BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

WATER QUALITY STANDARDS AND

EFFLUENT LIMITATIONS FOR THE

CHICAGO AREA WATERWAY SYSTEM

AND THE LOWER DES PLAINES RIVER:

PROPOSED AMENDMENTS TO 35 Ill.

Adm. Code Parts 301, 302, 303 and 304

R08-9

(Rulemaking

-

Water)

PRE-FILED TESTIMONY OF ADRIENNE D. NEMURA

This report presents the opinions that I

,

Adrienne D. Nemura, P.E., am submitting to the

Illinois Pollution Control Board related to the comprehensive water quality standards proposal by

the Illinois Environmental Protection Agency

(

IEPA

).

IEPA is proposing to update the

designated uses and criteria for the Chicago Area Waterway System

(CAWS).

My opinions

address IEPA's failure to consider the need for wet weather water quality standards for the

CAWS in the agency's proposal.

I am a Vice President and an Owner of LimnoTech, an environmental consulting firm

with headquarters in Ann Arbor

,

Michigan. I am a licensed Civil Engineer and have 24 years of

experience evaluating impacts of pollutant sources on watersheds and waterways

.

Specifically, I

have focused the last 11 years on evaluating the impacts of sewer overflows on water quality and

development of appropriate control measures to meet water quality standards

.

I have worked for

numerous municipalities on combined sewer overflow

(

CSO) control plans and have supported

the United States Environmental Protection Agency

(

US EPA

)

in developing guidance

documents

,

training materials, and Reports to Congress on these issues. This work has included

assessment of CSO impacts

,

evaluation of CSO control alternatives

,

preparation of long-term

1

---

control plans

,

and review and revision of water quality standards, including use attainability

analyses

(UAAs).

My education

,

registrations, professional appointments, professional affiliations, and

specific projects and publications are included in Attachment 1. My experience includes chairing

a scheduled workshop

at WEFTEC

2008 in Chicago on development of new "pathogen" criteria

and expert assistance to the National Association of Clean

Water

Agencies in the Beach Act

case.

Overview

It is my professional opinion

that IEPA

improperly established standards for aquatic life

and recreational uses in the

CAWS because

the agency did not demonstrate that the uses are

attainable when the system is impacted

by wet

weather discharges

.

The CAWS is

unique as the

system was designed and is operated to receive and transport wet weather discharges including

runoff from

tributaries

,

CSOs,

pump station bypasses

,

and stonnwater

runoff to

prevent flooding

and other impacts in the Chicago metropolitan area.

IEPA

failed to demonstrate that the proposed standards can be met despite wet weather

discharges today and in the future, even if additional treatment is provided. The proposed

standards are therefore premature and if adopted

,

should include a provision for exemptions to

the standards due to wet weather conditions. In particular, a provision is needed to inform the

public that the waterways should not be used for recreation when impacted

by wet

weather

discharges. Furthermore

,

the agency should address the impacts of these discharges on

attainability

of the

proposed aquatic life standards. Specific opinions are provided below.

---

1.

By deferring promulgation of criteria for recreational uses, Illinois EPA has not

established that the recreational uses will be attained when wet weather discharges occur.

Section 101(a)(2) of the Clean Water Act establishes a national goal that "wherever

attainable", water quality standards shall be set to protect aquatic life and recreational uses.

Section 303(c)(2)(A) directs that new or revised standards "shall consist of the designated uses of

the navigable waters involved and the water quality criteria for such waters based upon such

uses." The criteria are used for decisions about identifying impairments, notification of beach

closures, NPDES permitting, and development of Total Maximum Daily Loads.

The agency did not include "a numeric bacteria standard to protect recreational activity"

(IEPA, 2007, p. 24) and "defer setting numerical standard for bacterial parameters for all three of

the proposed recreational use designations" (IEPA, 2007, p. 42). IEPA instead proposed a

technology-based effluent disinfection requirement to "assure that disinfection technologies are

functioning properly" at wastewater treatment facilities so that the recreational uses can be met

(IEPA, 2007, p. 92). IEPA states, however, that:

"it is clear that as a result of CSOs during wet weather, any level of

recreational activity in the waterway is unhealthy during periods when

raw sewage is present. Until completion and operability of the

reservoir phase of the Tunnel and Reservoir Project system, numerous

CSO discharges will continue to produce highly elevated bacterial

levels that likely create an unacceptably high health risk for

recreational activity during and immediately following these periods.

While there may be an argument that most of the current recreational

activity may be reasonably attained during dry weather, conditions

under wet weather are clearly incompatible with recreational activity

and the recreational use is not being attained during those conditions at

any reasonably acceptable risk level" (IEPA, 2007, p. 45).

IEPA has failed to define "dry weather" or what recreational activity can be attained at

different locations or different times along the CAWS. The agency has not demonstrated that it

assessed how CSOs and other wet weather discharges prevent attainment of the designated uses

along the waterways, during or after a wet weather event. Attachment 2 provides a description of

3

---

the impact of the CSOs, pump station bypasses, and tributary runoff on bacteria levels in the

CAWS. This information shows that the magnitude, frequency and duration of the CSO impact

on bacteria levels vary from location to location and from storm to storm. In some instances,

these impacts are calculated to last several days after wet weather discharges have ceased.

It should be noted that there has been long-standing concern (as well as confusion) over

the validity and implementation of US EPA's 1986 bacteria criteria (ASIWPCA, 2005).

Nevertheless, States have adopted, with US EPA approval, numeric water quality criteria for

both primary and secondary contact recreation. Several states have retained numeric criteria for

recreational uses while recognizing the need for wet weather exemptions due to CSOs. Examples

are provided in Attachment 3. If no regulatory target is provided to address wet weather

conditions, the public will not know when the water is safe for recreation and when it is not, and

decisions about appropriate levels of control for sources other than wastewater treatment

facilities will be arbitrary. The District has completed a human health risk assessment for

conditions during dry and wet weather and is in the process of completing an epidemiological

study of the waterways. These results should be considered by the agency in any proposed

revisions to the designated uses so that the standards reflect the potential health risks associated

with recreation in the waterways.

2. IEPA

did not evaluate the impact

of wet

weather discharges on aquatic life or

whether

the proposed standards could be met when the

CAWS are impacted by wet weather.

IEPA established two new aquatic life uses (A and B) for the CAWS to maintain

populations "that are adaptive to the unique physical conditions, flow patterns, and operational

controls necessary to maintain navigational use, flood control, and drainage functions of the

waterway system" (IEPA, 2007, p. 46). The distinction between the two definitions is that Use A

waters include "tolerant and intermediately tolerant types" and Use B waters include "tolerant"

4

---

types that have adapted to "deep-draft, steep-walled shipping channels." For both uses, a daily

minimum dissolved oxygen of 3.5 mg/1 and a 7-day mean of daily minima of 4.0 mg/l is

proposed for when early life stages are absent. For Use A, a daily minimum of 5.0 mg/1 is

proposed as necessary to protect early life stages from March to July.

In establishing these uses and the associated criteria, IEPA (and the UAA upon which the

standards are presumably based) did not address the effects of intermittent low dissolved oxygen

as a result of wet weather discharges, even though these effects were recognized as being present

in the UAA (CDM, 2007). Ample continuous monitoring data and receiving water quality

modeling information exists that shows that wet weather discharges will cause the dissolved

oxygen to drop below the proposed criteria. Alp and Melching (in press) identified that

precipitation and duration of storm effects on low dissolved oxygen levels in the CAWS are well

correlated.

The magnitude, frequency and duration of these low dissolved oxygen conditions

varies from location to location and storm to storm as shown in Attachment 4.

IEPA did not identify the species of fish or benthic organisms that will benefit from the

proposed changes nor did the agency identify whether these species are adversely impacted by

periodic wet weather events. Furthermore, IEPA did not identify the magnitude, frequency or

duration of low dissolved oxygen events that could be tolerated by these species. Data from the

District's continuous dissolved oxygen monitoring network shows that the magnitude, frequency,

and duration of the CSO impacts varies from location to location and from storm to storm. These

data show that the dissolved oxygen can get very low (zero to two milligrams per liter) at times

and these impacts can last several days to a week at some locations.

As stated in testimony of Samuel Dennison, the ability of fish to avoid the low dissolved

oxygen segments may explain the lack of frequent fish kills throughout the system in spite of

---

dissolved oxygen levels that routinely drop below IEPA's proposed minimum criteria of 3.5

mg/l. These conditions are likely to remain as long as there are wet weather sources. For

example, as shown in Attachment 4, low dissolved oxygen levels are likely to remain even if the

gravity CSOs could be eliminated due to pump station discharges, sediment resuspension,

stormwater runoff, and tributary loads.

3. IEPA did not evaluate whether

provisions

could be

designed

to protect the proposed

aquatic life and recreational uses when

the CAWs are impacted by wet weather.

In research on UAAs, Freedman et al (2007, p. 1-4) notes that wet weather sources

"create unique issues in the context of meeting water quality standards because of the difficulty

of tracking these sources and the expenses associated with controlling them... therefore, having

realistic attainable standards as the regulatory target is critical." US EPA's guidance on using

flow duration curves in Total Maximum Daily Loads, for example, specifically mentions that

criteria could explicitly state applicability under certain conditions (e.g., dry weather or 7Q10

flow) to reduce the importance of the criteria during conditions such as wet weather (US EPA,

2007, p. 12). IEPA did not document that it considered the need to establish realistic attainable

targets for wet weather conditions in its proposed rulemaking.

Furthermore, a key principle of the 1994 CSO Policy is "[r]eview and revision, as

appropriate, of water quality standards and their implementation procedures when developing

CSO control plans to reflect site-specific wet weather impacts of CSOs" (59 FR 18688). In

response to directives from Congress, US EPA developed guidance in 2001 for coordinating

water quality standards reviews for water bodies where long-term CSO control plans will be

implemented because "implementation of this principle has not progressed as quickly as

expected" (US EPA, 2001, p. i).

6

---

IEPA indicates that the proposed dissolved oxygen criteria cannot be met during wet

weather. IEPA states:

"The existing Secondary Contact and Indigenous Aquatic Life dissolved oxygen

standards applicable to these waters are 3.0 mg/L in the Calumet-Sag Channel and

4.0 m/1 in the rest of the waters, and are frequently violated during wet weather

periods. During periods when wet weather causes CSO discharges to impact the

CAWS and Lower Des Plaines River, dissolved oxygen levels can drop to zero.

Similarly, at least until the Tunnel and Reservoir Project is complete in 2016, it is

highly likely the proposed dissolved oxygen standards will be violated" (IEPA, 2007,

p. 61).

IEPA should have considered the wet weather discharges in this standards review given

that the District has an approved plan -the Tunnel and Reservoir Project - for controlling

CSOs. As described in US EPA (2001), one of US EPA's goals in developing the water quality

standards' review guidance was "for states to review and revise water quality standards as

appropriate to ensure they are attainable." US EPA identifies a number of options that states can

pursue in adopting standards that recognize the impact of wet weather discharges. These

approaches include segmenting the water body; adopting subclasses to recognize intermittent

exceedances of criteria or physical characteristics and/or ecological systems; and high flow

cutoffs.

Several states have modified their water quality standards to reflect the challenges

associated with attaining uses during wet weather (Freedman, 2007, p. ES-5). Examples include

state legislation in Indiana, Maine, and Massachusetts as described in Attachment 3. Indiana

allows for a temporary suspension of the recreational uses if CSO discharges are in accordance

with an approved long-term control plan and a UAA. Massachusetts allows for a partial use

designation for recreational or aquatic life uses with a UAA or a variance. Maine allows for a

CSO subcategory where recreational and aquatic life uses may be temporarily suspended.

7

---

Several UAAs have also been conducted that allow for suspension of recreational uses due to

wet weather discharges (Attachment 3).

The District has made a significant investment in developing a water quality model that

can he used to assess the atta in ability

of

loth proposed

r

ec

reational us es and aquatic life uses,

and

th

is cnuld readily

b

e applied to ascertain the c onditions that

are caused

by wet weather.

The

appropriate path for establishing attainable uses for the CAWS would be to apply this model to

distinguish the effects of

dry

and wet weather s

ources; us

e

the results of the human health risk

assessment and epidemiological study; assess information Crom ongoing aquatic life and habitat

research; and asscss the economic and social impact to identify the controls necessary to attain

the proposed standards.

8

---

Respectfully

submitted,

fay:

Adrienne Nen

turca

---

Testimony Attachments

1.

Adrienne D. Nemura curriculum vita

2.

Description of the impact of the CSOs, pump station bypasses, and tributary runoff on

bacteria levels in the CAWS

3.

Examples of wet weather water quality standards

4.

Description of the impact of gravity CSOs and other wet weather discharges on

dissolved oxygen levels in the CAWS

5.

Alp, E. (2006)

REFERENCES

Alp, E. (2006). "A method to evaluate duration of the storm effects on in-stream water quality."

Ph.D. Thesis, Department of Civil and Environmental Engineering, Marquette University,

Milwaukee, WI.

Association of State and Interstate

Water Pollution Control Agencies (ASIWPCA) (2005).

Pathogen Criteria White Paper. ASIWPCA Water Quality Standards Taskforce. Nov. 4.

CDM. (2007). Chicago Area Waterway System Use Attainability Analysis. 8-01-07 edits

version.

http://www.ipcb.state.il.us/documents/dsweb/Get/Document-59252/

Accessed Jan.

2008.

Freedman, P. and T. Dupuis, et al (2007). Factors for Success in Developing Use Attainability

Analyses.

Water Environment Research Federation. 04-WEM-1.

IEPA. (2007). Statement of Reasons in the Matter of Water Quality Standards and Effluent

Limitations for the Chicago Area Waterway System and the Lower Des Plaines River: Proposed

Amendments to 35 111 Adm. Code Parts 301, 302, 303, and 304.

US EPA (2001) Guidance: Coordinating CSO Long-Term Planning With Water Quality

Standards Reviews. EPA-833-R-01-002.htt-p://www.epa.gov/n-pdes/pubs/wqs guide final.pdf

US EPA (2007) An Approach for Using Load Duration Curves in the Development of TMDLs.

EPA 841-B-07-006. August.

9

---

A

tt

a

chm

e

nt 1

---

Adrienne D. Nemura, P.E.

Vice President

LimnoTech

Principal Expertise

•

Tackling Wet Weather Problems (CSO,

SSO, Stormwater, Peak Municipal

Treatment Plant Flows)

•

Expert Monitoring and Modeling for

Water Resource Decisions

•

Developing and Reviewing TMDLs and

Use Attainability Analyses

•

Negotiating Fair & Effective NPDES

Permits

•

Expert Support for Litigation and

Consent Decrees

•

Technical & Policy Support to Local

Governments

Education

MS

Civil Engineering

Virginia Polytechnic

Institute

and State University, Blacksburg, Virginia, 1986

BS

Civil Engineering

Virginia Polytechnic Institute and State University, Blacksburg, Virginia, 1984

Registration

/

Certification

Professional Engineer, Michigan, 1999 (#46150)

National Council of Examiners for Engineering and Surveying (#24958)

Experience Summary

Ms. Nemura manages LimnoTech's services for providing creative solutions for permits and water quality

regulations. She has 24 years of experience evaluating impacts of pollutant sources on watersheds and

waterways, is active in several national organizations, and is a routine speaker at national conferences on

water quality issues.

Ms. Nemura works for municipalities, industries, state and federal regulatory agencies, and attorneys on a

wide variety of environmental engineering projects. For example, she has:

•

Assisted a utility in implementing the country's first wet weather Consent Decree based on the

principles of watershed management;

•

Provided training for US EPA, States, and municipalities on the national Combined Sewer Overflow

(CSO) Policy and provided expert assistance to numerous municipalities in complying with the

Policy;

•

Directed water quality strategy discussions and monitoring and modeling programs for a significant

number of wastewater treatment plants and CSO communities; and

•

Assisted municipal and industrial clients in reviewing TMDLs, assessing water quality standards

compliance, obtaining fair and cost-effective permit limits, and serving as an expert witness in

litigation.

---

While at the Virginia Water Control Board, Ms. Nemura was responsible for pollution control for the

James and Appomattox Rivers. At the Metropolitan Washington Council of Governments, she

represented a large constituency of regulated parties and directed the region's water resource programs.

Professional and Academic Appointments

Vice President

Apr. 2007 -

Present

LimnoTech

Ann Arbor, Michigan

Senior Manager

Jul. 2003 - Apr. 2007

Senior Environmental Engineer

Aug. 1997 -

Jun. 2003

Water

Resources Program

Director

Jan. 1997 - Aug. 1997

Chief, Water Quality Management &

Administrative & Technical Services

1992 - 1996

Section Manager, Water Quality

Modeling and Technical Support

1991-1992

Senior Environmental Engineer

1990-1991

Environmental Engineer

1988-1990

Water Resources Engineer

1986-1988

Cooperative Education Student

1981-1984

LimnoTech

Ann Arbor, Michigan

Limno-Tech, Inc.

Ann Arbor, Michigan

Metropolitan Washington Council of Governments

Washington, DC

Metropolitan Washington Council of Governments

Washington, DC

Metropolitan Washington Council of Governments

Washington, DC

Metropolitan Washington Council of Governments

Washington, DC

Metropolitan Washington Council of Governments

Washington, DC

Virginia Water Control Board

Richmond, Virginia

GKY and Associates, Inc.

Roanoke and Springfield, Virginia

Professional and Service Organization Affiliations

National Association of Clean Water Agencies (NACWA), 2002 - Present.

NACWA Emerging Contaminants Workgroup, 2006 - Present.

Water Environment Federation (WEF), 1998 - Present.

WEF Secondary Treatment Water Quality Workgroup, 2008 - Present.

American Society of Civil Engineers, 1984 - Present.

Chi Epsilon, 1980 -Present.

Charter Member. Avis Farms Toastmasters, 2001 - Present.

Board Member. Therapeutic Riding, Inc. 2004 - Present.

LimnoTech

Revised

7125108

Adrienne D. Nemura

Page 2

---

Selected Experience

Regulatory Support

Water Quality Regulations Support for the Chairman of the ORSANCO POTW Committee. Expert

review of proposed revisions to water quality standards and development of a bacterial TMDL for the

Ohio River. (Apr. 2008 - Present, <5%).

Advisory Panel for National Association of Clean Water Agencies v. EPA in the BEACH Act Case.

2:2006cv04843. Assist NACWA's counsel and expert witness in preparing testimony and negotiating a

multi-party settlement agreement (Jul. 2007 - Present, <5%).

Member, Strategic Advisory Team for Sanitation District No. 1 of Northern Kentucky. Provide strategic

advice to the District on development of watershed plans to meet the requirements of the country's first

consent decree for CSOs and SSOs that is based on the watershed approach (Jun. 2006 - Present, <5%).

Expert Witness for Northeast Ohio Regional Sewer District. Successfully represented the client in

demonstrating that an extensive data collection program proposed by EPA was not needed for making

decisions about the adequacy of the District's CSO long-term control plans. Case No. 1:07 CV 23(Feb. to

Mar. 2007, <5%).

Factors for Success in Developing Use Attainability Analyses. Senior engineer on research for the

Water Environment Research Federation on successes and failures associated with UAAs, particularly for

wet weather, urban, effluent dependent and effluent dominated water bodies. (Feb. to Nov. 2006, <5%).

Expert Witness for Colorado Springs Utilities. Analyzed information to assess water quality impacts

associated with SSOs and spills of reclaimed water. (Jun. 2006 - Feb. 2008, <5%).

Review of Proposed Revisions to the District of Columbia's Water Quality Standards. Senior

Manager for review and comment on the proposed changes to water quality standards that address Federal

criteria for bacteria, dissolved oxygen, clarity, and chlorophyll a. (Jan. 2005 to Oct. 2005, <5%)

National Combined Sewer Overflow Policy Support 1999 to Mar. 2007. Senior Engineer involved in

the development of guidance

manuals and training

for the combined sewer overflow policy. Assisted

in the development of the guidance manual Review of Long-Term Control Plans (10/01-2/02, 2%) to

assist federal and state regulatory agencies in approving long-term control plans. Conducted training for

EPA and state water quality agencies in Indianapolis, IN (2/02), Harrisburg, PA (3/02), Chicago, IL

(7/03), Buffalo, NY (10/04), Albany, NY (11/04), Philadelphia (12/04), and Covington, KY (9/05) on

developing and reviewing LTCPs. Reviewed two LTCPs for state regulatory

agencies

in Ohio (8-9/06)

and one for Illinois (3/07). Member of a senior technical team responsible for reviewing development of

the EPA guidance document for Coordinating CSO Long-term Control Planning with Water Quality

Standards Reviews (5/00-6/01, 2%). Presented the receiving water monitoring and modeling chapters of

the EPA guidance manual on CSO Monitoring and Modeling in Washington, PA (9/99). Provided

training on conducting CSO and SSO inspections in Chicago, IL (11/03). Author of a chapter on the

resources spent on sewer overflows for the 2004 Report to Congress on the Impacts of CSOs and

SSOs and senior reviewer of remaining chapters (3/03 - 7/04). Provided senior review of development of

case studies for the EPA Report to Congress on the Status of Long-term Control Plans (4/01-6/01,

2%).

Administrative Record Review for a Draft NPDES Permit for the Washington Aqueduct Water

Treatment Plant in Washington, D.C. Project manager supporting EPA Region 3 in a confidential

administrative project for establishing permit conditions for the Aqueduct for total suspended solids and

aluminum. Managed potential conflict-of-interest issues for LTI. Co-authored a report summarizing

EPA's best professional judgment for establishing permit limits and assisted EPA in responding to

comments. (Oct. 2002 - May 2003, 4%)

LimnoTech

Revised

7125108

Adrienne D. Nemura

Page 3

---

Mica Bay, Idaho - NPDES Storm

Water Case

Development

Support. Project manager supporting

EPA Region 10 in a confidential enforcement case against the Idaho Transportation Department and its

contractor. Developed an efficient work plan to accommodate limited time and resources, directed work,

and provided senior review of the report. (Nov. 2002 - Jan. 2003, 15%)

Preparation of SSO Case Studies

for EPA

to Assess the Effectiveness of Abatement Efforts and

Regulatory Programs.

Provided senior review and guidance on the development of three case studies on

sanitary sewer overflow (SSO) abatement across the United States. EPA is using the results of the case

studies to formulate an SSO control policy (Oct. 1997 - May 1998, <2%).

Virginia

State

Water

Control Board Pollution Response Team

. 1986-1988. Team member responding

to a variety of water pollution problems ranging from investigation and remediation of oil spills, leaking

underground storage tanks, and fish kills.

Combined Sewer Overflow and Collection System Studies

Development

of a CSO LTCP for the City of Ottawa, IL. Senior manager assisting a small city and

their engineer in updating their LTCP to respond to changing regulatory requirements. Assisting in

regulatory negotiations, development of a receiving water monitoring program, water quality assessment,

collection system model, and LTCP development for a community of 18,000 people. (Nov. 2007 to

present, <5%).

Water

Quality Assessment Services for Updating

the CSO LTCP for the

Louisville Jefferson

County Metropolitan Sewer District

.

Project manager for development of a water quality data report,

Ohio River model update, and development of a water quality compliance strategy. Provide critical

review of a proposed TMDL for a watershed impacted by CSOs and SSOs and lying entirely within a

Phase II municipal separate storm sewer system (MS4) area (Feb. 2007 to present, <5%).

Watershed Characterization and Planning Services for Northern Kentucky in Support of Consent

Decree Requirements

.

Project manager for adaptive watershed planning activities for the Sanitation

District No. 1 to support requirements associated with a draft Consent Decree for combined sewer

overflows (CSOs) and sanitary sewer overflows (SSOs). Oversee development of a framework for

complying with the Consent Decree. Also oversee watershed planning including development of

integrated databases, a Watershed Assessment Tool for assessing pollutant loading potential from all

sources, development of 16 watershed characterization reports, quality assurance of ongoing receiving

water and outfall sampling, and development of more detailed water quality modeling tools to support the

long-term control plans. (Sep. 2006 - Present, 15%).

Strategic

Advisory

Team for the Sanitation District

No. 1. Selected as one of four members of a team

providing strategic advice to the District on issues and approaches associated with implementing the

adaptive watershed approach for infrastructure and watershed management. (May 2006 - Present, <5%).

Update of a Facilities Plan for the North Side Water Reclamation Plant for the Metropolitan Water

Reclamation District of Greater Chicago.

Senior project manager for application of a water quality

model for evaluating decisions associated with disinfection, flow augmentation, supplemental aeration,

and additional CSO control to meet future water quality standards for the Chicago Area Waterways (Dec.

2004 -Feb. 2007, 10%).

Update of

the CSO

Long-term Control Plan for the St

.

Louis Metropolitan Sewer

District. Expert

advisor for response to a Federal 308 letter requiring additional activities for a long-term control plan

(LTCP), development of an integrated watershed monitoring program and receiving water modeling, and

updates of the LTCP. Also assist the utility in reviewing and finalizing Use Attainability Analyses for

CSO-impacted waters (Sep. 2004 -Present, 10%)

LimnoTech

Revised

7125108

Adrienne D. Nemura

Page 4

---

Update of the CSO Long

-

term Control Plans for New

York City. Expert advisor for review of draft

CSO LTCPs for NYC DEP. (Sep. 2005 -Nov. 2006, <5%)

Water Quality

and Regulatory Support

for the City

of Kansas City, Missouri

. Senior staff member

providing assistance in selection of performance measures and review of water quality regulations and

programs for CSOs, SSOs, and stormwater for the Kansas City Water Services Department. (Nov. 2003 -

Oct. 2005, 1%)

Technical Support on the 2020 Facilities Plan for MMSD

.

Project manager and senior reviewer for

review of water quality reports associated with CSO long-term control plan development for the

Milwaukee Metropolitan Sewer District. (Jun. 2004 -Dec. 2005, 1 %)

Development of a Combined Sewer Collection System Model for St

.

Louis

,

Missouri

.

Project

Manager for development of a detailed collection system model using XP-SWMM of a 2.5-square-mile

sewershed. (Apr. 2004 - Present, 5%)

Wet Weather Water

Quality Standards for the Ohio River

.

Assisted the Ohio River Valley Water

Sanitation Commission's POTW Committee in formulating options for pursuing revision of water quality

standards to address wet weather flows and establishing a process that could be used by an Advisory

Committee to identify and select options. Analyzed Ohio River data and compiled a list of various

approaches that could be used. Co-authored a report on the regulatory options associated with review and

revision of water quality standards for water bodies impacted by wet weather discharges. (Apr. 2003 -

Sep. 2005, <5%).

Update of a Long-term Control Plan for Combined Sewer Overflows

for the City

of South Bend,

IN. Project Manager for development of an update to South Bend's CSO long-term control plan. This

includes customization of a watershed model for the St. Joseph River and pre- and post-processing

software. Oversaw results of several control alternatives and presentation of alternative water quality

standards for E,

coli.

Assisted the City in discussions with EPA, IDEM, and MDEQ regarding updates to

the LTCP. (Oct. 2004 - Present, 10%)

Expert Assistance in Implementation of the CSO Policy for South Bend

, IN. Senior advisor to the

City of South Bend and its engineer at meetings with EPA on water quality issues associated with the

City of South Bend's CSOs. Directed the development of a methodology to select a "typical year" and

development of several chapters of the long-term control and subsequent updates (Sep. 2002 - Sep. 2002,

<5%)

Receiving Water Modeling Program for the West Fork of the White River

,

Indiana.

Senior manager

for the City of Anderson in developing a receiving water characterization and model for the White River

in the vicinity of the City's combined sewer overflows (CSOs) as part of a Consent Decree agreement.

Provided oversight of the data review, design of the sampling program, and development and application

of the model and review of the chapters for the various reports and workplans. Participated in meetings

with EPA and the Indiana Department of Environmental Management on meeting requirements of the

Consent Decree. (Aug. 2002 - present, 5%)

Water Quality

Assessment for the Southerly

,

Easterly, and

Westerly

Districts

'

CSO Phase II

Facilities Plans in Cleveland

,

Ohio. Project Manager for the receiving water assessment portions of

three CSO Phase II facilities plans for the Northeast Ohio Regional Sewer District. Developed receiving

water monitoring and modeling approaches; evaluated existing data; and provided senior review of the

development and application of the receiving water models, include watershed, creek, culverts, two rivers,

and Lake Erie. Project involved monitoring for biological and conventional pollutants and detailed

velocity and temperature monitoring of the harbor, and use of SWMM, WASP, and POM models.

Authored or co-authored several report chapters for the long-term control plans and assisted the District in

preparing their summary report of the three LTCPs. (Sep. 1997 to Mar. 2005, 15%)

LimnoTech

Revised

7125108

Adrienne D. Nemura

Page 5

---

CSO Water

Quality Monitoring and Assessment

for Three

Counties in Northern

Kentucky:

Evaluation

of CSO Control

Alternatives

.

Project Manager of the water quality analysis that is

supporting the development of a long-term control plan for the Sanitation District No. 1 in Fort Wright,

KY. Co-authored a major report evaluating the water quality impacts of CSOs on Banklick Creek and the

Licking River using data analysis and receiving water models. Facilitated a workshop on preliminary

screening of CSO control technologies, developed water quality objectives, and provided technical

direction in the development of a screening/ranking system for selection of CSO control technologies.

Coordinating application of receiving water models on a continuous basis to project the benefits of Long-

term Control Plan alternatives. Developed a proposed scope of work for a process for ORSANCO to

achieve a revision to the recreational water quality standards for the Ohio River. (Mar. 1998 - Aug. 2006,

<25%).

Water Quality

Model of

E.

Coli

Bacteria

for the St

.

Joseph and Elkhart Rivers for the Cities of

Elkhart,

Mishawaka

,

and South Bend

,

Indiana

.

Project Manager for a development of a regional

watershed model for three communities with combined sewer overflows (CSOs) in EPA Region 5. She

assisted the communities in obtaining two grants to conduct monitoring and develop and refine the model,

which includes a watershed model, hydraulic model, and water quality model of the St. Joseph and

Elkhart Rivers. (Oct. 2002 - Jan. 2006, 5%)

Combined

Sewer Overflow Control for the City of Lafayette, IN. Provided senior oversight of the

development of a Lagrangian transport model to characterize the impacts of CSO and storm water

discharges from two communities on the Wabash River. (Nov. 2001-May 2005, 5%)

Combined Sewer Overflow

Control

for the City of Terre

Haute

, IN. Provided senior oversight of the

development of a receiving water sampling program and a Lagrangian transport model to characterize the

impacts of CSO and storm water discharges on the Wabash River. Evaluated monitoring data, sewer

model results, and receiving water modeling results, and provided senior review of the entire long-term

control plan document and development of the use attainability analysis. Provided presentations at public

meetings. (Nov. 2001-Present, 5%)

Receiving

Water Modeling

of Combined

Sewer Overflow Long Term

Control Plan

for the City of

Elkhart, IN. Provided senior oversight of the development and application of a Lagrangian transport

model to characterize the impacts of CSO and storm water discharges on the Elkhart and St. Joseph

Rivers. Evaluated receiving water modeling results and development of the long-term control plan and

subsequent update (May 2001

Present, <5%).

Engineering Program Management Consultant for Development and Implementation of a Long-

Term

Control Plan

for the

District of Columbia

'

s

Combined Sewer

System. Task Leader for the

development of receiving water models and post-processors for assessing combined sewer overflow

(CSO) impacts on the Anacostia River, the Potomac River, and Rock Creek. Reviewing past modeling

efforts and known receiving water impacts, and recommending a modeling strategy to assist in the

development of a long-term control plan. Providing coordination with other agencies in receiving water

and source monitoring, and development of a Total Maximum Daily Load for the Anacostia River (Aug.

1998-Apr. 2002, 10%).

Water Quality

Benefits of Combined

Sewer Overflow Abatement

in the Tidal

Anacostia River.

Final Report and Data Report

.

Project Manager and Engineer of a wet weather monitoring program and

water quality assessment of the benefits to the tidal Anacostia of the District of Columbia's Phase I CSO

Control Plan. Project included wet weather and continuous monitoring, and evaluation of pollutant loads

and sediment oxygen demand to assist the District in making an $82.4 million decision regarding benefits

of proposed future controls (1987-1991).

LimnoTech

Revised

7125108

Adrienne D

.

Nemura

Page 6

---

Eutrophication Studies

Spatial Data Analysis for Developing Lake Nutrient Standards for the State of Indiana

. Project

manager for assisting the Indiana Department of Environmental Management with reviewing water

quality, geomorphometric, and biological data to establish proposed nutrient criteria for 2,000 lakes in

Indiana. (Nov. 2005 - Jan. 2007, 2%).

Maryland Nutrient Trading Strategy

.

Project Manager and senior engineer to provide assistance to the

prime contractor developing a nutrient trading strategy for the State of Maryland, under a Water

Environment Research Federation grant. Provided comments on the potential impacts on drinking water

and defined cross-basin trading issues (Feb. 1999-Sep. 2000).

Review of Chesapeake Bay Criteria and Water Quality Modeling for the Potomac Estuary near

Washington

,

D.C. Project Manager of the review and application of proposed designated uses and

criteria for dissolved oxygen, chlorophyll a, and clarity for the Chesapeake Bay system to develop load

allocations for nutrients and solids. Providing assistance to the Metropolitan Washington Council of

Governments in evaluating appropriateness of criteria and the calibration and application of the water

quality model for determining use attainability and load reductions necessary to meet the criteria. (5%,

Sep. 2001 to Jun. 2006, <5%)

Member, Maryland Middle Potomac Tributary

Team. Team member, appointed by the Governor of

Maryland, to oversee implementation of Maryland's Middle Potomac Tributary Strategy to meet

Chesapeake Bay Nutrient Reduction Goals. Provided regional and inter-governmental coordination

between local and state agencies, as well as technical support on wastewater issues (1995-1997).

Expert Assistance on Potomac River Nutrient Reduction Strategy

.

Project Manager and Engineer

providing expert assistance to local governments in reviewing the revised Chesapeake Bay Water Quality

and Watershed Models to support development of a tributary nutrient reduction strategy for the District of

Columbia, Maryland, and Virginia (1994-1997).

Regional Pilot Program for Wastewater Treatment Plants in the Metropolitan Washington Region

to

Meet Chesapeake Bay Restoration Goals.

As Project Manager, assisted in development of an

innovative agreement between local governments to maximize aggregate nitrogen reductions from

wastewater treatment plants in a facilitated environment without unnecessary regulatory burdens (1995-

1996).

Member

,

Potomac River Basin National

Water Quality

Assessment Team

.

Represented local

government members in the Washington metropolitan region on the USGS river basin team. Provided

presentations and analysis of water quality conditions within the region, assisted in the design of a basin-

wide monitoring network, and evaluation of the sources and impacts of nutrients, pesticides, and metals

throughout the basin for surface water and groundwater (1990-1992).

Chain Bridge Automated Storm flow Monitor

.

Project Manager providing oversight of automated

storm flow monitoring of the Potomac River, calculation of daily loads, and trend analyses (1987-1997).

Kingman

Lake. Provided water quality modeling of Kingman Lake using WASPS to evaluate the water

quality impacts of constructed wetlands (1996).

Evaluation of Potential Impacts of Nitrogen Removal on Eutrophication in the Potomac Estuary.

As Project Manager and Engineer, provided consultant oversight, prepared estuarine loads and

environmental conditions, performed water quality model simulations, and committee presentations.

Evaluated the development of a hybrid empirical and deterministic model to evaluate the potential risk of

nuisance bluegreen algal blooms in the Potomac Estuary (1991-1992).

Evaluation of Sediment Oxygen Demand and Nutrient Flux in the Tidal Anacostia River

.

Project

Manager and Engineer overseeing field and laboratory experiments to determine the magnitude of

sediment oxygen demand (SOD) and nutrient fluxes, development of an SOD and nutrient flux model

LimnoTech

Revised

7125108

Adrienne D. Nemura

Page 7

---

which is linked to a coupled hydrodynamic and water quality model, and application of the model to

determine sediment response to CSO abatement (1991-1992).

Development and Calibration of a Two-Functional

Algal

Group Model of the Potomac Estuary.

Project Manager and contributor to expansion of the Potomac Eutrophication Model to include

phosphorus sorption modeling and effect of wind speed on net Microcystis growth rate. Compiled,

organized, and summarized water quality data and model inputs. Reviewed development of model and

tested sensitivity of model to key parameters. Evaluated alternative treatment scenarios, forecasted water

quality effects, and presented results to wastewater agencies, regulatory agencies, and elected officials

(1989-1992).

NPDES and Special Studies

Review of Permit Limits for Unified Government of Kansas

City and Wyandotte County, KS.

Project manager for applying CORMIX and calculating appropriate seasonal ammonia discharge limits,

and providing comments on proposed permit conditions associated with WET testing, CSO LTCP

development, and nitrogen removal studies. (Feb. to Nov. 2006, <5%).

Development

of Water Quality

Based Effluent Limits for the Chicago O'Hare International

Airport

.

Project manager for the development of a monitoring and modeling program to establish

NPDES limits for O'Hare's discharge basins to a creek and the Des Plaines River. (May to Jun. 2004,

1

%)

Development of a Dissolved Oxygen Model for the Lower Black River from

Elyria,

Ohio

, to Lake

Erie. Project manager responsible for the design of a modeling and monitoring program for the Black

River to develop an understanding of the causes of low dissolved oxygen. Coordinated development of a

monitoring program between Ohio EPA, LTI, USGS, two laboratories, and four clients. Prepared

database of existing data, reviewed earlier studies, and co-authored the Phase 1 report, which addressed

existing data, development and application of a screening level model, and the recommended monitoring

program. Directed the implementation of the coordinated monitoring program, and provided QA/QC of

the data, and senior oversight of the Phase 2 Data Report. For Phase 3, providing senior oversight in the

development of a linked UNET/WASP model of the Black River, and refinement of a

hydrodynamic/water quality model of the navigation channel. Under Phase 4, directed the evaluation of

controls and assimilative capacity of the navigation channel, which showed that increases in WWTP loads

would not adversely affect the dissolved oxygen problem. (Oct. 2000 to Feb. 2004, 10%)

Blue Plains Regional Wastewater Treatment Plant

NPDES

Permit Support.

Project Manager

providing specialized technical and legal support in the District of Columbia's negotiations with the US

EPA Region 3 over permit conditions. Major issues included nitrogen removal, mercury, and combined

sewer overflow requirements. Designed sampling program for before and after testing of receiving water

response to a pilot (half plant) test of nitrogen removal (1995-1997).

Metropolitan Washington Regional Monitoring Program

. Program administrator overseeing

coordination of Federal, state and local monitoring of the Potomac and Anacostia Rivers in the

Washington metropolitan region (1986-1997).

Administrative and Technical Support to the Blue Plains Regional Committee (District of

Columbia

;

Fairfax County, Virginia; and Montgomery and Prince George's Counties

,

Maryland).

Project manager overseeing staff administrative, technical, and secretarial support to the Blue Plains

Regional and Technical Committees which coordinated technical and policy issues for a 370 mgd

regional wastewater plant and a regional composting facility. Provided support to the Blue Plains Chief

Administrative Officers. Blue Plains IMA of 1985 and renegotiation of a MOU on biosolids management

(1995-1997).

LimnoTech

Revised 7125108

Adrienne D. Nemura

Page 8

---

Development of an Environmental Geographic Information System for the District of Columbia

Environmental Regulatory Administration

.

Co-Project Manager conducting a user requirements

analysis, including the design and implementation of a customized GIS.

Blue Plains Flow Forecast Model

.

Provided project management of the development of a GIS-based

sewershed model to generate flow forecasts for a 370 mgd regional wastewater treatment plant in

Washington, D.C. Provided training of local government staff in operation of the model.

GIS Assistance

to MWCOG

in the Development of Model Inputs for, and Mapping of the Potomac

Interceptor to the Blue Plains Wastewater Treatment Plant

. Project Engineer overseeing consultant

development of an engineering study of the monitoring and capacity of a regional wastewater interceptor

in Washington, D, C. (1992-1994).

Water Quality

Analysis and Modeling in Support

of NPDES

Requirements for the Expansion of the

Lower

Potomac Pollution Control Plant

,

Fairfax Co

.,

Virginia

. Project Manager and Engineer

providing assistance on defining and modeling steady-state summer boundary conditions in the Potomac

Estuary with various assumed levels of nitrogen control for the Washington region's municipal

wastewater treatment plants (1992-1993).

Selected Trace-Element and Organic Contaminants in Streambed Sediments of the Potomac River

Basin

.

As part of the report team for this task of the Potomac National Water Quality Assessment being

conducted by the USGS, provided senior level review and input into the assessment of sediment

contamination in the Potomac River (1991-1992).

Fall-Line Toxics Monitoring

.

Provided oversight of monitoring of the Potomac River fall line for storm

and baseflow monitoring of pesticides, herbicides, and toxic contaminants. Key member of project team

in analysis of the water quality data, generation of annual pollutant load estimates, and comparison with

other tributaries (1991-1992).

TMDL and

Watershed Experience

Critique of a Draft Nutrient

TMDL. Expert review of a draft phosphorus TMDL for an industrial

discharger to an oxbow lake of the Mississippi River (Apr. 2008 - Present, <5%).

Support for a Category 4b Demonstration for the Shawsheen River Headwaters

.

Senior advisor for

evaluating biological impairments to the Shawsheen River for the Massachusetts Port Authority. The

purpose of the evaluation is to support a category 4b demonstration to replace a high-flow TMDL so that

the authority can address biological impairments in an adaptive manner as part of the Stormwater

Pollution Prevention Plan (SWPP). (Dec. 2007 - Present, <5%).

Support to the Yadkin Pee Dee River Basin Association

for Active

Review of the High Rock Lake

TMDL. Project Manager for expert review of NCDEP's plans to develop a water quality model of High

Rock Lake to address turbidity, dissolved oxygen, and eutrophication problems. Assisted the Basin

Association in identifying data collection, watershed, and water quality model needs and secure a grant

for conducting the monitoring to support model development. (Jul. 2005 to Dec. 2006, <5%).

Expert Review of Dissolved Oxygen TMDLs along the East Coast of the United States. Senior

manager providing expert review of example TMDLs dealing with standards revisions for dissolved

oxygen for an attorney (Jan. 2006, <

5%).Environmental and Regulatory Review of Wastewater

Facility

Plan for New

Castle County,

Delaware

.

Project manager and senior engineer evaluating

various disposal and recharge options for treated wastewater in southern New Castle County, DE. (Dec.

2004 to Sep. 2005, 2%).

Expert Review of the Cooper River Water

Quality

Model in South Carolina.

Project Manager for

expert review of development of a water quality model for the Charleston Harbor and advice to the North

LimnoTech

Revised

7125108

Adrienne D. Nemura

Page 9

---

Charleston Sewer District on application of model to assess compliance with dissolved oxygen standards.

(May 2005 - Present, 5%).

Expert Review

of TMDL

Development for the Reedy River in South Carolina

. Project Manager for

expert review of development of a water quality model of the Reedy River and the Reedy River arm of

Lake Greenville and development of TMDLs for Greenville County, South Carolina (Apr. 2005 -

Present, 5%).

Analysis

,

Identification

,

and Strategies for Urban Wildlife Contamination to Support TMDL

Implementation in Washtenaw County, Michigan

.

Project Manager for a sampling program to

investigate the sources of fecal contamination in storm sewers draining to the Huron River. Development

of a quality assurance project plan, monitoring plan including storm sewer and scat sampling for E.

coli

and bacteria source tracking. (Oct. 2004 - Dec. 2006, 5%)

Development of a Watershed Monitoring Plan for Clean Water Services in Oregon

. Senior staff

developing a monitoring plan to provide a comprehensive characterization of environmental conditions,

and the impacts of a wide range of environmental programs and projects in the Tualatin River watershed.

(Aug. 2004 - Jun. 2006, <5%)

Creating Successful Total Maximum Daily Loads

: An AMSA

Handbook

.

Working group member for

review of the handbook and contributor to the modeling section. (Dec. 2003 - Apr. 2004, <I%).

Review of Nearshore Lake Michigan

E.

coli

TMDL for the Gary

Sanitary District

,

Indiana

. Project

Manager and senior staff reviewing the TMDL which includes water quality model development and

application of an EFDC model of nearshore Lake Michigan for northern Indiana. (Nov. 2003 - Sep. 2004,

5%)

Navigating the TMDL Process: Evaluation and Design

.

Co-author of a section on adaptive watershed

management of a Water Environment Research Federation investigation on a comprehensive study of the

Total Maximum Daily Load (TMDL) program. Researched where adaptive management is currently

being used in developing TMDLs and watershed

plans.

Identified the necessary components of adaptive

management. (Apr. 2002 -Oct. 20025 1 %)

TMDL

Support Activities for Metals and Organics in the Anacostia River, District of Columbia.

Project manager providing peer review and expert

assistance

in hydrodynamic and water/sediment quality

modeling for development of TMDLs for metals and organics in the Anacostia River as part of an EPA

support contract. This project is on a tight timeframe caused by a court-ordered deadline, and requires

that LTI assist the District of Columbia in producing an approvable TMDL. Facilitated discussions

between the District of Columbia and EPA, reviewed model results and 303(d) listing justification, and

directed technical investigations and peer review of product. (Jul. 2002 - Mar. 2003, 5%)

Review of Maryland

'

s

Decision Criteria and Draft 303(d

)

List for the Washington Suburban

Sanitary Commission

.

Senior engineer

assisting

in reviewing Maryland's draft 2001 303(d) list for the

Washington Suburban Sanitary Commission. This includes review of the listing methodology and water

quality analysis for dissolved oxygen, pathogens, nutrients, and sedimentation. (May 2002 - Jul. 2002,

2%)

Action Plan for the Columbia Slough Watershed

,

Oregon

.

Project manager and senior reviewer of a

project to assist the Columbia Slough Watershed Council in developing a 5-year watershed action plan for

the 40,000-acre watershed. The plan recommends projects to improve the health of the watershed and

educational programs to increase awareness of watershed pollution. (May 2002 - Apr. 2003, 3%)

Development and Implementation of a Watershed Protocol for Northern Kentucky

.

Reviewed

applicable state and federal CSO requirements and integrated these requirements for watershed planning

into the draft protocol (Apr. 2002, 1%).

LimnoTech

Revised

7125108

Adrienne D

.

Nemura

Page 10

---

Review of

draft TMDLs

for the Mountain Run Watershed in Culpepper County, Virginia and the

Manokin River

,

Somerset

County,

Maryland

.

Project manager and senior engineer responsible for

providing comments to municipalities on two draft Total Maximum Daily Loads, one in Virginia for

bacteria based on an HSPF model, and one in Maryland for dissolved oxygen and nutrients based on a

WASP5 model. Identified problems in scarcity of data, inappropriate or incomplete calibration of model,

and implementation

issues

(Jun.-Jul. 2000, <5%).

Anacostia Restoration

Plan. Provided technical review and direction for evaluation of baseline water

quality, identification of pollutant loads on a subwatershed basis, tracking restoration project development

and costs, and determination of environmental indicators to be used in evaluating water quality benefits

(1996-1997).

Richmond

-

Crater Interim

Water Quality

Management Plan: Technical Support Information. As

Project Engineer provided tidally averaged water quality modeling of the James and Appomattox Rivers

near Richmond, Virginia, to develop a two-tiered wasteload allocation under steady-state, low flow

conditions. Results were used to set permit limits for major municipal and industrial wastewater

dischargers. Developed water quality and point source database for the Piedmont Regional Office of the

State

Water Control Board (1986-1988).

Metropolitan Washington Regional Drinking

Water

Summit

.

Provided staff support to over 100

drinking water professionals to examine the monitoring needs and watershed protection and public health

strategies needed to address drinking water contamination by cryptosporidium and other

bacteria/protozoa/viruses (Jan. 1994)

Metropolitan Washington

Water

Supply Emergency

Plan.-Provided staff support on development of a

Federal/state/local government coordination plan for water supply emergencies in the Washington

metropolitan region (1994).

Database and Model Development Support

Development

of TMDLs

for Nine Watersheds in Illinois

.

Senior staff member in the development of a

database of water quality data for use in evaluating listing decisions and development of TMDLs for

Illinois EPA for nine watersheds in southern Illinois (Jun. - Jul. 2004).

Ottawa River

Hot Spot Delineation

&

Risk Assessment

. Senior engineer providing a database design

for a human health and ecological risk assessment for the Ottawa River in Toledo, Ohio (Feb. 2000-Mar,

2000, <5%).

Data Management

for the Fox River PCB

Investigation

.

Senior oversight of the extraction of PCB

congener data for water, sediments, and fish for use in calibration of a fate and transport model of the Fox

River (1999).

Development of a Database to Manage Sewer Information

for the City of Toledo, Ohio. Expert

advisor on water quality and CSO compliance issues. Technical Manager developing a menu-driven data

entry tool for combined sewered areas in Toledo. The tool will be used by the city for future data

management and linked with a hydraulic model of the system (Apr. 1999 - Apr. 2005, <5%).

Linked Database and Visualization

Tool for Lower Fox River

and Green

Bay. Technical Manager

overseeing the development of a large (1.8 million results) ACCESS database of water quality, sediment,

and biota data for the Green Bay watershed in Michigan and Wisconsin. Refined database design,

developed data dictionaries, oversaw processing of data for entry, conducted quality assurance/quality

control checks, and investigated discrepancies and missing information. Provided senior oversight of the

development of a menu system for processing data. Developed the documentation of the database and

record of updates. (Apr. 1998- Apr. 2006, <15%)

LimnoTech

Revised

7125108

Adrienne D. Nemura

Page 11

---

Technical

Advisor to

the Milwaukee Metropolitan Sewer District

(MMSD)

on a Comprehensive

Modeling Strategy

.

Senior technical advisor as part of an MMSD team. Participated in a strategy

workshop and review of a modeling strategy document. (May to Oct. 2002, 1 %)

Selected Publications

Publications

The Role of Receiving Water Models in CSO Long-Term Control Plan Decision-Making and Water

Quality Standard Revisions. WEFTEC 2008 with C.L. Turner. Chicago, IL. Scheduled for Oct. 18-22,

2008.

Implementing a Sewer Overflow Consent Decree through Watershed Management. WEFTEC 2008 with

C.L. Turner, J.P. Gibson, Jr., J. Turner, B. Vatter, D. Zettler, G.M. Grant, S. Fitzgerald, J. Lyons.

Chicago, IL. Scheduled for Oct. 18-22, 2008.

The Role of Adaptive Watershed Management Concepts in Wet Weather Consent Decrees. WEFTEC

2007 with P.L. Freedman, J.A. Eger, J.P. Gibson Jr., and N. Clements. San Diego, CA. Oct. 13-17, 2007.

A Spatial Tool for Watershed Characterization and Assessment in Northern Kentucky. WEFTEC 2007

with J.P. Gibson, Jr., T.A.D. Slawecki, and D.K. Rucinski. San Diego, CA. Scheduled for Oct. 13-17,

2007.

Maximum Extent Practicable Meets TMDL for Municipal Stormwater Permits: Which Will Prevail?

StormCon 2006 with E. Powers. Denver, CO. Jul. 24-27, 2006.

Making a Case for Site-Specific, Performance-

Based

Water Quality Standards for Pathogens. 2005

TMDL Conference with H.P. Holmberg. WEF Specialty Conference, Philadelphia, PA, Jun. 26-29, 2005.

Emerging Wet Weather Issues for Municipal Permits with J.S. Moore. Collection Systems 2004:

Innovative Approaches to Collection Systems Management. WEF 2004 Specialty Conference

Series,

Milwaukee, WI, Aug. 8-11, 2004.

Tools for the St. Joseph River, Indiana Watershed Initiative for a Safer Environment (WISE) with C.L.

Turner, M.A. Salee, and A.K. Umble. Watershed 2004. WEF 2004 Specialty Conference

Series,

Dearborn, MI, Jul. 11-14, 2004.

Approaching TMDLs Using Aristotle as a Teacher: An Adaptive Watershed Management Approach with

P.L. Freedman and D.W. Dilks. National TMDL Science and Policy 2002 Specialty Conference; Phoenix,

AZ, Nov. 13-16, 2002.

Evolving Wet Weather and Water Quality Standards Issues for CSO Communities with J. J. Slack,

WEFTEC 2000: The 73rd Annual Conference & Exposition on Water Quality and Wastewater Treatment,

WEF, Anaheim, CA, Oct. 14-18, 2000.

The Chesapeake Bay Program: Meeting an "Unfunded Non-mandate" with S.A. Freudberg and K.W.

Berger,

WEFTEC 1995: The 680' Annual Program for Technical Professional Development, WEF, Miami

Beach, FL, Oct. 21-25, 1995.

An Alternative to the NPDES "Command and Control" Approach to Achieve Nitrogen Reductions at

Wastewater Plants with T.T. Spano and S.A. Freudberg, Management of Environmental Problems for

Elected and Public Officials, WEF Specialty Conference

Series,

Richmond, VA, Nov 13-16, 1994.

Presentations and Symposiums

DejA vu: New Recreational Use Criteria. Panel Presentation with M. Tate and M. Pla. NACWA Summer

Conference. Anchorage, AK. Jul. 15-18, 2008.

LimnoTech

Revised

7125108

Adrienne D. Nemura

Page 12

---

How to Address Daily Load

Issues

in TMDLs with F.P. Andes and L.H. Weintraub. Barnes & Thornburg

Clean Water Workshop. Chicago, IL. Sep. 26-28, 2007.

Use Attainability Analysis (UAA) as a Tool to Meet Clean Water Act Requirements. Panel on UAAs with

F.P. Andes, J.Perras, and J. Rexhausen. Indiana Water Environment Association Government Affairs

Committee CSO Workshop. Indianapolis, IN. Aug. 15, 2007.

The Link between Appropriate Water Quality Standards and Reasonable Total Maximum Daily Loads.

Indiana Water Environment Association. Indianapolis, IN. Nov. 13-15, 2006.

Spatial Data Analysis for Developing Lake Nutrient Standards for the State of Indiana. 26"h International

Symposium, North American Lake Management Association (NALMS) with Carol Newhouse, Indiana

Department of Environmental Management. Indianapolis, IN. Nov. 8-10, 2006.

Challenges

Associated

with Watershed Management for Bacteria

.

NOAA Great

Lakes Environmental

Research

Laboratory

Seminar

, Ann Arbor,

MI. Mar.

17, 2006.

Challenges Associated with Developing Nutrient and Sediment TMDLs for Impoundments in the

Southeastern United States. NALMS: 15"h Annual Southeastern Lake and Watershed Management

Conference with J.V. DePinto and V.J. Bierman. Columbus, GA. Mar. 8-11, 2006.

The Not So Ready for Prime Time Players Visit Indiana

Is the Price Right for Clean Water? Indiana

WEA 2005 Conference with J. Rexhausen and R. Hamilton., Indianapolis, IN. Nov. 14-16, 2005

Application of Modeling Tools for the St. Joseph River to Evaluate Bacteria Source Impacts on Water

Quality. Indiana WEA 2005 Conference with C.L. Turner and M. Salee., Indianapolis, IN. Nov. 14-16,

2005

Sustainable or In-Saneable

? The Wheel of Water Fortune

Debunking the Myths Associated with

Sustainable

Water

Resources

. Skit at the AMSA 2005 Winter Conference, San Antonio, TX. Feb. 2-4,

2005.

Making a Case for Site-Specific, Performance-Based Water Quality Standards for Pathogens. 2005

TMDL Conference with H.P. Holmberg. Indiana WEA 68"h Anniversary Conference, Indianapolis, IN,

Nov. 15-17, 2004.

Tackling the Challenge of Funding Wastewater and Water Supply Infrastructure in the 215` Century. 2004

Annual Conference of the Michigan Water Environment Federation and American Water Works

Association. Grand Rapids, MI. Aug. 11, 2004.

Water Quality Standards and the Use Impasse. Skit at the AMSA 2004 Summer Conference, Denver, CO.

Jul. 21, 2004.

Using Modeling Tools to Present Data to Gain EPA and IDEM Acceptance of Combined Sewer Overflow

Long-Term Control Plans. Indiana Water Environment Association, 67`h Annual Conference.

Indianapolis, IN. Nov. 19, 2003.

Emerging Wet Weather Issues for Municipal Permits with J.S. Moore. Three Rivers Wet Weather

Demonstration Project. Fifth Anniversary Sewer Conference. Four Points Sheraton North. Mars, PA. Sep.

11, 2003.

LimnoTech

Revised

7125108

Adrienne D. Nemura

Page 13

---

Case Studies in the Use of Adaptive Watershed Management for Total Maximum Daily Loads with P.L.

Freedman and D.W. Dilks. TMDL 2003 Specialty Conference. Water Environment Federation. The

Westin Michigan Avenue. Chicago, IL. Nov. 16-19, 2003.

Emerging Wet Weather Issues for Municipal Permits with J.S. Moore. Louisiana Water Environment

Association's Spring Technical Conference & Crawfish Boil. Gonzales, LA. Apr. 24, 2003

Review Criteria for Combined Sewer Overflow Long-Term Control Plans with J.S. Moore. 66th Annual

IWPCA Conference, Indianapolis, IN. Nov. 18-20, 2002

Evolution of Wet Weather Water Quality Standards for Urban Communities. Presentation to the 3 Rivers

Wet Weather Fourth Annual Sewer Conference, Pittsburgh, PA. Sep. 16-17, 2002.

Presentation to the Virginia Association of Metropolitan Wastewater Agencies on Chesapeake Bay Water

Quality and Watershed Modeling. 1996. Richmond, VA.

Fall-Line Toxics Monitoring to the Potomac National Water Quality Assessment Committee. 1993.

Harrisburg, VA.

Workshops

/

Short Courses

Getting Prepared for "New" Pathogen Standards. Workshop Chair and Presenter on Recreational Use

Attainability Analyses: Need For UAAs and Factors for Success. WEFTEC 2008. Chicago, IL. Scheduled

for Oct 19, 2008.

"Doing Successful Use Attainability Analyses (UAAs)". Panel Symposium with F. Andes, D.Pfeifer, J.

Perras, and J. Rexhausen. Keeping Your Head Above Water in the Regulatory World. Indiana Water

Environment Association. Marriott Indianapolis East. Aug. 15, 2007.

"Long Term Control Plan Issues". Panel Symposium with F. Andes, L. Benfield, and D. Markowitz at the

CSO Control Strategies and Key Developments Among Leading CSO Communities. The Drake Hotel,

Chicago, IL. Apr. 26-27, 2007.

How to be "Passionate about Pathogens" with Water Quality Modeling. 2006 Developments in Clean

Water Law: A Seminar for Public Agency Attorneys & Managers. Boston, MA. Nov. 15-17, 2006

"Getting Nutrient Limits Right." Presentation at the 2004 Barnes & Thornburg Clean Water Workshop,

The Standard Club, Chicago, IL. Jun. 9-11, 2004.

"It's Time to Start Talking TMDLs" with D.W. Dilks. TMDL Informational Seminar. Greenville Soil and

Water Conservation District, et. al. Greenville, SC. May 25, 2004.

EPA CSO / SSO Inspector Training with M.P. Sullivan and B.K. Hazelwood. EPA Region 5. Chicago,

IL. Nov. 12-14, 2003.

Presented at the training workshop for US EPA for the CSO LTCP Review Training for Permit Writers

and EPA Regional Staff. Indianapolis, IN. Feb. 6-7, 2002 and Harrisburg, PA. Mar. 2002.

Presented the receiving water monitoring and modeling chapters of the EPA Guidance Manual on CSO

Modeling and Modeling.

Washington, PA. Sep. 9-10, 1999.

Facilitation of a workshop to define water quality management objectives and evaluate/screen CSO

control technologies for preliminary facilities planning.

Series of workshops on Development of the Chesapeake Bay Water Quality and Watershed Models for

Washington metropolitan region's wastewater treatment plants.

Coordinated workshop on ultra-clean sampling techniques for metals and pesticides.

LimnoTech

Revised

7125108

Adrienne D. Nemura

Page 14

---

Client Reports and Unpublished Papers

Spatial Data Analysis for Developing Nutrient Standards for Indiana Lakes. Prepared for the Indiana

Department of Environmental Management. Jan. 29, 2007.

Effects of Disinfection at the North Side, Stickney, and Calumet Water Reclamation Plants on Bacteria

Levels in the Chicago Area Waterways. Prepared for the Metropolitan Water Reclamation District of

Greater Chicago under subcontract to Consoer Townsend Envirodyne Engineers, Inc. Dec. 7, 2005.

Nationwide Review of Wet Weather Water Quality Standards. Prepared for the Sanitation District No. 1

of Northern Kentucky. Sep. 2005.

Technical Review of the Katonak-Rose Report on Public Health Risks Associated with Wastewater

Blending (Nov. 17, 2003). Prepared for the National Association of Wastewater Agencies. Mar. 7, 2005.

Interim Water Quality Study Report: CSO Long-Term Control Plan Update. Prepared for Metropolitan St.

Louis Sewer District. Sep. 28, 2005.

Management Applications of the Lower Black River Water Quality Model, Phase 4 Report. Prepared for

the Black River Cooperative Parties under contract to the City of Elyria, Ohio. Feb. 27, 2004.

Draft Lower Black River Water Quality Model, Phase 3 Report. Prepared for the Black River Cooperative

Parties under contract to the City of Elyria, Ohio. Sep. 29, 2003.

Summary of Background Information for the Washington Aqueduct BPJ. Dec. 16, 2002.

2001 Monitoring Data for the Lower Black River Water Quality Model, Phase 2 Report. Prepared for the

Black River Cooperative Parties under contract to the City of Elyria, Ohio. Apr. 2002.

Southerly District Combined Sewer Overflow Phase II Facilities Plan. Submitted by Metcalf & Eddy in

association with CH2MHill. Prepared for the Northeast Ohio Regional Sewer District. Mar. 2002.

Easterly District Combined Sewer Overflow Phase II Facilities Plan. Submitted by Metcalf & Eddy in

association with CH2MHill. Prepared for the Northeast Ohio Regional Sewer District. Mar. 2002.

Design of the Modeling and Monitoring Programs for the Lower Black River Water Quality Model

(LBRWQM) Project. Prepared for the Black River Cooperative Parties under contract to the City of

Elyria, Ohio. Feb. 2001.

Study Memorandum LTCP-6-3: Receiving Water Model Selection. Prepared for District of Columbia

Water and Sewer Authority EPMC III - Sewer Systems. Draft. Dec. 1999.

Study Memorandum LTCP-6-1: Receiving Water - Existing Information. Prepared for District of

Columbia Water and Sewer Authority EPMC 1I1- Sewer Systems. Draft. Dec. 1999.

Northeast Ohio Regional Sewer District Westerly CSO Phase 11 Facilities Plan: Chapters 4 and 7. Water

Quality Analysis. Final Report, Dec. 1999.

Database for Lower Fox River and Green Bay: Database Report, Versions 1.0 to 3.0, Apr. 30, 1999.

Preliminary Control Alternatives Workshop, May 20, 1998.

Water Quality Assessment of Banklick Creek and the Lower Licking River, Mar. 1998.

Northeast Ohio Regional Sewer District Westerly CSO Phase II Facilities Plan: Water Quality Analysis

Interim Draft Report, Oct. 1997.

Wastewater Treatment Plants in the Washington Metropolitan Region, 1993-1994.

Potomac and Anacostia Rivers Water Quality Data Report 1990, Dec. 1992.

Modeling Sediment Oxygen Demand and Nutrient Fluxes in the Tidal Anacostia River, Dec. 1992.

LimnoTech

Revised 7125108

Adrienne D. Nemura

Page 15

---

Water Quality Benefits of Combined Sewer Overflow Abatement in the Tidal Anacostia River, Nov. 1

1991.

Richmond-Crater Interim Water Quality Management Plan Technical Support Information. Mar. 1988.

Specialized Training and Coursework

Institute on Mathematical Modeling of Water Quality, Manhattan College, New York, 1989.

Workshop on Group Facilitation Training for the "Partnership for Regional Excellence" by Whorton and

Youngquist, Inc. Atlanta, GA. Nov. 1992.

LimnoTech

Revised

7125108

Adrienne D. Nemura

Page 16

---

Attac

hm

ent 2

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

WATER QUALITY STANDARDS AND

EFFLUENT LIMITATIONS FOR THE

CHICAGO AREA WATERWAY SYSTEM

AND THE LOWER DES PLAINES RIVER:

PROPOSED AMENDMENTS TO 35 Ill.

Adm. Code Parts 301, 302, 303 and 304

R08-9

(Rulemaking

-

Water)

ATTACHMENT 2 TO

PRE-FILED TESTIMONY OF ADRIENNE D. NEM URA

This attachment provides a description of the impact of combined sewer overflows

(CSOs), pump station bypasses, and tributary runoff on bacteria levels in the Chicago Area

Waterway System (CAWS). The information presents fecal coliform results of the District's

water quality model for a simulation from July 12, 2001 to November 10, 2001 for the following

scenarios: (1) Existing Conditions with assumed CSO and pump station bypass concentrations of

1,100,000 colony forming units per 100 milliliters (cfu/100ml); (2) Existing Conditions with

assumed CSO and pump station bypass concentrations of 170,000 cfu/100ml; (3) Elimination of

bacteria in the CSO and pump station bypass discharges (concentration set at 0 cfu/I00ml); and

(4) Disinfection of the Water Reclamation Plants (WRPs). For the WRP disinfection scenario,

the following concentrations were assumed: 1,030 cfu/100m1 at the North Side and Calumet

WRPs and 2,740 cfu/100m1 at the Stickney WRP. These scenarios were conducted in the

summer of 2005 for the North Side WRP Facility Planning effort.

In summary, the results presented in this attachment (based on two representative storms)

show that:

1

---

Adrienne D. Nemura, Attachment 2

•

The effect of CSO and pump station discharges can increase in-stream fecal

coliform concentrations by 15,000 to 230,000 cfu/100m1 depending on the

discharge concentration and location;

•

The effect of these discharges can persist for at least three to five days depending

on location; and

•

These effects will remain even if disinfection is provided at the WRPs.

Model results for these scenarios are provided for eight representative locations shown in

Figure 1. These locations include three locations (Addison Street, Fullerton Avenue, and Kinzie

Street) on the North Branch Chicago River (NBCR); Halsted Street on the South Branch Chicago

River (SBCR); the B&O Railroad Bridge on the Chicago Sanitary Ship Canal (CSSC); Halsted

Street on the Little Calumet River (LCR); and two locations (Cicero Avenue, and 104th Avenue)

on the Calumet-Sag Channel (CSC). Results are presented for two CSO events shown in Table 1:

July 25, 2001 and August 2-3, 2001. These results are representative of the range of the 15 CSO

events for the portions of 2001 and 2002 that were modeled.

Table 1. Representative

CSO Events

for Model Simulation Periods in 2001 and 2002

Total Gravity

Total Pump

Date

(s) of CSO

CSO

Station

Bypass

Total Discharge

Event

million g

allons

)

(

million

g

allons

)

million

g

allons)

July 25, 2001

585

963

1,548

August 2-3, 2001

3,136

1,118

4,254

Range for

Portions of 2001

and 2002 that

0 to 11,417

0 to 2,347

409 to 12,982

were

Modeled

2

---

Adricime D. Nemurrr, Attrrchm.eiat

3

Figure 1.

Locations of Selected

Modeled In-Stream

Fecal Coliform

Concentrations

f.

C ad:nr

rorJa^

-

sbu^[ p.^n1

c + r....

---

Adrienne D. Nemura, Attachment 2

Figures 2 through 9 provide plots of the fecal coliform levels the eight locations for July

24 to August 10, 2001 which includes the two CSO events in Table 1. Results are presented for

existing conditions with the CSO and pump station discharge concentrations set at 1,100,000

cfu/100m1(green line) and 170,000 cfu/100 ml (blue line). This represents the hypothetical range

of CSO impacts as documented by Marquette University (Manache and Melching, 2005).

Bacteria concentrations in these discharges are likely to vary from event to event. The dashed

brown line shows the effect of zeroing out the CSO and pump station discharge concentrations.

This line represents lower concentrations than would be calculated with a scenario of actual

treatment or elimination of CSO because the associated "clean" flow from the CSO discharges is

still entering the CAWS in the simulation and diluting the calculated in-stream concentrations.

The effects of the bacteria loads from the North Side WRP, North Branch Pumping

Station, and the NBCR tributary (which includes storm water runoff and CSOs) can be seen at

Addison Road. If the assumed concentrations for the CSOs and pump station discharges are

1,100,000 cfu/100ml, the maximum difference in in-stream concentration with the scenario

where the fecal coliform is zero is approximately 100,000 cfu/100ml for the first event and

230,000 cfu/100m1 for the second event. If the assumed concentrations for the CSOs and pump

station discharges are 170,000 cfu/100m1, then the maximum in-stream difference is reduced to

16,000 cfu/100m1 and 35,000 cfu/100ml respectively. The effect of the wet weather discharges

lasts approximately three days for the first event and four days for the second event.

The effect of wet weather discharges is similar, and more pronounced, at Fullerton

Avenue and Kinzie Street on the NBCR (Figures 3 and 4). The higher peak concentrations in

these figures show the effect of the additional bacteria load from the CSOs located upstream of

4

---

Adrienne D. Nemura, Attachment 2

these locations. The effect of the wet weather discharges lasts approximately three to five days at

these locations.

Figure 5 shows the effect of the CSO and pump station discharges at Halsted Street on

the SBCR. Again, the higher peak concentrations and longer duration of the wet weather impacts

resulting from additional CSO is shown. The second event in Figure 5 also shows the effect of

flow reversals caused by the Racine Avenue Pump Station discharge where in-stream bacteria

concentrations increase on August 7 and 8, 2001. A similar effect is seen at the B&O Railroad

Bridge on the CSSC, as shown in Figure 6.

Figure 7 shows the effect of the CSOs, Calumet WRP, 125th Street Pump Station, and

other wet weather discharges on in-stream concentrations at Halsted Street on the Little Calumet

River. For the first event, the difference between the existing situation (with an assumed

discharge concentration of 1,100,000 cfu/100m1 in the CSOs and pump stations) is 100,000

cfu/100ml and 150,000 cf i/100ml for the second event. If the assumed discharge concentration

is 170,000 cfu/100ml, the impact of the CSOs and pump station discharges on in-stream

concentrations is 15,000 cf i/100ml and 23,000 cfu/100ml respectively. The duration of the wet

weather impacts at this location is four to five days.

As shown in Figures 8 and 9, the wet weather effects become more pronounced in the

CSC both in terms of peak concentrations and duration of impact of the wet weather discharges.

This is because of increased wet weather loads along the CSC and longer travel times.

5

---

Adrienne D. Nemura, Attachment 2

Figure 2. Comparison of Fecal Coliform Levels at Addison Road

, NBCR

for Existing

Conditions and Elimination

of CSO

/Pump Station Bacteria Concentration (2001)

1,000,000

of 100,000

0

r-I

1,000

100

10

C50'5

a1 1.100,000

[fW 1001

1

11

7/24 7/26 7/28

7/30 8/1

8/3

8/5

8/7 8/9

Figure 3. Comparison of Fecal Coliform Levels at Fullerton Avenue

,

NBCR for Existing

Conditions and Elimination

of CSO/

Pump Station Bacteria Concentration (2001)

1,000,000

10 -

7/24 7/26

7/28

7/30 8/1 8/3 8/5

8/7 8/9

Figure 4. Comparison of Fecal Coliform Levels at Kinzie Street, NBCR for Existing

Conditions and Elimination of CSO

/

Pump Station Bacteria Concentration (2001)

1,000,000

100,000

10,000

1,000

100

10

7/24

7

/26

7/28

7

/

30 8/1

8

/

3 8b 8//

8/9

6

---

Adrienne D. Nemura, Attachment 2

Figure 5

.

Comparison of Fecal Coliform Levels at Halsted Street

,

SBCR for Existing

Conditions and Elimination of CSO

/

Pump Station Bacteria Concentration (2001)

1,000,000 1

,CSOsat 1

,

100,000 cfu/100m1

0 100,000

/ \CSOsat

170,000 cfu/100ml

10,000

1U

7/24 7/26 7/28 7/30

8/1 8/3 8/5 8/7 8/9

Figure 6. Comparison of Fecal Coliform Levels at B&O Railroad Bridge

, CSSC for

Existing Conditions and Elimination of CSO/Pump Station Bacteria Concentration (2001)

1,000,000

--,

vv ^Iw[

AwwlIII

CSO$ at 0 c UAOOm1 _

U

100

10

-

1 , 1

,^- ..1-,_11^-1-

7/24 7/26

7/28

7/30 8/1 8/3 8/5 8/1

8/9

Figure 7. Comparison of Fecal Coliform Levels at Halsted Street

, LCR for

Existing

Conditions and Elimination

of CSO/

Pump Station Bacteria Concentration (2001)

1,000.000

0 100,000

0

10,000

1,000

100

10

C50sat

1,100

,000 du/100m1

CSOs

at 0 cfu/100m1

7/24

7/

26 7/28

7

/

30 8/1

8/3

8/5

8/7

8/9

7

---

Adrienne D. Nemura, Attachment 2

Figure 8. Comparison of Fecal

Coliform Levels at Cicero Avenue, CSC for Existing

Conditions and Elimination

of CSO/

Pump Station Bacteria Concentration (2001)

1,000,000

0 100,000

0

1,000

100

10

CSOsat 1,

100,000 Cfu/100m1

7/24

7/26

7/28

7/30 8/1 8/3 8/5 8/7 8/9

Figure 9. Comparison of Fecal Coliform Levels at 104th Avenue

,

CSC for Existing

Conditions and Elimination

of CSO

/Pump Station Bacteria Concentration (2001)

1,000,000

100,000

10,000

1,000

100

10

7/24

7/26 7/28 7/30 8/1

8/3 8/5 8/7

8/9

S

---

Adrienne D. Nemura, Attachment 2

Figures 10 to 17 provide a comparison of the existing condition (with an assumed CSO

and pump station discharge concentration of 170,000 cfu/100ml) to a scenario where the WRP

effluents are disinfected. Along the NBCR (Addison Street, Fullerton Avenue, and Kinzie Street)

there is a slight reduction in peak concentrations during the wet weather events due to

disinfection at the North Side WRP. Concentrations, however

, are still in

excess of 10,000

cfu/100m1. At the other locations, WRP disinfection does not reduce the peak concentrations

during the wet weather events.

Figure 10. Wet Weather Impacts at Addison Road

,

NBCR (2001)

1,000,000

0 100,000

0

CSOs

at 170,000 cfu/100mi

Disinfection at the WRPs

100

10

7/24

7/26

7/28

7/30

8/1

8/3

8/5

8/7

8/9

Figure 11. Wet Weather Impacts at Fullerton Avenue, NBCR (2001)

1,000,000

0 100,000

0

10,000

E

Disinfection at the WRPs

CSOsat 170,000 cfu/100mi

7/24

7/

26

7/28

7/30 8/1

8/3

8/5 8/7 8/9

---

Adrienne D. Nemura, Attachment 2

Figure

12.

Wet Weather

Impacts at Kinzie

Street, NBCR (2001)

1,000,000

0 100,000

0

10,000

E

100 1

CSOsat 170,

000 cfu/100ml

Disinfection at the WRPs

1U

7/24

7/26

7/28

7/30

8/1

8/3

8/5

8/7

8/9

Figure 13

.

Wet Weather Impacts at Halsted Street, SBCR (2001)

1,000,000

E 100,000

0

z

10,000

E

1,000

100

10

f

7/24

7/26

7/28

7/30

8/1

8/3

8/5

8/7

8/9

Figure

14. Wet Weather

Impacts at B&O Railroad Bridge

, CSSC (2001)

1,000,000

E

1,000

100

I

Disinfection

at the WRPs

10

1^-r-,-i- i- i-,-i- - I

7/24 7/26

7/28

7/30 8/1 8/

3 8/5 8/7 8/9

N,

^J f

r

4

-a

•

l

•

/r-, Disinfection at the WRPs

10

---

Adrienne D. Nemura, Attachment 2

Figure 15

.

Wet Weather

Impacts at Halsted

Street, LCR (2001)

1,000,000

o

f 100,000

0

-i

10,000

F^

CSOs at 170,

000 cfu/100mi

1,000 >

O

u

m

at

100

LA_

10 i

r7 - + - - - /

Disinfection at the WRPs

1 - _ - - - - -

7/24

7/26

7/28

7/30

8/1

8/3

8/5

8/7

8/9

Figure 16. Wet Weather Impacts at Cicero Avenue

,

CSC (2001)

1,000,000

100,000

10,000

1,000

100

1U

r

IF,

-

Disinfection

at the WRPs

7/24

7/26

7/28

7/30

8/1

8/3

8/5

8/7

8/9

Figure 17. Wet Weather Impacts at 104th Avenue

,

CSC (2001)

1,000,000

0 100,000

0

^ 10,000

a^

^►

LL

10

`Disinfection

at the

VVRPS

7/24

7/26 7/28

7/30 8/1 8/3

8/5

8/7

8/9

CSOsat 170

,

000 cfu/100mt

CSOs at 170,000 cfu/100mi

11

---

Adrienne D. Nemura, Attachment 2

REFERENCES

Manache, G. and Melching, C.S. (2005) Simulation of fecal coliform concentrations in the

Chicago Waterway System under unsteady flow conditions, "Technical Report 16, Institute of

Urban Environmental Risk

Management

, Marquette

University, Milwaukee, WI, and

Metropolitan

Water Reclamation District of Greater Chicago, Department of Research and

Development Report No. 2005-9, Chicago, IL.

12

---

A

tt

ac

hm

e

nt

3

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

WATER QUALITY STANDARDS AND

EFFLUENT LIMITATIONS FOR THE

CHICAGO AREA WATERWAY SYSTEM

AND THE LOWER DES PLAINES RIVER:

PROPOSED AMENDMENTS TO 35 Ill.

Adm. Code Parts 301, 302, 303 and 304

R08-9

(Rulemaking - Water)

ATTACHMENT 3 TO

PRE-FILED TESTIMONY OF ADRIENNE D. NEMURA

This attachment provides examples of wet weather water quality standards for three

states, and an interstate commission that recognized the potential need for wet weather standards,

because of the impact of wet weather discharges, primarily combined sewer overflows (CSOs).

The states of Indiana, Massachusetts, and Maine and the Ohio River Valley Water Sanitation

Commission (ORSANCO) have adopted provisions within their water quality standards to reflect

the challenges associated with meeting water quality standards due to CSOs or stormwater

discharges. Information is also presented on relevant Use Attainability Analyses (UAAs) that

have been conducted with respect to wet weather discharges.

Indiana

The State of Indiana revised its water quality standards to include a CSO wet weather

limited use designation that allows for temporary suspension of the recreational use criteria for

up to four days following a CSO event. This revision also allows the state to incorporate long-

term compliance schedules into NPDES permits for CSO communities. US EPA approved these

revisions on June 9, 2008 (US EPA, 2008). To obtain the limited use designation, CSO

communities must have completed a US EPA- approved UAA and have implemented a long-

term control plan. The state incorporates the long-term control plan into the NPDES permit

l

---

Adrienne D. Nemura, Attachment 3

(before the long-term control plan is fully implemented) and specifies the water quality based

requirements that apply to the remaining CSO discharges during and immediately following the

CSO events. US EPA indicated that these requirements "should be based upon the engineering

and modeling analyses and assumptions that were used in developing the LTCP and UAA, and

could be expressed in a number of different ways" (US EPA, 2008, p. 2). This includes, but is

not limited to, number of overflows per typical-year, percent capture, or a design-storm event.

Massachusetts

The State of Massachusetts has provisions in its water quality standards to provide for

partial designated use of CSO- or stormwater-imp acted waters. Communities can also obtain a

variance, if needed. The partial use designation indicates that the "criteria may depart from the

criteria assigned to the Class only to the extent necessary to accommodate the technology based

treatment limitations of the CSO or stormwater discharges" (MassDEP, 2007).

Maine

The State of Maine has adopted a variance approach to address CSO conditions during

implementation of an approved long-term control plan (MDEP

,

2003

).

A temporary CSO

subcategory is established after the community submits a long-term control plan, implementation

schedule, and

a UAA. A Citizen

Board may then temporarily suspend or modify the water

quality standards associated with the use (including the extent and duration) for CSO events

beyond a rainfall-selected event size.

ORSANCO

ORSANCO

adopted provision in its water quality standards for the Ohio River allowing

for development and application of alternative criteria if CSO communities have submitted a

long-term CSO control plan and

a UAA (ORSANCO,

2006

).

Several CSO communities along

2

---

Adrienne D. Nemura, Attachment 3

the Ohio are in the process of developing or updating their long-term control plans, although

none

have submitted UAAs to date.

City

of Indianapolis UAA

The City of Indianapolis incorporated a UAA into its long-term CSO control plan in

accordance with the State's provision for a CSO wet weather limited use designation. On May 7,

2008, the State submitted a proposed rule for public hearing to designate the receiving waters

affected by the City's CSOs for the wet weather limited

use designation

(IDEM, 2008).

Massachusetts Water Resources Authority (Boston)

On March 16, 2006, agreement was reached between the US EPA, Massachusetts

Department of Environmental Protection (MassDEP), the Conservation Law Foundation of New

England, Inc., and the Massachusetts Water Resources Authority (MWRA) on long-term

(through the year 2020) variances for the Charles River, Alewife Brook and East Boston (US

EPA, 2006). This allows MWRA to implement

its long

-term control plan and conduct post-

construction monitoring in 2018 to 2021 to demonstrate that it has achieved compliance with its

long-term control plan.

Santa Ana River UAA, California

A Stormwater Quality Standards Task Force has been meeting monthly since May 2004

to establish appropriate

recreational

uses for the Santa Ana River. A work plan was established

in 2003 to review the beneficial use classifications

and assess

existing conditions (Phase 1);

review and update the water quality objectives (Phase II); and develop permit implementation

and monitoring strategies (Phase III). The workgroup has completed Phase I and is in the process

of completing Phase II. Under Phase 1, it was determined that a high flow suspension of

recreational uses was appropriate along with re-designation of certain

segments

to Limited Rec-1

3

---

Adrienne D. Nemura, Attachment 3

or a lack of Rec-1 uses, along with revision of the numeric criteria (Bounds, 2008). Phase II

includes completion of a UAA.

Engineered Flood Channels UAA in Ballona

Creek,

California

The Los Angeles Regional Water Quality Control Board in California adopted a high

flow suspension of recreational uses for Ballona Creek, which is a straightened, concrete-lined

channel designed to move floodwaters from urban areas to the ocean (SWRCB, 2003). This

suspension was based on information showing that it is not safe to be in the modified channels

for this waterbody and therefore bacteria criteria for protection of recreational uses do not need

to be met. The suspension applies under the rainfall conditions that trigger swift-water protocols

(i.e., rescue squads are on alert if someone should happen to enter the water).

REFERENCES

Bounds, D. "Science Surrounding Effluent Disinfection and Pathogens in the Environment."

Presentation to the IAWA Technical Committee. Starved Rock Lodge, Utica, IL. Jul. 11, 2008.

Indiana Department of Environmental Management (IDEM

) (

2008

).

TITLE 327 WATER

POLLUTION CONTROL BOARD

Proposed

Rule LSA

Document

#

08-324. May 7, 2008. (3

pp.)

Maine Department of Environmental Protection (MDEP). 2003. 38 MRSA Section 464.

November 10, 2003.

Massachusetts Department of Environmental Protection (MassDEP

) (2007). 314 CMR 4.00:

Massachusetts Surface

Water Quality

Standards.

Ohio River Valley Water Sanitation Commission (ORSANCO) (2006). Pollution Control

Standards for Discharges to the Ohio River: 2006 Revision.

State

Water Resources Control Board (SWRCB) (2003). Ballona Creek Recreational Use

Attainability Analysis. Amendment to Water Quality Control Plan: Los Angeles Region, Basin

Plan for the Coastal Watersheds of Los Angeles and Ventura Counties.

United States Environmental Protection Agency (US EPA) (2008). Letter from B. Mathur to B.

Pigott. June 9, 2008. (3 pp.)

4

---

Adrienne D. Nemura, Attachment 3

US EPA (2006). Memorandum of the United States of America in Support of Joint Motion to

Amend Schedule Six with Respect to the Charles River, Alewife Brook and East Boston, Civil

Actions No. 85-0489-RGS and No. 83-1614-RGS. March 15, 2006.

5

---

A

tt

ac

hm

e

nt 4

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

WATER QUALITY STANDARDS AND

EFFLUENT LIMITATIONS FOR THE

CHICAGO AREA WATERWAY SYSTEM

AND THE LOWER DES PLAINES RIVER:

PROPOSED AMENDMENTS TO 35 Ill.

Adm. Code Parts 301, 302, 303 and 304

R08-9

(Rulemaking - Water)

ATTACHMENT 4 TO

PRE-FILED

TESTIMONY

OF ADRIENNE

D. NEMURA

This attachment provides a description of the impact of gravity combined sewer

overflows (CSOs) and other wet weather discharges on dissolved oxygen (DO) levels in the

Chicago Area Waterway System (CAWS). The information presents selected results of the

District's water quality model for a simulation from July 12, 2001 to November 10, 2001 for the

following

scenarios

: (1) Existing Conditions and (2) Elimination of Gravity CSOs. The

simulations

show that:

•

CSOs have different impacts on in-stream dissolved oxygen depending on

location and the nature of the wet weather event;

•

CSO impacts range from minimal duration to an impact that "could last for

weeks" (Zhang et al, 2007);

•

The impacts can range from less than 1 milligram per liter (mg/1) to more than 3.5

mg/l deficit in in-stream dissolved oxygen concentrations;

•

Elimination of gravity CSOs may not, at varying times at different locations,

result in attainment of the proposed minimum dissolved oxygen criteria; and

•

"Even if all gravity CSOs were eliminated... [a] target DO value of 4 mg/l could

not be satisfied 100 percent of the time at some locations in the CAWS under the

1

---

Adrienne D. Nemura, Attachment 4

summer conditions of 2001 and 2002" (Zhang et al, 2007) because pump station

discharges, sediment resuspension, stormwater, and tributary runoff will remain

and impact dissolved oxygen.

Model results for these scenarios are provided for eight representative locations shown in

Figure 1. These locations include three locations (Addison Street, Fullerton Avenue, and Kinzie

Street) on the North Branch Chicago River (NBCR); Halsted Street on the South Branch Chicago

River (SBCR); the B&O Railroad Bridge on the Chicago Sanitary Ship Canal (CSSC); Halsted

Street on the Little Calumet River (LCR); and two locations (Cicero Avenue and Route 83) on

the Calumet-Sag Channel (CSC). Results are presented for two CSO events shown in Table 1:

July 25, 2001 and August 2-3, 2001. These results are representative of the range of the 15 CSO

events for the portions of 2001 and 2002 that were modeled.

Table 1. Representative

CSO Events

for Model Simulation Periods in 2001 and 2002

Total Gravity

Total Pump

Date

(s) of CSO

CSO

Station Bypass

Total

Discharge

Event

million g

allons

)

million

g

allons

)

million

g

allons

)

July 25, 2001

585

963

1,548

August 2-3, 2001

3,136

1,118

4,254

Range for

Portions of 2001

0 to 11 417

0 to 2

347

409 to 12 982

and 2002 that

,

,

,

were

Modeled

Figures 2 through 9 provide plots of the dissolved oxygen levels at the eight locations for

July 24 to August 10, 2001 which includes the two CSO events in Table 1. Results are presented

for existing conditions (blue line) and elimination of gravity CSOs (dashed brown line). Oxygen-

demanding pollutant concentrations in these discharges vary from event to event (Zhang et al,

2007).

2

---

Figure 1.

Locations of Selected

Modeled In-Stream

Dissolved Oxygen

Concentrations

stibal

1, 4h

irade'vd

h Y c: firm Qz!.^

V.'.R1'AC oic,

i^•:rim d!'J.'i pent

un CAWS

C50 pw+p 51skA

Mow Kkan

t23

M

.

LlmnoTech

3

---

The effects of the oxygen-demanding loads from the North Branch gravity CSOs and

other wet weather sources (including the North Side Pump Station and runoff and CSOs in the

NBCR) on in-stream dissolved oxygen levels at Addison Road are shown in Figure 2. The

gravity CSO loads affect dissolved oxygen concentrations by 0.5 to 1 mg/l for three days for the

first event and 0.5 to 1.5 mg/1 for eight days for the second event. Depressions after the wet

weather events on July 25, 2001 and August 2-3, 2001 are still evident even with the elimination

of the gravity CSOs. These wet weather impacts are more pronounced at Fullerton (Figure 3) and

Kinzie Street (Figure 4).

The effect of the gravity CSOs on dissolved oxygen are also pronounced at Halsted Street

on the SBCR (Figure 5). For the second event, the CSOs depress in-stream dissolved oxygen by

as much as 2 mg/1. This effect is diminished at the B&O Railroad Bridge on the CSSC (Figure

6).

The effect of the gravity CSOs on in-stream dissolved oxygen is also substantial at

Halsted Street on the LCR (Figure 7) for the second event, with impacts lasting for eight days

and a maximum deficit of 1.5 mg/l. This effect is more pronounced tt Cicero Avenue on the

CSC, with a maximum deficit of 2.5 mg/l (Figure 8). The gravity CSOs impact in-stream

dissolved oxygen at Route 83 on the CSC for both the first event (1 mg/1) and the second event.

For the second event, the maximum dissolved oxygen deficit at this location is 3 mg/l and the

CSO effects are calculated to last more than seven days.

4

---

Adrienne D. Nemura, Attachment 4

Figure 2. Comparison of Dissolved Oxygen

Levels

at Addison Road

,

NBCR for Existing

Conditions and Elimination

of Gravity

CSOs (2001)

7/24 7/26 7/28 7/30 8/1

8/3

8/5

8/7

8/9

Figure 3. Comparison of Dissolved Oxygen Levels at Fullerton Avenue, NBCR for Existing

Conditions and Elimination of Gravity CSOs (2001)

Effect

of Eliminating

Gravity CSO

2

1

0

7/24

7/

26 7/28 7

/

30

8/1

8/3

8/5

8/7

8/9

Figure 4. Comparison of Dissolved

Oxygen Levels

at

Kinzie Street

, NBCR

for Existing

Conditions and Elimination

of Gravity CSOs (2001)

9

8

x

a

5

0 4

0

a

6 3

6 2

1

, Effect

of Eliminating Gravity CSO

RA mini U nl Cflt@I fOn

0

7/24

7/

26 7/28 7/30

8

/

1

8/3

8

/

5

8/7

8/9

5

---

Adrienne D. Nemura, Attachment 4

Figure 5. Comparison of Dissolved

Oxygen Levels at

Halsted

Street, SBCR

for Existing

Conditions and Elimination

of Gravity CSOs (2001)

9

8

7

6

5

Minimum Criterion

^.

3

2

i

1

ffort of Eliminating

Gravitv CSn

0

7/24 7/26 7/28 7/30 8/1

8/3

8/5

8/7

8/9

Figure 6

.

Comparison of Dissolved

Oxygen Levels at

B&O Railroad Bridge

, CSSC for

Existing Conditions and Elimination

of Gravity CSOs (2001)

1N

7/24 7/26 7/28 7/30

8/1

8/3

8/5

8/7

8/9

Figure 7. Comparison of Dissolved Oxygen Levels at Halsted Street, LCR for Existing

Conditions and Elimination of Gravity CSOs (2001)

Effect of

Eliminating Gravity C50

U

-

r -- f

-I

- -+-- ;- -i-- - -L -

7/24

7/26 7/28 7/30 8/1

8/3

8/5

8/7

8/9

6

---

Adrienne D. Nemura, Attachment 4

Figure 8. Comparison of Dissolved Oxygen

Levels

at Cicero

Avenue, CSC for

Conditions and Elimination

of Gravity

CSOs (2001)

9

8

7

6

Effect of Eliminating

Gravity C50

7/24

7/

26 7/28 7/30

8

/

1

8/3

8

/

5

8/7

8/9

Existing

Figure 9. Comparison of Dissolved Oxygen Levels at Route 83, CSC for Existing

Conditions and Elimination of Gravity CSOs (2001)

Effect of Eliminating

G ravsty CSD

7/24

7/26

7/28 7/30

8/1

8/3

8/5

8/7

8/9

REFERENCES

Zhang,

H., D. Bernstein

, J.

Kozak, I S. Jain, R. Lanyon, E. Alp, and C. S. Melching. 2007.

Evaluation of Eliminating Gravity CSOs on Water Quality of the Chicago Area Waterways

(CAWS) Using an Unsteady Flow Water Quality Model. WEFTEC 2007

.

San Diego

,

CA. Oct.

13-17, 2007.

7

---

A

ttachm

e

nt 5

---

EVALUATION OF THE DURATION OF

STORM

EFFECTS ON IN-STREAM WATER QUALITY

Emre Alp1, Charles S. Melching2

CE DATABASE SUBJECT HEADINGS:

Monte Carlo Method; Models; Watershed

Management; Water Quality; Combined Sewer Overflows

1

Post-Doctoral Researcher, Department of Civil and Environmental Engineering, Marquette

University, P.O. Box 1881, Milwaukee, WI 53201-1881, USA. Tel: 414 2880690, Fax: 414

2887521 ,

e-mail

: emre.alp@marquette.edu

z

Associate Professor, Department of Civil and Environmental Engineering, Marquette

University, P.O. Box 1881, Milwaukee, WI 53201-1881, USA. Tel: 414 2886080, Fax: 414

2887521 ,

e-mail

: charles.melching@marquette.edu

1

---

Abstract

One of

the primary reasons water

-

quality standards are not met is the effect of storm runoff and

combined sewer overflows

.

A methodology

is presented here to determine the duration of storm

effects on stream water

quality. The

evaluation

of the

duration of storm effects on water quality

involves two steps

.

First

,

calibration of an appropriate water

quality

model that is capable of

simulation

of unsteady-

state conditions

.

Second

,

execution of the calibrated model with a

number of storm loadings randomly sampled

from

a specific

probability

distribution that

represents realistic ranges of pollutant concentrations

.

When the variations in the simulated water

quality variables become negligible

,

it is assumed that the river system goes

back to

pre-storm,

dry-weather

conditions

.

To illustrate this methodology

, the DUFLOW

unsteady-state water

quality

model and Latin Hypercube Sampling are applied to evaluate the duration of storm

effects on water quality in the Chicago

Waterway

System

(CWS). The

duration of the storm

impacts on dissolved oxygen lasts 2

days

to 2 weeks

in the CWS

depending on the location in the

system and the magnitude of the storm

.

Moreover, a strong relation between the precipitation

depth and the duration of the storm effects on in-stream water quality constituents was found in

the CWS.

Outcomes of this research suggest that the duration of the storm effect on water quality

can reasonably be predicted

with

the help of robust unsteady-state water quality models.

---

Introduction

Because of storm related pollution like combined sewer overflows (CSOs), river systems may

not meet the water quality standards defined by the existing uses of the river system. As the

importance of the effects of CSOs on receiving water bodies is becoming more obvious, CSO

regulations are becoming stricter. In 1994, The U.S Environmental Protection Agency (EPA)

issued the Combined Sewer Overflow Control Policy, which contains provisions for developing

appropriate, site-specific National Pollutant Discharge Elimination System requirements for all

CSOs. Compliance most often takes the form of a long-term control plan, which outlines the

selection and implementation of CSO control alternatives. Current EPA regulations and

guidance, based on the Clean Water Act (CWA) and CSO Policy, are structured to provide States

some flexibility to adapt water quality standards to reflect site-specific conditions, including

those related to CSOs (Slack and Nemura, 2000). However, existing regulations provide that

designated uses can only be removed if there is a reasonable basis for determining that current

designated uses cannot be attained after implementing the technology based controls required by

the CWA. In determining whether a use is attainable, EPA guidance requires the State to conduct

and submit an Use Attainability Analysis (UAA). The methodology of the UAA is described in

related manuals (USEPA, 1983a, Novotny et al., 1995)

If the

problem of concern is a complicated phenomenon such

that the UAA

attributes the water

quality standard violations to the both wet and dry weather periods, it could be necessary to

determine the degree of attainment of the standards during wet and dry weather conditions to

identify the problem precisely

.

By delineating wet and dry weather, it is possible to compare the

3

---

contribution of both dry and wet weather management alternatives to the overall compliance

with the water quality standards.

If continuous time series of five day carbonaceous biochemical oxygen demand (CBOD5) and

ammonium as nitrogen (NH4-N) concentrations were available at short time steps, it is possible

that the duration of the storm effect on these constituents could be determined from the measured

CBOD5 and NH4-N concentrations. However, such a determination would require that the dry-

weather conditions-temperature, flow from wastewater treatment plants and tributaries,

boundary conditions, etc.-would be essentially the same as before the storm. Since such

continuous data generally are not available, water-quality models must be used to estimate the

duration of the storm effect. The situation for dissolved oxygen (DO) concentrations is much

more complex because DO concentrations are influenced by many conditions and processes

temperature, flow dilution, treatment plant loads, CBOD5, the nitrogen cycle, sediment oxygen

demand (SOD), algal growth and death, etc.-each of which is subject to a different duration of

storm effects. For example, DO recovery to pre-storm conditions does not indicate the end of the

storm effect because the new dry weather DO concentration may have changed because of

changes in temperature, SOD, treatment plant loads, etc. Again water-quality models must be

used to determine the duration of the storm effect.

This paper describes a method for evaluation of the storm effects on in-stream water quality to

define wet weather conditions and illustrates how different storm loadings affect the in-stream

DO, CBOD5, and NH4-N concentrations in the Chicago Waterway System (CWS). A relation

between precipitation and the duration of storm impacts on in-stream water quality is also

4

---

examined

.

The relation between the precipitation and the duration of the wet weather conditions

can help to estimate the duration of the wet weather conditions for future storms.

Method

Basically, an uncertainty analysis method is used together with an unsteady

-

state water quality

model to determine the duration of wet weather conditions

.

This methodology starts with the

assumption that the wet weather condition can be defined as the duration of storm effects on in-

stream water quality. In this approach

,

a water quality model is successively applied with

different storm loadings randomly sampled from a probability distribution representative of

actual storm loads to the receiving water body using an uncertainty analysis technique

.

Then the

variations in the water quality model output variables among the successive simulations are

observed

.

When the variation in the model output variables approaches zero, it means the river

system has returned to the pre-storm

(

dry weather

)

condition. Therefore, the duration between

the start and the end of the variations in the simulated constituent concentrations can be defined

as the duration of the storm effect on in-stream water quality, or the duration of the wet weather

condition.

Since the purpose of this research is to separate dry weather conditions from wet weather

conditions

,

it is necessary to work with a water quality model which is capable of simulating

flows under unsteady conditions

.

The DUFLOW

(2000

)

unsteady

-

state water

-

quality model

developed in the Netherlands was selected for this study for the following reasons : 1) Several

options are included for the simulation of water quality including a sediment flux model, 2)

Compatibility with Geographical Information Systems, 3) Microsoft Windows based including a

5

---

powerful graphical user interface

, 4) Low

license cost

,

5) Low computational time, and 6)

Successful application to several European rivers (e.g., Manache and Melching, 2004).

In this study, the DUFLOW water-quality simulation option that adds the DiToro and Fitzpatrick

(1993) sediment flux model to the Water Quality Analysis Simulation Program (WASP4)

(Ambrose et al., 1988) model of constituent interactions in the water column is applied.

DUFLOW distinguishes among transported material that flows with water, bottom materials that

are not transported with the water flow, and pore water in bottom materials that are not

transported but that can be subject to similar water-quality interactions to those for the water

column. Flow movement and constituent transport and transformation are two processes and

constituent transport is defined by advection and dispersion.

The flow simulation in DUFLOW is based on the 1-D partial differential equations that describe

unsteady flow in open channels (de Saint-Venant equations). These equations are the

mathematical translation of the laws of conservation of mass and momentum.

The calibrated DUFLOW unsteady water quality model is successively executed with different

storm loadings randomly sampled from a probability distribution to determine the duration of the

storm effect on water quality. The Latin Hypercube Sampling (LHS) technique (McKay et al.,

1979; McKay, 1988) is used in this study because of its good accuracy for a smaller sample size

compared with Monte Carlo Simulation (MCS). For unsteady water quality models with high

computational time requirements, the use of LHS has been suggested (Aalderink et al., 1996,

Manache and Melching, 2004) because it provides the flexibility of MCS with less

6

---

computational load. LHS has been used extensively in many studies. Vandenberghe et al. (2005)

focused on diffuse nitrate pollution due to fertilizer use in the Dender River basin (Belgium) and

applied LHS to analyze the uncertainty of water quality predictions caused by uncertainty in the

inputs related to emissions of diffuse pollution. Sieber and Uhlenbrook (2005) used LHS to

determine the most important parameters in a water quality model for the Brugga River basin

and the sub-basin St. Wilhelmer Talbach (Germany). Mukhtasor et al. (2004) described an

Ecological Risk Assessment procedure based on LHS. Sohrabi et al. (2003) used the ARRAMIS

(Advanced Risk & Reliability Assessment Model) software package to apply the LHS scheme to

analyze the uncertainty of the SWAT2000 (Soil and Water Assessment Tool) outputs concerning

nutrients and sediment losses from the Warner Creek watershed, Maryland.

LHS is a type of stratified Monte Carlo sampling in which n different values are selected for

each of

k

variables. The range of each variable is divided into

n

nonoverlapping intervals each

having equal probability. One value from each interval is selected at random. For intervals based

on equal probability, random sampling means random with respect to probability density in the

interval. The

n

values thus obtained for X, are paired in a random manner with the n-values

of X2,

These

n

pairs are combined in a random manner with the

n

values of X3 to form n triplets, and so

on, until n k-tuples are formed (Iman et al., 1981). This is the Latin Hypercube Sample, which is

used as input for the model.

7

---

Case Study

Modeling Water Quality in the Chicago Waterway System

The Chicago Waterway System (CWS) is located in Northeastern Illinois, USA, and is

composed of the Chicago Sanitary and Ship Canal (CSSC

),

Calumet

-

Sag Channel, North Shore

Channel (NSC), lower portion of the North Branch Chicago River (NBCR), South Branch

Chicago River (SBCR), Chicago River Main

Stem

,

and Little Calumet River (north). The CWS,

used mainly for commercial and recreational navigation and for urban drainage

,

is a 122.8 km

branching network of navigable waterways controlled by hydraulic structures

.

The CWS receives

pollutant loads from 3 of the largest wastewater treatment plants in the world, nearly 240 gravity

CSOs, 3 CSO pumping stations, direct diversions from Lake Michigan

,

and eleven tributary

streams or drainage areas. The water quality in the modeled portion

of the CWS

is also affected

by the operation of four Sidestream Elevated Pool Aeration stations and two in

-

stream aeration

stations

.

The Calumet and Chicago River Systems are shown in Figure 1.

The Illinois

Pollution Control Board

(

IPCB) regulations

(Title

35, Section

302.206 and

Section

302.405)

state that for General Use waters the DO concentration shall not be less than 6 mg/L

during at least 16 hours of

any 24 hour

period

,

nor less than 5 mg

/

L at any time

. In the CWS,

only the upper NSC

and the Chicago River Main Stem are considered General

Use waters. The

remainder

of the CWS

is considered Secondary Use (Indigenous

Aquatic Life)

waters wherein

the DO concentration shall not be less than 4

mg/L at

any time except that the Calumet-Sag

Channel

shall not be less than 3

mg/L at

any time. This regulation was established

in 1972 with

the modification for the Calumet

-

Sag Channel in 1988, and since that time the Metropolitan

8

---

Water Reclamation District of Greater Chicago (MWRDGC) has made many improvements to

the wastewater treatment plants (water reclamation plants), CSOs, and aeration resources of the

CWS. Thus, in 2003 the Illinois Environmental Protection Agency initiated an UAA for the

CWS to see if DO in the CWS could be brought closer to the General Use standard at a

reasonable cost. In anticipation of this UAA and to meet other water-quality management needs

the MWRDGC began an intensive sampling of hourly DO and temperature throughout the CWS

in 1998, and entered into an agreement with Marquette University in 2000 to develop a water-

quality model for the CWS that was suitable for simulating constituent concentrations during

unsteady-flow conditions. The outcomes of this study and the DUFLOW water quality model for

CWS developed by Marquette University have been supporting the CWS UAA study by

identifying the causes of water quality problems and the effectiveness of management

alternatives to achieve designated uses. The UAA has recommended revised uses of Modified

Warm Water Aquatic Life for the NSC and the NBCR up to Fullerton Avenue and for the

Calumet-Sag Channel and Little Calumet River (north), whereas the use for the rest of the

system will be Limited Warm Water Aquatic Life. The exact DO targets for these uses still are

under consideration by the IPCB.

The DUFLOW water-quality model was calibrated and verified for the periods of July 12-

November 9, 2001, and May 1- September 23, 2002, respectively. 2001 was a relatively wet year

and 2002 was a relatively dry year giving an acceptable variety of flows for the calibration and

verification. Complete details of the calibration and verification are given in Alp and Melching

(2006).

9

---

The comparison of measured and simulated hourly water-surface elevations at six locations

throughout the CWS were used for hydraulic calibration and verification of the model. Statistical

analysis for the locations used in the verification showed that the difference between the

measured and simulated stages are all below 8.5 % relative to the depth of the water except for

Wilmette. Wilmette is an upstream boundary location of the model located on the North Shore

Channel (NSC) and observed flow was used as the upstream boundary condition. The mean and

median error in water-surface elevation was 7.6 cm. Because of the generally low flows in NSC

and the backwater effect from downstream portions of the CWS, it was difficult to decrease this

error.

This error was considered too small to significantly affect simulated water quality in the

NSC, and so extraordinary means were not taken to improve this part of the hydraulic

simulation. For the other locations, mean and median values of the absolute value of the

difference between the measured and simulated stages are below 3.2 % relative to the depth at all

locations. The simulated water-surface elevations were within 3% relative to depth for 93.7-

99.9% of the measured values at all locations other than Wilmette. These high percentages of

small errors and the high correlation coefficients (0.79-0.98) indicate an excellent hydraulic

verification of the model.

An extensive data set including hourly in-stream DO data at 25 locations, monthly in-stream

water-quality measurements at 18 locations, daily composite treatment plant effluent

measurements, event mean concentrations for storm runoff from major tributaries and CSO

pumping stations determined from multiple samples collected by the MWRDGC during selected

events in 2001, daily solar radiation data, and detailed hydraulic data (at 15-min and 1-hour time

steps) were used to calibrate and verify the water-quality model at a 1-hour output time step. All

10

---

water quality variables including DO were measured by MWRDGC. The comparisons of the

simulated constituent concentrations (CBOD5, Nitrogen compounds, and Chlorophyll-a) with

long-term mean measured concentrations, one standard deviation confidence bounds, and

concentrations measured between July-November 2001 indicated reasonable simulations. There

are approximately 2900 measured hourly DO data at each location within the calibration period

and throughout the calibration process it was aimed to match hourly measured and simulated DO

concentrations as much as possible. On the other hand, as Harremoes et al. (1996) mentioned, it

is almost impossible to match all the measured hourly data if there are a large number of data to

be fitted to.

Hence, calibration was done manually in a way that the model can capture low DO

concentrations resulting from CSOs and produce similar probability of exceedences for different

DO concentrations. The focus on low concentrations was taken so that reliable management

practices to mitigate the CSO effects could be determined. Comparisons of the percentage of DO

concentrations less than 3, 4, 5, and 6 mg/L at different locations in the CWS for the calibration

period for selected locations are listed in Table 1.

Close agreement between the calibrated and measured DO concentrations were obtained

especially for the lower DO concentrations. The differences between the percentage of DO

concentrations less than 3 mg/L for the calibrated and measured DO concentrations vary 0.0 to

4.5 percentage points at all 25 locations in the CWS except for the upper NSC. The differences

between the percentage of DO concentrations less than 4 mg/L for the calibrated and measured

DO concentrations are less than 10.6 percentage points in the CWS except for the upper NSC.

Along the upper NSC it was difficult to match the measured DO concentrations because of the

hydraulic conditions in the upper NSC, i.e. flow near zero except during CSO events. The

11

---

differences between the percentage of DO concentrations less than 3 and 4 mg/L for the

calibrated and measured DO concentrations reach up to -30.4 percentage points in the upper

NSC. The overall average of the absolute differences of percentages of DO concentrations less

than 3, 4, 5, and 6 mg/L for the calibrated and measured DO concentrations are 1.7, 4.4, 7.7, and

9.6 percentage points, respectively, in the CWS except for the upper NSC.

For model verification purposes, average values of constituent concentrations in CSOs taken as a

mean from historic measured data were applied, whereas measured event mean concentrations

were available at the CSO pumping stations for the calibration period. Verification of the CWS

DUFLOW model generally shows good agreement between measured and simulated DO

concentrations. For the entire CWS except the upper NSC the average error in daily DO

concentration is 8.3 % and the average absolute percentage error is 26.9 % (Neugebauer and

Melching, 2005). Comparison between the DUFLOW model prediction ability for the

verification and calibration periods indicates that the prediction ability of the DUFLOW model is

comparable for these two periods. It was concluded that, in general, the DUFLOW model

represents water-quality processes in the CWS well enough for simulation of remediation

strategies and to be used in the determination of the duration of the storm effects on water

quality.

12

---

Duration

of Effects of Combined Sewer Overflows in the Chicago Waterway System

The CWS

receives a high amount

of CSOs

during larger storms

.

Hence the CWS is a good

example study to determine the duration of storm effects on

CBOD5, NH4-N, and DO

concentrations.

Generation of the Latin Hypercube Sample

In this step, random values of the input variables are generated from their assigned distributions.

Pollutant loadings from CSOs are the combination of CSO volume and pollutant concentrations.

In this study, 8 constituents from each of the 3 pumping stations (Table 2) for a total of 24

variables are considered. Uncertainty in the CSO volume could affect the variability in the CSO

loading.

However, in order for the hydraulics of the channel to be properly simulated (i.e. to

maintain the proper system-wide water balance and match the observed stage measurements) the

overall CSO volume cannot vary substantially from the value used. Thus, in this study, the

variation in CSO pollutant loads is considered using a fixed CSO flow and variable event mean

concentrations (EMCs) of pollutants. For this reason, only CSO EMCs were used as input

variables in the LHS simulations to determine the duration of the storm impact on in-stream

water quality.

The flow from CSO drainage areas during storms has a substantial effect on the CWS. There are

nearly 240 CSOs in the CWS drainage area. Since it is practically difficult to introduce all CSO

locations in the modeling, 28 representative CSO locations were identified and flow distribution

was done on the basis of drainage area for each of these locations. The volume of CSO was

13

---

determined from the system wide flow balance and water level measurements at Romeoville.

Successful results with hydraulic calibration and verification suggest that CSO volumes were

reasonably estimated and distributed along the waterway system. Further, Novotny and Olem

(1994, p. 484) state in most cases, the total load resulting from the runoff event is more important

than the individual concentrations within the event due to the fact that runoff events are

relatively short, the receiving water body provides some mixing, and the concentration in the

receiving water body is a response to the total load rather than the concentration variability

within the event. Similarly, the modeling results in this study have shown that if approximately

the right amount of flow and pollutant loads are input to the CWS at approximately the right time

and right location an acceptable simulation of the pollutant concentrations in the CWS has

resulted. Further, the evaluation of storm durations was done at the DO monitoring locations

which are sufficiently downstream from the representative CSO locations so that sufficient

mixing of the water body has taken effect.

Because of the importance of the total load, the EMC has been found to be the most appropriate

variable for evaluating the impact of urban runoff (U.S. EPA, 1983b). Hence, EMCs were used

to characterize all stones in this study. Historic EMCs were calculated based on the

measurements done by the MWRDGC for each pumping station listed in Table 2. The North

Branch Pumping Station water-quality variables were used for NSC and NBCR CSOs, the

Racine Avenue Pumping Station water-quality variables were used for the Chicago River Main

stem and SBCR CSOs, and 125th Street Pumping Station water-quality variables were used for

the Calumet-Sag Channel and Little Calumet River CSOs. The reasonableness of this approach

was shown statistically in Neugebauer and Melching (2005). There are just 4 and 7 measured

14

---

events for the 125th Pumping Station and the North Branch Pumping Station, respectively, for the

statistical analysis. Thus, even though different probability distributions were tested, the limited

number of data did not allow a robust conclusion on the appropriate probability distribution.

Novotny (2004) showed that event mean concentrations in runoff follow the log-normal

probability distribution. Therefore, the assumption of a log-normal probability distribution was

made.

Several computer packages that include routines for MCS and LHS methods are available

.

In this

study, the

UNCSAM

program developed by the Dutch Institute for Public Health and the

Environment

(

Janssen et al., 1992) was used to generate 50 sets of random CSO pollution

variables corresponding to the LHS procedure. As a general rule, as the sample size increases,

the model output variability better converges to its true value

.

Because of the long computational

time for the

DUFLOW

Model

,

selection of a reasonable sample size that can lead model output

statistics to converge is an essential part of this step

.

In the literature different sample sizes have

been suggested as varying between 4/3 to 5 times the number of the uncertain input variables

(McKay,

1988; Manache, 2001

).

Since there are 24 input variables

,

fifty sets of random EMCs

are enough to obtain satisfactory results.

Following

the LHS method, fifty sets

of the 8 input constituents were generated for each

pumping station and related

gravity

CSOs and the

DUFLOW model

was run successively for

each

of the fifty

CSO loadings

.

These DUFLOW model

runs generated 50 sets of the

concentrations

of DO, CBOD5, and NH4-N in the CWS.

Simulations

were conducted for the

DUFLOW calibration

and verification periods. Calculations are based on a 15

-

minute

15

---

computational time step and a 1 hour time step is used for the output variables to match the

availability

of measured DO concentrations.

Duration of the Effects of Combined Sewer Overflows on Dissolved Oxygen for 2001

To determine how long storm loadings affect the DO concentrations in the CWS for each

location, the standard deviation of computed DO concentrations was plotted against time. At

Romeoville the standard deviation was plotted against time together with the flow for the

calibration period (Figure 2). As can be seen in Figure 2, the effects of some storms overlap and

this makes it hard to distinguish the start and end time of the storm effects. Hence, some of the

storms are combined and treated as a single storm.

It is a difficult question to set a rule to determine the start and the end of the storm load effect.

Different approaches were tried to see if a specific rule can be applied to all constituents and

locations. One of the approaches tried was to assume that there is no storm effect if the standard

deviation is smaller than a certain set value. It was found that as this number gets smaller the

system gets more sensitive to the selected set value. So it was difficult to select a number that

works well for all storms at all locations. Another approach assumes that the standard deviations

of simulated DO concentrations follow a statistical distribution (i.e. log-normal, normal) and

there is no storm effect on DO after a specific probability of exceedence. For example, if the

standard deviation of simulated DO concentrations compiled over all time steps follows a normal

distribution with the mean and standard deviation of 0.6 and 0.2, respectively, it can be assumed

that there is no storm effect after the DO standard deviation reduced to 0.27 which corresponds

16

---

to a 5% probability of exceedence. This approach is problematic because every storm has

different characteristics and each location responds differently to the storms making it difficult to

come up with a specific execeedence probability that can be applied to all storms and locations.

This makes the second approach more complicated than the first. The last approach assumes that

storm effects start with the increase in the DO standard deviation and it ends when there is no

significant change in the DO standard deviation (i.e. once the DO standard deviation reduces and

essentially becomes a constant). Although it is hard to give a quantitative description for the rule

of "no significant change in the DO concentration", since every reach in the CWS responds

differently to a given storm, in general, it can be said that the DO standard deviation tends to

become a constant quickly after the difference between daily average standard deviation of DO

on consecutive days reduces to 15% or less. In this approach some engineering judgment is

necessary to pinpoint the end of the storm event effects on DO, but this approach worked best for

all storms and locations. The duration of the storm effects on DO concentrations was determined

for the CWS using the last approach and the results are listed in Table 3 for the calibration

period.

Substantial impact of storm loading on DO concentration in the CWS on average lasts one day to

a few weeks depending on the location in the CWS (Table 3). For the combined storms

(overlapping storms), the duration of wet weather effects is the result of consecutive storms

hence durations of the effect of overlapping storms on in-stream water quality are longer than for

other storms. Because of the hydraulic characteristics and behavior of the system, for most of the

storms very similar durations are obtained at Cicero Avenue and Baltimore and Ohio Railroad,

which are just upstream and downstream from Stickney Water Reclamation Plant (WRP),

17

---

respectively. Effluent from the Stickney WRP dominates the hydraulics of the system. Due to

small slopes and velocities (during low flow periods), the Stickney WRP discharge often flows

in two directions: upstream from the plant and downstream towards Romeoville, causing in this

way a "hydraulic dam" for upstream flow. In these sections water becomes practically stagnant.

In such cases, the residence time of storm loads upstream from the plant are greater than

downstream, and intensive self-purification processes consume DO while there is no additional

source of DO other than atmospheric reaeration, which is very low.

For the larger storms (indicated by larger CSO volumes in Table 3) the system tends to respond

very similarly at every location whereas for smaller storms the duration of storm impact is

significantly larger at the downstream locations. For example, for the storms August 2 and 9,

2001, the duration of the storm effect lasts 15.5 and 18.2 days on the CSSC at Romeoville and on

the NBCR at Fullerton Avenue, respectively, whereas for the July 25, 2001 storm, the duration

of the storm effect lasts 8.6 and 5.5 days on the CSSC at Romeoville and on the NBCR at

Fullerton Avenue, respectively. This is because for smaller storms a greater percentage of CSO

flows occur at pumping stations, on the other hand for larger storms a greater percentage of CSO

flows occur at gravity CSOs. Therefore, during larger storms the system receives a more

homogenous CSO load which leads to a homogenous response time over the Chicago River

System (NBCR-SBCR-CSSC). During smaller storms, the pumping stations produce relatively

more CSO volume which leads to different storm impacts over the Chicago River System. The

reason for this CSO flow distribution is twofold. The drainage areas for the pumping stations are

83.89, 40.97, and 15.43 kmz for Racine Avenue, North Branch, and 125th Street, respectively.

These drainage areas are far larger than those for individual gravity CSOs. Thus, because they

18

---

capture runoff from larger areas the CSO pumping stations are more likely to discharge for

smaller storms than are the gravity CSOs. Further, to avoid flow reversals from the CWS to

Lake Michigan, the MWRDGC prefers to reserve space in the Tunnel and Reservoir Plan

(TARP) tunnels for gravity CSOs at locations closer to the lake, and, thus, diverts relatively

more flow during smaller storms to the CWS at the pumping stations. During larger storms all

drainage areas generate runoff in excess of the interceptor capacity and the TARP tunnels fill

resulting in a more even distribution of CSO flows.

Unlike the Chicago River System, the duration of storm effects for a given storm are very similar

along the Calumet River System (Little Calumet River (north) - Calumet-Sag Channel). Since

there is just one pumping station, 125th Street Pumping Station, and it is located close to

upstream boundary (O'Brien Lock and Dam), differences in the volume of gravity and pumping

station CSOs do not create a big variation in the duration of storm impacts along the river

system.

Duration of the Effects of Combined Sewer Overflows on CBOD5 and NH4-N for 2001

Unlike the storm load effect on DO concentrations, it is relatively easy to pinpoint the end of the

storm effect on CBOD5 and NH4-N concentrations. At Romeoville the standard deviations of

simulated CBOD5 and NH4-N concentrations were plotted against time together with the flow

(Figure 3). As can be seen in Figure 3, the standard deviation clearly decreases almost to zero

except for overlapping storms. Hence, it is assumed that at the point where the CBOD5 and NH4-

N standard deviation approaches zero the storm pollution load does not affect water quality in

the system at that location anymore.

19

---

The storm effect on CBOD5 and NH4-N lasts from 2 days to 2 weeks depending on the storm and

the location (Tables 4 and 5). In general, the duration of the storm effect on CBOD5 and NH4-N

concentrations along the CSSC lasts 3-4 days longer than on the Calumet-Sag Channel. As

expected, the duration of the storm effect on CBOD5 and NH4-N concentrations decreases

towards upstream locations along CSSC and NBCR. On the other hand, in the Calumet

Waterway System, the response of the river system to storm loading stays almost the same along

the waterway for a given storm.

Duration of the Effects of Combined Sewer Overflows for 2002

The standard deviation of simulated DO concentrations for each location in the CWS, was

plotted against time to determine how long storm loadings affect the 2002 verification period.

The strategy explained in the previous section was followed to determine the duration of the

storm effect on the simulated DO, CBOD5, and NH4-N concentrations. 2002 was a period of

drier weather than was 2001, but the conclusions derived for 2001 are also valid for the 2002

verification period. Details of the 2002 simulations are given in Alp (2006).

Comparison of the duration

of storm effects

on water-quality constituents

Several statistical tests including an Analysis of Variance, Fischer's least significant difference,

and the Kruskal-Wallis test were applied to compare the average of the duration of the storm

impact on in-stream water quality among the studied constituents. For a given constituent, results

for all storms were considered. The mean duration of the storm effects on in-stream DO, CBOD5,

20

---

and NH4-N concentrations are the variables evaluated in the statistical comparison. A statistically

significant difference amongst the medians was found at the 5 % significance level. Thus, from

these tests it can be concluded that storm effect is longest on DO (on average 9.6 days) followed

by CBOD5 (7.2 days), and is shortest for NH4-N (6.2 days). The duration of the storm effect on

DO concentrations reflects a combination of different factors. Results showed that the storm

effect continues on DO concentrations even though CBOD5 and NH4-N concentrations and flow

go back to dry weather conditions. There are two main types of sinks of DO in the DUFLOW

model, those in the water column and those from the sediments. Oxidation of CBOD5, algal

respiration, and nitrification are oxygen-consuming processes within the water column. The

sediment sink involves diffusion of oxygen between the water body and the sediment layer and

resuspension of oxygen consuming substances. Therefore, even though water column effects on

DO stop, sediment effects on DO continue resulting in the almost constant DO standard

deviations.

Relation between Precipitation and Duration of Storm Impact on Water Quality

It is important to understand the behavior of the CWS under storm loading conditions and to

predict the duration of the storm effect on in-stream water quality constituent concentrations for

future use. It was attempted to estimate the duration of the storm impact on water quality

constituents by examining the precipitation data for the Chicago area.

21

---

Rainfall Data

A dense network of 25 raingages is operated by Illinois State Water Survey (ISWS) in Cook

County, Ill. Since terrain effects are fairly minimal in northeastern Illinois, gridding which

allows the use of simple arithmetic averaging to compute areal average precipitation depths was

applied in the layout of the network (Westcott, 2003). Average precipitation for storms in 2001

and 2002 were computed using hourly precipitation data provided by the ISWS. Cook County

was divided into several sub-areas to get a better understanding of rainfall distribution over the

CWS drainage area. These included Cook County; the CWS drainage area (hereafter

"Waterway"); the City of Chicago; the NBCR drainage area; the Chicago River main stem,

SBCR, and CSSC drainage area; and the Little Calumet River and Calumet-Sag Channel

drainage area.

Regression

Analysis

Results

Precipitation depth data were regressed against the duration of storm impact on water quality for

all locations for the July 12 - November 9, 2001 and May I - September 23, 2002 periods. The

highest correlation coefficients for DO regressions are obtained for the Chicago and Waterway

sub-areas precipitation data for all locations. The overall average DO concentration correlation

coefficients for the Chicago and Waterway precipitation data are very close at 0.86 and 0.87,

respectively. The highest overall average CBOD5 and NH4-N concentration correlation

coefficients are obtained for the Waterway precipitation data with an overall average of 0.80 for

both CBOD5 and NH4-N concentrations. Results show that there is a strong relation between the

22

---

total precipitation on the CWS drainage area and the duration of the storm effect on the in-stream

water quality constituent concentrations. The strong relation between the precipitation depth and

the duration of the wet weather effects on water quality also indicates that the hydrologic inputs

to the CWS system have been reasonably estimated since precipitation is an independent variable

that was not used to generate the CSO flows. The strong relations indicate it is possible to predict

the duration of the storm loading effect on in-stream water quality constituent concentrations on

the basis of accurate precipitation data. The regression equation plots and regression equations

for a selected site are shown in Figure 4. It is possible that consideration of the duration of

precipitation in the regression analysis could further improve the relations obtained, but the high

coefficients of determination indicate that precipitation amount is a useful variable for a practical

method to estimate the duration of storm effects for the CWS.

Figure 4 shows a clear relation between the total precipitation on the CWS drainage area and the

duration of the storm effect on water-quality constituents even though a limited number of

storms are used in this analysis. The correlation is the strongest for the DO concentrations and

weakest for the NH4-N concentrations. The practical side of this approach is that local authorities

or decision makers can easily determine the duration of the wet weather conditions by examining

precipitation data. It should be noted that these regression equations are valid for precipitation

between 20.3 to 81.3 mm recorded over the CWS drainage area. For storms that result in

precipitation larger than 81.3 mm, more studies are needed to extend the range of the regression

estimates. The coefficient of determination, RZ, of 0.85 obtained at Romeoville for DO (Figure 4)

indicates that 85% of the variance in the duration of the storm effects on DO concentrations can

be explained by the magnitude of the precipitation. If the probability of occurrence of a certain

23

---

magnitude of rainfall can be combined with the outcomes of the regression analyses, it may be

possible to obtain generalized probabilistic conclusions about the duration of the storm impact on

in-stream water quality.

Conclusions

Wet weather impacts resulting from urban catchments often create substantial problems for

receiving water quality. One of the questions decision makers are always interested in is "how

long does it take for a river to go back to pre-storm water quality conditions?" In other words,

the question is "what is the duration of the storm effects on water quality?"

The results of this study show that application of a statistical sampling technique with an

unsteady-state water quality model can result in reasonable estimates of the duration of wet

weather conditions. The power of the calibrated water quality model plays an important role in

the accurate determination of the duration of the wet weather period. Estimates of wet weather

conditions may be as robust as the calibrated water quality model.

It

was found that the duration of the wet weather period varies between 2 days to 2 weeks in the

CWS. The magnitude and spatial distribution of the storm are the most important factors that

affect the wet weather conditions in the receiving water body. Regression analysis showed that

there is a strong relation between the precipitation measured in the CWS drainage area and the

duration of the storm effects on in-stream water quality constituents. Regression equations

derived from measured rainfall data and simulation results can be used to predict the duration of

24

---

the storm effects oil

i

n-stream water quality for future storms so that wet weather periods can be

determined from the total storm precipitation. This information can be useful for future water-

quality management in the CWS

.

It is hoped the procedure illustrated here can be used to

understand wet-weather conditions in other waiter bodies.

25

---

References

Aalderink, R.H., Zoeteman, A., and Jovin, R. (1996). Effect of input uncertainties upon scenario

predictions for the River Vecht.

Water Science and Technology,

33(2), 107-118.

Alp, E. (2006), "A method

to evaluate duration of the storm effects on in-stream

water quality."

Ph.D. Thesis,

Department

of Civil

and Environmental Engineering

,

Marquette

University,

Milwaukee, WI.

Alp, E. and Melching, C.S. (2006). Calibration of a model for simulation of water quality during

unsteady flow in the Chicago Waterway System and application to evaluate use attainability

analysis remedial actions.

Technical Report 18,

Institute of Urban Environmental Risk

Management, Marquette University, Milwaukee, WI.

Ambrose, R.B., Wool, T.A., Connolly, J.P., and Schanz, R.W. (1988). WASP4, a hydrodynamic

and water quality model-Model theory, User's manual, and programmer's guide. U.S.

Environmental Protection Agency,

EPA160013-87-039,

Athens, GA.

Di Toro, D. M. and Fitzpatrick, J. (1993).

Chesapeake Bay Sediment Flux Model.

HydroQual,

Inc.

Mahwah, NJ. Prepared for U.S. Army Engineer Waterway Experiment Station, Vicksburg,

MS. Contract Report EL-93-2.

DUFLOW (

2000

).

DUFLOWfor

Windows V3

.

3: DUFLOW modelling studio: User's guide,

reference guide DUFLOW, and reference guide RAM,

EDS/STOWA, Utrecht, The Netherlands.

26

---

Harremoes, P., Napstjert, L., Rye, C., and Larsen, H.O. (1996). "Impact of rain runoff on oxygen

in an urban river."

Water Science and Technology,

34(12), 41-48.

hnan, R.L., Helton, J.C., and Campbell, J.E. (1981). "An approach to sensitivity analysis of

computer

models: Part I-Introduction, input variable selection and preliminary variable

assessment."

Journal of Quality Technology,

13(3), 174-183.

Janssen

,

P.H.M., Heuberger, P.S.C., and Sanders

,

R. (1992

)

UNCSAM 1.1: a Software

Package

for Sensitivity

and Uncertainty Analysis.

Report No. 959101004

.

National Institute of Public

Health and Environmental Protection

,

Bilthoven

,

The Netherlands.

Manache, G. and Melching, C.S. (2004). "Sensitivity analysis of a water-quality model using

Latin hypercube sampling."

Journal of Water Resources Planning and Management,

130(3),

232-242.

Manache, G. (2001). "Sensitivity of a continuous water-quality simulation model to uncertain

input parameters."

Ph.D. Thesis,

Chair of Hydrology and Hydraulics, Vrije Universiteit Brussel,

Brussels, Belgium.

McKay, M.D., Beckman, R.J., and Conover W.J. (1979). "A comparison of three methods for

selecting

values of input variables in the analysis of output from a computer code."

Technometrics,

21(2), 239-245.

27

---

McKay,

M.D. (1988

). "

Sensitivity and uncertainty analysis using a statistical sample of input

values." in

Uncertainty Analysis, Y.

Ronen, ed., CRC, Boca Raton, FL, p.145-186.

Mukhtasor, Husain, T., Veitch, B., and Bose, N. (2004). "An ecological risk assessment

methodology for screening discharge alternatives of produced water."

Human and Ecological

Risk Assessment,

10(3), 505-524.

Neugebauer, A. and Melching, C.S. (2005). "Verification of a continuous water quality model

under uncertain storm loads in the Chicago Waterway System."

Technical Report 17,

Institute of

Urban Environmental Risk Management, Marquette University, Milwaukee, WI.

Novotny, V.

and Olem

,

H. (1994).

Water Quality: Prevention

,

Identification

,

and Management

of Diffuse

Pollution,

Van Nostrand Reinhold

,

New York.

Novotny, V., Braden, J., White, D., Capadaglio, A., Schonter, R., Larson, R., and Algozin, K.

(1995). "A comprehensive UAA Technical Reference."

Prof. 91-NPS-1,

Water Environment

Research Foundation, Alexandria, VA

Novotny, V. (2004). "

Simplified databased total maximum daily loads

,

or the world is log-

normal."

Journal of Environmental Engineering,

130(6), 674-683.

Sieber, A. and Uhlenbrook, S. (2005). "Sensitivity analyses of a distributed catchment model to

verify the model structure."

Journal of Hydrology,

310(1-4), 216-235.

28

---

Slack, J. and Nemura, A. (2000). "Evolving wet weather and water quality standards issues for

CSO communities."

WEFTEC 2000: Surface Water Quality and Ecology Symposium I: Wet

Weather CSO Issues,

Water Environment Federation 73rd Annual Conference & Exposition on

Water Quality and Wastewater Treatment, Anaheim, CA, October 14-18, 2000.

Sohrabi, T.M., Shirmohammadi, A., Chu, T.W., Montas, H., and Nejadhashemi, A.P. (2003).

"Uncertainty analysis of hydrologic and water quality predictions for a small watershed using

SWAT2000."

Environmental Forensics,

4(4), 229-238.

U.S Environmental Protection Agency (USEPA). (1983a).

Water Quality Standards Handbook,

Office of Water Regulations

and Standards

, Washington, D.C.

U.S. Environmental Protection Agency (USEPA). (1983b).

Results of the Nationwide Urban

Runoff Program.

Vol.

I.

Final Report, Water Planning Division,

U.S EPA, Washington, D.C.

Vandenberghe, V., van Griensven, A., Bauwens, W., and Vanrolleghem, P.A. (2005).

"Propagation of uncertainty in diffuse pollution into water quality predictions: Application to the

River Dender in Flanders, Belgium."

Water Science and Technology,

51(3-4), 347-354.

Westcott, N.E. (2003). "Continued Operation of a 25-Raingage Network for Collection,

Reduction, and Analysis of Precipitation Data for Lake Michigan Diversion Accounting: Water

Year 2002."

Illinois State

Water Survey Contract Report 2003-01,

35 p.

29

---

List of Figures:

Fig. 1. Schernatic diagram of the Calunnct and the Chicago River Systems (note: WRP means

Water Reclamation Plant and P.S means Pumping Station)

Fig. 2. Flow and duration of the storm effect on the standard deviation of simulated DO

concentration at Romeoville for July 12 to November 9, 2001

Fig. 3. Flow and duration of the storm effect on the standard deviation of simulated CBOD5 an

NH4-N

concentrations at Romeoville

for July 12 to November 9, 2001

].ig.

4.

Relation between precipitation and the duration of the storm effects on simulated DO,

CBOD

;,

and N1-14-N

concentrations at Romeoville for July 12

-

November 9, 2001 and May 1-

September 23, 2002.

30

---

4

Cook County

North S

0

WR

Upper

North

Branch

- __

1$

Dupage County

Wilmette

U

per North Shore Channel

-------------

Lo

North

Lower

North Branch

Stickney W.

1

-^I^

a^,d

gr

.q

Lemont WRP

Romeoville

o

Lockport

the Calu

6

Will County

Li.

iver at

South Holland

&

Boundaries

Counties

Chicago Waterway

T Model CSO Locations

_a Major

Inflows

Figure 1. Schematic diagram of the Calumet and the Chicago River Systems (note: WRP means

Water Reclamation Plant and P.S means Pumping Station)

00

------------

r North Shore Channel

F

ranch P.S

cago River Main Stem

- Columbus Drive

th Branch Chicago

R.

er

S

"Line

ve.

.

Calumet-Sag Channel

.- r -A-,

alumet

VVRP;25th

LAKE MICHIGAN

S

rien Lock4and Dam

31

---

of o m

w

W -

A N G

N

Hate

Figure 2. Flow and duration of the storm effect on the standard deviation of simulated DO

concentration at Romeoville for July 12 to November 9, 2001

32

---

0.30

0.25

Z

v

= 0.20

Z

0

A 0.15

m

0

0.10

a

N 0.05

0.00

-NH4-NSTD - Romeovilledailyflow

V_ OD OD O O t0 tD tD aD

ao

N V1

w

N

^

N

m

QI

A N

N W

o

Date

S7

H

O O O

W

rn A

N --^ t0

500

3

0

LL

300

Figure 3. Flow and duration of the storm effect on the standard deviation of simulated CBOD5

and NH4-N concentrations at Romeoville for July 12 to November 9, 2001

33

---

18

16

14

12

10

8

10 20

30 40 50 60 70 80 90

20

30

40

50

60

70

80

90

Precipitation

(

mm) - Waterway average

Figure 4. Relation between precipitation and the duration of the storm effects on simulated DO,

CBOD5, and NH4-N concentrations at Romeoville for July 12-November 9, 2001 and May 1-

September 23, 2002.

16

14

12

10

8

6

4

2

Romeoville

(

Chicago Sanitary and Ship Canal)

y = 0.159x + 2.6273

R' = 0.8506

Precipitation

(

mm) - Waterway average

Romeoville (Chicago Sanitary and Ship Canal)

Y

10

20

30

40

50

60

70

80

90

Precipitation (mm) - Waterway

average

Romeoville

(

Chicago Sanitary and Ship Canal)

34

---

"fable 1. Comparisons of the percentage DO concentrations less than 3, 4, 5, and 6 ing/1, at

different locations in the Chicago Waterway System fOr July 12-November 9, 2001

Percent

of DO (

Measured and Calibrated

)

less than

3 mg/L

< 4mg/L

< 5 mg/L

< 6 mg/L

Location

Waterway

Meas.*

Sint.**

Meas.

Sim.

Meas.

Sim.

Meas. Sim.

Fullerton Avenue

NBCR

6.3

3.9

20.1

14

49.6

46.5

63.2

77

Cicero Avenue

CSSC

21.1

20.5

483

48.8

77

62.3

86.1

75O

Baltimore and

CSSC

2.5

2.6

93

193

34.6

48.3

65.2

70

Ohio Railroad

Romeoville

CSSC

17.2

17.9

40.8

37.3

77

61.1

87.3

74.6

Ked%]c Street

Cal-Sag

1.1

0

4.7

3.9

15.6

15.1

38.9

51.1

104111 Avenue

Cal-Sag

8.4

8.3

13.6

17

29.1

36.8

55.2

56.5

'Meas.: Measured ; **

S i111.:

S lmll

lated

35

---

Table 2. The mean values and variances used for the Latin Hypercube Sampling of the event

mean concentrations in milligrams per liter for pumping stations discharging to the Chicago

Waterway System

North Branch

Pumping S.

Racine avenue

125th Steet

Pumping S.**

Pumping S.

Variable

Mean Var.* Mean

Var.

Mean

Var.

DO

4.0

3.6

6.9

8.1

4.3

0.0001

CBOD5

35.4

303.2

51.2

341.8

25.7

262.0

NH4-N

2.9

2.0 1.6

0,7

1.0

0.2

NO3-N

0.7

0.1

0.8

0.04

1.8

0.1

Norg-N

6.1

11.6

4.1

0.9

3.6

1.0

qg

1.0

0.5

0.2

0.003

0.4

0.049

Pin

0.4

0.3

0.7

0.040

1.3

3.1

SS

102

4554

825 241360 76

1634

`Var.: VarMll1Cc, *

*S.: Station

36

---

Table 3. Magnitude of Combined Sewer Overflow (CSO) volume in m3/s and the duration of

storm effect on the simulated dissolved oxygen concentration in days at different locations in the

Chicago Waterway System for July 12-November 9, 2001.

Event

1

2

3

4

S

6

7

Date-2001

7/25

8/2 & 8/9

8/25 & 8/31

9/19-9/23

1015

10/13

10/23

Total Pump S

.

CSO

39.52

6.52

13.36

5.44

1.77

8.60

2.81

Total

Gravity CSO

25.67

11.87

8.70

9.81

2.36

12.82

1.18

Chicago River System *

Romeoville

Baltimore and Ohio Railroad

Cicero Avenue

Fullerton Avenue

Duration of storm effect on dissolved oxygen concentration in days

8.6

15.5

15.1

10.9

7.8

10.6

7.0

93

14.2

13.3

10.3

7.5

9.6

6.3

9.2

14.7

15.8

10.2

8.0

9.5

7.7

5.5

18.2

12.8

9.0

5.2

5.8

3.8

Calumet River System

Duration of storm effect on dissolved oxygen concentration in days

Route 83

7.5

10.5

15.6

11.1

6.5

9.7

2.5

Division Street

6.6

12.9

15.7

10.5

6.4

3.7

1.5

Halsted Street

8.0

13.6

15.4

10.4

7.3

11.1

1.5

Conrail Railroad

8.1

7.8

10.7

10.0

7.2

10.8

ND***

*

Chicago River System:

Chicago Sanitary and Ship Canal, South Branch Chicago River, and North Branch Chicago

River

** Calumet River System:

Calumet-Sag Channel and Little Calumet River (North)

*** ND= The duration of the storm effect on DO concentration cannot be detected since variations in simulated DO

concentrations are negligible

37

---

Table 4. The duration of storm effect

on the simulated

CBOD5

concentration

in days at different

locations in the Chicago Waterway System for July 12-November 9, 2001

Event

1

2

3

4

5

6

7

Date-2001

7/25

8/2 & 8/9

8/25 & 8/31

9/19-9/23

1015

10/13

10/23

Chicaco River System *

Duration of storm effect on CBOD5 concentration in days

Romeoville

8.5

13.8

12.7

11.1

7.0

8.8

8.0

Baltimore and Ohio Railroad

9.3

13.7

12.7

10.5

7.3

7.3

7.3

Cicero Avenue

8.8

12.7

13.4

10.2

7.3

7.2

7.3

Fullerton Avenue

3.6

5.9

6.2

4.0

3.5

3.3

1.2

Calumet River System **

Duration of storm effect on CBOD5 concentration in days

Route 83

7.0

9.3

11.9

10.3

5.8

10.5

4.4

Division Street

5.3

8.8

8.2

7.1

5.7

3.8

3.5

Halsted Street

1.2

1.8

2.9

4.5

0.8

1.8

0.7

Conrail Railroad

4.8

6.9

8.8

8.0

3.7

9.1

3.0

* Chicago River System:

Chicago Sanitary and Ship Canal, South Branch Chicago River, and North Branch Chicago

River

** Calumet River System:

Calumet-Sag Channel and Little Calumet River (North)

38

---

Table 5. The duration of storm effect on the simulated NH4-N concentration at different locations

in the Chicago Waterway System for July 12-November 9, 2001

Evertt

Date-2001

Ch is (go 12i ve)- Svsreni

Romeoville

Baltimore and Ohio Railroad

Cicero Avenue

Fullerton Avenue

Calumet River System"

Routc 83

1]tvlsloii Street

Ilalsted

Street

Ccmrail Railroad

12

3

4567

7125

912 & 819

9125 & 9131

911 L]-9/23

10/5

10113

10123

Duration of storm effect on NH4-N concentration in days

8.5

12.8

13.8

10.6

7.1

9.0

6.7

6.7

7.4

10.7

9.0

6.2

62

5.1

5.7

6.9

9.8

8.5

5.0

5.7

4.5

3.6

5.1

6.2

3.5

3.6

3.3

1.7

Duration of storm effect on NH4

-

N concentration in days

5.0

7.5

10.0

9.5

5.2

5,1

3.5

4,9

6.2

8.4

5.8

4.0

3.7

3.7

5.2

7.7

9.8

8.7

4.5

9.7

2.7

5.0

7.4

9.6

6.3

.3

9.8

1.9

* Clliccrgo River

S)weiri:

Cliicago Sanitary and Ship Canal, South 13ranc11 Chicago River, and North Branch Chicago

River

** Calomel

River

Syslem: Calumct-Sag C:

liawiel

and Little Calumet River ^Norlh)

39

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

WATER QUALITY STANDARDS AND

EFFLUENT LIMITATIONS FOR THE

CHICAGO AREA WATERWAY SYSTEM

AND THE LOWER DES PLAINES RIVER:

PROPOSED AMENDMENTS TO 35 Ill.

Adm. Code Parts 301, 302, 303 and 304

R08-9

(Rulemaking

-

Water)

PRE-FILED TESTIMONY OF CHARLES S. MELCHING

INTRODUCTION

My name is Charles S. Melching and I am an Associate Professor of Civil and

Environmental Engineering at Marquette University in Milwaukee

,

Wisconsin

.

I hold a

Bachelor of Science degree from Arizona State University and Master of Science and Doctor of

Philosophy degrees from the University of Illinois at Urbana

-

Champaign

.

I am also a licensed

Professional Engineer in Illinois and Arizona.

I have more than 20 years of post

-

doctorate experience in the fields of water resources

and environmental engineering research

(

theoretical and applied

)

and education

.

I have been

awarded the 2001 Walter L. Huber Civil Engineering Research Prize from the American Society

of Civil Engineers and the 2008 Outstanding Researcher Award from the College of Engineering

at

Marquette University

.

My professional experience includes 2

.

5 years as a Visiting Scholar at

the Laboratory of Hydrology at the Vrije Universiteit Brussel in Belgium

;

2.5 years as an

Assistant Professor of Civil and Environmental Engineering at Rutgers University

;

7.5 years as a

Hydraulic Engineer

/

Hydrologist with the U

.

S.

Geological Survey, Illinois District

;

1

year as a

Visiting Professor in the Department of Hydraulic Engineering at Tsinghua University in

Beijing, China

;

and 9 years at Marquette University

.

Details of my work at these places are

given in my curriculum vitae

,

which is Attachment 2 to this testimony.

---

My experience in water-quality modeling began in 1990 at Rutgers University with an

uncertainty analysis of the QUAL2E model applied to the Passaic River. Other modeling

experience includes developing a QUAL2E model for Salt Creek in Illinois in cooperation with

the Illinois Environmental Protection Agency (IEPA); modeling of streams in Belgium;

modeling the Milwaukee Outer Harbor; and advising the U.S. Geological Survey North Dakota,

Kentucky, Minnesota, and Florida Districts on modeling projects. I also have a long history of

working on the Chicago Area Waterway System (CAWS) beginning in 1992 when I evaluated

the flow measurements at the acoustical velocity meter on the Chicago Sanitary and Ship Canal

at Romeoville. I then assisted U.S. Geological Survey colleagues on the measurement program

done in support of the U.S. Army Corps of Engineers Accounting of Lake Michigan Diversion.

This experience with the CAWS led to my selection as the Hydrologic and Hydraulic Modeling

Expert for the 5t" (2003) and 6th (2008) Technical Committees for the Review of the Lake

Michigan Diversion Accounting selected by the U.S. Army Corps of Engineers, Chicago

District.

This experience with water-quality modeling and the CAWS led to my selection by the

Metropolitan Water Reclamation District of Greater Chicago (District) to develop an unsteady

flow water-quality model of the CAWS (DUFLOW model) in 2000.

OVERVIEW

My opinions are set forth in greater detail in the report provided as Attachment 1 of this

testimony. The purpose of my testimony is threefold. First, my testimony describes the

DUFLOW model developed for the CAWS and its reliability. The model has been used to

evaluate water-quality management scenarios involving (a) supplemental aeration on the North

and South Branches of the Chicago River, (b) flow augmentation on the North Shore Channel,

and (c) a combination of these water-quality improvement technologies for the South Fork of the

South Branch (Bubbly Creek) as described in Attachments 00, PP, and QQ, respectively, of the

2

---

rulemaking proposal before the Board. The model also was used to determine the

ineffectiveness of pollutant removal at selected gravity combined sewer overflows (CSOs), to

consider supplemental aeration in the Chicago Sanitary and Ship Canal, and to evaluate the

effects of disinfection on fecal coliform concentrations in the CAWS (references are given in

Attachment 1). Finally, the model is currently being refined in order to develop an integrated

strategy combining flow augmentation, supplemental aeration, and perhaps other technologies to

achieve the proposed water-quality standards throughout the CAWS.

Second, my testimony describes unique and complex features of the hydraulics of the

CAWS determined by the modeling studies. A large amount of flow, water-surface elevation,

cross-sectional geometry, aeration, and pollutant load data have been collected for the CAWS by

the District, U.S. Geological Survey, and U.S. Army Corps of Engineers. The model integrates

and interprets these data on the basis of hydraulic theory and well accepted pollutant transport

and transformation concepts, and as such the model can facilitate understanding of the

fundamental operations and flow and pollutant patterns in the CAWS. Third, implications of the

unique and complex hydraulic features of the CAWS are integrated with the results of the

determination of biological potential reported in the Use Attainability Analysis (Attachment B of

the rulemaking proposal before the Board) to discuss reasonable aquatic life use goals for the

CAWS. The second and third issues are the focus of this oral testimony.

HYDRAULICS OF THE CAWS

The following testimony will try to illustrate some key hydraulic features of the CAWS

that influence the biological potential of the CAWS. IEPA indicated on pages 19-20 in its

Statement of Reasons that: "Flow reversal projects, such as this one, place a premium on head

differential.

The entire system has minimum slope and, consequently, low velocity, stagnant

flow conditions." The evaluation of flow and water-surface elevation data used to apply the

3

---

DUFLOW

model and the hydraulic results of the modeling reveal just how stagnant

the CAWS

is and the potential limitations to the current and future biological community.

Flow reversals

It is well known that large storms can result

i

n flow reversals

from the CAWS to Lake

Michigan

.

The flow

need not result in a reversal to Lake Michigan to have a flow reversal

within

the CAWS.

Because the water-surface slope of the

CAWS

is so small and the flow from

the North Side

,

Stickney

,

and Calumet Water Reclamation Plants is substantially higher than the

flow upstream of these Plants, flow reversals also are common during dry weather flows

upstream of the Plants

.

Figures 4-6 in Attachment 1 show that for each of the Plants, the water-

surface elevations

"

upstream

"

of the Plants frequently are lower than those

"

downstream" of the

Plants.

Thus

,

the outfall of each of the Plants acts as a hydraulic dam inserting treated effluent to

the upstream reaches and then holding it and upstream flows back to truly stagnate in the

upstream reaches. This backflow explains why the upper

North

Shore Channel remains ice free

for many miles north of the North Side Plant.

The bi-

directional flow gives us some impression

of the

unnatural condition

of the CAWS.

Slow travel times

The DUFLOW

model was used to determine average travel times

in the CAWS. Table 2

in Attachment 1 lists the average travel times

,

lengths, and average velocities for several reaches

in the CAWS for the July 12

to September 15, 2001 simulation period

.

The hydraulic dam

upstream from the Stickney Plant is obvious as it takes 2.5 days to go 8 miles from Madison

Street to

Cicero Avenue. The hydraulic

dam upstream from the Calumet Plant also is obvious as

it takes 1.5 days to go 2.3 miles from Indiana

Avenue

to Halsted Street.

Huge travel times and low flow velocities also are apparent upstream from the junction of

the Chicago Sanitary and Ship Canal and the Calumet

-

Sag Channel

.

This is because

when the

4

---

Chicago Sanitary and Ship

Canal

was originally constructed the Calumet

-

Sag Channel was not

anticipated and the Chicago Sanitary and Ship Canal cross

-

sectional geometry is the same

upstream and downstream from Sag Junction

.

Thus, Sag Junction acts like two lanes narrowing

to one lane on the freeway

with

large backups and long travel times resulting. In total it takes

more than 8 days for water to travel from the upstream ends of

the North

Shore Channel and

Little Calumet River

(

north

)

to Romeoville on the Chicago Sanitary and Ship

Canal. For

perspective

,

we should remember that 5-day biochemical oxygen demand

(

BOD) was originally

taken as the standard measurement because the test was devised in England

,

where the River

Thames has a travel time to the ocean of less than 5 days, so there was no need to consider

oxygen demand at longer times

.

The long travel time gives

us further

impression of the

unnatural condition

of the CAWS. This

feature of the

CAWS contributes

to the lower dissolved

oxygen that is observed

in CAWS

compared to general use rivers because of the reduced natural

reaeration resulting from low velocity and very low slope. Further, this feature

of the CAWS

makes it challenging and costly to disperse dissolved oxygen that is contributed artificially from

engineered aeration stations.

Wet weather effects

IEPA

appears to assume that the duration of storm effects on water quality lasts only as

long as the causative rainfall, or the period of elevated flow rates

.

However, research on the

CAWS

shows that the effect of storm runoff and CSOs on water quality lasts substantially longer

than the hydraulic

effects of

the storm

.

That is, once a load of pollutants is introduced to the

system

,

it takes longer for the system to dissipate the effects of these loads than it does to pass

the high flows.

Merely considering the time for dissolved oxygen (DO) recovery to pre

-

storm levels does

not indicate the end of the storm effect because the new dry weather DO concentration

may have

5

---

changed because of changes in temperature, sediment oxygen demand, treatment plant loads, etc.

Dr. Emre Alp proposed and tested (on the CAWS) a method to determine the duration storm

effects on water quality. In his approach, the DUFLOW water-quality model was successively

applied with different storm 5-day carbonaceous BOD and ammonium as nitrogen loadings (i.e.

Event Mean Concentrations) randomly sampled from a probability distribution representative of

the Event Mean Concentration data collected by the District at the CSO pump stations using an

uncertainty analysis technique. Then the variations in the DUFLOW model output parameters

among the successive simulations were observed. When the variation in the model output

parameters approaches zero, it means the river system has returned to the pre-storm (dry

weather) condition. Therefore, the duration between the start and the end of the variations in the

simulated DUFLOW model output parameters can be defined as the duration of the storm effect

on in-stream water quality, or the duration of the wet-weather condition. A paper summarizing

this approach was recently accepted for publication in the Journal of Water Resources Planning

and Management, American Society of Civil Engineers validating the approach and the

DUFLOW model of the CAWS through peer review.

Substantial impact of storm loading on DO concentration in the CAWS on average lasts

one day to a few weeks depending on the location in the CAWS (see Exhibit 1, which is Table 3

in Attachment 1). The storm effect on five-day carbonaceous BOD (CBOD5) and ammonium as

nitrogen (NH4-N) lasts from 2 days to 2 weeks depending on the storm and the location (see

Exhibits 2 and 3, which are Tables 4 and 5 in Attachment 1), In general, the duration of the storm

effect on CBOD5 and NH4-N concentrations along the Chicago River System (North Branch

Chicago River-South Branch Chicago River-Chicago Sanitary and Ship Canal) lasts 3-4 days

longer than on the Calumet River System (Little Calumet River (north)-Calumet-Sag Channel).

6

---

The key point to be derived from Exhibits 1-3 (i.e. Tables 3-5 in Attachment 1) is that

even at upstream locations the CSO loadings can affect water quality for more than a week for

some storms. This long storm effect is related to the hydraulic dams and other stagnant

conditions in the CAWS. Further the long storm effects can negatively impact the aquatic

community, and these long storm effects cannot be reduced until the reservoirs of the Tunnel and

Reservoir Plan are fully on line. Exhibit 4 (Table 6 in Attachment 1) lists the duration of storm

effects on DO, CBOD5, and NH4-N averaged over all locations in Exhibits 1-3 and compares this

with the duration of elevated flows (i.e. greater than 100 m3/s, 3,530 ft3/s) at Romeoville for all

the single storm events in simulated periods of 2001 and 2002. The comparison shows that the

duration of storm effects on water quality can be up to 4 times longer than the duration of

elevated flows at Romeoville. Thus, the effects of storm flows on the ability to meet water

quality standards should not be considered a trivial or insignificant problem for the CAWS. The

long effects of storm flows on water quality also indicate that it may be appropriate to consider

wet weather standards for the CAWS.

In summary, the following hydraulic features of the CAWS distinguish it from natural

systems. The normal flow in the CAWS is bidirectional in places and very slow everywhere, and

as a result wet weather impacts can linger for long periods suggesting that wet weather standards

may be appropriate for the CAWS. Further, the combination of low velocities and very low

slope limits natural reaeration and challenges the effectiveness of supplemental aeration due to

the slow distribution throughout the water body of the artificially introduced oxygen. This

challenge will become greater as DO standards are raised.

RELATIONSHIPS BETWEEN HYDRAULIC AND ECOLOGICAL CONDITIONS

The CAWS effectively is a long, narrow, moderately deep impoundment not at all similar

to natural streams, Even dam impoundments on formerly natural streams have variation in

7

---

habitat and substrate including shelter areas for fish, whereas these features are generally absent

from the CAWS.

Habitat

(QHEI)

and biological

„

(IBI) scorinjZ

Rankin (1989) examined relations between the Qualitative Habitat Evaluation Index

(QHEI) and the Index of Biological Integrity (IBI) in order to develop a procedure for relating

stream potential to habitat quality that would provide some insight into how habitat might affect

biological expectations in a given water body. The goal of his study was to provide guidance on

the specification of aquatic life uses (i.e. potential aquatic ecological community) for water

bodies that were impaired by pollution impacts. To develop the relations between QHEI and its

subcomponent metrics and life uses Rankin (1989) considered data from a large number and

wide variety of streams in Ohio. This procedure was used by Rankin (2004) [Attachment R to

the proposal before the Board] to estimate life uses of Modified Warmwater Habitat and Limited

Resource Water for the reaches designated Aquatic Life Use A and B water, respectively, in the

proposal before the Board.

The IEPA states that where QHEI is "higher" and IBI is "lower" this indicates that

improvement in water quality is needed to achieve the ecological potential of the "higher"

QHEI.' Rankin (1989, p. 12) noted that "using the QHEI as a site-specific predictor of IBI can

vary widely depending on the predominant character of the habitat of the reach." He also

presented examples that showed that a QHEI of 50 could result in a low or a very high IBI.

Thus, whether the higher QHEI scores found in select portions of the CAWS are truly indicative

of a higher potential ecological community for the CAWS requires further consideration.

April 23, 2008

Hearing, transcript at pp

. 211-216.

8

---

Effect of p

oor habitat on biolo

One way to determine whether a higher QHEI score truly indicates higher biological

potential is to consider in detail the nature of the key habitat metrics included in the QHEI.

Rankin (1989, p.13) noted "Analysis of the frequency of occurrence of QHEI metric

subcomponents among IBI ranges indicates that "negative" habitat characteristics generally (but

not universally) contribute more to the explanation of deviations from a random distribution with

IBI range than "positive" habitat characteristics." The key metric subcomponents are substrate

quality, pool quality, and channel quality.

Poor habitat

in the CAWS

Rankin (1989, p. 24) noted "The influence of high quality substrates is probably related

to their importance in providing food organisms (macroinvertebrates) to the insectivores and

benthivores that typify midwest streams." Insectivores and benthivores are different groupings of

fish based on the preferred diet of the fish.

The Macroinvertebrate data on the CAWS reported in CDM (2007) [Attachment B of the

proposal before the Board] clearly illustrates the poor quality of the substrate present in the

CAWS. For 17 of the 18 locations sampled with a petite ponar dredge the Macroinvertebrate

Biotic Index (MBI) indicated very poor water-quality whereas at 16 locations where Hester

Dendy samplers were used the MBI indicated that the water quality was fair or good.. Hester

Dendy samplers are plates placed in the water that provide an artificial substrate which can be

colonized by macroinvertebrates. The grab sample reflects conditions in the sediment at a site

whereas the artificial substrate shows/predicts the potential benthic community in the drift that

will settle on the plate. The difference in the sampler results shows that CAWS substrate will

prevent any further improvements in water quality from translating to a better macroinvertebrate

community and will not likely result in improvements in aquatic life use. The fact that the

9

---

CAWS has a poor substrate is no surprise, because the system is completely human created,

rather than a natural system that was allowed to geologically develop over thousands of years

and, thus, develop appropriately varied substrates. Additional details on what constitutes a

balanced, healthy benthic community and its preferred substrate conditions are presented in the

fact witness testimony of Jennifer Wasik of the District.

With respect to pool quality, Rankin (1989, p. 24) noted sites with fast currents had

higher IBI scores than expected by chance. As noted in Table 2 in Attachment I the average

flow velocity is less than 1 ft/s and for more than 60 percent of the CAWS the average velocity is

less than 0.4 ft/s. These velocities are very low compared to the reach average velocities for the

234 measurements in the U.S. Geological Survey roughness coefficient database for Illinois

(hlip-..//il.water.usgs.gov/proi/i^values/) where only one measurement was less than 0.4 ft/s and

more than 87 percent of the measurements had velocities greater than or equal to 1 ft/s.

With respect to channel quality, Rankin (1989, p. 25 and 29) noted

a)

streams with little or no sinuosity were associated with lower IBI scores,

b) sites with only fair to poor riffle/pool development generally have lower IBI scores and

sites with excellent to good development have higher IBI scores, and

c) lower gradients are generally, but not universally, associated with lower IBI values and

higher gradient scores with higher IBI values.

The CAWS falls at the lower extreme of all these factors.

Rankin (1989, p. 41) listed the key features that result in a stream to be classified as a

Modified Warmwater Stream (the analogue of Warmwater Aquatic Life Use A) noting that

streams with QHEI scores between 45 and 60 should have several of the primary factors to be

considered a Modified Warmwater Stream. Exhibit 5 (Table 7 in Attachment 1) lists the habitat

10

---

features that distinguish between Modified Warmwater Streams and Warmwater Streams (i.e. the

analogue of General Use waters). Among these primary features for Modified Warmwater

Streams the CAWS has recent channelization (truly permanent channelization), silt/muck

substrates (in many reaches), low-no sinuosity, cover sparse to none (in many reaches), poor

pool and riffle development, and lack of fast current. Thus, there can be no doubt that the

potential ecological community is degraded by habitat impairment in the CAWS. Also, this

analysis indicates that the Calumet-Sag Channel is more of a poor habitat (Warmwater Aquatic

Life Use B) than a fair habitat (Warmwater Aquatic Life Use A). In March 10, 2008, IEPA

testimony it was stated that the Calumet-Sag Channel is different from the Chicago Sanitary and

Ship Cana1.2

While they are different, they are not substantially different. For example,

threadbare tires are different from tires with an eighth of an inch of tread, but both are dangerous

to drive on.

The ecological community in the CAWS is substantially impaired by poor habitat, as

IEPA acknowledged during its testimony.3 The U.S. Environmental Protection Agency (U.S.

EPA) has established a DO criterion of 3.0 mg/L for full attainment of warmwater life uses.

IEPA indicated that it does not expect Aquatic Life Use A waters to meet the Clean Water Act

goals, but is here proposing that both A and B waters achieve DO levels of at least 3.5 mg/L----

even higher than would be required by U.S. EPA.4 Further, IEPA has proposed a DO standard

for Aquatic Life Use A of 5.0 mg/L for March through July to support early life stages, with no

evidence that the habitat and physical characteristics of the CAWS could support such a use or

attain the proposed criterion. Essentially, the rulemaking proposal before the Board is requiring

2

March 10, 2008 Hearing, transcript (morning) at pp. 31-32.

3 January 28, 2008 Hearing, transcript at p. 220; January 29, 2008 Hearing, transcript at p. 104; March 10, 2008

Hearing, transcript (morning) at p. 33.

4

March 10, 2008 Hearing, transcript (morning) at p. 28.

11

---

that the degraded CAWS meet in certain critical aspects the General Use standards in role R04-

25 that was recently adopted by the Board. A tabular comparison of the rulemaking proposal

before the Board and the General Use standards is included in the expert testimony of Freedman.

Alternative

approaches to DO criteria

In the State of Ohio the DO criteria for Modified Warmwater Streams (the equivalent of

Warmwater Aquatic Life Use A) is a daily minimum of 3.0 mg/L and a daily average of 4.0

mg/L, and the minimum reduces to 2.5 mg/L in the Huron/Eric Lake Plain Ecoregion (Ohio rule

3745-1-07).

Whereas for Limited Resources Waters (the equivalent of Warmwater Aquatic Life

Use B) the criterion for the daily minimum is 2.0 mg/L with a daily average of 3.0 mg/L (Ohio

rule 3745-1-07). Similarly, Novotny et al. (2007) [Attachment WW of the proposal before the

Board] recommended a daily minimum of 3.0 mg/L and a daily mean of 4.0 mg/L for Brandon

Pool, which has been designated Warmwater Aquatic Life Use B.

In the IEPA testimony on April 24, 2008, the partial justification for the selected DO

criteria was the target fish species largemouth bass, smallmouth bass, and channel catfish, whose

protection is sought by the target DO criteria with smallmouth bass and channel catfish as the

targets for the early life stages protection.5

Mr. Roy Smogor characterized channel catfish and

smallmouth bass protection as follows: "For early life stages that are as sensitive as the early life

stages of channel catfish or smallmouth bass, we need to keep the dissolved oxygen levels above

a daily minimum of five in order to protect for those types of early life stages." 6. Consideration

should then be given to whether the CAWS offers suitable habitat for early life stages of these

fish species.

5

March 10, 2008 Hearing, transcript (morning

)

at pp

. 70-71; April 24,

2008 Hearing, transcript at pp, 98-99.

G

April 24, 2008

Hearing, transcript at p. 99,

12

---

Alternative

analysis

of CAWS

habitat

In the early 1980s, the Fish and Wildlife Service of the U.S. Department of the Interior

did detailed literature reviews seeking to identify the physical and chemical conditions of water

bodies suitable for various fish species. These models are known as Habitat Suitability Indexes

(HSIs), where a value of 1 indicates optimal habitat and 0 indicates unsuitable habitat. These

models are not perfect predictors, and in each report for the species of interest here a statement

appears indicating the species of interest may be present even if the suitability index is 0, and

habitat with a high suitability index may contain few fish. The Fish and Wildlife Service

recommends that the suitability indices should be compared with fish data for the water body of

interest before interpreting the suitability results.

HSI ratings have been developed for each of

the target fish species for the CAWS.

The summary of the Habitat Suitability evaluation detailed in Attachment 1 indicates the

CAWS is poor habitat for adult smallmouth bass and channel catfish, which is consistent with

the low abundance of these fish in the CAWS (see fish relative abundance data in the UAA

report, Attachment B to the rulemaking proposal before the Board). It is, however, near optimal

habitat for adult largemouth bass, which is consistent with the high abundance of this fish in the

CAWS (see fish abundance data in the UAA report, Attachment B to the rulemaking proposal

before the Board). Further, the high abundance of largemouth bass implies that the current water

quality of the CAWS is sufficient for a healthy largemouth bass community and higher standards

are not needed. However, the CAWS is poor habitat for early life stages of all these target fish

species.

The tributaries of the CAWS might have suitable habitat for early life stages of the target

fish species.

However, District fish sampling data from 1995, 1997, and 2001-2005 indicate that

none of these species were found in the lower reaches of the North Branch Chicago River

13

---

upstream from the junction with the North Shore Channel. Further, District fish sampling data

from 2001-2005 indicate that none of these species were found in the Little Calumet River

(south).

Finally, District fish sampling data from 2001-2005 indicate largemouth and

smallmouth bass are the third and fourth, respectively, most abundant species in the Calumet

River upstream from O'Brien Lock and Dam. Thus, it seems these fish enter the CAWS from

Lake Michigan not the CAWS tributaries. Thus, seeking to protect early life stages for these

species of fish in the CAWS is inconsistent with the habitat suitability and the available fish

abundance data.

CONCLUSIONS

When summarizing the relation between habitat, fish communities, and water-quality

management Rankin (1989, p. 52) offered the following warning:

It

makes little sense to "protect" the biota by multimillion dollar

improvements to a point source discharge while important

biological uses are impaired by habitat modifications for reasons

such as "flood control", construction activities, and waterway

improvements.

Considering the foregoing discussion of habitat

,

the rulemaking proposal before the

Board is contrary to the findings

of the UAA

contractors. For example

,

CDM indicated that

"The data showed that the aquatic habitats were rated from

very

poor to fair with most reaches

having habitat unable to support a diverse aquatic community

." 7

CDM

also stated,

"Improvements to water quality through various technologies, like re-aeration may not improve

the fish communities due to the lack of suitable habitat to support the fish population

."&

Further,

Novotny recommended the previously described lower DO standards

(

relative to the proposal

7

CDM (2007) [Attachment

B to proposed rule R08-91

,

page 1-12.

S

CDM (2007) [

Attachment B to proposed rule R08-91 page 5-3,

14

---

before the Board) for the Warmwater Aquatic Life Use B waters in the Brandon Pool of a daily

minimum of 3.0 mg/L and a daily mean of 4.0 mg/L.9

I

hope that the Illinois Pollution Control Board will carefully consider this testimony and

other supporting documents, and should not hastily approve the rulemaking proposal before the

Board, when the State of Illinois and the Chicago Area have many other problems requiring

public financing.

9

Novotny et al. (2007) [Attachment WW to proposed rule R08-9].

15

---

Respectfully

submitted,

CL

4&"^,

7dAA^

,

By:

Charles S. Melching

---

Testimony

Attachments

T.

Supporting Report for the Pre-Filed Testimony of Charles S. Melching with Respect

to Proposed Rule R08-9

2.

Curriculum Vitae

16

---

Exhibit 1-Melching Testimony

Table 3. Magnitude of Combined Sewer Overflow (CSO) volume in m3/s and the duration of

storm effect on the simulated dissolved oxygen concentration in days in the Chicago Area

Waterway System for July 12-November 9, 2001. (after Alp, 2006)

Event

1

2

3

4

5

6

7

9/19-

Date-2001

7/25

8/2 & 819

8125

& 8/31

1015

10113

10123

9/23

Total CSO

65.19

18.39

22.06

15.25

4.13

21.43

3.99

Total Pump

S. CSO

39.52

6.52

13.36

5.44

1.77

8.60

2.81

Total Gravity CSO

25.67

11.87

8.70

9.81

2.36

12.82

1.18

Chicago River System

Duration of storm effect on dissolved oxygen concentration in days

Romeoville

8.6

15.5

15.1

10.9

7.8

10.6

7.0

River Mile 11.6

8.6

14.0

13.9

10.8

7.5

10.3

6.3

Route 83

8.8

153

14.9

10.8

7.7

10.3

6.9

Baltimore and Ohio

Railroad

9.3

14.2

13.3

103

7.5

9.6

6.3

Cicero Avenue

9.2

14.7

15.8

10.2

8.0

9.5

7.7

Jackson Boulevard

9.4

16.6

15.5

9.0

6.8

10.9

4.3

Kinzie Street

8.2

17.5

13.5

8.3

6.1

7.3

4.4

Division Street

7.6

18.5

13.5

9.3

7.2

7.6

4.6

Fullerton Avenue

5.5

18.2

12.8

9.0

52

5.8

3.8

Addison

Street

2.0

14.6

12.8

8.8

1.2

3.3

2.1

Calumet River

Svstem * *

Duration of storm effect on dissolved oxygen concentration in days

Route 83

7.5

10.5

15.6

11.1

6.5

9.7

2.5

104th Street

7.9

14.0

13.3

10.9

7.2

10.8

2.3

Southwest Highway

8.1

13.4

16.9

10.6

6.2

11.2

2.0

Harlem Avenue

7.5

13.1

16.8

10.5

6.1

11.2

2.2

Cicero Avenue

7.4

14.5

16.2

10.3

7.0

11.1

2.1

Kedzie Avenue

6.9

14.3

15.9

9.9

6.4

10.9

2.0

Division Street

6.6

129

15.7

10.5

6.4

3.7

1.5

Halsted Street

8.0

13.6

15.4

10.4

7.3

11.1

1.5

Conrail Railroad

8.1

7.8

10.7

10.0

7.2

10.8

ND***

*

Chicago River System:

Chicago Sanitary and Ship Canal, South Branch Chicago River, and North Branch Chicago

River

** Calumet River System:

Calumet-Sag Channel and Little Calumet River (north)

*** ND= The duration of the storm effect on DO concentration cannot be detected since variations in simulated DO

concentrations are negligible

17

---

Exhibit 2-Melching Testimony

Table 4. Magnitude of Combined Sewer Overflow (CSO) volume in million gallons (MG) and

the duration of storm effect on the simulated five-day carbonaceous biochemical oxygen demand

(CBOD5) concentration in days in the Chicago Area Waterway System for July 12-November 9,

2001 (after Alp, 2006)

Event

1

2

3

4

5

6

7

Date-2001

7125

812 & 819

8/25 &

8131

9119-

9/23

1015

10/13

10123

Total

CSO Volume

1488

4859

5828

4029

1092

5660

1054

Total P

.S.

CSO

Volume

902

1723

3530

1437

468

2272

743

Total

Gravity CSO

Volume

586

3136

2298

2592

624

3388

311

Location

*

Chicago River Svstem

Duration of storm effect on CBODS concentration in days

Romeoville

8.5

13.8

12.7

11.1

7.0

8.8

8.0

River Mile 11.6

8.6

13.4

12.8

10.8

7.4

8.4

8.1

Route 83

8.8

14.5

13.0

10.8

7.3

8.2

7.8

Baltimore and Ohio

Railroad

93

13.7

12.7

10.5

7.3

7.3

7.3

Cicero Avenue

8.8

12.7

13.4

10.2

7.3

7.2

73

Jackson Boulevard

6.4

12.2

11.3

8.2

5.1

4.8

5.4

Kinzie Street

5.8

8.7

8.7

8.0

6.3

4.5

4.5

Division Street

5.3

8.8

8.2

7.1

5.7

3.8

3.5

Fullerton Avenue

3.6

5.9

6.2

4.0

3.5

3.3

1.2

Addison Street

2.8

5.0

4.7

3.4

2.3

3.3

2.1

Location

Calumet River

System

Duration of storm effect on

CBOD5

concentration in days

Route 83

7.0

9.3

11.9

10.3

5.8

10.5

4.4

1040' Street

6.0

8.0

10.8

9.5

5.9

9.8

3.2

Southwest Highway

5.3

7.5

10.5

9.0

4.8

9.5

3.1

Harlem Avenue

6.1

7.5

10.1

9.0

4.8

9.5

4.8

Cicero Avenue

4.9

7.0

9.9

8.6

7.3

8.8

3.5

Kedzie Avenue

4.2

6.8

8.8

7.7

7.2

8.3

2.1

Division Street

5.3

8,8

8.2

7.1

5.7

3.8

3.5

Halsted Street

1.2

1.8

2.9

4.5

0.8

1.8

0.7

Central and Wisconsin

Railroad

4.4

7.8

9.0

9.0

4.0

9.1

2.0

Conrail Railroad

4.8

6.9

8.8

8.0

3.7

9.1

3.0

* Chicago River System:

Chicago Sanitary and Ship Canal, South Branch Chicago River, and North Branch Chicago

River

** Calumet River System:

Calumet-Sag Channel and Little Calumet River (north)

18

---

Exhibit 3-Melching Testimony

Table 5. Magnitude of Combined Sewer Overflow (CSO) volume

in million gallons

(MG) and

the duration of storm effect on

the simulated ammonium as nitrogen

(NH4-N)

concentration in

days in Chicago Area Waterway System for July 12-November 9, 2001

(after

Alp, 2006)

Event

1

2

3

4

5

6

7

Date-2001

7125

812 &

819

8125 &

8131

9/19-

9123

1015

10113

10123

Total CSO

Volume

(MG)

1488

4859

5828

4029

1092

5660

1054

Total P

.S.

CSO

Volume(MG)

902

1723

3530

1437

468

2272

743

Total

Gravity CSO

Volume (MG)

586

3136

2298

2592

624

3388

311

Location

Chica o River System

*

Duration of storm effect on

NH

a

N concentration in da

y

s

Romeoville

8.5

12.8

13.8

10.6

7.1

9.0

6.7

River Mile 11.6

8.2

12.1

13.3

10.0

7.2

8.7

6.3

Route 83

7.4

6.9

11.7

9.5

7.0

7.0

5.6

Baltimore and Ohio

Railroad

6.7

7.4

10.7

9.0

6.2

6.2

5.1

Cicero Avenue

5.7

6.9

9.8

8.5

5.0

5.7

4.5

Jackson Boulevard

4.0

6.5

10.4

8.0

5.1

4.8

3.5

Kinzie Street

4.8

6.3

9.1

6.2

4.8

4.1

2.8

Division Street

4.9

6.2

8.4

5.8

4.0

3.7

3.7

Fullerton Avenue

3.6

5.1

6.2

3.5

3.6

3.3

1.7

Addison Street

3.0

3.9

5.9

3.5

2.1

2.2

0.6

Location

**

Calumet River System

Duration of storm effect on NH4

-

N concentration in days

Route 83

5.0

7.5

10.0

9.5

5.2

5.1.

3.5

104[4 Street

4.8

6.9

9.5

9.0

4.7

4.3

2.5

Southwest Highway

4.9

7.0

9.5

9.0

4.8

4.3

2.5

Harlem Avenue

4.9

7.1

9.6

9.0

4.7

4.3

2.6

Cicero Avenue

5.2

7.4

9.7

9.0

4.0

4.2

2.5