Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Bureau of Design and Environment
2300 South Dirksen Parkway
Springfield, Illinois 62764
Petition for an Adjusted Standard
ILLINOIS DEPARTMENT OF TRANSPORTATION – DISTRICT 8
BOWMAN AVENUE PUMP STATION AND DEEP WELL SYSTEM
EAST ST. LOUIS, ST. CLAIR COUNTY, ILLINOIS
Back to top
NPDES PERMIT NO. IL0070955
3300 Ginger Creek Drive
Springfield, Illinois 62711
Tel: (217) 787-2334
July 2007
By:
Submitted to:
Illinois Pollution Control Board
1021 North Grand Avenue East
P.O. Box 19274
Springfield, Illinois 62794-9274
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
i
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
TABLE OF CONTENTS
INTRODUCTION AND BACKGROUND ............................................................................ 1
A. STATEMENT OF STANDARD OF GENERAL APPLICABILITY FROM
WHICH RELIEF IS SOUGHT ..................................................................................... 2
B. IMPLEMENTATION OF FEDERAL LAW ................................................................... 3
C. LEVEL OF JUSTIFICATION REQUIRED .................................................................. 3
D. NATURE AND DESCRIPTION OF ILLINOIS DEPARTMENT OF
TRANSPORATION ACTIVITIES ................................................................................ 4
Individual Well Systems
.................................................................................4
Tri-Level System .......................................................................................5
I-64 System ..............................................................................................5
25
th
Street System ....................................................................................5
Missouri Avenue System ..........................................................................5
Operations
......................................................................................................6
Pumping Results ......................................................................................6
Historical Groundwater Results
......................................................................7
Chloride, Total ..........................................................................................7
Fluoride, Total ...........................................................................................8
Sulfate, Total ............................................................................................8
Total Dissolved Solids (TDS) ....................................................................8
Combined Equivalent Effluent
........................................................................8
Combined Actual Effluent
...............................................................................9
E. EFFORTS THAT WOULD BE NECESSARY TO ACHIEVE
COMPLIANCE AND ALTERNATIVES ..................................................................... 10
F. DESCRIPTION OF PROPOSED ADJUSTED STANDARD (35 ILL. ADM.
CODE SECTION 104.406(F)) .................................................................................. 12
G. DESCRIPTION OF PETITIONERS’ IMPACT ON THE ENVIRONMENT
(35 ILL. ADM. CODE SECTION 104.406(G)) .......................................................... 13
Analyses of Discharge Characteristics
.........................................................13
Sulfates
........................................................................................................13
Total Dissolved Solids (TDS)
.......................................................................13
Toxicity of Discharge
....................................................................................13
H. EXISTING PHYSICAL CONDITIONS (DESCRIPTION OF RECEIVING
STREAM) ................................................................................................................. 14
I.
THE CHARACTER OF THE AREA INVOLVED INCLUDING
SURROUNDING LAND USE AND ZONING CLASSIFICATIONS ........................... 15
J. JUSTIFICATION FOR PROPOSED ADJUSTED STANDARDS (35 ILL.
ADM. CODE SECTION 104.406(H)) ........................................................................ 16
K. ADDITIONAL JUSTIFICATION FACTORS .............................................................. 16
Bowman Avenue Pump Station
....................................................................17
Material Service’s Federal Quarry
................................................................17
Services and Training Center of Exelon
.......................................................18
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
ii
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Rhodia, TCBSD, and Consumers Illinois Water
...........................................19
L.
FUNDAMENTALLY DIFFERENT FACTORS ........................................................... 20
M. WAIVER OF HEARING (35 ILL. ADMINISTRATIVE CODE SECTION
104.406(J)) ............................................................................................................... 21
N. CONCLUSIONS ....................................................................................................... 21
REFERENCES ................................................................................................................ 22
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
iii
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
FIGURES
Figure 1 – Schematic of Bowman Yard Discharge .........................................................23
Figure 2 – Location of East St. Louis Dewatering Sites..................................................24
Figure 3 – Locations of Dewatering Wells at the I-70 Tri-Level, I-64 and 25
th
Street
Sites ..............................................................................................................25
Figure 4 – Locations of Dewatering Wells at Missouri Avenue Site................................26
APPENDICES
Appendix A Site Location Map.........................................................................................A
Appendix B Geologic Cross Sections ..............................................................................B
Appendix C Bowman Avenue Pump Station and Missouri Avenue Well Field Historical
Water Quality Data ...................................................................................... C
Appendix D Bowman Avenue Pump Station and Missouri Avenue Well field Graphs of
Parameters versus Time ............................................................................. D
Appendix E Individual Deep Pumping Wells Historical Water Quality Data.....................E
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
1
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
PETITION OF ILLINOIS DEPARTMENT OF )
AS 07-
TRANSPORTATION FOR AN ADJUSTED
)
STANDARD FROM 35 Ill. ILLINOIS
)
ADMINISTRATIVE CODE 302.208(G)
)
FOR THE BOWMAN AVENUE PUMP
)
STATION AND DEEP WELL SYSTEM IN
)
EAST ST. LOUIS, IL
)
Back to top
Petition for an Adjusted Standard
INTRODUCTION AND BACKGROUND
The Illinois Department of Transportation (IDOT) is submitting a petition for an adjusted
standard from 35 Illinois Administrative Code (Ill. Adm. Code) 302.208(g) for sulfates and
total dissolved solids. In order to prevent flooding and structural damage to the Interstate
Highway system in the East St. Louis area, groundwater levels are kept pumped down by
four separate groundwater pumping systems. Three of the systems discharge to the IDOT
District 8 Bowman Avenue Pump Station (Bowman) where they are pumped to a discharge
sewer. The Bowman discharge is combined with the final system discharge from the
Missouri Avenue Pumping system and the combined effluent discharges to an unnamed
drainage way. The discharge is regulated by effluent standards from 35 Ill. Adm. Code
304 and an Illinois Environmental Protection Agency (Illinois EPA) National Pollutant
Discharge and Elimination System (NPDES) Permit. Due to the naturally occurring
concentrations of the various parameters, the groundwater pumped from the well
systems may cause exceedences of water quality standards as set forth in 35 Ill. Adm.
Code 302.208. The groundwater in this system is not known to have been contaminated
by any human activity.
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
2
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
The NPDES Permit requires the discharge waters meet parameter effluent limits that are
derived from water quality limits. The sulfate constituent may have occasionally and the
total dissolved solids (TDS) parameter has routinely exceeded the respective permitted
NPDES effluent limits. Therefore, IDOT seeks an adjusted standard for sulfates and
TDS.
This discharge has been the subject of a previous adjusted standard in AS 96-12, for
iron, suspended solids and color. On October 3, 1996, the Illinois Pollution Control
Board (IPCB) issued an order granting IDOT relief for the aforementioned parameters.
Pursuant to Section 28.1, the Illinois Environmental Protection Act (Act) provides a
means for a petitioner to ask and receive approval for a revised environmental standard
from the IPCB that varies from a standard the petitioner is regulated by. The purpose of
the standards for which adjustment is sought in this petition is to protect aquatic life,
safeguard the quality for crop irrigation, and to protect the streams as a potential public
water supply. It is believed the regulations were promulgated, in whole or in part, to
implement the provisions of the Clean Water Act.
A.
STATEMENT OF STANDARD OF GENERAL APPLICABILITY FROM WHICH
RELIEF IS SOUGHT
IDOT seeks adjusted standards from the IPCB’s regulations for constituents contained
in 35 Ill. Adm. Code 302.208(g). The additional regulations 35 Ill Adm. Code 304.105
(regarding compliance with water quality standards) and 35 Ill. Adm. Code 304.141
(regarding compliance with limits in the permit) were evaluated to see if they should
also be adjusted. The IPCB found in AS 03-1 (Exelon Generation Company) that if 35
Ill. Adm. Code 302.208 was adjusted, it is not necessary to adjust 35 Ill. Adm. Code
304.105. If the water quality standards were changed, and the petitioner could meet the
new standard, then there would be no need to provide additional relief from meeting
that standard. Using similar logic, IDOT has decided not to petition the IPCB regarding
35 Ill. Adm. Code 304.105. While not addressed in the above referenced decision (AS
03-1), the applicability of 35 Ill. Adm. Code 304.141 is analogous. If the water quality
standard changes, then the permit can be changed to reflect the adjusted standard;
therefore, relief will not be requested for this standard either. The standard from which
an adjusted standard is being sought is:
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
3
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Section 302.208 - Numeric Standards for Chemical Constituents
g) Concentrations of the following chemical constituents shall not be exceeded
except in waters for which mixing is allowed pursuant to Section 302.102.
STORET
CONSTITUENT
UNITS
NUMBER
STANDARD
Sulfate
mg/L
00945
500
Total Dissolved Solids
mg/L
70300
1000
Where: mg/L = milligrams per liter
B.
IMPLEMENTATION OF FEDERAL LAW
The IDOT does not believe the granting of an adjusted standard proposed in this matter
would be inconsistent with Section 303(a) of the Clean Water Act, if the Board finds the
proposal to be protective of human health and welfare. It is also noted here that the
Illinois EPA has conducted a triennial water quality standards review required under
section 303(c)(1) of the Clean Water Act and as a result proposed revised standards for
the substances being addressed here in R007-009. The existing discharge would meet
the standards of R007-009 if that proposal passes as proposed. The IDOT’s NPDES
permit could be modified to incorporate the adjusted standard, and IDOT could comply
with any such permit.
C.
LEVEL OF JUSTIFICATION REQUIRED
The regulation of general applicability does not specify a level of justification required of
a petitioner to qualify for an adjusted standard. Therefore Section 28.1(c) of the Act
allows the IPCB to grant individual standards upon adequate proof by petitioner that:
1. Factors relating to that petitioner are substantially and significantly different from
the factors relied upon by the IPCB in adopting the general regulation applicable
to that petitioner;
2. The existence of those factors justifies an adjusted standard;
3. The requested standard will not result in environmental or health effects
substantially or significantly more adverse than the effects considered by the
IPCB in adopting the rule of general applicability; and
4. The adjusted standard is consistent with any applicable federal law.
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
4
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
This petition provides material to address all four demonstrations.
D.
NATURE
AND
DESCRIPTION
OF
ILLINOIS
DEPARTMENT
OF
TRANSPORATION ACTIVITIES
Deep wells were installed as early as 1973 for the purpose of dewatering shallow
groundwater in order to lower the water levels to a safe depth below the designed road
grades. The IDOT District 8 Bowman Avenue Pump Station is located adjacent to
Exchange Avenue (Exit 3 from Interstate 55/70) in East St. Louis, St. Clair County, Illinois
(See Appendix A). There are typically three employees at the Bowman Yard facility. The
pump station is part of the IDOT District 8 Bowman Yard maintenance facility. The pump
station receives water from three well fields and various stormwater drainage ways.
Another well field discharge combines with the discharge from the Bowman pump station
and together they go to a drainage way (See Figure 1). The well fields are located
adjacent to low pavement areas near Interstates 55 and 70 (Tri-level), Interstate 64 (I-64),
the 25
th
Street underpass to I-64, (25
th
) and the I-55/I-70 underpass near Missouri Avenue
(Missouri). The water from Bowman Yard maintenance facility includes the pump station
discharge and the Missouri discharge and is discharged into a drainage way, which flows
approximately 1,750 feet to the Schoenberger Creek, thence to the Cahokia Canal, and
finally to the Mississippi River at Mile 180.6 (See Figure 1 and Appendix A).
Individual Well Systems
Forty-nine wells produce groundwater from four well fields that pump to the Bowman
Yard. On average, 13 to 16 of the 49 wells are operational at any given time. The four
well fields are identified as the Tri-Level (15 wells), I-64 (20 wells), 25th Street (10 wells),
and Missouri Avenue (4 wells) dewatering sites (See Figure 2). These deep wells are
equipped with submersible pumps to control the water table in areas of low pavement
elevation. Without the systems of pumping wells, the respective interstate and intercity
routes would flood and be impassable, ultimately requiring closure or modification in
roadway grades.
The groundwater from the pumping wells is transferred via 6-inch to 42-inch diameter
gravity and/or pressure collection systems to intermediate pump stations located at each
well field. From the intermediate pump stations, the fluids are transported by 60-inch to
72-inch sewers. The groundwater from the Tri-level, I-64, and 25
th
Street dewatering
sites goes to the Bowman Avenue Pump Station and is discharged to a 72-inch (RCP)
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
5
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
sewer. The Missouri Avenue dewatering site discharge is conveyed to the Bowman
Yard where it combines with the pump station discharge.
Tri-Level System
The Interstates 55 and 70 Tri-Level System is located southwest of the Bowman Avenue
Pump Station at the interchange of I-55/I-70 and I-64 (See Figure 3). The Tri-Level
System consists of 15 deep pumping wells ranging in depth from 90 to 110 feet (see
geologic cross sections A-A’ and B-B’ in Appendix B). To attain sufficient drawdown in
the Tri-Level area, approximately seven of the fifteen wells need to pump at any given
time. If significant groundwater recharge occurs due to precipitation and runoff,
additional pumping wells can be turned on to maintain adequate water levels.
I-64 System
The I-64 System is located southeast of the Bowman Avenue Pump Station and the Tri-
Level interchange (See Figure 3). The I-64 network is made up of 20 wells ranging in
depth from 90 to 110 feet (See geologic cross sections B-B’ in Appendix B). The
roadway grades at the Tri-Level are lower than the I-64 surface elevations. The Tri-
Level groundwater drawdown is sufficient enough to adequately maintain potentiometric
levels for most of the I-64 System roadway grades except for the far southeastern
elevations. Therefore, only one or two southern wells at I-64 require pumping to attain
sufficient drawdown.
25
th
Street System
The 25
th
Street System is located approximately one and a quarter miles southeast of
the I-55/I-70 Tri-Level and I-64 interchange (See Figure 3). This system is located on
25
th
Street which exits from I-64. Low road grades at 25
th
Street were required to gain
access below an I-64 overpass and a St. Louis Metro Transit System rail bridge. The
25
th
Street System consists of 10 deep pumping wells ranging in depth from 110 to 115
feet (See geologic cross sections C-C’ in Appendix B). To attain sufficient drawdown in
the vicinity of the 25
th
Street low pavement elevations, approximately four of the ten wells
need to pump at any given time.
Missouri Avenue System
The Missouri Avenue System is located approximately one mile west-southwest of the
Bowman Avenue Pump Station and the Tri-Level interchange (see Figure 3 and
Appendix A). The low pavement elevations along I-55/I-64/I-70 at the Missouri Avenue
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
6
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
overpass include a network of four wells ranging in depth from 75 to 110 feet (see
geologic cross sections D-D’ in Appendix B). To attain sufficient drawdown at the
Missouri Avenue area, generally two to four of the wells need to pump at any given time.
The flow from this system goes to the Bowman Yard where it mixes with the discharge
from the Bowman Pump Station.
Operations
Generally, between 13 to 16 of the 49 wells are pumping into the Bowman Avenue Pump
Station system. The electrical circuitry of each pump is hooked up to a local control center.
Each control center is self-contained and securely locked. Each well field system has one
or more control centers that enable one to manually turn on/off the pumps and to monitor
the status of each pumping well hooked up to the respective control center. When any
number of wells need to be turned on or off due to well/pump repairs or to modify the water
level (raise or lower), the control center for the respective system(s) are accessed.
Water levels are monitored by taking measurements from piezometers or observation
wells located within each well field. The low pavement
areas require a predetermined
potentiometric level. When the water level measurements attained from the piezometers
or observation wells in a given system indicates a need to increase or decrease the water
levels, the number of wells to be turned on/off are modified based on the need. The
number of wells from each system that pump at any given time include approximately 6-7
of the 15 wells at the Tri-Level area, generally 1 or maybe 2 southern wells at I-64,
generally 4 of the 10 wells at 25th Street, and between 2 and 4 wells at Missouri Avenue.
Pumping Results
The NPDES permit application from 2001 provided estimated average flow (volume) of 19
MGD (13,000 gpm) with maximum levels of 26 MGD (18,000 gpm) from the Tri-Level, I-64,
Missouri Avenue, and 25
th
Street sites.
During the sampling of the individual wells from October 2003 to February 2005, the Tri-
Level, I-64, Missouri Avenue, and 25
th
Street operated an average of six, one, three and
four wells, respectively, to maintain adequate water levels at each site. Based on the
estimated pumping rates and the average number of wells operating, the Tri-Level pumps
between 2,700 and 3,600 gpm, I-64 pumps between 450 and 600 gpm, Missouri Avenue
pumps between 3,250 and 3,700 gpm, and 25
th
Street pumps between 1,800 and 2,400
gpm, totaling an estimated 8,200 and 10,300 gpm (or 11.8 to 14.8 MGD). Based on the
average number of wells pumping and estimated pumping rates, the percent groundwater
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
7
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
volumes that contribute to the Bowman Avenue Pump Station from the Tri-Level is 37%, I-
64 is 6%, Missouri Avenue is 33%, and 25
th
Street is 24%.
Historical Groundwater Results
A revised Illinois EPA NPDES permit became effective January 1, 2003. The revised
NPDES permit requires monthly sampling of pH, total suspended solids (TSS), iron
(dissolved and total), TDS and sulfate, and semiannual sampling of manganese, boron,
fluoride and ammonia. Of these parameters, TDS and possibly sulfate have exceeded
the respective effluent standards.
To comprehensively evaluate the effluent quality, including sulfate and TDS, IDOT
collected and compiled data at a greater frequency than required by the permit. All of
the monthly and semi-annual parameters were sampled twice a month from the Bowman
Avenue Pump Station between February 2003 and January 2005. From February 2005
to present, the pump station has been sampled on a monthly basis. The table provided
in Appendix C summarizes the water quality results for total dissolved solids and sulfates
from the Bowman Avenue Pump Station grab samples. Graphs showing the trends of
the individual parameters from the grab samples are given in Appendix D.
In addition to the bimonthly, monthly, and semi-annual sampling at the Bowman Avenue
Pump Station, groundwater sampling was collected during eight events from individual
wells from October 2003 through February 2005 for comparison with the grab sample
results and characterization of the originating groundwater. Analyzing the groundwater
from the individual wells contributing to the pump station was conducted to determine
the potential source(s) of the sulfate and TDS. The table in Appendix E shows the water
quality data for individual deep pumping wells within the Bowman Avenue Pump Station
system and Missouri Avenue well field. The data show there is significant variability
between well fields and between individual wells in any given field.
Chloride, Total
Total chloride is not required as part of the site NPDES monitoring program. However,
TDS is a primary constituent in the NPDES permit. Since the chloride contributes to the
TDS, it was sampled for during the same events as the individual wells. The chloride
levels for the individual well samples were low (33-336 mg/L) and well below the
concentration limits of 35 Ill. Adm. Code 302.208 (500 mg/L). The individual wells show
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
8
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
concentrations below 500 mg/L, with most data results below 100 mg/L. See Appendix
E.
Fluoride, Total
The total fluoride levels of the Bowman Station and individual well samples are generally
below the 35 Ill. Adm. Code 302.208 standard of 1.4 mg/L. All of the Bowman Station
samples were below 1 mg/L while only two wells from the I-64 system had regular
detections above 1.4 mg/L. See Appendix E. The NPDES permit for the facility does
not include a concentration limit for total fluoride.
Sulfate, Total
The 35 Ill. Adm. Code 302.208 water quality standard and NPDES concentration limit for
total sulfate is 500 mg/L. The grab sample levels for all sampling points for total sulfate
are generally below 500 mg/L. However, occasionally the concentrations exceed the
sulfate limits. A few individual wells show total sulfate concentrations exceeding the
limit. I-64 wells 19 and 20, and 25
th
Street well 2, experienced total sulfate exceedences
relatively consistently, while I-55 wells 11A, 12A, and 13, and Missouri Avenue well 2
recorded one to three exceedences out of the eight sampling events (see Appendix E).
Total Dissolved Solids (TDS)
The 35 Ill. Adm. Code 302.208 water quality standards and NPDES concentration limit
for total dissolved solids is 1,000 mg/L. The grab sample levels for TDS are frequently
above 1,000 mg/L. A few individual wells from the Tri-Level, 25
th
Street, and Missouri
Avenue sites and all of the sampled wells at I-64 show high TDS concentrations. The
Bowman Station TDS concentrations, despite the well-to-well variability, are relatively
consistent, generally with TDS levels between 1,050 mg/L and 1,130 mg/L (See
Appendix D). The grab and individual well sample TDS levels are attributable to
naturally occurring conditions.
Combined Equivalent Effluent
Historically, the final outfall discharge to the drainage way has not been sampled.
However, the pump station (which includes the I-64, 25
th
Street and Tri-level well fields),
and the Missouri well field have been sampled as previously noted. The analytical
results of the Bowman pump station and the Missouri well field have been
mathematically added using estimated flow data to create a combined equivalent
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
9
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
effluent (CEE). The Bowman data represents one sampling point (representing three
well fields). The Missouri data represent results from all the wells in that field.
A statistical analyses of results from 2003 until the end of 2005 has been conducted to
determine various numerical characteristics of the groundwater sampling results. Both
the mean and the 95% upper confidence limit (UCL) are presented. The mass was
calculated using flow and concentration figures. The CEE concentration was calculated
using combined mass and flow. The tables below show the results of this analysis.
For sulfates, concentrations at the Bowman Station were greater than 500 mg/l three
times, but there has only been one sample result greater then 500 mg/l from the
Missouri Avenue field. These excursions did not occur at the same time so it is unclear
as to whether the CEE would have ever exceeded the 500 mg/l limit.
Sulfates, Total
Flow,
MGD
Concentration
mg/l
Mass Lbs/day –
(flow x conc x 8.34)
Mean
Max
95%UCL
Mean
95%UCL
Bowman Station
9.504
381
580
496
30,199
39,315
Missouri Well field
5.328
291
642
445
12,931
19,774
Combined equiv.
effluent - mass/(flow x
8.34)
14.832
349
478
43,130
59,088
For TDS, it is estimated that the CEE for both the mean and the 95% UCL would have
exceeded the 1,000 mg/l level.
Total Dissolved Solids
Flow,
MGD
Concentration
mg/l
Mass, Lbs/day – (flow
x conc x 8.34)
Mean
Max
95%UCL
Mean
95%UCL
Bowman Station
9.504
1,097 1,280
1,178
86,952
93,372
Missouri Well field
5.328
912
1,390
1,121
40,525
49,812
Combined equiv.
effluent - mass/(flow x
8.34)
14.832
1,031
1,158
127,477 143,184
Combined Actual Effluent
Starting in the fall of 2006, the discharge to the drainage way has been sampled for
parameters consistent with the NPDES permit. Results for key parameters are listed
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
10
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
below. The mean for sulfate is 341 mg/l, and TDS is 1047 mg/l. These levels seem to be
consistent with what is expected.
Analyte
Units 9/13/06
10/24/06
11/28/06
Mean
Sulfates
Mg/l
397
300
326
341
TDS
Mg/l
1070
1020
1050
1047
Chloride
Mg/l
94.4
-
82.8
86.6
Hardness Mg/l
639
639
E.
EFFORTS THAT WOULD BE NECESSARY TO ACHIEVE COMPLIANCE AND
ALTERNATIVES
This discharge was also the subject of a IPCB action in 1996, in the matter of AS 96-12
regarding suspended solids iron and color. As part of that proceeding, IDOT evaluated
two alternatives -- treatment of the discharge and direct discharge to the Mississippi
River. While the treatment cost for the parameters evaluated then are not applicable to
TDS and sulfates, they were nonetheless very high; $14,120,000 to $21,550,000. The
cost for river outfall and diffusion system, which remains an applicable alternative, was
estimated at that time to be $5,690,000 to $9,630,000. Using the Implicit Price Deflator,
the estimated costs in the 1994 Horner & Shifrin report associated with the river
outfall/diffusion system alternatives have been updated for inflation. To update the
estimate costs for inflation, an inflation factor derived from the Implicit Price Deflator for
Gross Domestic Product as published by the U.S. Department of Commerce was
calculated. Tables of the Implicit Price Deflator can be downloaded from the U.S.
Department
of
Commerce,
Bureau
of
Economic
Analysis’
website
at
http://www.bea.doc.gov/bea/dn/nipaweb/index.asp
. The Implicit Price Deflator for Gross
Domestic Product table contains the Implicit Price Deflators in Annual or Quarterly formats.
As of the writing of this report, the latest Implicit Price Deflator was published in fourth
quarter 2006.
The inflation factor can be derived in one of two ways: (1) the inflation factor is the result of
dividing the current deflator by the deflator for the previous reporting period, or (2) the
inflation factor is the result of dividing the current deflator by the deflator for the reporting
period you wish to start from. The Horner & Shifrin estimates were submitted in 1994. The
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
11
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
1995 implicit price deflator is 92.106. The fourth quarter 2006 implicit price deflator is
116.857. Thus, the inflation factor is 1.2687 (i.e., 116.857 ÷ 92.106 = 1.2687). Costs
today are approximately 26.9% higher than they were in 1995. Therefore, the updated for
inflation estimated costs for the river outfall/diffusion system alternatives range between
$7,219,033 and $12,217,581, respectively.
There are other types of treatment available, such as reverse osmosis, electrodialysis,
and others. These are not considered conventional treatment technologies and would
be expected to be more expensive than conventional technologies. In other proceedings
before the IPCB petitioners have evaluated such technologies and determined them to
be economically unreasonable. The IPCB has concurred.
In the current regulatory proceeding, R-26-04, regarding a TDS change for the Des
Plaines River, Mobil Oil investigated both sulfate and TDS removal and found the only
potentially effective technology would be evaporation/crystallization. Applied to a small
200ppm (.288MGD) stream, the costs would be $36 million to $56 million, not including
operation costs. Projected flows for this project would be over 19MGD.
In a similar situation, in adjusted standard proceeding, AS 02-1 Material Service Corp.
pumped a lesser flow 3.6MGD, but it was groundwater with high TDS and sulfates, and
discharged to Summit Ditch. In 2001, Material Service estimated the 20-year costs of
reverse osmosis to be $81 million to $113 million.
In adjusted standard proceeding, AS 01-9, Rhodia Inc., a pretreatment discharger to the
Thorn Creek Sanitary District, evaluated reverse osmosis followed by evaporation with a
mechanical vapor recompression, for a 0.59MGD discharge. Capitol costs were $4
million and annual operating costs were estimated at $600,000. This was estimated at
$7.78/1,000 gallons. IDOT acknowledges that this cannot be correlated with its
discharge, but nonetheless, the IDOT discharge will be 32 times greater than Rhodia’s.
In adjusted standard proceeding, AS 99-5, Abbott Laboratories estimated the cost to use
reverse osmosis was $750,000 capitol and $500,000/yr operating costs.
Given the widely accepted known high costs of treating TDS and sulfates, IDOT feels
that the river discharge option is still the least expensive. Even at the lower end of the
estimate, $7.2 million, IDOT feels this cost is economically unreasonable, especially
given the fact that there would be no improvement to the environment.
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
12
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Due to the high cost of the conventional water treatment plant and the outfall/diffusion
system alternatives, the option to seek adjustment of the standard(s) has been selected.
Thus, to achieve compliance, IDOT is seeking an adjusted standard from the IPCB.
F.
DESCRIPTION OF PROPOSED ADJUSTED STANDARD (35 ILL. ADM. CODE
SECTION 104.406(F))
Due to the complicated nature of this situation, a system of 49 wells with varying water
quality, operating at varying flows, from an uncontrolled groundwater source,
determining the appropriate adjusted standard involved the evaluation of several factors.
For sulfates, it is arguable as to whether there has even been an exceedence, since the
combined Bowman Station and Missouri Avenue discharge has not been sampled after
mixing, but rather before mixing and averaged mathematically. The current mean and
95% UCL do not exceed 500 mg/l, and the highest estimated concentration may not
have ever exceeded 500mg/l. However, since individual sample results may have
exceeded 500 mg/l, it is felt that the maximum value recorded of 642 mg/l is appropriate.
For TDS the current mean and 95% UCL exceed the 1,000 mg/l limit. Therefore, the
present 95%UCL of 1,128 mg/l should be the appropriate adjusted standard.
The following language is proposed:
The General Use Water Quality Standard for total dissolved solids and sulfates
shall not apply to the drainage way that receives the Bowman Yard facility discharge
from the point of discharge approximately 1,750 feet to the drainage way’s confluence
with Schoenberger Creek, and in Schoenberger Creek approximately 5,000 feet to its
confluence with Cahokia Canal. Instead, the portions of waterway mentioned above
shall be subject to a total dissolved solids standard of 1,128 mg/l, and a sulfates
standard of 642 mg/l.
Internally and separate from the Bowman Avenue Pump Station situation with effluent
concentrations, the Illinois EPA is reviewing the sulfate and TDS water quality standards
as part of statewide NPDES discharge requirements. The Illinois EPA has petitioned the
IPCB in R007- 009 with a proposal to modify the existing effluent standards by:
a. Removing TDS;
b. Keeping the current chloride standard at 500 mg/l;
c. Increasing the sulfate concentration limits;
d. Using the combined chloride and sulfate limits to replace TDS.
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
13
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
If the Illinios EPA’s petition were to be adopted as proposed, there would be no need for
the adjusted standard proposed in this case. The proposed sulfate standard is
calculated to be over 2,000 mg/l for this discharge (see Toxicity of discharge – sulfates
section below). If this becomes the new standard then no adjusted standard is needed. If
the TDS standard is eliminated then no adjusted standard is needed in this case either.
G.
DESCRIPTION OF PETITIONERS’ IMPACT ON THE ENVIRONMENT (35 ILL.
ADM. CODE SECTION 104.406(G))
Analyses of Discharge Characteristics
The concentrations representative of the pumping wells are not known to have been
contaminated by any human activity and are representative of naturally occurring
conditions. The NPDES permit identifies one discharge point, 001. This point is actually
the combination of the discharge from the Bowman pump station and the flow from the
Missouri System.
Grab samples have been collected individually of the three
groundwater systems that go through the Bowman Avenue pump station (the Tri-level,
the I-64, and the 25
th
Street), the Bowman Station discharge and the Missouri Avenue
system. The final discharge represents a combination of the Missouri Avenue and the
Bowman Pump Station. In order to mathematically combine the discharges, nominal
flow rates based on pump designs were used. Actual flow rates have not been
collected, but had they been, they would have been less and would not have changed
any recommendations made herein. These data are summarized in the table in Section
3.
Sulfates
The mean concentration from Bowman station was 381 mg/l and the 95% upper
confidence limit of the data (UCL) was 496 mg/l. When the Missouri Avenue data is
added, the CEE mean becomes 349 mg/l and the 95% UCL is 478 mg/l. While
individual wells may have exceeded 500 mg/l, it is unclear whether the CEE has ever
exceeded the threshold; therefore any impact would be minimal, if at all.
Total Dissolved Solids (TDS)
The mean concentration was 1,031 mg/l and the 95% UCL is 1,158 mg/l.
Toxicity of Discharge
•
Total dissolved solids – in the R07-009 Proposed Amendments Statement of
Reasons the Illinois EPA stated that its “investigations into sulfate toxicity
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
14
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
discovered that the existing TDS standard is unnecessary as the toxicity of each
constituent rather than the sum, is the essential factor ensuring protection of
aquatic life. With toxicity based sulfate and chloride standards in force, a TDS
standard is unnecessary as it is incapable of predicting the threshold of adverse
effects to aquatic life.” Having said this, the Illinois EPA has proposed
eliminating the TDS standard. Thus, it is not felt the TDS limits proposed here
represent a threat to aquatic toxicity, per se. The discussion below will address
the likelihood of toxicity resulting from sulfate and chloride levels.
•
Chlorides – As noted in sec. 3.1.1 the chloride levels are well below the current
standard of 500 mg/l; they are typically below 100 mg/l. The most recent
samples were 82.8, and 94.4 mg/l. thus chlorides exhibit no indication of toxicity.
•
Hardness - Hardness data is not collected routinely but was included as part of
the last NPDES submittal. The hardness data submitted ranged from 454 to 898
mg/l (mostly over 500mg/l). Recent data shows hardness of 639 mg/l.
•
Sulfates – In Illinois EPA studies and follow up research by Dr. David Soucek,
the toxicity was found to be related to hardness and chloride levels. The
relationship is explained in formulae proposed by the Illinois EPA in R07-009.
The standards are determined by these formulae as “concentrations not to be
exceeded at any time.” Using recent hardness data of 639 mg/l and chloride
values of 82 mg/l and 94 mg/l, the sulfate standard would be 2,000 mg/l. Even if
more historical values (using hardness of 454 mg/l and chlorides of 80 mg/l) were
evaluated, the sulfate standard would still be greater than 2,500 mg/l. The table
in sec. 3.2 shows the sulfate average (mean) to be 349 mg/l and the 95%UCL of
478mg/l - both considerably below the toxicity based sulfate standards proposed
by the Illinois EPA. The IDOT feels that the research information presented in
the Statement of Reasons and the historical data demonstrate the discharge is
not toxic to aquatic life.
H.
EXISTING PHYSICAL CONDITIONS (DESCRIPTION OF RECEIVING STREAM)
The Bowman discharge and the Missouri Avenue discharge combine in a sewer and go
thence to the Bowman Pump Station drainage way. This drainage way is a channelized
ditch that also takes stormwater flow from the Interstate System near Collinsville Road.
This ditch goes 1,750 feet to the reported Schoenberger Creek. Schoenberger Creek at
this point is channelized also and goes about 5,000 feet to Cahokia Canal. Cahokia
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
15
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Canal is also channelized and goes to the Mississippi River. Flow data are not kept on
all these waterways, but it is suspected that during non-rainy weather most if not all of
the flow in the drainage way is from the IDOT flows. The Pfizer Co. also reportedly
discharges to Schoenberger Creek. This discharge was the subject of a IPCB action in
AS 81-29.
There are no known users of the receiving drainage way or Schoenberger Creek for
drinking water or other purposes.
The entire receiving water system from the discharge point to the Mississippi River is
channelized and habitat limited. This system serves as a stormwater control system for
this area, and is not known as a recreational area.
I.
THE CHARACTER OF THE AREA INVOLVED INCLUDING SURROUNDING
LAND USE AND ZONING CLASSIFICATIONS
This area covers a number of political jurisdictions including East St. Louis, Madison,
Fairmont City and unincorporated St. Clair County. The Bowman Yard facility is in East St.
Louis and is reported zoned as “unknown”. The areas immediately to the northeast and
northwest are zoned “R-3” or multifamily. The property to the east from the facility from
Bowman Station to the discharge point is “M-2” or heavy manufacturing and industrial.
Adjacent areas are zoned R- 1A single family. The drainage way to which to outfall
discharges and Schoenberger Creek from the outfall to the confluence with Cahokia Canal
are in unincorporated St. Clair Co. and are zoned “B-2” or general business. At least part
of the area near the confluence of Schoenberger Creek and Cahokia Canal is in Madison
(zoned as “planned commercial”), and Fairmont City (zoned as highway business). The
drainage way and Schoenberger Creek are located in largely undeveloped, uninhabited
areas. There are no known uses of these waters for potable or agricultural uses. To the
east of the drainage way is the highway system, including exchanges and overpasses, and
to the west is a vacant undeveloped field. To the east of Schoenberger Creek is a vacant
field and several hundred feet further is the Gateway International Raceway. To the west
is a vacant field for several hundred feet. The area further to the west contains industrial
facilities, including waste management activities, and is fairly flat, allowing water to pond (in
undeveloped areas) during wet period.
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
16
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
J.
JUSTIFICATION FOR PROPOSED ADJUSTED STANDARDS (35 ILL. ADM.
CODE SECTION 104.406(H))
In the aforementioned R81-29 matter the IPCB recognized the impact of IDOT’s
discharges and stated “…for purposes of this decision, the Board will accept the IDOT
discharge as a fundamental, irreversible change in the stream.” Given the IPCB’s
position, the fact an adjusted standard was granted for this discharge in AS 96-012 in
1996, and the data presented, IDOT still represents that there is no adverse impact on
the environment.
The typical sulfate discharge meets the 500mg/l standard and could only be expected to
rarely, if ever, exceed it. Additionally, the ILLNOIS EPA’s petition indicates there is no
adverse impacts at this level (considering chlorides and TDS as well). Thus, it is not felt
that there is any adverse impact related to sulfates.
The TDS average is only slightly greater than the 1,000mg/l standard (1,031 mg/l ave.
and 1,158 mg/l for 95% UCL). It has also been noted that the Illinois EPA intends to
recommend of the elimination of the TDS standard in the future because there is no
relationship to toxicity. It is IDOT’s opinion that since the discharges either meet or
almost meet the standards now, the receiving waters are severely habitat limited, and
the Illinois EPA intends on eliminating the standard, there is no impact on the
environment, nor will there be one in the future.
K.
ADDITIONAL JUSTIFICATION FACTORS
Various sites have been granted approved adjusted standards similar to the requested
constituents, discharge type, and concentration limits of Bowman Yard. An outline of
several of these sites is provided below to illustrate that the proposal to adjust the
standards of total sulfate and total dissolved solids is viable and justifiable. These
decisions also confirm that the proposed adjusted standard would be consistent with
federal law.
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
17
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Bowman Avenue Pump Station
•
Petitioner – Illinois Department of Transportation
•
Facility – Bowman Avenue Pump Station and associated IDOT deep well system
•
Location – East St. Louis, St. Clair County, Illinois
•
Case No. – AS 1996-012
•
Case Type – Adjusted Standard
•
Approval date: October 3, 1996
•
Media Type – Water
•
Proposal to adjust standards of iron (dissolved) from 1 mg/L to 10 mg/L, iron (total)
from 2 mg/L to 20 mg/L and total suspended solids from 15 mg/L to 40 mg/L.
•
Illinois EPA Response – The Illinois EPA recommended a grant of the requested
adjusted standards. The Illinois EPA asserted that the requested alternative levels
should provide relief with a margin of safety for compliance.
•
IPCB granted IDOT an adjusted standard from 35 Ill. Adm. Code 302.208 and
304.124 as they apply to the discharge of iron (dissolved), iron (total) and total
suspended solids in its discharge from the FAI-55/70-FAI-64 system; and 35 Ill. Adm.
Code 302.203 as it applies to color resulting from oxidation and biotransformation of
naturally occurring iron.
Material Service’s Federal Quarry
•
Petitioner – Material Service Corporation
•
Facility – Material Service’s Federal Quarry and associated McCook Drainage Ditch
(from the 47th Street culvert to the Summit Conduit).
•
Location – Village of McCook, Cook County, Illinois
•
Case No. – AS 02-1
•
Case Type – Adjusted Standard
•
Approval date: June 6, 2002
•
Media Type – Water
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
18
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
•
Proposal to adjust effluent limits of sulfate from 500 mg/L to 850 mg/L and total
dissolved solids (TDS) from 1,000 mg/L to 1,900 mg/L. The groundwater seepage
into the quarry is a shallow dolomite aquifer with sulfate and TDS levels ranging from
500 mg/L to 700 mg/L and 1,200 mg/L to 1,600 mg/L, respectively.
•
Illinois EPA Response – The Illinois EPA recommended a grant of the requested
adjusted standards. The Illinois EPA agreed and/or asserted that (1) the discharge
levels of sulfate and TDS are not likely to have any adverse or detrimental effects on
the aquatic life that resides in the ditch, (2) the proposed adjusted standard limits are
lower than necessary to protect the aquatic life, and (3) the sulfate and TDS
standards were established to protect domesticated livestock watering, which the
ditch does not support as a use.
•
IPCB granted Material Service an adjusted standard from 35 Ill. Adm. Code 304.105
and 406.202. However, the IPCB did not grant the petitioners an adjusted standard
from 35 Ill. Adm. Code 302.208 because such relief was unnecessary.
Services and Training Center of Exelon
•
Petitioner – Exelon Generation Company
•
Facility – Services and Training Center (STC) of Exelon (located on Essex Road)
and associated small drainage ditch tributary to Horse Creek, about 3.5 miles
upstream of the confluence of Horse Creek with the Kankakee River.
•
Location – South of Braidwood, Will County, Illinois
•
Case No. – AS 03-1
•
Case Type – Adjusted Standard
•
Approval date: June 19, 2003
•
Media Type – Water
•
Proposal to adjust effluent limits of total dissolved solids (TDS) from 1,000 mg/L to
1,900 mg/L. The discharge from the STC includes domestic and cafeteria waste
streams, as well as pollution control waste produced in the electrodialysis reversal
process used to treat the brackish groundwater to potable standards.
The
concentrations of TDS from the groundwater range from 1,300 mg/L to in excess of
1,600 mg/L.
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
19
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
•
Illinois EPA Response – The Illinois EPA recommended the IPCB grant Exelon the
requested adjusted standard from the general use water quality standards (Section
302.208) for TDS. The Illinois EPA agreed that (1) the discharge levels of TDS are
not likely to have any adverse or detrimental effects on the aquatic life in the
receiving stream, (2) the unnamed tributary and the area of confluence with Horse
Creek are not public water supplies, (3) TDS is not the limiting factor in the receiving
stream, (4) decreasing the concentrations of TDS in the STC effluent would not
necessarily improve the biological communities in the receiving stream, (5) the TDS
concentrations in the unnamed tributary have no impact on Horse Creek due to the
water flow at the confluence of the unnamed tributary and Horse Creek, and (6)
Exelon’s request for an adjusted standard from the IPCB’s TDS water quality
standard (Section 302.208(g)) is consistent with federal law. However, the Illinois
EPA argues that granting an adjusted standard from the IPCB’s effluent limits
(Section 304.105) is not consistent with federal law. Therefore, the Illinois EPA
recommended the IPCB deny an adjusted standard from Section 304.105.
•
IPCB granted Exelon Generation Company an adjusted standard from 35 Ill. Adm.
Code 302.208.
Rhodia, TCBSD, and Consumers Illinois Water
•
Petitioner – Rhodia, Inc., the Thorn Creek Basin Sanitary District (TCBSD), and
Consumers Illinois Water Company.
•
Facility – Rhodia’s proposed expansion of their existing silica manufacturing plant
and the TCBSD treatment plant.
•
Location – Chicago Heights, Cook County, Illinois
•
Case No. – AS 01-9
•
Case Type – Adjusted Standard
•
Approval date: January 10, 2002
•
Media Type – Water
•
Proposal to adjust effluent limits of sulfate and total dissolved solids (TDS) for the
following locations:
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
20
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
a. Thorn Creek from the TCBSD WWTP discharge to the confluence with Deer
Creek for sulfate from 1,000 mg/L to 1,350 mg/L and total dissolved solids (TDS)
from 2,100 mg/L to 2,650 mg/L.
b. Thorn Creek from the confluence with Deer Creek to USGS Gauging Station
05536275 at Thornton for sulfate from 1,000 mg/L to 1,340 mg/L and total
dissolved solids (TDS) from 1,900 mg/L to 2,620 mg/L.
c. Thorn Creek from USGS Gauging Station 05536275 at Thornton to Thorn
Creek’s confluence with the Little Calumet River for sulfate from 850 mg/L to
1,160 mg/L and total dissolved solids (TDS) from 1,900 mg/L to 2,360 mg/L.
d. Little Calumet River from the Thorn Creek confluence to the Calumet-Sag
Channel for sulfate from 750 mg/L to 1,000 mg/L and total dissolved solids (TDS)
from 1,700 mg/L to 2,020 mg/L.
•
Illinois EPA Response – The Illinois EPA recommended a grant of the requested
adjusted standards. The Illinois EPA agreed that granting the adjusted standards for
sulfate and TDS will have no measurable adverse effect on aquatic life in Thorn
Creek and the Little Calumet River.
•
IPCB granted the petitioners adjusted standards from 35 Ill. Adm. Code 304.105.
However, the IPCB did not grant the petitioners an adjusted standard from 35 Ill.
Adm. Code 302.208 because such relief was unnecessary.
L.
FUNDAMENTALLY DIFFERENT FACTORS
The Environmental Protection Act at ILCS 5/28.1(c) provides that if the regulation of
general applicability does not specify a level of justification, the Board may grant individual
adjusted standards whenever the Board determines that: “…factors relating to the
petitioner are substantially and significantly different from the factors relied upon by the
Board in adopting the general regulation”. Factors in this situation are fundamentally
different from factors relied upon by the Board in promulgating the current rule in many
aspects. Firstly, the discharge waters are all naturally occurring, not waste waters
contaminated by anthropogenic activities as is the case with other wastewater discharges.
IDOT has absolutely no control over the nature of the discharge. Also, unlike other
discharges the purpose of this discharge is not to get rid of water because it is
contaminated, but it has to be moved form its underground location in order to prevent
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
21
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
flooding and potentially significant structural damage to a major urban highway system.
Flooding of the interstate system would create a major safety hazard to the general public.
Attempting to move the discharge to go directly to the Mississippi River would cause an
enormous financial burden on the citizens of Illinois for no improvement in the
environment. This is a very unique situation, unlike anything typically contemplated in
rulemaking, and unlike any other in the State.
M. WAIVER OF HEARING (35 ILL. ADMINISTRATIVE CODE SECTION 104.406(J))
The IDOT waives hearing on this petition.
N.
CONCLUSIONS
The IDOT District 8 Bowman Yard receives water from several well field systems and
discharges to a drainage way, thence to Schoenberger Creek, thence to the Cahokia
Canal, and finally to the Mississippi River. The discharge is regulated by effluent
standards from 35 Ill. Adm. Code 304 and an Illinois EPA NPDES permit. Sulfate and
TDS have or may have exceeded the respective permitted NPDES effluent limits and
require an adjusted standard so that the IDOT facility will stay in compliance with
applicable regulations. The discharged water, including concentrations of sulfate and
TDS, is representative of naturally occurring conditions and is not known to have been
contaminated by any human contact. IDOT believes that the above factors are
substantial and significantly different from the factors relied upon by the IPCB in
adopting the general regulation, and justify an adjusted standard. The proposal to adjust
the standards was chosen over the other compliance alternatives (i.e. treatment at the
facility versus pumping or piping discharge to the Mississippi River) because of the
substantial cost.
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
22
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
REFERENCES
Andrews Environmental Engineering, Inc., 2003,
Compliance Schedule Plans and
Specifications for IDOT District 8 Bowman Avenue Pump Station At FAI 55/7-FAI-
64 Deep Well System, 7
th
and Bowman, East St. Louis, St. Clair County, Illinois
,
Consultant’s report to Illinois Environmental Protection Agency Bureau of Water
pursuant to IEPA NPDES Permit No. IL0070955.
Anliker, M.A., and R.D. Olson, 2003,
Dewatering Well Assessment for the Highway
Drainage System at Four Sites in the East St. Louis Area, Illinois (FY00-Phase 17)
,
Illinois State Water Survey Contract Report 2003-08, 53 p.
Bergstrom, R.E., and T.R. Walker, 1956,
Groundwater Geology of the East St. Louis Area,
Illinois
, Illinois State Geological Survey, Report of Investigations 191, 44 p.
Consoer Townsend Envirodyne (CTE) Engineers, Inc., 2004,
Mainline Drainage Report –
Final Submittal Illinois – FAP 999 Section 81-2 82 R, Project: I-55/70/64 Tri-Level
Interchange, St. Clair County IL
, Consultant’s report to Illinois Department of
Transportation District 8, Job No. D-98-067-00, 9 p.
Horner & Shifrin, Inc., 1994,
Stage I – Existing Condition and Analysis for Groundwater
Treatment Facilities Route FAI-55/64/70 Tri-Level Complex and Missouri Avenue in
East St. Louis and IL Route 3 Railroad Viaduct in Venice
, Consultant’s report to
Illinois Department of Transportation District 8, Job No. D-98-120-93, 47 p.
Illinois Environmental Protection Agency – Division of Water Pollution Control, December
18, 2002,
NPDES Permit No. IL0070955 for IDOT District 8 Bowman Avenue
Pump Station
.
Illinois Pollution Control IPCB, October 3, 1996,
Petition of Illinois Department of
Transportation, District 8 for an Adjusted Standard from 35 Ill. Adm. Code 302.208,
304.124 and 302.203,
AS 96-12 (Adjusted Standard – Water).
Layne Western Company, 2003,
Computer Simulation of Groundwater Flow Illinois
Department of Transportation Dewatering Wellfield, East St. Louis Illinois – FAP
999 Section 81-2 82 R (I-55/70/64) Tri-Level Interchange, St. Clair County IL
,
Consultant’s report for Consoer Townsend Envirodyne Engineers, Inc. and Illinois
Department of Transportation District 8, Job No. D-98-120-93, 47 p.
Sanderson, E.W., A.P. Visocky, M.A. Collins, R.D. Olson, and C.H. Neff, 1984,
Dewatering
Well Assessment for the Highway Drainage System at Four Sites in the East St.
Louis Area, Illinois (Phase 1)
, Illinois State Water Survey Contract Report 341, 48
p.
Schicht, R.J., and A.G. Buck, 1995,
Ground-Water Levels and Pumpage in the Metro-East
Area, Illinois, 1986-1990
, Illinois State Water Survey Circular 180, 44 p.
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
23
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Figure 1
Back to top
Schematic of Bowman Yard Discharge
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
24
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Figure 2
Back to top
Location of East St. Louis Dewatering Sites
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
25
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Figure 3
Back to top
Locations of Dewatering Wells at the I-70 Tri-Level,
Back to top
I-64 and 25th Street Sites
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
26
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Figure 4
Back to top
Locations of Dewatering Wells at Missouri Avenue Site
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
A
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Appendix A
Back to top
Site Location Map
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
B
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Appendix B
Back to top
Geologic Cross Sections
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
C
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Appendix C
Back to top
Bowman Avenue Pump Station and Missouri Avenue Well Field
Back to top
Historical Water Quality Data
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
D
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Appendix D
Back to top
Bowman Avenue Pump Station and Missouri Avenue Well Field
Back to top
Graphs of Parameters versus Time
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
IDOT Bowman Avenue Pump Station
E
Petition for Adjusted Standard
Andrews Engineering, Inc.
July 2007
Appendix E
Back to top
Individual Deep Pumping Wells Historical Water Quality Data
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Appendix E - Individual Deep Pumping Wells
(25th St./I-55 TRI-Level/I-64/Missouri Ave.) - Historical Water Quality Data
Min
Max
Mean
Min
Max
Mean
Min
Max
Mean
Well
Analyte
Units
Limits
Oct-03
Dec-03
Feb-04
Mar-04
May-04
Aug-04
Nov-04
Feb-05
33.5
336
91.03304
25th St.-2
Chloride, total
mg/L
41.4
35.4
46.7
43.1
45.5
80.4
47.5
35.4
80.4
48.57143
25th St.-4
Chloride, total
mg/L
38.4
37.3
38.7
40.1
41.3
85.4
55.3
37.3
85.4
48.07143
25th St.-7
Chloride, total
mg/L
38.4
33.5
34.7
35.2
41.4
51.9
33.5
51.9
39.18333
25th St.-8
Chloride, total
mg/L
37.4
33.5
40.7
37.2
41.7
51.4
33.5
51.4
40.31667
33.5
85.4
44.36538
I55 - 04
Chloride, total
mg/L
68
85.2
94.3
87.1
93.4
111
75.3
68
111
87.75714
I55 - 05
Chloride, total
mg/L
112
106
69.5
97.8
134
69.5
134
103.86
I55 - 06A
Chloride, total
mg/L
89.7
101
96.3
92
82.9
100
93.9
82.9
101
93.68571
I55 - 09A
Chloride, total
mg/L
67
67
67
67
I55 - 10
Chloride, total
mg/L
85.7
74.7
71.5
88.6
71.5
88.6
80.125
I55 - 11A
Chloride, total
mg/L
72.9
77.5
89.3
82.2
79.8
68.5
85.1
68.5
89.3
79.32857
I55 - 12A
Chloride, total
mg/L
55.2
85.2
98.3
86.1
86.3
93.3
94.4
55.2
98.3
85.54286
I55 - 13
Chloride, total
mg/L
79.4
94.3
82.2
85.8
79.4
81.2
79.4
94.3
83.71667
I55 - 15
Chloride, total
mg/L
113
105
108
103
132
103
132
112.2
55.2
134
89.67959
I64-19
Chloride, total
mg/L
168
166
175
173
85.2
191
158
85.2
191
159.4571
I64-20
Chloride, total
mg/L
315
297
275
111
290
336
333
111
336
279.5714
85.2
336
219.5143
Missouri - 1
Chloride, total
mg/L
71
87.1
68.5
71.4
71.4
68.5
87.1
73.88
Missouri - 2
Chloride, total
mg/L
80.8
76.6
76.4
69.5
64.2
39.7
82.2
39.7
82.2
69.91429
Missouri - 3
Chloride, total
mg/L
64.1
69.9
72.5
63.6
61.6
69
70.4
61.6
72.5
67.3
Missouri - 4
Chloride, total
mg/L
77.9
80.4
83.9
78.3
80.4
39.7
77.3
39.7
83.9
73.98571
39.7
87.1
71.06923
Well
Analyte
Units
Limits
Oct-03
Dec-03
Feb-04
Mar-04
May-04
Aug-04
Nov-04
Feb-05
0.1
2.69
0.525621
25th St.-2
Fluoride, total
mg/L
0.26
0.801
0.8
0.757
0.669
0.73
0.386
1.16
0.26
1.16
0.695375
25th St.-4
Fluoride, total
mg/L
0.82
0.259
0.22
0.27
0.1
0.162
0.285
0.226
0.1
0.82
0.29275
25th St.-7
Fluoride, total
mg/L
0.26
0.271
0.22
0.259
0.1
0.196
0.223
0.1
0.271
0.218429
25th St.-8
Fluoride, total
mg/L
0.32
0.305
0.23
0.276
0.1
0.188
0.408
0.1
0.408
0.261
0.1
1.16
0.375367
I55 - 01A
Fluoride, total
mg/L
2.27
2.27
2.27
2.27
I55 - 04
Fluoride, total
mg/L
1.41
0.312
0.26
0.263
0.13
0.199
0.266
0.273
0.13
1.41
0.389125
I55 - 05
Fluoride, total
mg/L
0.325
0.299
0.245
0.403
0.288
0.245
0.403
0.312
I55 - 06A
Fluoride, total
mg/L
0.43
0.413
0.36
0.365
0.258
0.335
0.442
0.389
0.258
0.442
0.374
I55 - 09A
Fluoride, total
mg/L
0.26
0.236
0.236
0.26
0.248
I55 - 10
Fluoride, total
mg/L
0.47
0.463
0.29
0.226
0.212
0.212
0.47
0.3322
I55 - 11A
Fluoride, total
mg/L
0.38
0.319
0.39
0.395
0.275
0.385
0.978
0.544
0.275
0.978
0.45825
I55 - 12A
Fluoride, total
mg/L
0.29
0.271
0.26
0.276
0.1
0.26
0.328
0.278
0.1
0.328
0.257875
I55 - 13
Fluoride, total
mg/L
0.59
0.282
0.115
0.171
0.386
0.882
0.115
0.882
0.404333
I55 - 15
Fluoride, total
mg/L
0.28
0.167
0.261
0.39
0.312
0.167
0.39
0.282
0.1
2.27
0.386732
I64-19
Fluoride, total
mg/L
0.34
2.12
2
1.95
1.56
2.32
2.36
2.02
0.34
2.36
1.83375
I64-20
Fluoride, total
mg/L
0.34
1.44
1.5
1.61
1.38
1.8
1.82
2.69
0.34
2.69
1.5725
0.34
2.69
1.703125
Missouri - 1
Fluoride, total
mg/L
0.36
0.315
0.32
0.323
0.167
0.286
0.167
0.36
0.295167
Missouri - 2
Fluoride, total
mg/L
0.33
0.343
0.38
0.281
0.1
0.335
0.806
0.341
0.1
0.806
0.3645
Missouri - 3
Fluoride, total
mg/L
0.32
0.338
0.34
0.333
0.183
0.32
0.329
0.283
0.183
0.34
0.30575
Missouri - 4
Fluoride, total
mg/L
0.32
0.286
0.29
0.276
0.124
0.269
0.243
0.273
0.124
0.32
0.260125
0.1
0.806
0.307133
by Parameter
by site
within each well
* System - Well # (ex. I55 - 01A) = Individual Well System followed by the specific well from the system.
Andrews Engineering, Inc.
6/7/2007 10:02 AM
1 of 2
J:\IDOT2006\IDOT2006-003\Analytical\Bowman Yard Data May 1994 to Present
Parameter (rev2)
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
Appendix E - Individual Deep Pumping Wells
(25th St./I-55 TRI-Level/I-64/Missouri Ave.) - Historical Water Quality Data
Min
Max
Mean
Min
Max
Mean
Min
Max
Mean
by Parameter
by site
within each well
Well
Analyte
Units
Limits
Oct-03
Dec-03
Feb-04
Mar-04
May-04
Aug-04
Nov-04
Feb-05
586
2350
1081.364
25th St.-2
Solids, Total Dissolved (TDS)
mg/L
1000
1350
1370
1400
1320
1240
1300
939
1560
939
1560
1309.875
25th St.-4
Solids, Total Dissolved (TDS)
mg/L
1000
724
712
719
738
756
697
1040
810
697
1040
774.5
25th St.-7
Solids, Total Dissolved (TDS)
mg/L
1000
639
648
655
661
639
675
706
639
706
660.4286
25th St.-8
Solids, Total Dissolved (TDS)
mg/L
1000
641
586
644
691
686
677
886
586
886
687.2857
586
1560
870.3
I55 - 01A
Solids, Total Dissolved (TDS)
mg/L
1000
1170
1170
1170
1170
I55 - 04
Solids, Total Dissolved (TDS)
mg/L
1000
775
812
932
972
883
924
1130
818
775
1130
905.75
I55 - 05
Solids, Total Dissolved (TDS)
mg/L
1000
993
997
688
1020
972
688
1020
934
I55 - 06A
Solids, Total Dissolved (TDS)
mg/L
1000
806
784
782
792
772
676
736
772
676
806
765
I55 - 09A
Solids, Total Dissolved (TDS)
mg/L
1000
1040
1040
1040
1040
1040
I55 - 10
Solids, Total Dissolved (TDS)
mg/L
1000
1120
1180
1120
1130
1070
1070
1180
1124
I55 - 11A
Solids, Total Dissolved (TDS)
mg/L
1000
1210
1150
1190
1190
1280
1140
999
1210
999
1280
1171.125
I55 - 12A
Solids, Total Dissolved (TDS)
mg/L
1000
717
973
1220
1330
1160
1200
1300
1280
717
1330
1147.5
I55 - 13
Solids, Total Dissolved (TDS)
mg/L
1000
1040
1100
1100
1070
983
1050
983
1100
1057.167
I55 - 15
Solids, Total Dissolved (TDS)
mg/L
1000
980
1020
828
924
864
828
1020
923.2
676
1330
1007.393
I64-19
Solids, Total Dissolved (TDS)
mg/L
1000
1780
1800
1840
1860
1810
1770
1840
1630
1630
1860
1791.25
I64-20
Solids, Total Dissolved (TDS)
mg/L
1000
2210
2290
2350
2280
2210
1830
2070
2260
1830
2350
2187.5
1630
2350
1989.375
Missouri - 1
Solids, Total Dissolved (TDS)
mg/L
1000
831
836
942
813
879
866
813
942
861.1667
Missouri - 2
Solids, Total Dissolved (TDS)
mg/L
1000
963
933
856
957
808
883
1390
938
808
1390
966
Missouri - 3
Solids, Total Dissolved (TDS)
mg/L
1000
963
943
935
970
916
948
954
970
916
970
949.875
Missouri - 4
Solids, Total Dissolved (TDS)
mg/L
1000
990
1060
1050
1070
1050
979
746
948
746
1070
986.625
746
1390
946.2333
Well
Analyte
Units
Limits
Oct-03
Dec-03
Feb-04
Mar-04
May-04
Aug-04
Nov-04
Feb-05
108
1420
392.1515
25th St.-2
Sulfate, total
mg/L
500
377
876
1420
711
569
685
227
716
227
1420
697.625
25th St.-4
Sulfate, total
mg/L
500
256
315
249
202
141
205
250
205
141
315
227.875
25th St.-7
Sulfate, total
mg/L
500
198
273
236
172
141
240
201
141
273
208.7143
25th St.-8
Sulfate, total
mg/L
500
259
349
231
226
139
188
302
139
349
242
139
1420
351.9667
I55 - 01A
Sulfate, total
mg/L
500
368
368
368
368
I55 - 04
Sulfate, total
mg/L
500
219
256
381
287
220
341
247
224
219
381
271.875
I55 - 05
Sulfate, total
mg/L
500
388
250
139
275
245
139
388
259.4
I55 - 06A
Sulfate, total
mg/L
500
202
237
225
159
146
184
108
232
108
237
186.625
I55 - 09A
Sulfate, total
mg/L
500
368
438
368
438
403
I55 - 10
Sulfate, total
mg/L
500
388
466
272
329
457
272
466
382.4
I55 - 11A
Sulfate, total
mg/L
500
589
500
482
426
401
491
289
431
289
589
451.125
I55 - 12A
Sulfate, total
mg/L
500
307
419
461
487
522
670
342
516
307
670
465.5
I55 - 13
Sulfate, total
mg/L
500
368
308
289
593
248
295
248
593
350.1667
I55 - 15
Sulfate, total
mg/L
500
368
251
248
183
181
181
368
246.2
108
670
334.2143
I64-19
Sulfate, total
mg/L
500
1190
938
798
603
486
833
478
708
478
1190
754.25
I64-20
Sulfate, total
mg/L
500
1340
1010
871
683
748
945
762
951
683
1340
913.75
478
1340
834
Missouri - 1
Sulfate, total
mg/L
500
301
257
280
188
241
257
188
301
254
Missouri - 2
Sulfate, total
mg/L
500
340
288
267
281
179
301
642
447
179
642
343.125
Missouri - 3
Sulfate, total
mg/L
500
365
326
295
260
248
335
247
289
247
365
295.625
Missouri - 4
Sulfate, total
mg/L
500
405
360
316
344
265
373
181
267
181
405
313.875
179
642
304.8333
* System - Well # (ex. I55 - 01A) = Individual Well System followed by the specific well from the system.
Andrews Engineering, Inc.
6/7/2007 10:02 AM
2 of 2
J:\IDOT2006\IDOT2006-003\Analytical\Bowman Yard Data May 1994 to Present
Parameter (rev2)
Electronic Filing, Received, Clerk's Office, July 27, 2007
* * * * * AS 2008-001* * * * *
