STATE OF ILLINOIS
BEFORE THE ILLINOIS POLLUTION CONTROL BOAxu
POLLUTION CONTROL BOARD
NEQEIVED
APR 281995
In the Matter of :
)
Petition of the Metropolitan Water
) R-
Reclamation District of Greater
)
(Site-Specific Rule-
Chicago for Site-Specific Water
Quality
Regulation :
) making) 35 Ill . Adm .
) Code 302, 303, 304
NOTICE OF FILING
TO :
Mr . Bruce Carlson
Division of Legal Counsel
Mr . William Denham
Illinois Environmental
Department of Energy and
Natural Resources
2200
Springfield,
Protection
Churchill
IL
AgencyRoad62794
Springfield,
325 West Adams
IL
Street62704
MrIllinois
Chicago,
100
.
West
William
Attorney
IL
Randolph
60601SeithGeneral
Street
Office
PLEASE TAKE NOTICE that I have today filed with the Of-
fice of the Clerk of the Pollution Control Board the
APPEARANCE of Michael Rosenberg, Attorney, of the Metropoli-
tan Water Reclamation District of Greater Chicago, a copy of
which is herewith served upon you .
April 28, 1995
Signature
Michael
AttorneyRosenberg
Metropolitan
District of
Water
Greater
ReclamationChicago
100
Chicago,
East Erie
Illinois
Street60611
(312)751-6565
[THIS FILING IS SUBMITTED ON RECYCLED PAPER]
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the
Notice and Appearance of Michael Rosenberg, Attorney for the
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO by
first class mail upon the following persons
:
Mr . Bruce Carlson
Illinois Environmental
Mr . William Denham
Protection Agency
Department of Energy and
2200 Churchill Road
Natural Resources
Springfield, IL 62794-9276
325 West Adams Street
Springfield, IL 62704
MrIllinois
. William
Attorney
Seith
General Office
Chicago,
100 West
IL
Randolph
60601
Street
Signature
Bernard
100
Metropolitan
District
East
SawyerErie
of
Water
StreetGreater
ReclamationChicago
Chicago,
(312)751-6565Illinois
60611
Subscribed and sworn before me this
I
V-
day of
1995 .
OFFICIAL SEAL
ROSALIE BOTTARI
NOTARY PUBLIC, STATE OF
ILLINOIS
MY COMMISSION
EXPIRES :04110/98
[THIS FILING IS SUBMITTED ON RECYCLED PAPER]
BEFORE THE ILLINOIS POLLUTION CONTROL BOAR
Signature
Michael Rosenberg
AttorneyMetropolitan
Water Reclamation
100
District
East Erie
of
StreetGreater
Chicago
Chicago,
(312)751-6565Illinois
60611
(THIS FILING IS SUBMITTED ON RECYCLED PAPER]
APR
to
1995
OLLUTIONECONTROLL BOARD
In the Matter of :
)
Reclamation
Petition of
District
the Metropolitan
of GreaterWater
) R-
~~ /T
Chicago
for Site-Specific Water
)
(Site-Specific Rule-
Quality
Regulation :
) making) 35 Ill . Adm .
) Code 302, 303, 304
APPEARANCE
I hereby, file my appearance in this proceeding, on
behalf of the Metropolitan Water Reclamation District of
Greater Chicago .
In
the Matter of :
)
Petition of the Metropolitan Water
) R-
Reclamation District of Greater
) (Site-Spe ific Rule-
Chicago for Site-Specific Water
)
making) 35 Ill . Adm .
Quality Regulation
:
) Code 302, 303, 304
NOTICE OF FILING
TO :
Mr . Bruce Carlson
Mr . William Denham
Division of Legal Counsel
Department of Energy and
Illinois Environmental
Natural Resources
2200
Protection
Churchill
AgencyRoad
Springfield,
325 West Adams
IL 62704Street
Springfield, IL 62794
MrIllinois
100
.
West
William
Attorney
Randolph
SeithStreetGeneral
office
Chicago, IL 60601
BEFORE THE ILLINOIS POLLUTION CONTROL BOARE
ReutiVED-
APR
2 R 1995
STATE OF ILLINOIS
POLLUTION CONTROL BOARD
PLEASE TAKE NOTICE that I have today filed with the of-
fice of the Clerk of the Pollution Control
FOR SITE-SPECIFIC RULEMAKING of the Metropolitan Water
Reclamation District of Greater Chicago, a copy of which is
herewith served upon you
.
Signature
April
Michael
28,
Rosenberg1995
AttorneyMetropolitan
District of
Water
Greater
ReclamationChicago
100 East Erie Street
Chicago,
(312)751-6565Illinois
60611
[THIS FILING IS SUBMITTED ON RECYCLED PAPER]
Board the PETITION
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the
Notice and Petition of the METROPOLITAN WATER RECLAMATION
DISTRICT OF GREATER CHICAGO for SITE-SPECIFIC RULEMAKING from
35 Iii . Adm
. Code 302, 303, 304 by first class mail on 7
;t~,,;,Qtr , 1y9/
at
,TL• HXp'; cupon the following persons
M
_
r . Bruce Carlson
Mr
. William Denham
Illinois Environmental
Department of Energy and
Protection Agency
Natural Resources
2200 Churchill Road
325 West Adams Street
Springfield, IL 62794-9276
Springfield, IL 62704
MrIllinois
100
.
West
William
Attorney
Randolph
SeithStreetGeneral
office
Chicago, IL 60601
Signature
Bernard
Metropolitan
District
Sawyerof
Water
Greater
ReclamationChicago
100
Chicago,
East Erie
Illinois
Street60611
(312)751-6565
Subscribed and sworn before me this
day of , 1995 .
N tary Public
[THIS FILING IS SUBMI
OFFICIAL SEAL
ROSALIE BOTTARI
NOTARY PUBLIC, STATE OF ILLINOIS
MY COMMISSION EXPIRES :04110/98
R
RD
STATE OF ILLINOIS
POLLUTION CONTROL BOARD
In the Matter of
:
)
Petition
Reclamation
of the
District
Metropolitan
of GreaterWater
) R- 5
) (Si a-Spe ific Rule-
Chicago for Site-Specific Water
) making) 35 Ill
. Adm .
Quality Regulation :
) Code 302, 303, 304
NOTICE OF FILING
TO :
Mr
. Bruce Carlson
Mr . William Denham
Division of Legal Counsel
Department of Energy and
Illinois Environmental
Natural Resources
Protection Agency 325 West Adams Street
2200 Churchill Road
Springfield, IL 62704
Springfield, IL 62794
MrIllinois
. William
Attorney
Seith
General office
100 West Randolph Street
Chicago, IL 60601
PLEASE TAKE NOTICE that I have today filed with the Of-
fice of the Clerk of the Pollution Control Board a Motion to
Waive the 200 Signature Petition Requirement, a copy of which
is herewith served upon you
.
BEFORE THE ILLINOIS POLLUTION CONTROL BO
Signature
April
Michael
28,
Rosenberg1995
AttorneyMetropolitan
District of
Water
Greater
ReclamationChicago
100
Chicago,
East
Illinois
Erie Street60611
(312)751-6565
[THIS FILING IS SUBMITTED ON RECYCLED PAPER]
KEGEIVED
APR 2 8 1995
PROOF OF SERVICE
I, the
undersigned, on oath state that I have
served a
Motion to Waive the 200
Signature Petition Requirement by
first class mail upon the following persons :
Mr
. Bruce Carlson
Illinois Environmental
Mr . William Denham
Protection Agency
Department of Energy and
2200 Churchill Road
Natural Resources
Springfield, IL 62794-9276
325 West Adams Street
Springfield, IL 62704
Mr . William Seith
Chicago,
Illinois
100 West
IL
Attorney
Randolph
60601
General
Street
office
day of
1995 .
Signature
Bernard Sawyer
Metropolitan Water Reclamation
100
District
East Erie
of
StreetGreater
Chicago
Chicago,
(312)751-6565Illinois
60611
Subscribed and sworn before me this
'i
° -. -
=, I
OFFICIAL SEAL
ROSALIE BOTTARI
TARP PUBLIC, STATE
UP ILUNOW
Notary Public
MV
COMMISSIONEXPINESs0440/6§
[THIS FILING IS SUBMITTED ON RECYCLED PAPER]
REGLNED
STATE OF ILLINOIS
POLLUTION CONTROL BOARD
APR
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
81995
In the Matter of :
)
Petition
Reclamation
of the
District
Metropolitan
of GreaterWater
)
R-
~J
Chicago
for Site-Specific Water
) (Site-Sp ific Rule-
Quality
Regulation :
) making) 35 Ill . Adm .
) Code 302, 303, 304
MOTION TO WAIVE THE 200 SIGNATURE PETITION REQUIREMENT
As provided under 35 Ill . Adm . Code 102 .103, the Dis-
trict hereby requests a waiver of the 200 signature petition
requirement for filing a rulemaking [Sections 102 .121(h) and
102 .160(a)] based upon the fact that the District is a public
agency, and the issues raised in this filing involve the pos-
sible expenditure of millions of dollars of taxpayer funds,
and are of obvious public importance .
Signature
Michael
Metropolitan
AttorneyRosenbergWater
Reclamation
100
District
East Erie
of
StreetGreater
Chicago
Chicago, IL 60611
[THIS FILING IS SUBMITTED ON RECYCLED PAPER]
BEFORE THE ILLINOIS POLLUTION CONTROL BO
In the Matter of :
)
Petition of the Metropolitan Water
) R-
Reclamation District of Greater
)
(Site-Specific Rule-
Chicago for Site-Specific Water
) making) 35 Ill
. Adm .
Quality Regulation :
) Code 302, 303, 304
PETITION FOR SITE-SPECIFIC RULEMAKING
The Metropolitan Water Reclamation District of Greater
Chicago (District), through its attorney, hereby files one
original and nine copies of this signed petition for site-
specific rulemaking in accordance with 35 Ill
. Adm . Code
102 .140
.
Respectfully submitted,
Michael
Metropolitan
AttorneyDistrict
Rosenbergof
Water
Greater
ReclamationChicago
Chicago,
100
(312)751-6565East
Illinois
Erie
60611
t 9
POLLUTION
RD
APR
STATE
CONTROL
OF
281995
ILLINOISBOARD
[THIS FILING IS SUBMITTED ON RECYCLED PAPER]
APR 2
STATE OF ILLINOIS
OLLUTION CONTROL BOARD
In
the Matter of :
)
Petition
Reclamation
of the
District
Metropolitan
of GreaterWater
)
R-
e
,
J
)
(Site-Specific Rule-
Chicago for Site-Specific Water
) making) 35 Ill
. Adm .
Quality Regulation
:
) Code 302, 303, 304
PETITION FOR SITE-SPECIFIC
AFFIDAVIT
RULEMAKING
I hereby verify, in accordance with 35 Ill
. Adm . Code
102
.140, that to the best of my knowledge all facts asserted
in the attached PETITION FOR SITE-SPECIFIC RULEMAKING are
true and correct .
By :
BEFORE THE ILLINOIS POLLUTION CONTROL BOA
Cecil Lue-Hing, D
.Sc ., P .E .
Director, Research and Development
Metropolitan
District of
Water
Greater
ReclamationChicago
Chicago,
100
(312)751-5190East
Illinois
Erie
60611
Notary Seal
SUBSCRIBED D SWORN TO BEFORE ME
this
O
-
day of A.J
1995
c
OFFICIAL SEAL
SALIE BOTTARI
NOTARY PUBLIC, STATE OF ILLINOIS
MY COMMISSION EXPIRES
: 04110/98
[THIS FILING IS SUBMITTED ON RECYCLED PAPER]
otary P
,
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
In the Matter of
:
)
Petition of the Metropolitan Water
) R-
Reclamation District of Greater
)
(Site-Specific Rule-
Chicago for Site-Specific Water
)
making) 35 Ill
. Adm .
Quality Regulation :
)
Code 302, 303, 304
Metropolitan
District of
Water
Greater
ReclamationChicago
100
Chicago,
East Erie
Illinois
Street60611
(312)751-6565
[THIS FILING IS SUBMITTED ON RECYCLED PAPER]
APR
d 1995
STATE OF ILLINOIS
OLLUTION CONTROL BOARD
PETITION OF THE METROPOLITAN WATER RECLAMATION DISTRICT
OF
(GENERAL
GREATER
35 ILL .
USE
CHICAGO
ADMCHRONIC
. CODE
(DISTRICT)
SUBTITLE
WATER QUALITY
FOR
C, SECTIONS
SITE-SPECIFIC
STANDARD
302,
FOR
303,
RULEMAKINGCYANIDE)304
Introduction
In this petition before the Board, the District asks the
Board to grant a site-specific regulation
. The District asks
the Board, through the adoption of the site-specific regula-
tion, to do the following :
1
. Revise the existing numerical General Use
chronic water quality standard for weak acid
dissociable (WAD) cyanide from 5 .2 pg/l to 10
.0
yg/l for :
a
. West Branch of the DuPage River
b . Higgins Creek
c
. Salt Creek
d . Des Plaines River (within cook county)
The existing General Use chronic water quality standard
for WAD cyanide is 5
.2 pg/l
. This standard was adopted as a
result of the Board's Hearings in R88-21
. The Board's ex-
isting General use chronic water quality standard for cyanide
uses the laboratory analytical test method for WAD Cyanide
(Storet Number 00718) to determine compliance
.
Background
DESCRIPTION OF THE DISTRICT
The District is located within the boundaries of Cook
County Illinois and serves an area of 872 square miles
. The
1
area
served by the District includes the city of Chicago and
124 suburban communities with a combined population of 5
.1
million people
. In addition, a waste load equivalent to 4 .9
million people is contributed by industrial sources
. The
District, on a daily basis, treats on the average, 1500 mil-
lion gallons per day of wastewater
. This wastewater flow is
treated at the District's seven water reclamation plants
(WRPs) .
DISTRICT WRPs ON GENERAL USE STREAMS
Three of the District's seven WRPs discharge to General
Use streams
. These WRPs, the streams to which they dis-
charge, and their average daily flows, are as follows
:
1994 Average
WRP Daily
Flow
Receiving Stream
Hanover Park
8 .87 MGD
West Branch DuPage River
John E
. Egan
24 .5 MGD
Salt Creek
James C . Kirie
31
.8 MGD
Higgins Creek
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY PERMITS
In 1993, the Illinois Environmental Protection Agency
(Agency) issued renewed National Pollutant Discharge Elimina-
tion (NPDES) permits for the Hanover Park and James C
. Kirie
WRPs which for the first time included numerical effluent
limits based upon the General Use Chronic Water Quality Cri-
teria for Cyanide adopted by the Board in R88-21
.
2
The Agency placed the following limits in the NPDES
permits for the Hanover Park and James C . Kirie WRPs :
WRP
NPDES Permit Number
Hanover Park
IL0036137
James C . Kirie
IL0047741
The numerical effluent limits were set
General Use chronic water quality standard for WAD cyanide
since the West Branch of the DuPage River and Higgins Creek
have a 7-day, 10-year low flow of zero . The District in
these NPDES permits is required to measure the WAD cyanide
concentration in the effluents from these WRPs to determine
compliance
. This is in keeping with the Board's existing
General Use chronic water quality standard for WAD cyanide
.
Because the District had never before measured the WAD
cyanide concentration in the effluent from the James C . Kirie
and Hanover Park WRPs, a 12-month delay in the imposition of
the effluent limits for cyanide in the new NPDES permits was
requested . The Agency granted the District's request and the
effective date for the new WAD cyanide limits in these NPDES
permits was changed to April 1, 1995 . Thus, these new limits
are now in effect .
DISTRICT STUDIES
During the past 20 months, the District has been con-
ducting routine monitoring of the WAD cyanide level in the
effluents from the James C . Kirie and Hanover Park WRPs .
3
Monthly
CyanideEffluent
Average(jig/1)WAD
5
.2 pg/l
5 .0 gg/l
equal to the Board's
In addition, the
District has
conducted studies on the
following topic areas
:
1
. Inputs of WAD cyanide from industrial sources
to the James C
. Kirie and Hanover Park WRPs
.
2
. Effect of wastewater treatment on WAD cyanide
levels .
3
. Accuracy and precision of the laboratory ana-
lytical method for WAD cyanide
.
4
. Chlorine interference in the WAD cyanide
analysis .
The District has also investigated the following
:
1
. Basis for the existing General Use chronic
water quality standard for WAD cyanide
.
2
. Basis for Using the WAD cyanide analytical pro-
tocol for determining compliance with the Gen-
eral Use chronic water quality standard for WAD
cyanide
.
In the above mentioned studies and investigations, the
District has used the services of two experts
. These are :
1 . Dr . Richard Luthy
Carnegie
Professor
Department
Environmental
Mellon
and
of
HeadCivil
UniversityEngineeringand
Pittsburgh, PA
4
2 .
ProfessorDr
. Herbert E . Allen
Department
University
Engineeringof
of
CivilDelaware
Newark, Delaware
Dr . Luthy is a nationally recognized expert on cyanide
chemistry and analytical measurements, and is currently the
Chairman of the Standard Methods Joint Task Group on Cyanide .
He has published many papers on these topics . His complete
resume is contained in Attachment 1 .
Dr . Herbert Allen is a nationally recognized expert on
speciation chemistry, including chemical analysis . He has
extensively studied the fate of pollutants in receiving
streams and treatment plants and the effect of pollutants on
aquatic life . He is currently the Principal investigator on
the following two United States Environmental Protection
Agency (USEPA) sponsored research projects .
1 . Speciation of Metals in Effluents and Receiving
Waters .
2 . Speciation,
Bioavailability,
and
Fate of
Contaminants in the Aquatic Environment .
A complete resume for Dr . Allen is contained in Attachment 2 .
Summary of Site-Specific Relief Sought
The District asks that the Board revise the existing
General Use chronic water quality standard for WAD cyanide
from 5 .2 ug/l to 10 .0 pg/l for the following streams :
1 . West Branch DuPage River
5
2 . Higgins Creek
3
. Salt Creek
4 . Des Plaines River
(in Cook County)
The District has found that the existing numerical chronic
water quality standard of 5
.2 pg/1 WAD cyanide assumes that
the receiving stream is capable of supporting a large popula-
tion of the cold water fish species of rainbow trout . These
streams in fact do not support such populations
. Using USEPA
approved procedures, and the fact that rainbow trout are not
indigenous to the waterways in question, a General Use
chronic water quality standard for cyanide of 10 .0 pg/l WAD
cyanide is justified
.
The toxic form of cyanide to aquatic species is free
cyanide (HCN + CN-
) .
The USEPA acknowledges this fact in
their National Water Quality Criteria
. However, the existing
Board General Use chronic water quality standard for cyanide
requires that compliance be based upon WAD cyanide
. In fact
the WAD cyanide analytical determination measures other cya-
nide species besides free cyanide
.
As such this test does
not represent a true measurement of the cyanide form intended
to be regulated, which is toxic to aquatic species, and is
therefore a conservative methodology which overestimates free
cyanide content and cyanide toxicity .
6
Informational Requirements
from35 111 .Adm .Code 102 .141
REGULATIONS FOR WHICH A SITE-SPECIFIC RULEMAKING IS SOUGHT
The regulation for which a site-specific rulemaking is
sought is the General Use chronic water quality standard for
WAD cyanide
. The specific language requested for the site-
specific rulemaking is as follows :
1 . At 35 Ill . Adm
. Code, Subtitle C, Subpart B,
Section 302
.208 add a new paragraph (f) which
reads :
f) The chronic standard (CS)
for cyanide
(STORET number 00718) listed in
Section
302 .208(d) shall not apply to Salt
Creek,
Higgins Creek, the West
Branch of the DuPage
River, and
the Des Plaines River in Cook
County, Illinois .
2
. At 35 Ill . Adm
. Code, Subtitle C, Subpart C add
a new Section 303
.444 which reads :
Section 303 .444 Salt Creek,
Higgins Creek,
West Branch of the DuPaqe
River, Des Plaines
River
The General Use
chronic water quality standard
for cyanide (STORET
number 00718)
contained in
Section 302 .208 shall not
apply to Salt Creek,
Higgins Creek,
the West Branch of the DuPage
River, and the Des Plaines
River in Cook
County, Illinois . Instead,
these waters shall
7
comply with a chronic cyanide
standard of 10
ug/l
.
3 . At 35 Ill
. Adm . Code, Subtitle C, Subpart B,
Section 304
.201 add a new paragraph (d) which
reads :
d) John E .
Eqan, Hanover Park, and James C .
Kirie Water Reclamation Plants
The discharges of the John E . Egan, Hanover
Park, and James C
. Kirie Water Reclamation
Plants must meet a monthly average WAD cyanide
effluent standard of 10 pg/l, subject to
the
averaging rule of Section 304
.104(a) .
DESCRIPTION OF PETITIONER'S ACTIVITY
General Description of the District . The District is
located within the boundaries of Cook County, Illinois, and
serves an area of 872 square miles
. The area served includes
the city of Chicago and 124 communities with a population of
5
.1 million people . In addition, a waste load equivalent of
4 .9 million people is contributed by industrial sources,
making the total population served by the District equivalent
to 10 .0 million people
. Obviously, such a population concen-
tration and the attendant industrial and commercial enter-
prises require a complex and extensive wastewater collection
and treatment system
. In the case of the District, this sys-
tem is comprised of seven water reclamation plants and over
500 miles of intercepting sewers
.
The District, since its
8
inception 105 years ago, has been at
the forefront of using
up-to-date processes and facilities for wastewater treatment
and sludge management .
District Water Reclamation
Plants (WRPs) . The Dis-
trict's
WRPs are designed to remove the soluble and insoluble
organic matter in wastewater in an efficient and cost-
effective manner . The final discharge from these WRPs
meets
or exceeds the effluent standards of the Board
. The series
of wastewater treatment operations that are employed to ac-
complish the purification process are generally classified as
pretreatment, primary treatment, secondary treatment and ad-
vanced waste treatment .
The District operates seven
WRPs that range in design
capacity from the 3
.4 MGD (Lemont WRP),
to the 1200 MGD
(Stickney WRP) . A
listing of the daily capacity for each of
the seven WRPs is as follows :
1 . Lemont WRP, located in
design capacity of 3 .4
2 . James C . Kirie WRP,
Illinois, has a design
3 . John E . Egan WRP,
Illinois, has a design
4 . North Side WRP,
located in Skokie, Illinois,
has a design capacity of 333 MGD
.
5 . Calumet
WRP, located in Chicago, Illinois, has
a design capacity of 354 MGD .
9
Lemont, Illinois, has a
MGD,
located in Des Plaines,
capacity of 72 MGD .
located in Schaumburg,
capacity of 30 MGD .
6 .
Stickney WRP, located in Stickney, Illinois,
has a design capacity of 1200 MGD
.
7 . Hanover Park WRP, located in Hanover Park,
Illinois, has a design capacity of 12 MGD
.
Generally, initial treatment at these WRPs consists of
coarse and fine screens and grit chambers followed by primary
settling tanks
. All seven WRPs next employ the activated
sludge process for secondary treatment
. Tertiary treatment
is employed at the John E
. Egan and James C . Kirie WRPs using
dual media filters, while the Hanover Park WRP employs single
media filters
. The final effluents from the Hanover Park,
John E . Egan, and James C
. Kirie WRPs are first chlorinated
and then dechlorinated before discharge to the receiving
stream
. Chlorination and dechlorination is only performed
between April 1 and October 30 of each year
.
With respect to this Petition, three District WRPs
should be directly impacted .
They are the John E . Egan,
James C
. Kirie, and Hanover Park WRPs, all of which discharge
to General Use waters of the state of Illinois
. The John E
.
Egan WRP discharges to Salt Creek, the James C
. Kirie WRP
discharges to Higgins Creek, and the Hanover Park WRP dis-
charges to the West Branch of the DuPage River
. All of these
waterways eventually flow into the Des Plaines River
.
Attachment 3
presents 1994 monthly averages of final ef-
fluent quality from each WRP .
As can be seen from the final
10
effluent data, all
three WRPs produce tertiary quality ef-
fluent, low in BOD5, suspended solids, and ammonia .
Attachment 4
presents detailed data on WAD cyanide con-
centrations in the raw sewage and final effluent from the
Hanover Park and James C
. Kirie WRPs . WAD cyanide is the
parameter of concern in this Petition
. In August 1993 the
District received draft NPDES permit renewals for the Hanover
Park and James C . Kirie WRPs
. These permits contained ef-
fluent limits for WAD cyanide . The previous permits had con-
tained effluent limits for total cyanide
. WAD cyanide had
been substituted for total cyanide in the new permits based
upon the Board's R88-21 rulemaking which revised the General
Use water quality standards for cyanide
. The proposed WAD
cyanide effluent limit for the Hanover Park WRP was a monthly
average of 5
.2 pg/l and a daily maximum of 22 pg/l . The
proposed effluent limit for the James C
. Kirie WRP was a
monthly average of 5 .0
Rg/l
and a daily maximum of 22 pg/l .
These effluent limits were set equal to the General Use water
quality standard for WAD cyanide, as no dilution is available
in the receiving stream .
As there had been no previous standards for WAD cyanide,
the District had never analyzed the final effluents from its
WRPs for WAD cyanide .
Therefore, no database was available
on WAD cyanide levels in WRP effluents
. Thus, in September
1993 the District began to analyze the raw sewage and final
effluent from the Hanover Park and James C
. Kirie WRPs for
11
WAD cyanide . It
quickly became apparent that final effluent
WAD cyanide concentrations
at both WRPS measured well below
22 pg/l on a daily basis, but were often equal to or greater
than 5 pg/l, making compliance with the proposed monthly av-
erage NPDES permit limits problematic .
As so little infor-
mation was available on the sources and fate of WAD cyanide
in the wastewater treatment process, discussions were held
with the Illinois Environmental Protection Agency (Agency)
relative to the NPDES permit limits for WAD cyanide
. The
Agency stated that the WAD cyanide effluent limits were water
quality driven based upon the General Use standards for cya-
nide, and could not be changed without Board action
. The
Agency did agree, however, to add a Special Condition to the
NPDES permits for both WRPs which changed the effective date
for complying with the WAD cyanide standard from April 1,
1994 to April 1, 1995 . This was done to allow the District
adequate time to assess the occurrence, fate, treatability,
and distribution of WAD cyanide throughout the Hanover Park
and James C . Kirie WRP systems
.
From September 1993 to the present, the District has
been studying the WAD cyanide issue relative to the Hanover
Park and James C . Kirie WRPs . These studies have involved
the wastewater treatment processes at the WRPs, laboratory
research work, industrial waste monitoring, and literature
searches .
12
These studies revealed an unexpected result which can be
seen from the WAD cyanide data presented in
Table 1 . During
the months of November through April, when the chlorination/
dechlorination system is not in use, the final effluent WAD
cyanide concentrations measured at the Hanover Park WRP av-
eraged 1
.0 ug/l each month . The raw sewage wad cyanide con-
centrations also averaged 1 .0 ug/l .
For the months of May
through October when the chlorination/dechlorination system
is operational, the monthly average final effluent WAD cya-
nide concentrations increased to the 4 .0-6 .0 pg/l level even
though the raw sewage WAD cyanide concentrations remained at
either an 1 .0 or 2 .0 yg/l level . These monthly average val-
ues were thus equal to or exceeding the proposed NPDES permit
limit for WAD cyanide of 5
.2 ug/l at the Hanover Park WRP .
A similar, though not as pronounced, pattern occurred at
the James C . Kirie WRP (Table 2)
where November through April
effluent WAD cyanide concentrations averaged either 1
.0 or
2
.0 pg/l versus May through October monthly averages of 3 .0
and 4 .0 pg/l .
In the summer of 1994 when the correlation between
chlorination/dechlorination and effluent WAD cyanide concen-
trations was becoming evident, a more comprehensive sampling
program was begun at both WRPs to study the fate of WAD cya-
nide through the wastewater treatment process
. This involved
collecting special samples for one month of raw sewage, pri-
mary effluent, secondary effluent, chlorine contact tank
13
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 1
MONTHLY AVERAGE OF RAW SEWAGE AND FINAL
EFFLUENT WAD CYANIDE AT THE HANOVER PARK WRP
14
Month
Raw
WAD
SewageCyanide
(hg/1)
Final Effluent
WAD Cyanide
(jig/1)
December 1993
1 .0
1 .0
January 1994
1 .0
1 .0
February
1 .0
1 .0
March
1 .0
1 .0
April
1 .0
1 .0
May
1 .0
4 .0
June
2 .0
5 .0
July
2 .0
6 .0
August
1 .0
5 .0
September
1 .0
5 .0
October
1 .0
5 .0
November
1 .0
1 .0
December
1 .0
1 .0
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 2
EFFLUENT
MONTHLY
WAD
AVERAGES
CYANIDE
OF
AT
RAW
THE
SEWAGE
JAMES
AND
C . KIRIE
FINALWRP
15
Month
Raw Sewage
WAD Cyanide
(hg/1)
Final
WAD CyanideEffluent
(11g/l)
December 1993
1 .0
1 .0
January 1994
2 .0
2 .0
February
3 .0
2 .0
march
4 .0
2 .0
April
2 .0
2 .0
May
1 .0
3 .0
June
2 .0
4 .0
July
5 .0
4 .0
August
14 .0
4 .0
September
2 .0
3 .0
October
1 .0
2 .0
November
2 .0
1 .0
December
1 .0
1 .0
effluent,
and dechlorinated effluent, and analyzing them for
WAD cyanide
. The results are presented in
Attachment 5
and
verify that chlorination is causing an increase in WAD cya-
nide as measured by the WAD cyanide analytical methodology
.
As will be discussed in more detail in later sections of
this Petition, the District pursued many avenues of study in
1994 relative to the issue of WAD cyanide
. These included
laboratory studies of cyanide and chlorine chemistry, studies
of WAD cyanide analytical methodology, studies concerning
chlorine interference in the WAD cyanide analysis, special
industrial waste sampling programs, literature reviews, and
the engaging of private consultants with expertise in the
cyanide chemistry and toxicity fields
.
Among the conclusions of these various studies was the
agreement that chlorination/dechlorination was causing an
interference which resulted in an increase in WAD cyanide
concentrations as measured by accepted laboratory analytical
procedures
. What could not be definitely determined was the
mechanism which would account for this increase
.
It was also concluded that the current General Use
chronic water quality standard for WAD cyanide of 5
.2 pg/l
for the waterways receiving the effluents from the John E
.
Egan, Hanover Park, and James C
. Kirie WRPS could not be
justified based upon guidelines set forth by the USEPA for
determining such standards
(Guidelines for Deriving National
16
Water Quality Criteria for the Protection of
Aquatic
Organismsand Their Uses,
NTIS, PB 85-227049, 1985) .
EFFORTS NEEDED TO COMPLY WITH EXISTING BOARD REGULATIONS,
COMPLIANCE ALTERNATIVES AND COSTS
As documented above, the District has reason to believe
that the Hanover Park and James C
. Kirie WRPs will not be
able to consistently achieve a monthly average effluent WAD
cyanide concentration of 5 .2 and 5 .0 pg/l, respectively, as
specified in their NPDES permits . These Permit limits are
based on the General Use chronic water quality standard for
WAD cyanide
. In addition, a study of the wastewater treat-
ment processes at these WRPs has shown that chlorination/de-
chlorination interferes with the analytical methodology and
causes an increase in WAD cyanide as measured by the accepted
analytical procedures .
In order to reduce effluent WAD cyanide concentrations
to levels which will meet the current standards, three
potential options were identified
.
1
. Add an additional treatment process to the WRP
to remove WAD cyanide from the effluent .
2
. Reduce the raw sewage loading of WAD cyanide to
each WRP by amending the District's Industrial
Waste Ordinance relative to cyanide discharges
.
3
. Replace the existing chlorination/dechlorina-
tion system with a different disinfection pro-
cess such as ozonation or ultraviolet light
.
17
With respect
to Alternative No . 1 above, a review of the
technical literature indicated that no technologically feasi-
ble treatment processes exist for removing WAD cyanide from
municipal wastewater at the low
pg/l
levels, which enter
these WRPs .
In respect to Alternative No . 2 the District has in
place a rigorous program to control discharges from industry
including those that contain cyanide .
For over 15 years the District has had a program to
continuously monitor discharges from industries in the North
Service Area including the drainage basins of the John E
.
Egan, James C . Kirie, and Hanover Park WRPs . This program
includes all industries subject to Federal Categorical Pre-
treatment Standards under the Electroplating Point Source
Category (40 CFR 413) and the Metal Finishing Point Source
Category (40 CFR 433), not just those which discharge cya-
nide . In this program automatic samplers are dedicated to
continuously monitor discharges from industries, 24 hours per
day, seven days per week . These dedicated samplers have a
small computer which can be programmed to take samples at
varying time intervals over the entire sampling period to
ensure that the industry being monitored cannot circumvent
the ability of the District to detect discharges which occur
at any time during the day . The District has found that the
use of dedicated continuous monitoring at an industry results
18
in strict adherence to
the District's
and federal pretreat-
ment
regulations .
Table 3 contains a
listing of the industries where dedi-
cated continuous monitoring is taking place in the District's
North area
. As can be seen, dedicated continuous monitoring
is now being performed at 69 industries compared with 43
prior to 1993
. This requires the District to maintain 83
dedicated automatic samplers in continuous operation, since
some industries have multiple discharge points .
The District's dedicated continuous monitoring program
has identified two industrial dischargers of cyanide in the
Hanover Park WRP service area and six industrial dischargers
of cyanide in the James C
. Kirie WRP service area
.
Although monitoring data existed on total cyanide con-
centrations in the discharges from these companies, no data
existed on WAD cyanide concentrations, as this parameter is
not currently regulated by the District's Sewage and Waste
Control Ordinance
.
Therefore, the District instituted a
special sampling program at these companies to measure the
WAD cyanide concentrations and wastewater flows from each
company
. This WAD cyanide data is presented in
Attachment 6 .
The highest WAD cyanide concentration measured in the
industrial discharges to the Hanover Park WRP tributary
sewers was 4
.0 pg/l with most values at the 1
.0 ug/l level .
Taking dilution from the domestic wastewater into account,
19
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 3
REGULATED
DEDICATED
INDUSTRIAL
CATEGORICAL
SAMPLING
WASTE DIVISIONPROGRAMSINDUSTRIES
20
Facility
BegunStudy
Duration
Pollutants
Analyzed*
A . B . Dick Co .
05/16/94
Indef .
CN, TM
A P I Industries
09/10/84
Indef .
TM, CN
Altec Specialty
05/14/92
Indef .
TM, CN
Amber Plating Co .
08/04/89
Indef .
CN,
TM
Amitron
07/11/91
Indef .
TM, CN
Arlington Plating
07/23/83
Indef .
TM, CN
Bartlett Mfg .
10/31/88
Indef .
TM, CN
Berteau-Lowell Ptg .
10/24/90
Indef .
CN,
TM
Bilbo Plating Co .
01/25/93
Indef .
CN,
TM
Castle Metal Fin .
01/01/94
Indef .
TM, CN
Century Plating Co .
09/25/92
Indef .
CN, TM
Chem-Plate Ind
.
05/19/93
Indef .
TM, CN
Chicago Faucet
01/01/94
Indef
.
TM, CN
Chicago Magnet Wire
06/26/90
Indef .
TM, CN
Chicago Nameplate
03/31/88
Indef .
TM
Cinch Connectors
10/31/88
Indef .
TM, CN
Circuit Etching Tech .
04/12/91
Indef .
TM, CN
Circuit Systems
07/06/87
Indef .
TM
Circuit Systems #2
02/29/88
Indef .
TM, CN
Craftsman Plating
10/01/92
Indef .
CN,
TM
Crescent Plating
11/02/92
Indef .
CN,
TM
Davies Plating
07/16/90
Indef .
CN, TM
Dover Ind . Chrome
09/25/92
Indef .
CN, TM
Eagle Electronics
05/01/85
Indef .
TM, CN
Electro-Circuits
03/25/92
Indef .
TM, CN
Elec . Interconnect
12/16/94
Indef .
TM
Elk Grove Plating
12/05/88
Indef .
TM, CN
Enamlrs & Japann
10/01/92
Indef .
CN, TM
Gem Coat, Inc
.
10/23/92
Indef .
CN, TM
Graham Plating Co
.
08/18/89
Indef .
CN, TM
Gutmann Leather Co .
10/05/92
Indef .
TM
Hanover Park WRP
11/08/93
Indef .
TM, CN
Haydock Caster
05/16/94
Indef
.
CN, TM
Horween Leather Co .
10/95/92
Indef .
TM
J .P
. Custom Metal
01/22/93
Indef .
CN, TM
Jensen Plt . (Waban)
01/22/93
Indef .
CN,
TM
Jensen Plt . (West)
01/22/93
Indef .
CN, TM
METROPOLITAN
WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 3 (Continued)
INDUSTRIAL WASTE DIVISION
DEDICATED SAMPLING PROGRAMS
REGULATED CATEGORICAL INDUSTRIES
*CN -
Total cyanide, TM - Trace metals
21
Facility
BegunStudy
Duration
PollutantsAnalyzed
KVF
11/08/88
Indef .
TM
Lake City Pltg .
01/12/93
Indef .
CN, TM
Littelfuse
05/16/94
Indef .
TM, CN
Methode
10/12/92
Indef .
TM
Midwest Printed
07/25/89
Indef .
TM, CN
Motorola
10/14/92
Indef .
TM, CN
National Technology
01/03/89
Indef .
TM, CN
National Technology
11/05/93
Indef .
TM, CN
Northrop
10/13/92
Indef .
TM
Ohmite Mfg . Co .
05/16/94
Indef .
CN, TM
P&H Plating
05/01/91
Indef .
CN, TM
Petersen Finishing
01/01/94
Indef .
TM, CN
Pioneer Plating
09/30/92
Indef .
CN,
TM
Plating Service
05/16/94
Indef .
CN, TM
Precision Pltg .
12/04/92
Indef .
CN, TM
Precision Plating
11/07/88
Indef .
TM, CN
Precision Sci .
05/16/94
Indef .
CN, TM
Q M A, Inc .
07/13/93
Indef .
TM, CN
Redeen Engraving
09/21/92
Indef .
TM, CN
Regency Metal Fin .
05/16/90
Indef
.
TM, CN
Scott Plating
05/16/94
Indef .
CN, TM
Senior Flexonics
11/29/88
Indef .
TM, CN
Star Electronics
02/13/90
Indef .
TM, CN
Sterling Labs
03/07/94
Indef .
CN,
TM
Sun-Tronics
07/10/89
Indef
.
TM, CN
Three J's Industries
06/17/91
Indef .
TM, CN
United Metal Fin .
01/22/93
Indef .
CN, TM
Universal Scientific
07/08/86
Indef .
TM,
CN
V .P . Anodizing
06/04/93
Indef .
CN, TM
V .P . Plating/Par
06/04/93
Indef .
CN, TM
Western Chain Co .
05/16/94
Indef .
CN,
TM
Western Rustproof
09/30/92
Indef .
CN,
TM
the industrial contribution of WAD cyanide to the Hanover
Park WRP is insignificant .
For the six companies discharging to the James C
. Kirie
WRP, typical WAD cyanide concentrations are in the 0
.2 to 0 .4
mg/l range, with the highest observed value being 0
.76 mg/1 .
However, taking flow dilution into account, the industrial
contribution of WAD cyanide at the James C
. Kirie WRP would
only contribute 1 .0 to 2
.0 pg/l of WAD cyanide to the raw
sewage .
Of these eight dischargers, only five use cyanide in
their industrial processes . Four of these dischargers are
electroplaters or metal finishers and are subject to cate-
gorical pretreatment standards . For the Electroplating Point
Source Category the daily maximum discharge limit is 1
.9 mg/l
for total cyanide .
For the Metal Finishing Point Source
Category the daily maximum limit is 1 .0 mg/l for total cya-
nide . The fifth discharger is not subject to categorical
pretreatment standards, but must meet the local limit of 5 .0
mg/L for total cyanide . All four categorically regulated
dischargers are continuously monitored for total cyanide by
the Industrial Waste Division, which represents the maximum
enforcement effort possible . The District is continuing its
surveillance of all other industrial dischargers to ensure
that any new cyanide discharger would be identified and
controlled .
22
In
addition, the District, through its
USEPA approved
Pretreatment Program, has imposed more vigorous self-
monitoring requirements on the above eight companies to
sample and analyze their waste discharges for WAD cyanide . A
self-reporting sampling program was conducted by outside
laboratories, at industry expense, to document WAD cyanide
concentrations in their discharges
. The results of this
program were consistent with those obtained by the District,
and added nothing of substance to the data base
.
Thus increased industrial waste enforcement activities
would not be a solution to the WAD cyanide problem at these
two WRPs as maximum effort is currently being expended to
control such discharges by the District's Industrial Waste
Division .
With respect to Alternative No
. 3, technically feasible
disinfection alternatives do exist as substitutes for chlori-
nation/dechlorination in the wastewater treatment process
.
Since District data indicates that the chlorination/dechlori-
nation process is causing the increase in effluent WAD cya-
nide, replacing this process with an alternate technology may
reduce effluent WAD cyanide concentrations
. However, since
the reasons for the increase in WAD cyanide due to chlorina-
tion/dechlorination are not known, there is no guarantee that
an alternative disinfection process would not also cause
similar increases
.
23
The District has developed a cost estimate for replacing
the chlorination/dechlorination system at the Hanover Park
and James C . Kirie WRPs
(Attachment 7) . This cost estimate
indicates that ozonation would be the least costly alterna-
tive if the existing chlorination/dechlorination systems had
to be replaced
. For the Hanover Park WRP
an ozone disinfec-
tion system is estimated to have a total construction cost of
$1,294,228 and an annual operating cost of $35,400
. The to-
tal annualized construction plus operating cost is $186,604
.
For the James C . Kirie
WRP an ozone disinfection system is
estimated to have a total construction cost of $4,405,500 and
an annual operating cost of $128,800
. The total annualized
capital plus operating cost is $643,493
.
Thus, the total cost to the District for replacing the
chlorination/dechlorination system with an ozonation system
would be a construction cost of $5,699,728 and an annual
operating cost of $164,200 .
The total annualized capital
plus operating cost for both
WRPS would be $830,097 . It
should be noted that these costs do not include any costs for
replacing the existing chlorination/dechlorination system at
the John E . Egan WRP .
However, it is the District's under-
standing that when the current NPDES Permit for the John E
.
Egan WRP
expires on September 30, 1995, the new permit will
contain a WAD cyanide effluent limit similar to that of the
Hanover Park and James C . Kirie WRPs .
Therefore, the
24
District
anticipates even greater costs
than those listed
here for
complying with the existing WAD cyanide standard
.
Again, however, there is no guarantee that an ozonation
system would not produce increases in WAD cyanide as observed
for chlorination/dechlorination
.
The current NPDES permits for the Hanover Park and James
C
. Kirie WRPs contain monthly average WAD cyanide limits
equal to the existing General Use chronic water quality stan-
dard, as no instream dilution factor is available
. Since the
District anticipates that a similar NPDES Permit limit for
WAD cyanide will be imposed at the John E
. Egan WRP when its
permit is renewed, the John E
. Egan WRP and Salt Creek are
included in this petition
.
EFFORTS TO ACHIEVE PROPOSED STANDARD AND CORRESPONDING
COSTS
The District believes that no changes in its existing
operations will be required to meet the proposed standard
assuming that the NPDES permits for the Hanover Park and
James C
. Kirie WRPs are modified to reflect the proposed
change in the WAD cyanide chronic water quality standard
.
Likewise, no additional costs are anticipated
.
QUANTITATIVE AND QUALITATIVE IMPACT OF ADJUSTED STANDARD ON
THE ENVIRONMENT
The District's proposal in this Petition requests a
change in the General Use chronic water quality standard for
WAD cyanide
. As will be demonstrated in a later section of
25
this Petition,
no qualitative
impact on the environment would
occur if the proposed site-specific regulation is adopted
since the waterways in question do not contain rainbow trout .
Trout are not indigenous to these waterways and would not
populate these waterways, even if the existing cyanide stan-
dard is retained .
No adverse qualitative effects on the
environment are anticipated if the proposed site-specific
regulation is adopted
.
No quantitative impacts on the environment are expected
as a result of adopting the site-specific regulation as no
change in District WRP operations would occur
. Thus, WRP
effluent quality would remain the same even after the site-
specific regulation is adopted
. As can be seen from
Attachment 3
the final effluent from the Hanover Park, James
C . Kirie, and John E
. Egan WRPs is representative of well
operated nitrifying activated sludge treatment plants with
tertiary filtration .
Applicable NPDES permit limits are
consistently met at all three WRPs
.
Receiving
Biomonitoring
Waters From
Tests
the
Performed
John E
.
on
Egan,
Effluents
Hanover
andPark,
and James C
. Kirie WRPS in 1993 and 1994
To further demonstrate the fact that no adverse environ-
mental impacts would occur if the proposed site-specific
regulation is adopted, the following biomonitoring informa-
tion from the three WRPs in question is presented
.
In 1988 the District began conducting acute bioassays
(toxicity tests) with water fleas (Daphnia
up lex) and fathead
26
minnows (Pimephales
promelas)
developed by the USEPA for use
in the NPDES Permit program
. These bioassays were designed
to identify WRP effluents and receiving waters containing
toxic materials in acutely toxic concentrations
. Since 1986
the District has also conducted the Microtox
TM
analysis to
detect aquatic toxicity and the Ames test to detect geno-
toxicity
. In 1993 the District also developed the capability
to conduct chronic bioassays with fathead minnows and water
fleas
(Ceriodaphnia dubia)
to detect more subtle, low-level,
long-term adverse effects of effluents on aquatic organisms
.
The trend in aquatic toxicology is to use end-points which
are more sensitive than the mortality end-point which is
normally used in acute tests .
ples were collected for biomonitoring tests at the District's
John E
. Egan, Hanover Park, and James C
. Kirie WRPS in 1993
and 1994
.
In 1993 effluents and receiving waters from the John E
.
Egan, Hanover Park, and James C
. Kirie WRPS were monitored
quarterly for acute toxicity to the bacterium
Photobacterium
phosphoreum
(MicrotoxTM
reagent), the fathead minnow
Pimephales promelas,
and the water flea (either
Daphnia pulex
or
Ceriodaphnia dubia) .
During the first three quarters of
1993 effluents from these WRPs were screened for genotoxicity
with the Ames test
. During the first quarter, effluents from
these WRPs were also assayed for toxicity to the green alga
Selenastrum
capricornutum
(four-day, static exposure) .
27
Table 4 shows the dates sam-
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 4
JOHN E
. EGAN, HANOVER PARK, AND JAMES C
. KIRIE WATER RECLAMATION PLANT EFFLUENT SAMPLE
COLLECTION' FOR BIOMONITORING TESTS IN 1993 AND 1994
IG = Grab sample
; C = 24-hour composite sample .
John E . Egan WRP
Date Collected
Hanover Park WRP
James C
. Kirie WRP
March 1, 1993 (G)
May 17, 1993 (G)
January 25, 1993 (G)
April 12, 1993 (G)
February 1, 1993 (G)
May 3, 1993 (G)
August 16, 1993
(G)
July 19, 1993 (G)
August 2, 1993 (G)
November 8, 1993
(G)
November 22, 1993 (G)
November
15, 1993 (G)
January 31, 1994
(G)
March 13-14, 1994 (C)
December 13, 1993 (G)
April 4, 1994 (G)
March 15-16, 1994 (C)
January 3, 1994 (G)
July 5, 1994 (G)
March 17-18, 1994 (C)
April 4, 1994 (G)
October 17, 1994
(G)
April 10-11, 1994 (C)
July 5, 1994 (G)
April 12-13, 1994 (C)
October 24, 1994
(G)
April 14-15, 1994 (C)
May 15-16, 1994 (C)
May 17-18, 1994 (C)
May 19-20, 1994 (C)
June 12-13, 1994 (C)
June
June
14-15,
16-17,
1994
1994
(C)(C)
July 19-20, 1994 (C)
July 21-22, 1994 (C)
July 24-25, 1994 (C)
August 14-15, 1994 (C)
August 16-17, 1994 (C)
August 18-19, 1994 (C)
November 7, 1994 (G)
Table5 shows
the results of 53 toxicity
tests conducted
throughout 1993
on 12 WRP
effluents . No toxicity was
observed in 53 of the 55 tests conducted
. LC50 values of 51
percent and 69 percent were observed for the fathead minnow,
and the
Ceriodaphnia
tests, respectively, for the fourth
quarter samples collected at the James C
. Kirie WRP on No-
vember 15, 1993
. Additional fourth quarter samples from the
James C . Kirie
WRP were collected on December 13, 1993
. The
fathead minnow and the Ceriodaphnia
tests were repeated on
these additional samples, and no toxic effects were observed
.
In 1994 effluents and receiving waters from the John E
.
Egan, Hanover Park, and James C
. Kirie WRPS
were monitored
quarterly for acute toxicity to the bacterium
Photobacterium
phosphoreum
(MicrotoxTM
reagent), and these effluents were
tested for mutagenicity with the Ames assay
. From March
through August, effluents from the Hanover Park
WRP were
monitored for chronic toxicity to the water flea
Ceriodaphnia
dubia and the fathead minnow
Pimephales
promelas . These
chronic bioassays were performed as required by the Hanover
Park WRP
NPDES permit
. The effluent from the James C . Kirie
WRP was assayed for acute toxicity to
Ceriodaphnia
dubia and
Pimephales promelas .
This was also required by NPDES permit
.
Table 6
shows the results of 23 biomonitoring tests
conducted throughout 1994 on nine effluents from the John E
.
Egan, James C
. Kirie, and Hanover Park WRPs .
The results of
chronic bioassays conducted on Hanover Park
WRP effluent are
29
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE S
BIOMONITORING RESULTS' FOR THE JOHN E . EGAN, HANOVER PARK, AND JAMES C . KIRIE WATER
RECLAMATION PLANTS DURING 1993
Effluent
Tested
Bioassay 2
Onarter R1nassay Performed
First
Second
Third
Fourth
Hanover Park WRP Minnow
NTE
NTE
NTE
NTE
Q . pu1ex
NTE
NTE
NTE
NA
~ .
wig
NA
NTE
NTE
NTE
AlgaeMicrotoxT1'
NTENTE
NTENA
NANTE
NANTE
Ames
NME
NME
NME
NA
John E . Egan WRP Minnow12
.
Pn1ex
NTENTE
NTENTE
NTENTE
NANTE
~ . duthia
NA
NTE
NTE
NTE
Algae
NA
NA
NA
NA
MicrotoxTM
NTE
NTE
NTE
NTE
Ames
NME
NME
NME
NA
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 5 (Continued)
BIOMONITORING RESULTS' FOR
RECLAMATION
THE JOHN E
.
PLANTS
EGAN, HANOVER
DURING 1993PARK,
AND JAMES C . KIRIE WATER
'Resultsof
periodLC50
in
algae
the
=
;
Microtox
:
Effluent
EC50
in
NTE
test
15
= No
reagent
min
concentration
sample
Toxic
= the
light
less
Effecteffective
than
output
lethal
; NME
1%
concentration
after
of
=
to
No
growth
50%
,15
Mutagenic
of
minutesof
the
algae
(%)
Effectorganisms
of
.
in
This
sample
control)
; TE
measurement
tested
causing
= Toxic
; NA
within
a
Effect
=
50%
is
No
analogousAnalysisthe
decrease(Growthtest
;
to LC50 values obtained in other bioassays ; EC10 15 min = the effective concentration
minutes(%)
of
.
sample
This is
causing
interpreted
a 10%
to
decrease
indicate
in
the
the
toxicity
Microtox
threshold
reagent light
of the
output
analysisafter
.
15
2
Bioassaypulex
=
:
DaphniaMinnow
.
pnlex,=
Fathead
48 h
Minnowacute
toxicity
pimephalestestprnmelas,
; L, . duh
;a96 =h
f',Prindaphniacute
toxicity
duhiatest
;
48
ph.
acute toxicity test ; Algae = Green Alga ,Selenastrnm napricornut,nm,
96 h chronic
toxicity test ; MicrotoxT1t = Luminescent bacterium phot.ohanterium
phnsphorellm toxicity
assay; Ames = Ames Salmonella mutagenicity assay .
3No toxicity was observed when a follow-up WRP effluent sample was collected and
tested .
Effluent
Tested
Bioassay2
Quarter Bioassay Performed
First
Second
Third
Fourth
James C . Kirie
WRP
Minnow
fl . mile
.
NTE
NTE
NTE
NTE
NTE
NTE
LC50 = 51%3
NA
-, . dnhi,~
AlgaeMicrotox1'
Ante s
NA
NTENTE
NME
NTE
NA
NTE
NME
NTE
NA
NTE
NME
LC50 = 69%3
NA
NTENA
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 6
BIOMONITORING RESULTS' FOR
RECLAMATION
THE JOHN E .
PLANTS
EGAN, HANOVER
DURING 1994PARK,
AND JAMES C . KIRIE WATER
1 ResultsEffluent :
concentration
NTE = No Toxic
lethal
Effectto ; NME
50%
=
of
No
the
Mutagenic
organisms
Effecttested
; NA
within
= No Analysisthe
test
;
periodLC50
=
(acute bioassays) ; NOEC = no observed effect concentration (chronic bioassays) .
2Bioassay : Minnow (Acute) = Fathead Minnow, pimephales prnmelas, 96 h acute toxicity
test ; Minnow (Chronic) = Fathead Minnow, pimephalas
nrnr4elas,
Larval Survival and
Growth
(Chronic)
Test= ;
Cladoceran
f, . dnhi . (Acute)
(Cerindaphnia=
CPrindaphniadubia)
Survival
dubia 48-h
and
acute
Reproduction
toxicity
Testtest
;
;
MicrotoxT'Q
. rya
Luminescent bacterium photahanterium nhnsphoreua toxicity assay
; Ames = Ames
,Salmonella
mutagenicity assay .
Effluent
Tested
Bioassay 2
OuartRr Rinagsay Performed
First
Second
Third
Fourth
Hanover Park WRP Minnow (Chronic) NOEC = 25% 3 NTE3
,
4
NTE 3 , 5
NA
f, . diihia (Chronic) NTE
NTE 3 , 4
NTE3,5
NA
AmesMicrotoxTD'
NMENTE
NANTE
NTENA
NTENA
John E
. Egan WRP
AmesMicrotoxT°'
NMENTE
NANTE
NANTE
NTENA
James
WRP
C
. Kirie
C
Minnow
. duhia(Acute)(Acute) NTENTE
NANA
NANA
NANA
MicrotoxTm
NTE
NTE
NTE
NTE
Ames
NME
NA
NA
NA
3See Table 6 .
4Three bioassays . See Table 6 .
5Two bioassays
.
See Table 6 .
shown in Table 7 .
No
toxic effect was observed
in 22 of
these 23 tests
.
A no observed effect concentration (NOEC) of
25 percent was observed for
the first chronic fathead minnow
bioassay conducted on Hanover Park WRP effluent (collected
March 13-18)
. No toxicity was observed in any of the five
subsequent chronic bioassays performed from April through
August 1994
.
In summary, the District has conducted extensive bio-
monitoring tests on WRP effluents since 1986 as part of an
integrated approach consisting of whole effluent and chem-
ical-specific analyses as a means of protecting aquatic life
and human health
. These biomonitoring tests give a better
picture of the true effect which effluents have on the
aquatic community than do chemical-specific data alone
. In
1993 and 1994, 76 biomonitoring tests were conducted on ef-
fluent and upstream receiving water from the John E
. Egan,
Hanover Park, and James C
. Kirie WRPs
. The biomonitoring
data is summarized in
Tables 5-7 .
These data indicate that
neither acute nor chronic toxicity is associated with the
effluents from these three WRPs .
Attachment
8 contains the detailed biomonitoring reports
which were summarized above
.
Water Quality Upstream and Downstream of the
John E . Eqan, Hanover
Park, and James C . Kirie
WRPs
For over 20 years the District has conducted a compre-
hensive monitoring program of water quality in the
33
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 7
RESULTS OF CHRONIC BIOASSAYS CONDUCTED ON HANOVER PARK WRP EFFLUENT IN 1994 EXPRESSED
AS NO OBSERVED EFFECT CONCENTRATION VALUES'
1No Observed Effect Concentration (NOEC) = the highest effluent concentration having no
observable effect on survival, growth, or reproduction .
2 Fathead Minnow (pimenhales
promelas) Larval Survival and Growth Test, (EPA/600/4-
89/001, Second Edition, March, 1989) .
3 Cladoceran (Cerindaohnia dnhia)
Survival and Reproduction Test (EPA/600/4-89/001,
Second Edition, March, 1989)
.
Effluent
Sampling
Dates
Fish Rinassay2
Water Flea Bioassay
3
Survival
Growth
Survival
Reproduction
March 13-18
25
25
100
100
April 10-15
100
100
100
100
May 15-20
100
100
100
100
June 12-17
100
100
100
100
July 19-25
100
100
100
100
August 14-19
100
100
100
100
Chicagoland area
. One part of this program involves the
collecting of grab samples, once per month, in the receiving
waters upstream and downstream of the District WRPs
. These
water samples are analyzed for 43 water quality parameters
.
The outfalls for the Hanover Park, John E
. Egan, and
James C
. Kirie WRPs are located in the West Branch of the
DuPage River, in Salt Creek, and in Higgins Creek, respec-
tively . These streams
fall within the General Use classifi-
cation
. For the Hanover Park WRP, the upstream station is
located at Long Meadow Lane, 100 feet above the outfall, and
the downstream station is located at Walnut Lane, a distance
of 1,000 feet below . For the John E
. Egan WRP, the upstream
station is located at Higgins Road, 7,500 feet above the
outfall, and the downstream station is located at Arlington
Heights Road, a distance of 1,300 feet below
. The upstream
sampling point for the James C
. Kirie WRP is located at the
Visitor's Road "A" Bridge, about 1,000 feet upstream of the
outfall, while the downstream station is at the Wille Road
Bridge, about 300 feet downstream of the outfall
.
In order to assess the impact of the WRP effluents on
the corresponding receiving stream a statistical analysis of
the 1993 and 1994 monitoring data has been performed
. This
statistical analysis is based upon comparing the annual means
of each parameter measured at the respective upstream and
downstream locations using a paired t-test
. The complete
data Tables used for this statistical analysis are presented
35
in Attachment9 .
The results of this analysis using the 1993
data can be summarized as follows :
1 . James C
. Kirie WRP
of the parameters for which the downstream
average levels are significantly higher than
the upstream average levels, dissolved oxygen,
temperature, sulfate, fluoride, zinc, total
iron, and manganese, have an Illinois water
quality standard
. The water quality standard
compliance rate of dissolved oxygen was 92 and
100 percent at the downstream and the upstream
locations, respectively . The water quality
standard compliance for other parameters was
100 percent at both locations .
2 . John E . Eqan WRP
Significant differences are observed be-
tween the average levels at the upstream and
the downstream locations for 13 parameters
. Of
these, three parameters - total iron, manganese
and fluoride -
have a pertinent Illinois water
quality standard . The water quality standard
compliance rate of total iron was 54
.6 at the
upstream location, and 100 percent at the down-
stream location .
The water quality standard
compliance rate of the other two parameters was
100 percent at both the locations .
36
3 . Hanover Park WRP
There are significant differences between
the upstream and downstream locations for seven
parameters, of these, four parameters have a
pertinent Illinois water quality standard
. The
water quality standard compliance rates for
these parameters were very high
. The water
quality standard compliance rate of dissolved
oxygen was 92 percent at both locations, and
total iron was 83 .3 percent at the upstream and
100 percent at the downstream locations . The
water quality standard compliance rate of the
other two parameters -
fluoride and manganese
was 100 percent at both locations .
The results using the 1994 water quality data can be
summarized as follows :
1 . James C . Kirie WRP
The average levels of the parameters COD,
total iron, and manganese upstream of the WRP
are significantly higher than the average lev-
els observed in downstream waters . The average
levels of the parameters
temperature,
NO2+NO3, total phosphorus, soluble phosphorus,
alkalinity, sulfate, and fluoride at the down-
stream location are significantly higher than
the corresponding upstream averages
. Of these
37
parameters, temperature,
sulfate, total cya-
nide, and
fluoride have
pertinent Illinois
water quality standards
; and these parameters
were in total compliance at both the upstream
and downstream locations
.
2 .
John E . Egan WRP
The average levels, at the upstream loca-
tion, of the parameters COD, total suspended
solids, volatile suspended solids, turbidity,
and total iron are significantly higher than
the downstream levels
. The downstream average
levels of NO2+NO3, total phosphorus, soluble
phosphorus, total cyanide, and fluoride are
significantly higher than the corresponding
upstream average levels . Of these parameters,
cyanide and fluoride have a pertinent Illinois
water quality standard which was in total
compliance at both upstream and downstream
locations .
3 . Hanover Park WRP
The upstream average levels of TOC,
chloride, and total iron are higher than the
corresponding downstream averages
; and the
downstream averages of N02+NO3, total phos-
phorus, soluble phosphorus, and fluoride
higher than
the corresponding upstream
38
are
averages . Of these
parameters,
chloride and
fluoride have pertinent Illinois water quality
standards and these parameters were in total
compliance at the upstream and downstream
locations .
The above information demonstrates that the existing
effluent discharges from the John E
. Egan, Hanover Park, and
James C
. Kirie WRPs are not producing any detrimental water
quality effects on the receiving streams
.
As WAD cyanide had not previously been a constituent of
concern to the District, no historical waterways database
exists for it
. However, beginning in January 1995 the Dis-
trict has collected special waterways samples upstream and
downstream of the Hanover Park and James C
. Kirie WRPS for
WAD cyanide analysis .
Table 8
presents the January 1995 results
. As can be
seen, WAD cyanide concentrations in the waterways upstream
and downstream of the two WRPs range from 0 to 3
.0 jig/l,
which is below the existing General Use chronic water quality
standard for cyanide of 5
.2 pg/l .
If the Board grants the relief sought by the District,
no degradation of existing water quality will occur
. The
District will continue its program to reduce cyanide dis-
charges to the John E
. Egan, Hanover Park, and James C
. Kirie
WRPs through the use of dedicated continuous monitoring and
strict
self-reporting requirements
for industry .
In
39
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 8
WAD CYANIDE
OF THE HANOVER
CONCENTRATIONS
PARK AND
UPSTREAM
JAMES C .
AND
KIRIE
DOWNSTREAMWRPS
40
Date
of
Upstream
Hanover
Downstreamof
Hanover
Upstream
James C .
of Downstream of
James C .
Kirie WRP
Park WRP Park WRP
Kirie WRP
1/5/95
1
.0
1WAD
.0
Cyanide
2()1g/1).0
2 .0
1/6/95
NS*
1 .0
NS
1 .0
1/9/95
1 .0
1 .0
NS
3 .0
1/11/95
1 .0
0
NS
1 .0
1/17/95
1 .0
1 .0
2 .0
2 .0
1/19/95
2 .0
2 .0
2 .0
1 .0
1/23/95
3 .0
2 .0
3 .0
2 .0
1/25/95
2 .0
1 .0
2 .0
1 .0
*No sample .
addition, the District will continue to operate its WRPS to
produce maximum removal efficiency for cyanide . Thus, no
degradation of existing water quality will result from a
change in the WAD cyanide water quality standard from 5
.2 to
10 pg/l .
A STATEMENT OF JUSTIFICATION FOR THE PROPOSED SITE-SPECIFIC
REGULATION
As presented above, the District believes that it has
demonstrated that no adverse environmental impacts will re-
sult if the site-specific regulation proposed in this Peti-
tion is adopted
. In addition, the District has shown that an
unreasonable economic burden will be placed upon the tax-
payers of Cook County if this Petition is rejected
. This is
due to the fact that even without the costs for modifying the
John E
. Egan WRP, $830,097 in annualized capital and op-
erating costs would have to be needlessly expended at
the two
WRPS in question to install alternative disinfection systems
with no assurance that the WRPS would comply with the ex-
isting General Use chronic water quality standard for cya-
nide, and with no anticipated environmental benefits being
achieved
.
The Illinois Legislature, with the approval of Governor
Edgar, adopted into law on February 12, 1995 tax cap
legislation which severely limits the operating and capital
works budget of the District
. For example, in 1995 because
of this legislation the District must reduce its planned
41
budgetary expenditures by 17 million dollars . Overall, for
the next five years (1995-1999), the District projects that
its planned expenditures must be reduced by 147 million dol-
lars
. This makes it even more critical that each and every
tax dollar be spent with maximum effectiveness
. The un-
necessary installation of alternative disinfection systems
would not be a proper use of District funds
. District
taxpayer dollars would be better spent on projects which are
environmentally more meaningful .
Therefore, the District maintains that the Board is
justified in granting the requested relief
.
TECHNICAL JUSTIFICATION FOR PROPOSED REGULATIONS
The District has identified four factors in its proposal
which it believes significantly distinguishes it from those
relied on by the Board in the R88-21 rulemaking relative to
WAD cyanide . These are :
A
. The indigenous species used in calculating fish
toxicities are not applicable to the waterways
named in the District's proposal .
B . Use of WAD cyanide for determining water
quality standards is not directly related to
toxicity as compared to use of free cyanide
.
C
. Chlorine interferes with the WAD cyanide test
.
D
. The regulatory limits are at or below the limit
of detection
.
42
Each of these factors is discussed in the following
sections .
The Use of Non-Indigenous Species in
Calculating Fish Toxicities
In reviewing the record of the Board's R88-21 rulemaking
it can be seen that the Board adopted the Agency's recom-
mendations relative to the General Use water quality stan-
dards for WAD cyanide
. The Agency recommendations were based
upon two USEPA documents
. These are :
1 . Ambient Water Quality Criteria for Cyanide-
1984, EPA-440/5-84-028 .
2 . Guidelines for Deriving
National Water Quality
Criteria for
the Protection of Aquatic
Organisms and Their Uses,
NTIS, PB85-227049 .
Dr
. Herbert Allen, a nationally recognized expert on
speciation chemistry and the effects of metals on aquatic
life was retained by the District to review how the informa-
tion contained in these two documents was applied in the R88-
21 rulemaking, and how this methodology relates to the Dis-
trict's request for an adjusted standard .
Dr . Allen's report is presented, in full, in
Attachment
10
. The key findings can be summarized as follows
. Using
the cyanide toxicity data presented in the
Ambient Water
Quality Criteria for Cyanide
- 1984
and the methodology spe-
cified in the
Guidelines
for Deriving National Water Quality
Criteria for the
Protection of
Aquatic Organisms and Their
43
Uses, the Final
Chronic Value for cyanide using the four most
sensitive fish species (rainbow trout, brook trout, yellow
perch, and bluegill which are the national default species)
can be calculated to equal 7 .32 pg/l . However, the Guide-
lines document states that if the species Mean Acute Value of
a commercially or recreationally important species is lower
than the calculated Final Acute Value, then the Species Mean
Acute Value can replace the calculated value in order to
provide protection for that one important species
. The R88-
21 record indicates that the Agency made the decision to use
rainbow trout as the most important species, and substituted
rainbow trout toxicity data for the calculated Species Mean
Acute Value
. This Species Mean Acute Value was then used to
calculate a new Final Chronic Value for cyanide of 5
.2 pg/l .
The Agency then recommended the 5 .2 pg/l value to the Board,
instead of the national default value of 7 .32 pg/l contained
in the USEPA Guidelines document .
Dr
. Allen's report also discusses the fact that the
USEPA Guidelines document allows for the calculation of a
site-specific toxicity value, if sufficient data exists for
the rivers in question . The methodology for determining a
site-specific toxicity value is contained in the USEPA docu-
ment entitled "Guidelines for Deriving Numerical Aquatic
Site-Specific Water Quality Criteria" (EPA-600/3-84-099) .
The methodology allows indigenous fish species to be substi-
tuted for the national default four most sensitive species
44
mentioned previously
. Based upon the allowed USEPA method-
ology, the four most sensitive fish species which may ac-
tually exist in the rivers covered by this Petition are brook
trout, black crappie, bluegill, and yellow perch
. Rainbow
trout do not exist in the waters covered by this petition .
Using the cyanide toxicity data for these four fish species,
the calculated Final Chronic Value for cyanide is 9 .799 pg/l .
Thus, the existing chronic standard for WAD cyanide of 5 .2
Ug/l is inappropriate .
It is the position of the District that the use of rain-
bow trout as the sole species for determining a chronic
quality standard for WAD cyanide in the rivers under question
in this Petition is incorrect due to the fact that rainbow
trout are not indigenous to Salt Creek, Higgins Creek, the
West Branch of the DuPage River, or the Des Plaines River in
Cook County .
For the past 20 years, as part of its environmental
monitoring programs, the District has conducted fish collec-
tions in the rivers of Cook County
. A total of 18,308 fish
composed of 61 species and seven hybrids have been collected
by the Metropolitan Water Reclamation District of Greater
Chicago from the Des Plaines River, Salt Creek, and the
DuPage River during the period 1974 through 1994
(Table
9) .
Fishing gear used included boat and backpack electrofishers,
15-foot and 25-foot minnow seines with 3/16-inch square mesh,
45
water
METROPOLITAN
WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 9
FISH SPECIES AND NUMBER OF FISH COLLECTED BY THE METROPOLITAN WATER RECLAMATION DISTRICT FROM THE DES
PLAINES RIVER, SALT CREEK AND THE DU PAGE RIVER FROM 1974 THROUGH 1994
Amia calva
Alosa chrysochloris
Dorosoma cepedianum
Umbra limi
Esox americanus
vermiculatus
Esox lucius
Campostoma anomalum
Carassius
auratus
Cyprinus carpio
C . carpio
x
C .
auratus
Notropis
nubilus
Nocomis biguttatus
Notemigonus
crysoleucas
Notropis
atherinoides
Luxilus chrysocephalus
Luxilus cornutus
Notropis dorsalis
Cyprinella lutrensis
Notropis rubellus
Cyprinella spiloptera
Notropis stramineus
Lythrurus umbratilis
Notropis volucellus
Fish Species
Collected
Des Plaines Salt
Du Page
Grand
Scientific Name
Common Name
River
Creek
River
Total
--------------- Number of Fish ---------------
Bowf in
1
-
1
Skipjack herring
1
1
Gizzard shad
210
8
218
Central mudminnow
21
11
32
Grass pickerel
1
1
Northern pike
17
-
17
Central stoneroller
279
-
129
408
Goldfish
2396
95
15
2,506
Carp
1216
36
87
1,339
Carp x goldfish hybrid
405
3
3
411
Ozark minnow
1
-
-
1
Hornyhead chub
135
16
151
Golden
shiner
19
4
1
24
Emerald
shiner
176
4
180
Striped
shiner
145
-
4
149
Common
shiner
4
2
8
14
Bigmouth shiner
70
290
130
490
Red shiner
5
5
Rosyface shiner
6
-
6
Spotfin shiner
699
-
307
1,006
Sand shiner
499
74
573
Redfin shiner
5
56
61
Mimic shiner
1
-
1
METROPOLITAN WATER
RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 9 (Continued)
FISH SPECIES AND NUMBER OF FISH COLLECTED BY THE METROPOLITAN WATER RECLAMATION DISTRICT FROM THE DES
PLAINES RIVER, SALT CREEK AND THE DU PAGE RIVER FROM 1974 THROUGH 1994
--------------- Number of Fish ---------------
Phenacobius
mirabilis
Suckermouth minnow
4
18
22
Pimephales
notatus
Bluntnose minnow
4204
81
410
4,695
Pimephales promelas
Fathead minnow
410
80
54
544
Pimephales vigilax
Bullhead minnow
4
4
Semotilus atromaculatus Creek chub
219
7
77
303
Carpiodes
cyprinus
Quillback
3
-
3
Catostomus
commersoni
White sucker
157
18
19
194
Erimyzon
oblongus
Creek chubsucker
1
1
Hypentelium nigricans
Northern hogsucker
3
3
Moxostoma duquesnei
Black redhorse
1
1
Moxostoma erythrurum
Golden redhorse
4
-
4
Moxostoma macrolepidotum
Shorthead redhorse
6
-
-
6
Ameiurus melas
Black bullhead
214
38
11
263
Ameiurus natalis
Yellow bullhead
32
5
X*
37
Ictalurus punctatus
Channel catfish
9
-
9
Noturus flavus
Stonecat
1
5
6
Noturus
gyrinus
Tadpole madtom
23
2
25
Fundulus
notatus
Blackstripe topminnow
150
3
153
Gambusia affinis
Western mosquitofish
152
X
152
Culaea
inconstans
Brook stickleback
1
-
-
1
Morone
mississippiensis Yellow bass
13
13
Ambloplites rupestris
Rock bass
32
-
3
35
Lepomis cyanellus
Green sunfish
1876
46
407
2329
Lepomis gibbosus
Pumpkinseed
76
7
37
120
Fish Species Collected
Des Plaines
Salt
Du Page
Grand
Scientific Name
Common Name
River
Creek
River
Total
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 9 (Continued)
FISH SPECIES AND NUMBER OF FISH COLLECTED BY THE METROPOLITAN WATER RECLAMATION DISTRICT FROM THE DES
PLAINES RIVER, SALT CREEK AND THE DU PAGE RIVER FROM 1974 THROUGH 1994
--------------- Number of Fish ---------------
Lepomis gulosus
Warmouth
2
2
Lepomis humilis
Orangespotted sunfish
32
9
41
Lepomis macrochirus
Bluegill
918
57
93
1068
Lepomis megalotis
Longear sunfish
47
2
49
Micropterus dolomieu
Smallmouth bass
26
7
33
Micropterus salmoides
Largemouth bass
108
52
8
168
Pomoxis annularis
White crappie
8
17
25
Pomoxis nigromaculatus
Black crappie
106
14
2
122
Lepomis cyanellus
x
Green sunfish x
Lepomis
megalotis
longear sunfish hybrid
1
1
Lepomis cyanellus
x
Lepomis
humilis
Lepomis cyanellus x
Lepomis gibbosus
Green sunfish x orange-
3
x
15
x
18
spotted sunfish hybrid
Green sunfish x
pumpkinseed hybrid
Lepomis cyanellus x
Green sunfish x
Lepomis
macrochirus
bluegill hybrid
4
2
1
7
Lepomis gibbosus x
Lepomis humilis
Pumpkinseed x orange-
1
x
x
x
1
spotted sunfish hybrid
Lepomis gibbosus x
Lepomis macrochirus
Pumpkinseed x
bluegill hybrid
Etheostoma flabellare
Fantail darter
24
24
Etheostoma nigrum
Johnny darter
154
11
165
Etheostoma spectabile
Orangethroat darter
8
-
8
Etheostoma zonale
Banded darter
1
1
Fish Species Collected
Des Plaines
Salt
Du Page
Grand
Scientific Name
Common Name
River
Creek
River
Total
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 9 (Continued)
FISH SPECIES AND NUMBER OF FISH COLLECTED BY THE METROPOLITAN WATER RECLAMATION DISTRICT FROM THE DES
PLAINES RIVER,
SALT CREEK AND THE DU PAGE RIVER FROM 1974 THROUGH 1994
*Species present, but count of fish not completed
.
Perca flavescens
Yellow perch
---------------1
Number of Fish 1
Percina maculata
Blackside darter
23
23
Aplodinotus grunniens
Freshwater drum
2
2
Cottus bairdi
Mottled sculpin
31
31
Total number of
fish
15,392
865
2,051
18,308
Total number of
species
57
18
39
61
Total number of
hybrids
4
2
7
7
Fish SneriPs Collected
Des Plaines
Salt
Du Page
Grand
Scientific Name
Common Name
River
Creek
River
Total
and
an electric seine .
The data in Table9 can be
summarized as follows :
1 . Des Plaines River
: 15,392 fish composed of 57
species and 4 hybrids were collected from the
Des Plaines River and its tributaries in Lake,
Cook, DuPage, and Will Counties during 1976,
1977, 1978, 1979, 1992, and 1993
.
2
. Salt Creek : 865 fish composed of 18 species
and two hybrids were collected from Salt Creek
and its tributaries in Eastern DuPage County
and north and central Cook County during 1974,
1975, and 1976 .
3 . DuPage River :
2,051 fish composed of 39
species and seven hybrids were collected from
the DuPage River, including the east and west
branches, and tributaries contained in DuPage
County and northwestern Will County during 1976
and 1994 .
Neither rainbow trout, nor any other species of trout,
were ever present in any of these collections
.
The Des Plaines River, Salt Creek, and the DuPage River
are sluggish low gradient warmwater streams
. Warmwater
streams have more severe fluctuations of water temperature,
chemical conditions, water volume, current velocity, and
bottom contours than do coldwater trout streams
. Warmwater
streams are generally more turbid and deeper than coldwater
50
trout streams . The difference between warmwater streams and
coldwater streams are summarized in Table 10 .
Coldwater streams are suitable for trout while warmwater
streams are not . Trout require coldwater streams containing
riffles with good water and oxygen flow through the gravel on
the stream bottom for embryo survival
. Temperature influ-
ences fish by controlling reproductive cycles, feeding and
metabolic rates, swimming performance, growth rates, and
distribution . Temperatures below or above the general range
of 10°C to 20°C have unfavorable consequences on the de-
velopment and growth of trout .
The Des Plaines River, Salt Creek, and the DuPage River
have summer temperatures exceeding 20°C and contain only
warmwater fish species . The silty deposition of sluggish low
gradient streams also prevents good water and oxygen flow for
trout embryo survival . No species of trout was ever found in
any of the collections from the Des Plaines River, Salt
Creek, or the DuPage River . The habitat in these streams and
their tributaries is not suitable for trout to successfully
maintain sustainable populations .
This same general position has recently been affirmed by
the Agency as evidenced by the Agency's recent testimony be-
fore the Board in the R94-1 rulemaking . In the Agency testi-
mony (excerpts presented in Attachment 11) the Agency clearly
states that it is improper to use cold water species toxicity
data in calculating General Use water quality standards for
51
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 10
GENERALIZED CHARACTERISTICS OF WARMWATER STREAMS CONTRASTED
WITH COLDWATER STREAMSa
52
Stream Category
Characteristic
Coldwater
Warmwater
Geology
Youthful
More mature
Valley shape
V
U
Temperature
Cold(<20°C)
Cool-warm(>20°C)
Discharge
Low
Medium-high
Velocity
Moderate (high
turbulence)
Moderate
(low turbulence)to
high
Depth
Shallow
Medium to moderate
Width
1-6 m
> 3 m
Substratum
Rubble-gravel
Rubble-sand-mud
Gradient
High
Low
Elevation
High
Low
Turbidity
Clear
clear-turbid
Pools (riffles)
Short (many
Long (few riffles)
riffles)
Temporal
High
Low
variability
Aquatic flora
Periphyton
Macrophytes
Shade and cover
Extensive
Sparse
Organic
Coarse particulate
Fine particulate
material
organic matter
organic matter
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
TABLE 10 (Continued)
GENERALIZED CHARACTERISTICS
WITH COLDWATER
OF WARMWATER
STREAMSaSTREAMS
CONTRASTED
aReference : Winger, Parley V
., "Physical and Chemical Char-
acteristics of Warmwater Streams
: A Review," In Krumholz,
Division,
L . A., Editor,
American
The
Fisheries
Warmwater
Society,
Streams
Allen
Symposium,
Press, Lawrence,Southern
Kansas, pp . 32-44, 1981 .
53
Characteristic
ColdwaterStream
Category
Warmwater
Distance from
< 8 km
> 16 km
source
Stream Order
Low (< 3)
Higher (> 3)
Competition
Intraspecific
Interspecific
Predatory fish
Few
Many
Fish community
Trout
SunfishCatfish
Suckers
Fish diversity
Low
High
ammonia nitrogen . The Agency also states that cold water
species are not resident in Illinois waters except for Lake
Michigan .
The District believes that the above information clearly
demonstrates that the existing General Use chronic water
quality standard for WAD cyanide was based upon factors sig-
nificantly different than those relating to the District's
situation .
UseforofDetermining
WAD Cyanide
Water
Instead
Quality
of Free
StandardsCyanide
The R88-21 rulemaking established General Use water
quality standards for cyanide based upon the measurement of
WAD cyanide . However, the USEPA Ambient Water Quality
Criteria for Cyanide-
1984 states that "free cyanide would
provide a more scientifically correct basis upon which to
establish criteria for cyanide ." Free cyanide is defined as
HCN + CN- whereas WAD cyanide is defined as HCN + CN- + weak
metal cyanide complexes . Thus it is clear that WAD cyanide
is a conservative measure of the truly toxic form of cyanide,
i .e ., free cyanide, and thus overestimates its presence .
Further details on cyanide chemistry and speciation are
presented in Attachment 12 which was prepared for the Dis-
trict by Dr . Richard Luthy, a nationally recognized expert on
cyanide chemistry and analytical methodology
.
Unfortunately, there is no USEPA approved method for the
analysis of free cyanide . Therefore, it is understandable as
54
to why the Board chose WAD cyanide as a regulatory measure .
However, the District requests that the Board take this added
measure of conservatism into account when evaluating the
District's request for a site-specific rulemaking .
Chlorine Interference in the WAD Cyanide Test
As discussed above, the District believes that chlorina-
tion of WRP effluents causes analytical interferences which
result in increased WAD cyanide concentrations as determined
by the accepted WAD cyanide analytical method
. During 1994
the District conducted a number of bench-scale laboratory
experiments in an attempt to determine whether the chlorine
interference was strictly a methodology related problem, or
if the chlorine was actually affecting the cyanide speciation
in the WRP effluent . The District also retained Dr . Richard
Luthy to visit the District's laboratory and evaluate the WAD
cyanide analytical procedures .
The types of bench-scale experiments conducted were as
follows :
1 . Studying the relationship between sodium hypo-
chlorite (chlorination) and sodium bisulfite
(dechlorination) dosage and WAD cyanide concen-
trations in effluent from the James C
. Kirie
and Hanover Park WRPs .
2 . Checking the purity of the sodium hypochlorite
and sodium bisulfite used at the two WRPs
.
55
In the bench-scale
experiments, secondary effluent,
prior to chlorination, was collected at both the Hanover Park
and James C
. Kirie WRPs and brought to the laboratory . The
effluents were then dosed with sodium hypochlorite, stirred
for an appropriate contact time, and then dechlorinated by
the addition of sodium bisulfite . Sodium hypochlorite and
sodium bisulfite dosages were varied to span all normal WRP
operating conditions .
To check the purity of the industrial grade sodium hypo-
chlorite and sodium bisulfite used full-scale, at the two
WRPs, samples of these chemicals were analyzed for trace
amounts of cyanide, and were also compared to pure laboratory
grade reagents .
The data from these laboratory experiments is presented
in Attachment 13 . The data indicates that chlorination/
dechlorination interferes with the analytical test and causes
an increase in WAD cyanide concentrations in some cases, but
the magnitude of the increase in the laboratory did not al-
ways correspond to the field data observed at the District
WRPs . The data also shows that there was no cyanide contami-
nation in any of the chemicals being used at the two WRPs .
Dr . Luthy concluded that there were no problems with the
analytical procedures being used (Attachment 14) . However,
he could not explain the observed chlorine interference . He
did point out the fact that the chemical interactions of
chlorine and cyanide are extremely complicated in a
56
wastewater matrix, especially at the low pg/l concentrations
that are of concern . At higher WAD cyanide concentrations
these matrix interactions would not be as significant .
The District believes that this unanticipated chlorine
interference at low WAD cyanide concentrations was not known
to the District, the Agency, or the Board during the R88-21
Rulemaking, and requests that this problem be taken into
account when the Board reviews this Petition .
Setting Regulatory Limits at or Below the Limit of Detection
The current General Use chronic water quality standard
for WAD cyanide is 5 .2 pg/l
. Standard Methods for the
Examination of Water and Wastewater, 18th Edition, lists the
limit of detection of the WAD cyanide analysis as 5 to 20
pg/1 depending on the sample matrix . Thus, by adopting the
5 .2 pg/l limit, the Board has unwittingly placed a con-
siderable burden on the District to accurately analyze WAD
cyanide in the effluents from its WRPs, perhaps beyond the
limits of existing laboratory analytical methodology .
Dr . Richard Luthy, who is the chairman of the Standard
Methods committee on cyanide analysis has prepared a report
(Attachment 14) discussing the difficulties of accurately
analyzing WAD cyanide at these low concentrations . In
particular it should be noted that the precision of the WAD
cyanide analysis at the limit of detection is t 8 .0 pg/l .
Thus, at the lower limit of detection of 5 pg/l, the true
value could be between -3 .0 and 13 .0 pg/l, and at the upper
57
limit of detection of 20 jig/l, the true value could be
between 12 .0 and 28 .0 jig/l . For this reason, a regulatory
limit of 5
.2 jig/1 is not meaningful .
Indeed, the District believes that a reasonable conclu-
sion here would be that even the more conservative 7
.32 jig/1
WAD cyanide value, which is a calculated value designed to
protect rainbow trout, falls below the accepted analytical
range of precision of ± 8 .0 jig/l .
The District has a comprehensive quality assurance/
quality control (QA/QC) program in place at all of its
laboratories . The details of this program as it relates to
the WAD cyanide analysis is presented in Attachment 15
.
It can be noted in Attachment
15
that for the past 20
years the District has been researching methods for improving
cyanide analytical methodology . In 1977 the USEPA granted
the District approval of an alternate test procedure for
total cyanide and dissociable cyanide . The alternate test
procedure improved the accuracy and precision of the standard
cyanide test procedures (Attachment 16) .
In addition, the
District holds the following two patents which relate to
improvements in cyanide analysis :
1 . Patent No . US4,265,857 (1981) - Thin film dis-
tillation apparatus for total cyanide analysis .
2 . Patent No
. US4,804,631 (1989)
-
Apparatus for
differentiating total cyanide, simple cyanide,
and thiocyanate .
58
In early 1994, as
the District gained experience with
the Standard Methods WAD cyanide procedure, it became clear
that with our sample matrix, some modifications of the
Standard Methods procedure would be required to allow the
District to analyze for WAD cyanide at concentrations below 5
pg/l . This methodology is described in
Attachment 15 . Dr .
Richard Luthy reviewed this methodology when he visited our
laboratory, and as can be seen in his report
(Attachment 14),
he approves of our procedures .
It should also be noted that the USEPA continues to
think highly of our laboratory as evidenced by the fact that
the USEPA recently approved a District request for an al-
ternate test procedure relating to the chemical extraction
step of the "600 Series" of methods for priority pollutant
analysis
. Over two years of experimental work was involved
in gaining this approval
.
As stated previously, the Board has unwittingly placed a
considerable analytical burden on the District, since the
regulatory limit for WAD cyanide is so near the analytical
detection limit . This led the District to conduct additional
QA/QC studies above those routinely conducted in the labora-
tory to verify that we could accurately determine low Ug/l
levels of WAD cyanide on our actual sample matrix . These
studies consisted of spike recovery tests using known WAD
cyanide concentrations and the chlorinated and unchlorinated
effluents from the Hanover Park and James C
. Kirie WRPs . The
59
results of these studies are
presented in Attachment 17 and
demonstrate that the District's analytical methods are ca-
pable of accurately measuring WAD cyanide at low concentra-
tions as evidenced by excellent spike recoveries near the
limit of detection of the method .
Thus, the District believes that it has demonstrated to
the Board that the increased WAD cyanide concentrations that
are observed at these two WRPs during the chlorination/de-
chlorination season are not the result of poor analytical
techniques .
It is the District's understanding that no other munici-
pal wastewater dischargers in the state of Illinois are being
required to achieve a detection limit below 10 pg/l for WAD
cyanide . The District believes that requiring the develop-
ment of special analytical methodology to demonstrate com-
pliance with an inappropriate regulatory limit places an
undue burden on its resources as compared to other discharges
in the State, and is thus a significant factor to take into
account .
Also, while the District is disappointed that it is
being singled out to develop methodology to measure WAD cya-
nide concentrations below 10 pg/l, we believe that a WAD
cyanide limit of 10 pg/l would be more meaningful for the
following reasons :
60
1 . Dr
. Allen's calculated chronic value of 9 .799
jig/1 which is indistinguishable from 10 pg/1
will protect all species except rainbow trout
.
2 . Dr
. Luthy's determination that at the detection
limit (5-20 jig/1) for WAD cyanide the precision
is t8 .0 jig/l .
3 .
The District's demonstration, supported by Dr .
Luthy, that chlorine interference is signifi-
cant
for WAD cyanide measurements below 10
pg/1
.
4 .
The analytical burden of constantly trying to
measure WAD cyanide concentrations below 10
pg/l
.
5 .
The fallacy that reported WAD cyanide values of
<10 .0 pg/l obtained by existing methodology
provide any meaningful basis for technical
discussions relative
to indigenous aquatic
species toxicity .
6 . The Agency's affirmation that cold water spe-
cies such as rainbow trout are not indigenous
to the water bodies in this Petition .
7 . The value of 10 .0 pg/1 more properly targets
the aquatic species of concern in the affected
waterways .
Thus, notwithstanding the fact that the District is
prepared to be cooperative regarding analytical methodology
61
development, the need
for a WAD cyanide limit of <10
.0 pg/l
is not warranted .
JUSTIFIES
THE EXISTENCE
A SITE-SPECIFIC
OF THE FACTORS
REGULATIONRELATING
TO THE DISTRICT
The District's Petition clearly demonstrates that a num-
ber of unique factors exist which justify the adoption of a
site-specific regulation for WAD cyanide . The Petition also
demonstrates that no adverse environmental effects will re-
sult if the site-specific regulation for WAD cyanide is
adopted .
The District has a long history of being in the fore-
front of wastewater treatment in the state of
62
Illinois and
nationally . The three WRPs in question produce high quality
final effluents, and they will continue to produce these same
high quality effluents after the site-specific regulation is
adopted .
THE REQUESTED STANDARD IS PROTECTIVE OF HUMAN HEALTH AND THE
ENVIRONMENT
The District believes that this petition has amply
demonstrated that there will be no adverse environmental or
health effects caused by revising the chronic water quality
standard for WAD cyanide to protect indigenous species in the
rivers in question .
Approved USEPA methodology indicates
that rainbow trout, which are not present in these rivers,
would be the only species that might be affected by a
revision in the WAD cyanide standard
. However, the presence
of rainbow trout is not an issue here .
CONSISTENCY
LAW
OF PROPOSED SITE-SPECIFIC REGULATION WITH FEDERAL
As demonstrated above, the District has followed USEPA
guidelines in calculating the proposed General Use chronic
water quality standard for WAD cyanide
. The Board in R8B-21
actually took a very conservative approach to the cyanide
toxicity question by adopting a WAD cyanide standard that was
based solely upon toxicity to rainbow trout
. The USEPA
guidelines specify using the four most sensitive species
. In
addition, USEPA guidelines specify that the toxicity data is
based upon free cyanide concentrations
. The Board in R88-21
has taken the conservative approach of basing the cyanide
standard on WAD cyanide, which is a broader measure of
cyanide .
If the Board grants the proposed request for a site-
specific regulation it will be consistent with existing USEPA
guidelines and will conform with all applicable Federal
Regulations .
ADVISABLERECOMMENDATION
OF WHETHER AN ECONOMIC IMPACT STUDY IS
Section 27 of the Environmental Protection Act no longer
requires an "economic impact study" recommendation . The
District notes though that it is the only entity directly
63
affected by this rulemaking, and the economic impacts on the
District have already been described in this petition
.
SYNOPSIS OF TESTIMONY TO BE PRESENTED
The District anticipates that three individuals will
present testimony at the hearing on this proposal
.
A
synopsis of their testimony is as follows .
1 . Dr . Cecil Lue-Ring,
Director of Research and
Development at the District
Dr . Lue-Hing will present a summary of the en-
tire petition, which will include discussion of
the existing WAD cyanide standard, the existing
NPDES permits at the John E
. Egan, Hanover
Park, and James C . Kirie WRPS, and a review of
the studies that the District has conducted
relative to WAD cyanide . He will also discuss
the economic impacts to the District, and the
water quality of the rivers impacted by this
petition
. He will conclude by presenting the
proposed site-specific regulations that the
District is requesting .
2 . Dr . Richard Luthy, Consultant
Dr . Luthy will discuss the analytical method-
ology for determining WAD cyanide concentra-
tions, the method detection limits, and the
precision and accuracy of the WAD cyanide test .
64
He will also discuss his assessment of the
District's laboratory procedures .
His
presentation will summarize the information
contained in Attachments 12, 14, 15, and 17 .
3 . Dr . Herbert Allen, Consultant
Dr
. Allen will discuss USEPA methodologies for
deriving water quality criteria, and will
explain, in detail, the various options that
can be used for calculating a chronic water
standard for WAD cyanide . His presentation
will summarize the information contained in
Attachment 10 .
Summary Comments
The District has an outstanding record in providing high
quality wastewater treatment to the residents of Cook County .
The addition of an extremely conservative WAD cyanide limit
to the NPDES Permits for two of the District's WRPs has cre-
ated a situation where potential permit violations could
occur even though effluent quality remains high, and reported
WAD cyanide values would not endanger indigenous species .
This could result in an unnecessary expenditure of taxpayer
dollars for unneeded modifications to the WRPs .
The District believes that this Petition clearly demon-
strates that the existing General use chronic water quality
standard for WAD cyanide was promulgated based upon incom-
plete and overly conservative assumptions which do not relate
65
to the District's true situation
. The District believes that
it has provided in this Petition ample justification that is
technically feasible and economically reasonable, for a grant
by the Board of a site-specific regulation, and respectfully
asks the Board to so grant its Petition .
Respectfully
behalf of the
submitted
Metropolitanon
Water
of Greater
Reclamation
Chicago,District
by :
Cecil
Metropolitan
100
District
East
Lue-Hing,
Erieof
Water
Greater
D.ScReclamation.,
ChicagoP.E
.
Chicago, Illinois 60611
(312)751-5190
66
PROPOSED ORDER FOR ILLINOIS REGISTER
Section 302 .208
Numeric
stituentsStandards
for Chemical Con-
f)
DuPage
The
County,00718)to
Salt
chronic
River,listed
Creek,Illinoisstandard
in
andHiggins
.
Sectionthe(CS)Creek,Desfor
302.208(d)thePlainescyanide
Westshall
(STORET
BranchRivernot
in
numberof
applyCookthe
Section 303 .444
Salt
theDuPage
Creek,River,
Higgins
Des
Creek,
Plaines
West
RiverBranch
of
DuPage
Theapply
Illinoiscyanide(STORET
General
to
River,number
standard
.
Salt
Instead,UseCreek,00718)andof
chronic10
these
thecontainedHigginspg/1Deswaterwaters
.
PlainesCreek,quality
in
shall
Section
Riverthe
comply
standardWest
302inwith
.208
Branch
Cookfor
a
shall
chroniccyanideCounty,of
thenot
Section 304
.201 Wastewater
tionthe
Metropolitan
District
Treatment
of Greater
SanitaryPlant
ChicagoDischarges
Water Reclama-of
d) JohnReclamation
E
. Egan,PlantsHanover Park, and James C
. Kirie Water
The
meetand304of
10
.104(
discharges
Jamesapg/l,monthly
a) .
Csubject
.
ofaverage
Kirietheto WaterWAD
the
Johncyanide
averaging
ReclamationE
. Egan,effluent
rule
HanoverPlants
of
standardSectionPark,must
67
Attachment 1
Attachment 2
Attachment 3
Attachment 4
Attachment 5
Attachment 6
Attachment 7
Attachment 8
Attachment 9
Attachment 10
Attachment 11
Attachment 12
Attachment 13
LIST OF ATTACHMENTS
Resume of Dr . Richard G . Luthy
Resume of Dr . Herbert E . Allen
James
1994 Final
C . Kirie,
Effluent
and Hanover
Quality
Park
of the
WRPsJohn
E
. Egan,
Concentrations
Daily Raw Sewage
from
and Final
the James
Effluent
C .
WAD
Kirie
Cyanideand
Hanover Park WRPs
WAD
Hanover
During
Cyanide
Park
Treatment
WRPsConcentrations
at the James
at Various
C . Kirie
Pointsand
WRPsWAD
Discharges
Cyanide
to
Concentrations
the James C . Kirie
in Industrial
and Hanover
WastePark
Cost
Hanover
Dechlorination
Estimate
Park WRPsfor
Systems
Replacing
at the
the
James
Chlorination/C
. Kirie and
1993 and 1994 Biomonitoring Results from the John
E . Egan, James C . Kirie, and Hanover Park WRPs
Upstream
Statistical
and
Analysis
Downstream
of
of
Water
the
Quality
John E . Egan,Data
James C . Kirie, and Hanover Park WRP
Report
of Chemistry,
by Dr . Herbert
Toxicology
E . Allen
and
Entitled
Standards
"Reviewfor
Effluents
Cyanide Species
and Receiving
in Water
Waters
Reclamation
--
Application
Plantto
Metropolitan
Greater Chicago"Water
Reclamation District of
Excerpts from Illinois Environmental Protection
Agency Testimony to the Board in the R94-1
Rulemaking
Letter from Dr . Richard G . Luthy Discussing
Cyanide Speciation
Laboratory Data
Interference in the WAD
Demonstrating
Cyanide Analysisa
Chlorine
68
LIST OF ATTACHMENTS (continued)
Attachment 14
Letter from Dr
. Richard G
. Luthy Discussing
Detection Limits for Cyanide Analyses
Attachment 15 Analytical
Quality Assurance
Methodology
Procedures
and
for
Quality
the WAD
Control/Cyanide
Analysis
Attachment 16 Letter
Procedure
from
for
USEPA
Cyanide
Approving
Analysis
Alternate Test
Attachment 17
Spike Recoveries of WAD Cyanide in Effluent
Matrix
69
