,der,thry .per
of ii vest 1 OO malin,e cooed et a nndomfy-
sespte0 Mwa over a oerod not a .oeryq I S rogue
24 )lets Console . 9ennph mealy. • coanbardon of .t We.,
8 temple Wopta of
100 mW tale . Co4ned
n pal,odc wits" . dIm 9 ma open.erq
hoof of
.
lectern omen . 2 a !
nOO Tied
mAtMen
a lip . Cocollected
.rcoene
at
8angE7r.odic
. 'emc
ln.enrlCpnaMnon
. door, IVof . ooeral.rp
w . .
nova
3 s.mor
.
a fac,wty.lpao,
.
oral
of A,anlaws.,8-hou,100
c> •,od
Flow Pro.Vtioea Coinpq/M1
peerless rlwaa mWU.Fn of
'em.
of d
100 mouser . collected al
le
'no.". sod met anyway. ny, 11 r twel pawn e
au or , r
algrat n p000monef to
tiller
In
.Tern flaw .l me uma o .
,amOnq o me local shorn torn vac-
he
-1.- .1 In. .- .1roob,
D"", 1.
comel
y In
.
l
pa,mrlsw must comp ((,m + cords .
. .
,
of 11s rm,.
ny oenmn rid
pence consnbl. . . .a,n of ine Act
a grounds IOr
anlo,Cen.ynl mcool
peon Ipnn .non,
IV. .
Inc
.
Denn
m
lnw
f
od .
•
lo, dwa.l of a pm,mws appcoonThe
n,
.
.,-M
sunup. Or prdnrbbon . .
.LbnheO under Sec . 7071 .1
Comply
of he Clean+"In
Wet! Act
for
tdsc poYUUnn n n the lone
In 11.
In.,
nnpdilad
nubw .h
to
then(.corporate
1 .
One
or
r.
ponrbrnpneaesnynL . .ya 11 me posh nn no,
yet peen
131 Duty to reswo
lye I1 the partrut ee wish., 10
an only ,pulaled on thus
palms ahoy IC, . ee lta. flan of the OSyrIL a lemon . must
soon,
for and
nbla n a new pernut
n
me o,m.n
. suown a Props eooacaoonet r .ou„ed by
Agony
ro Is . T .
I
Bo ey, orua la
eapebln dye uno
. cal
fn r
•
1n low Iocs w
.Hot Once bass hnr Agency
.1
. OnIn . appKaton
has
been
may.
'.71
Need 1.
IoM o , .nay ec.lnin M e defense a new not be a deem . lot a
pwTllte m an
blot
n n, ac000 Moat ,t npMd how been rw
. .h Is
hale
or
,educe IM permlbd .cpnh n order to mama" co wf.nce nom The cond,t.ona
01 thus perms .
,AI
Duty to mnlps .. The owrnmw show take .d r.
.aonebu sell to m-noto or
An, dscheq. In - ..
s al m, osmn notch Ns s,e .onad.
Ir,arrhobn
of adneaws aflecnng northern hat o In
. Tveonnment
I51 Proper op ..
.ly,
w to 8 sso
. TM
p.nrmY
sba, at W lane, onp.my
openers
w mangy
. W lecle e w h •t n, of b.tpwnl end contact (and
,Meted appb.w,wcn/
-In she
u . by, b . "If o .,h-
.
• mptia.ce
won me c
n
.1 Ins card. Pmoer ooealon and m n .
lodwea WqM
. perfarme ce. Ill funded, s
uHrng and
Irarnnq .
no edg,ut,
A . .,
and access c poll ,nduda,q teppoo,ers
fate assurance ow.
Thre
ooV . .on rqu .. aho
hosestoo, 0 , be,.,
or
uafeny
"ca"rs"
51maw
ystem, ply .hen oecs .aT
. In
.ch,. .e
,nn ."AICn
.11h
the caneuuans al thr her-
PRINTED CN RECYCLED POPEP
Ids
fomaPen,waaThys,.ae- oseAUar
.-hensWyosas
pa0CH712222
.,etc.ene
tN.fte~ww~wytep
pw.were ienreenrrat mo oj ..
ec rwMe 1wn
4
•~ ~07r~®
en
_.le esg_,o .
robvepe a4
used ds7.e
o e.pp . W even
ly pie . hose ora, >7.
-
mmun .
M1galn
any eacanrat
r,pwu
cynic,Ibis .
plans
.
does p1 cony"
am poverty rglap d any sot or
Dun to powyease o-m.t oat The oemun.e
show funned n S
. /petite wrn., a
Inhonsr
M. onne
c
any
lnloma.cn
shah m • Agency I rootless ,
,o glen,
s for norobf r
V
up anot rasvq way seasonal ,,,
0 oelemuM Com
e -, In I e permit The penmryY an, ear,
caromMass,
.
Ib IN Agency upon regret copes of record . t
e0 ten se apt by Inn
Insl.etq . end an, . The
Porn,
e11 altoon an Au ,, .a . .el]r.senu
IM Agency . Nn 1be p loon
.. we, of crredentill, and .,I- d¢umer,u as mw he
rats .d by few . ro
cal
lEnMUppn
ocat ed
o1
Inconcocted.'uruseA
.
de
'y'--ono,Orwn
. .
. Inhere
mull
a
be
regtleb
feat under
base,the
or aCLVrh
Conpnomn
Ol- print
Here access
aho cccy'
. 1 ea.onable nm.s any , .cords mat run n.
fps under its
10
cO dMn . of Ihn pea-
"'.
al reasonable lInr- any 1ac11iuees equo hnan, including noon/an,g
aho
under
Conpbtnta
prmu,
scurpnendand . o.c n.. . Or Operenona r.gsaayd
o Ieuuaes
IN
Sampbp hatineraw,
.1 reasonaW bras
. fa,, a purpose of a vng o .m1,,
myaro or
om.n.,e
.ulndnrp or ma Act +ny aubeunce. 0,
nararMtws aI any location
MoAren,ne end aegene
ul
bards arw m menu assn Or me Or' . .
.1 'n-on" n.,.
reosW,Ydve of In . mourned actir,h .
1bl
ale
I
he oenlnlte,sbrapn .nand
.w near,May
.
. of
,
.II
-nor-n,and
as arsg.o
temp c^
reooa nge for conrnNOU . monnonng o swm.nuldn COgle. of .11 report
leddyed by Its ant and ,scam . of all data used to connate!
. r e
apW,ceobn
Ip
inn palm, IM a period no .1 we., 5 1. Ions, lines fee .1
Id, pennet. m.
t report or
ca bon This period may be
ursr,ded by ,
.duel of the Agar, a anv IoM.
Id
R .rade of nvesong nlpnutan show include
111
Th . dote enact place . and Lmy al samduq or
,neawsernen,a
(21
The ind .nduell.l vela prtonnw the e .mplaq
o mete
171 The Intel MNsw yen. performed
1A1 The Irdrvhualls oh . perform. Ice aMhHS-
ISI
Th
. ansltM .l Iecnmoues or methods used . and
151
The,esWn of focn ah .IV ...
IN Mor.mm, must co p
,mug IO e» Onoced
aopored
once a0 CFRPan 1717
m
n
pocaiurenece ono oeun.d
n nr
r w
t
r
r tan
s0 CFR Pan 1to b, peen
ao v / m
in* Agero lent m Iwd for
aObova
. The
per I
1 a l, bra n enlo,m m
nce
ppeoures On all ,td onlq ad analyLCa •m tWnenulon aI ml
In
erv
na
aa 10
an . accuracy of moseumeMnn.
1) SgM1oy rpuiunrnt All anolutcna . r,pons or lnfonna,on aubmrned m Ihe
calA
gency
anal be ., .
also caroled.
Aplfulion
. All prmn aoolnabons ,all be tcgnad W lolb .n .
For coperetbn'. by a Onnt
.pel eaeC
ollger of
at A . .1
enel of r e or.YOen1 or
n n u pabdn
he.." --.It
reepnaduh for ervucOrrel l menen to Ito coroOaron .
121 For a ownereasa
. or
sole p lelo .nq'. by a genera
o.mN( Or
IM onTato, respcnywr, or
171
For A
dc'be111y . State . F
ed.cel,
o open peanut eq.r,cp br
e
.per a
principal
saeulne officer or tanw ., eaecip orfdiaa
R . . All uponf ,scoop by oenntf, or o,hw
nloninaron
rqusl .d by
Ire Agency shall be sign or a
n
acnbed n pen.gr.g, cal or Oy a
duly ate onoed leoerluM . of tna, person . A prso, re a but, aumon,ed
~ep.ei,up. only 1
1
Ill The audwnaaoon may In
-Of
by
a La
. d.acnbod m
peredrapn
WW
and
cults eh., a rndnbua
o
a
,ndOTIOae for the oven ., operap of IM I .cyh, front we,
.
dlscnvg . Try,' -saw
.went menagef s, .penntwgent or
pence, o1 qunwenl re.oonubtaty
:
A-
-ire
((linen
sumo laton a
me-moo
a the Agency
1052 •1 Amended
Ageray mere me Iw+,ors
Etwwr.rwany Pmrec , Agency
.
171
aloe. meets the Nnv
. Poludon Control Bae c ..
Clean W .t
. Acs ]loon, ten 11
m as the Federal Water Pollunhn Control AcU moms
Pub. L 92500
. as arnenoe6 33 U.S C 1251 .1 ama.
NeOES Ibet,onaf Plowshare 0echenge Ll .mrutun Syar .ml m
u ,ng,mcarh
.rV .re .o .ugan,ensng.I nmnannq .rn
rro .l oognm la,
onrga enlorcirgp
.mnI and
Or
mpovng
me Cum
any
Water
enlmuM
Act
pnmrtrMm rqurrsmenn . ands Sections 707
. 002 718 1 .0 405
USEPA mean
the
Unaad .
Soles Ew .onMny Pmtacbon Agency
Drh
24 tsowOLCNgperiod
.
onesmeaty
the dschege of a peason, naeew
.b dump a
cale ndar
da
y Or A,,
r .oeenlN
181
,lot
newreph
oollaunu ((,m I(nla.on,
. .pissed n
ma calendar
day for psgesn of sa ping . For
of m .
be daily O.sCh .rg~
m"t m
cacuulao a
of me pwnans bacheged o
eM
de,
. Foe p
enarescineeaaen~it
.
.d In
alomen
the
unn al mwaa IS rerastire "dewy d,achorpa' n calculated-,m
ii he
Lmlv,mniarwpe
POE far ace nwa day
.
O .scheryemaan
Daily D'soonenpe Llmlteceon (deity
rear-o"
,MU1a In . "he,
ald
.yaole
daily
7rwegAten
.ee
. ofMOnsNs
duly
bpcnaagea
Oiecawee
OVllm/etch
170 do iscr.gel
mean- m . ngn.. . alb- .d .
'roo
m¢naryndon,.,.,used
tma,
doing
month .
a cae ce,
caehen
moor omoor.y.d .d
.
OCa,uleew,
r 1 .
number
a Init
.
dale
,
of
OuUargefall
daily
