v.
    )
    PCB
    No.
    08-86
    )
    (NPDES
    Permit
    Appeal)
    ILLINOIS
    ENVIRONMENTAL
    )
    PROTECTION
    AGENCY,
    )
    Respondent.
    )
    NOTICE
    OF
    FILING
    //
    /
    To:
    James
    Therriault,
    Clerk
    Carol
    Webb
    Illinois
    Pollution
    Control
    Board
    Hearing
    Officer
    James
    R.
    Thompson
    Center
    Illinois
    Pollution
    Control
    Board
    Suite
    11-500
    1021
    North
    Grand
    Avenue
    East
    100
    West
    Randolph
    Street
    P.O.
    Box
    19274
    Chicago,
    IL
    60601-32
    18
    Springfield,
    IL
    62794-9274
    Thomas
    Davis
    Division
    of
    Legal
    Counsel
    Illinois
    Attorney
    General’s
    Office
    500
    South
    Second
    Street
    Springfield,
    IL
    62706
    On
    October
    5,
    2009,
    the
    Hearing
    Officer
    advised
    Petitioner’s
    counsel
    that
    the
    Board
    requested
    that
    Petitioner
    file
    two
    color
    copies
    of
    photographs,
    charts,
    etc.,
    found
    within
    pages
    304-33
    1
    (September
    11,
    2007,
    CDM
    Memo)
    and
    pages
    338-359
    (September
    21,
    2007,
    CDM
    Memo)
    of
    the
    Record.
    Accordingly,
    two
    color
    copies
    of
    the
    September
    1
    1,
    2007,
    CDM
    Memo
    and
    the
    September
    21,
    2007,
    CDM
    Memo
    are
    attached
    hereto.
    CITY
    OF
    QUINCY,
    an
    Illinois
    municipal
    corporation,
    Petitioner
    By
    ZD
    Q
    Joel
    A.
    Benoit
    MOHAN,
    ALE
    WELT,
    PRILLAMAN
    &
    ADAMI
    1
    N.
    Old
    Capitol
    Plaza,
    Ste.
    325
    Springfield,
    IL
    62701
    Telephone:
    217/528-2517
    Facsimile:
    217/528-2553
    THIS
    FILING
    IS
    SUBMITTED
    ON
    RECYCLED
    PAPER

    James
    Therriault,
    Clerk
    Illinois
    Pollution
    Control
    Board
    James
    R.
    Thompson
    Center
    Suite
    11-500
    100
    West
    Randolph
    Street
    Chicago,
    IL
    60601-32
    18
    and
    a
    true
    and
    correct
    copy
    of
    this
    Notice
    of
    Filing,
    without
    copies
    of
    the
    September
    11,
    2007,
    CDM
    memo
    and
    the
    September
    21,
    2007,
    CDM
    Memo,
    was
    today
    served
    upon
    the
    hearing
    officer
    and
    counsel
    of
    record
    by
    enclosing
    the
    same
    in
    envelopes
    addressed
    to
    such
    attorneys
    and
    to
    said
    hearing
    officer
    with
    postage
    filly
    prepaid,
    and
    by
    depositing
    said
    envelopes
    in
    a
    U.S.
    Post
    Office
    Mailbox
    in
    Springfield,
    Illinois
    on
    the
    A
    day
    of
    October,
    2009.
    Thomas
    Davis
    Division
    of
    Legal
    Counsel
    Illinois
    Attorney
    General’s
    Office
    500
    South
    SecondStreet
    Springfield,
    IL
    62706
    Carol
    Webb
    Hearing
    Officer
    Illinois
    Pollution
    Control
    Board
    1021
    North
    Grand
    Avenue
    East
    P.O.
    Box
    19274
    Springfield,
    IL
    62794-9274
    Joel
    A.
    Benoit
    MOHAN,
    ALEWELT,
    PR1LLAMAN
    &
    ADAMI
    1
    N.
    Old
    Capitol
    Plaza,
    Ste.325
    Springfield,
    IL
    62701
    Telephone:
    217/528-2517
    Facsimile:
    217/528-2553
    THIS
    FIIJNG
    IS
    SUBMITTED
    ON
    RECYCLED
    PAPER
    C:\Mapa\Quincy\Not
    Filing
    color
    copieswpd/crk
    10/9/09
    4:12pm
    2

    Date:
    11
    September
    2007
    Subject:
    Primaty
    Recreation
    Contact
    Survey
    for
    Curtis
    Creek
    and
    Whipple
    Creek,
    City
    of
    Quincy,
    Illinois
    INTRODUCTION
    The
    City
    of
    Quincy
    has
    received
    a
    Draft
    NPDES
    permit
    (1L0030503)
    from
    the
    Illinois
    Environmental
    Protection
    Agency
    (IEPA)
    that
    describes
    three
    CSO
    outfalls
    (002,
    006,
    and
    007)
    as
    discharging
    to
    sensitive
    areas.
    Prior
    to
    this
    draft
    permit,
    IEPA
    had
    consistently
    found
    that
    these
    three
    CSO
    outfalls
    did
    not
    discharge
    to
    sensitive
    areas.
    The
    waterbodies
    in
    question
    are
    as
    follows:
    Curtis
    Creek
    downstream
    South
    Side
    CSO
    Outfall
    002
    discharge
    CedarStreet
    CSO
    Outfall
    006
    discharging
    to
    Quincy
    Bay
    Whipple
    Creek
    downstream
    CSO
    Outfall
    007
    discharge
    Responding
    to
    the
    City
    of
    Quincy’s
    request
    for
    an
    explanation,
    the
    IEPA
    stated
    that
    it
    believed
    these
    waterbodies
    to
    be
    suitable
    for
    primary
    contact
    recreation
    because
    they
    flow
    through
    residential
    areas
    or
    public
    use
    areas
    that
    have
    a
    high
    probability
    for
    primary
    contact
    activity
    (IEPA
    letter
    dated
    August
    28,
    2007).
    However,
    based
    uponour
    investigation
    and
    our
    experience
    in
    such
    matters,
    it
    is
    our
    opinion
    that
    none
    of
    these
    waterbodies
    have
    a
    high
    probability
    for
    primary
    contact
    activity,
    nor
    do
    any
    of
    themcontain
    any
    of
    the
    features
    that
    would
    qualify
    them
    as
    “sensitive
    areas.”
    Primary
    contact
    use
    is
    defined
    as
    ‘any
    recreationalor
    other
    water
    use
    in
    which
    there
    is
    prolonged
    and
    intimate
    contact
    with
    the
    water
    [wherethe
    physical
    configuration
    of
    the
    water
    bodypermits
    it]
    involving
    considerable
    risks
    of
    ingesting
    water
    in
    quantities
    sufficient
    to
    pose
    a
    significant
    healthhazard,
    such
    as
    swimming
    or
    water
    skiing.”
    (35
    III.
    Adm.
    Code
    301.355).
    A
    water
    body
    that
    is
    designated
    as
    primary
    contact
    is
    protected
    under
    the
    Illinois
    General
    Use
    Standards
    (35
    III.
    Adm.
    Code
    Part
    302,
    Subpart
    B).
    To
    assess
    primary
    contact
    use
    in
    streams
    in
    rivers,
    IEPA
    uses
    fecal
    coliform
    bacteria
    from
    water
    samples
    collected
    from
    a
    waterbody
    to
    determine
    if
    the
    water
    quality
    standard
    for
    fecal
    coliform
    bacteria
    is
    being
    met.
    35
    Ill.
    Adm.
    Code
    302.209
    states
    that
    “During
    the
    months
    May
    through
    October,
    based
    on
    a
    minimum
    of
    five
    samples
    taken
    over
    not
    more
    than
    a
    30
    day
    period,
    fecal
    coliform
    shall
    not
    exceed
    a
    geometric
    mean
    of
    200
    per
    100
    ml
    norshall
    more
    than
    10%
    ofthe
    samples
    during
    any
    30
    dayperiod
    exceed
    400
    per
    100
    ml
    in
    protected
    waters.
    Protected
    waters
    1-1

    be
    frequented
    by
    the
    public
    on
    a
    routine
    basis
    as
    determined
    by
    the
    Agency
    at
    35
    Ill.
    Adm.
    Code
    309.
    Subpart
    A,
    are
    exempt
    from
    this
    standard.”
    METHODS
    To
    determine
    if
    the
    above
    situation
    applies
    to
    the
    sensitive
    areas
    defined
    in
    the
    City’s
    Draft
    NPDES
    permit,
    a
    stream
    assessment
    survey
    was
    conducted
    of
    Whipple
    Creek
    and
    Curtis
    Creek
    to
    determine
    if
    primary
    contact
    uses
    were
    occurring
    and
    if
    not
    what
    were
    the
    limiting
    factors
    that
    prevent
    the
    attainment
    of
    that
    use.
    On
    August
    20
    th
    representatives
    from
    CDM
    and
    Klingner
    &
    Associates,
    P.C.
    conducted
    a
    preliminary
    tour
    of
    CSO
    Outfalls
    002,
    006,
    and
    007
    to
    develop
    a
    study
    approach
    to
    identifying
    existing
    uses
    downstream
    of
    the
    CSO
    discharges.
    Under
    CDM’s
    direction,
    a
    more
    detailed
    stream
    assessment
    was
    conducted
    on
    August
    23
    (Whipple
    Creek)
    andAugust
    28
    (Curtis
    Creek)
    by
    representatives
    from
    Klingner.
    Attachment
    A
    to
    this
    report
    is
    an
    example
    field
    data
    sheet
    that
    the
    field
    crew
    completed
    while
    conducting
    the
    stream
    assessment.
    Key
    metrics
    to
    be
    evaluated
    werewater
    depth,
    wetted
    stream
    width,
    visible
    signs
    of
    recreation
    (e.g.
    swimming),
    access
    to
    the
    site
    and
    proximity
    of
    residential
    and
    park
    areas.
    Sampling
    locations
    (T-_)
    were
    spaced
    300
    feet
    apart,
    starting
    upstream
    of
    the
    CSO
    discharge
    (Figures
    1
    and
    2).
    At
    each
    sampling
    location,
    a
    transect
    was
    placed
    across
    the
    stream,
    and
    depth
    measurements
    were
    taken
    at
    three
    equally
    distributed
    locations
    across
    the
    transect.
    RESULTS
    Whipple
    Creek
    Approximately
    3,330
    feet
    of
    stream
    from
    the
    CSO
    discharge
    point
    to
    theconfluence
    of
    Cedar
    Creek
    was
    surveyed
    in
    this
    study.
    Wetted
    stream
    width
    in
    Whipple
    Creek
    downstream
    of
    the
    CSO
    discharge,
    ranged
    from
    I
    to
    18
    feet,
    with
    the
    average
    stream
    width
    being
    8.8
    feet
    (Table
    1).
    Depths
    in
    Whipple
    Creek
    ranged
    from
    0
    to
    4.8
    inches,
    with
    the
    average
    depth
    at
    1
    .5
    inches.
    Attachment
    B
    contains
    photographs
    showing
    stream
    depths
    at
    selected
    locations
    in
    Whipple
    Creek.
    The
    stream
    bottom
    consisted
    mostly
    of
    exposed
    bedrock,
    with
    limited
    areas
    of
    cobble
    and
    gravel.
    Over
    95%
    of
    the
    stream
    bank
    was
    rated
    DIFFICULT
    for
    access
    to
    the
    waterbody,
    and
    moderate
    to
    steep
    for
    bank
    slope.
    Both
    stream
    banks
    are
    densely
    populated
    by
    trees
    and
    shrubs,
    the
    under
    story
    composed
    of
    herbaceous
    vegetation
    dominated
    by
    poison
    ivy
    (Toxicodendron
    radicans).
    cOM
    1-2

    T-1B
    T-17
    1-3

    coM
    1-4

    No
    visual
    evidence
    of
    recreation
    activity
    (swimming,
    wading,etc)
    past
    or
    present
    was
    observed
    in
    the
    creek
    during
    thesurvey.
    Past
    recreational
    activity
    was
    identified
    by
    looking
    for
    rope
    swingsover
    the
    water,
    paths
    or
    trails
    to
    the
    creek
    or
    the
    presence
    of
    bait
    containers
    and
    “Y”
    sticks
    used
    for
    fishing.
    The
    creek
    is
    not
    deep
    enough
    or
    provides
    sufficient
    flow
    to
    support
    recreational
    watercraft
    such
    canoes,
    kayaks
    and
    powerboats.
    No
    established
    beaches
    or
    public
    access
    points
    to
    the
    creek
    were
    present
    alongWhipple
    Creek.
    Along
    with
    not
    supporting
    primary
    contact
    recreation,
    Whipple
    Creek
    has
    not
    been
    designated
    an
    Outstanding
    National
    Resource
    Water.
    It
    does
    not
    contain
    threatened
    or
    endangered
    species,
    has
    no
    public
    water
    intake
    structures
    and
    contains
    no
    shellfish
    beds.
    Curtis
    Creek
    Approximately
    5,900
    feet
    of
    Curtis
    Creek
    was
    surveyed
    in
    thisstudy,starting
    just
    upstream
    of
    the
    CSO
    Outfall
    002
    to
    theconfluence
    with
    the
    Mississippi
    River.
    The
    wetted
    stream
    width
    ranged
    from
    7
    to
    60
    feet,
    with
    the
    average
    width
    being
    31.5
    feet(Table
    2).
    T-2
    3.0
    0.6
    1.2
    0.6
    T-3
    0.0
    0.0
    0.0
    0.0
    T-4
    0.0
    0.0
    0.0
    0.0
    T-5
    7.0
    0.6
    1.2
    0.6
    T-6
    10.0
    2.4
    4.8
    2.4
    T-7
    0.0
    0.0
    0.0
    0.0
    T-8
    11.0
    1.2
    3.6
    1.2
    T-9
    10.0
    0.6
    1.2
    0.6
    T-10
    11.0
    1.2
    3.6
    1.2
    T-11
    8.0
    0.6
    2.4
    0.6
    T-12
    18.0
    1.2
    2.4
    1.2
    1-5

    T-2
    42.0
    18.0
    12.0
    18.0
    T-3
    38.0
    9.6
    9.6
    9.6
    T-4
    34.0
    2.4
    2.4
    2.4
    T-5
    8.0
    3.6
    1.8
    9.6
    T-6
    13.0
    4.8
    6.0
    4.8
    T-7
    13.0
    3.6
    2.4
    3.6
    T-8
    22.0
    8.4
    9.6
    7.8
    T-9
    7.0
    6.0
    4.2
    4.2
    T-1
    0
    21.0
    19.2
    19.2
    16.8
    T-11
    37.0
    26.4
    34.8
    49.2
    T-
    12
    40.0
    N/A
    N/A
    N/A
    T-1
    3
    N/A
    N/A
    N/A
    N/A
    T-1
    4
    35.0
    N/A
    N/A
    N/A
    T-
    15
    60.0
    N/A
    N/A
    N/A
    T-1
    6
    55.0
    N/A
    N/A
    N/A
    T-1
    7
    50.0
    N/A
    N/A
    N/A
    T-1
    8
    35.0
    N/A
    N/A
    N/A
    T-1
    9
    40.0
    N/A
    N/A
    N/A
    T-20
    40.0
    N/A
    N/A
    N/A
    N/A=
    Not
    Available-
    Water
    conditions
    were
    high
    and
    Mississippi
    River
    DM
    unsafe
    to
    access
    due
    to
    backflow
    from
    the
    1-6

    waterbody,
    and
    moderate
    to
    steep
    for
    bank
    slope.
    The
    lower
    portions
    of
    the
    creek
    flow
    through
    an
    industrial
    area
    with
    concrete
    bank
    walls
    and
    is
    channelized
    until
    the
    confluence
    with
    the
    Mississippi
    River.
    In
    the
    upper
    reaches,
    stream
    banks
    were
    densely
    populated
    by
    trees
    and
    shrubs
    making
    access
    to
    the
    creek
    difficult.
    As
    observed
    on
    Whipple
    Creek,the
    under
    story
    is
    composed
    of
    herbaceous
    vegetation
    dominated
    by
    poison
    ivy.
    No
    visual
    evidence
    of
    recreation
    activity
    (swimming,
    wading,
    etc)
    past
    or
    present
    wasobserved
    in
    Curtis
    Creek
    during
    the
    survey.
    Past
    recreational
    activity
    was
    identified
    by
    looking
    for
    rope
    swings
    over
    the
    water,
    paths
    or
    trails
    to
    the
    creek
    or
    the
    presence
    of
    bait
    containers
    and
    “Y”
    sticks
    used
    for
    fishing.
    The
    upper
    half
    of
    Curtis
    Creek
    is
    not
    deep
    enough
    or
    provides
    sufficient
    flow
    to
    support
    recreational
    watercraft
    such
    canoes,
    kayaks,
    and
    powerboats.
    No
    established
    beaches
    or
    public
    access
    points
    to
    the
    creek
    were
    present
    alongCurtis
    Creek.
    Along
    with
    not
    supporting
    primary
    contact
    recreation,
    Curtis
    Creek
    has
    not
    been
    designated
    an
    Outstanding
    National
    Resource
    Water,
    does
    not
    contain
    threatened
    or
    endangered
    species,
    has
    no
    public
    water
    intake
    structures
    and
    contains
    no
    shellfish
    beds.
    DISCUSSION
    The
    United
    States
    Environmental
    Protection
    Agency
    (EPA)
    Combined
    Sewer
    Overflow
    (CSO)
    Control
    Policy
    states
    (Federal
    Register
    Vol.
    59,
    No.75,
    1994)
    that
    “...a
    permittees
    long-term
    control
    plan
    to
    give
    the
    highest
    priority
    to
    controlling
    overflows
    to
    sensitive
    areas.”
    Sensitive
    areas
    as
    defined
    by
    EPA
    include:
    Outstanding
    National
    Resource
    Waters
    National
    Marine
    Sanctuaries
    Waters
    with
    threatened
    or
    endangered
    species
    and
    their
    habitat
    Waters
    with
    primary
    contact
    recreation
    Public
    drinking
    water
    intakes
    or
    their
    designated
    protection
    areas;
    and,
    Shellfish
    beds
    Both
    Whipple
    Creek
    and
    Curtis
    Creek
    were
    evaluated
    to
    determine
    if
    they
    contained
    any
    of
    the
    features
    identified
    above,
    with
    particularly
    emphasis
    on
    “waters
    with
    primary
    contact
    recreation”.
    1-7

    portion
    of
    the
    creek
    is
    channelized
    and
    lined
    with
    concrete
    in
    selected
    locations.The
    lower
    reach
    beforetheconfluence
    with
    the
    Mississippi
    River
    has
    steep
    banks
    that
    are
    densely
    vegetated
    with
    trees
    and
    shrubs.
    Public
    access
    to
    this
    portion
    of
    Curtis
    Creek
    is
    restricted
    by
    the
    dense
    vegetation
    and
    steep
    banks.
    Based
    upon
    the
    physical
    and
    hydrologic
    configuration
    of
    the
    stream
    channel
    to
    support
    primary
    contact
    recreation,the
    probability
    that
    the
    stream
    is
    accessed
    by
    the
    public
    on
    a
    routine
    basis
    is
    low.
    Although
    Whipple
    Creek
    flows
    by
    several
    residential
    areas
    in
    its
    upper
    reaches
    (Figure
    4),
    access
    to
    the
    creek
    is
    very
    difficult.
    Stream
    banksare
    steep
    and
    densely
    covered
    with
    vegetation,and
    at
    most
    sites
    the
    under
    story
    is
    dominated
    by
    poison
    ivy.
    There
    is
    low
    probability
    that
    individuals
    from
    the
    residential
    areas
    are
    visiting
    or
    recreating
    in
    the
    creek
    on
    a
    routine
    basis.
    Based
    upon
    the
    recentuse
    survey
    and
    the
    physical
    obstacles
    thatprevent
    access
    to
    the
    two
    creeks,
    primary
    contact
    recreation
    is
    not
    an
    existing
    use.
    Although
    IEPA
    now
    states
    that
    there
    is
    a
    high
    probability
    of
    primary
    contact
    activity,
    this
    statement
    alone,
    which
    contradicts
    its
    previous
    findings,
    cannot
    support
    its
    conclusion
    that
    the
    streams
    in
    questioncan
    be
    designated
    “primary
    contact
    recreation”
    streams,
    particularly
    in
    light
    of
    all
    evidence
    to
    the
    contrary.
    Recently,
    IEPA
    has
    proposed
    new
    standards
    for
    the
    Chicago
    Area
    Waterway
    System
    (CAWS)
    through
    aUse
    Attainability
    Analysis
    approach
    (www.chicaqoareawaterways.org)
    in
    a
    Draft
    Report
    (November
    2004).
    Although
    the
    CAWS
    areadjacent
    to
    numerous
    residential
    areas
    and
    parks,
    and
    the
    water
    depth
    is
    sufficient
    to
    support
    swimming
    and
    waterskiing,
    IEPA
    and
    the
    stakeholder
    group
    determinedthat
    primary
    contact
    recreation
    was
    not
    an
    existing
    or
    potential
    use
    and
    therefore
    certain
    general
    use
    water
    quality
    standards
    do
    notapply.
    Instead
    new
    use
    designations
    and
    water
    quality
    standards
    are
    being
    proposed
    by
    IEPA
    for
    the
    CAWS.
    CSO
    Outfall
    006,
    Discharging
    Into
    the
    Mississippi
    River
    With
    regard
    to
    CSO
    Outfall
    006
    discharging
    to
    a
    sensitive
    area
    in
    Quincy
    Bay,
    it
    should
    benoted
    that
    Quincy
    Bay
    is
    not
    a
    designated
    waterway
    and
    is
    only
    a
    backwaterchannel
    of
    the
    Mississippi
    River.
    Therefore,
    it
    should
    be
    corrected
    in
    the
    City’s
    NDPES
    Permit
    that
    the
    receiving
    water
    is
    the
    Mississippi
    River.
    There
    is
    no
    known
    water
    supply
    intake
    in
    the
    vicinity
    of
    CSO
    Outfall
    006
    and
    primary
    contact
    recreation
    has
    not
    beenobserved
    in
    the
    Quincy
    Bay
    portion
    of
    the
    Mississippi
    River.
    There
    are
    several
    public
    boat
    launches
    and
    severalparks
    along
    thisportion
    of
    the
    river,
    but
    the
    physical
    limitations
    of
    the
    waterway
    itself
    may
    prevent
    primary
    contact
    recreation
    from
    occurring.
    Physical
    limitations
    include
    rip-rap
    banks,
    deep
    sediments
    and
    unstable
    bottoms.
    There
    is
    a
    no-wake
    policy
    on
    this
    portion
    of
    the
    waterway,
    therefore
    waterskiing
    would
    not
    be
    a
    recreational
    activity
    likely
    to
    occur.
    Based
    upon
    the
    presence
    of
    boat
    launches
    and
    several
    marinas,
    recreational
    navigation
    would
    be
    the
    existing
    use
    on
    this
    portion
    of
    the
    Mississippi
    River.
    There
    are
    no
    known
    shellfish
    beds
    downstream
    of
    CSO
    Outfall
    006.
    1-8

    request
    that
    IEPA
    remove
    thesensitive
    area
    designation
    from
    its
    draft
    permit
    until
    the
    LTCP
    is
    completed.
    If
    evidence
    surfaces
    during
    the
    LTCP
    process
    which
    suggests
    a
    change
    to
    the
    designation
    of
    any
    of
    these
    waterbodies,
    thisinformation
    would
    bethoroughly
    evaluated
    and,
    if
    necessary,
    the
    change
    made,
    as
    part
    of
    the
    LTCP.
    cOM
    1-9

    1-10

    1—11

    Transect
    Number
    T
    __________
    Transect
    Location
    (GPS
    coordinates)
    Parameter
    to
    Measure
    Transect
    Location
    insert
    or
    circle
    appropriate
    value
    Stream
    Bottom
    A-
    Transect
    Point
    bedrock,boulder,cobble,
    gravel,
    sand
    B-
    Transect
    Point
    bedrock,boulder,cobble,
    gravel,
    sand
    C-
    Transect
    Point
    bedrock,
    boulder,
    cobble,
    gravel,
    sand
    Stream
    Width
    (feet)
    Wetted
    Stream
    Width
    Stream
    Depth
    (inches)
    A-
    Transect
    Point
    B-
    Transect
    Point
    C-
    Transect
    Point
    Vegetationat
    Top
    of
    Bank
    Right
    Bank
    trees,
    shrubs,
    weeds,
    grass,
    lawn,
    crop
    Left
    Bank
    trees,
    shrubs,
    weeds,grass,
    lawn,
    crop
    Stream
    Velocity
    slight
    (few
    to
    no
    riffles)
    moderate(balance
    of
    pools
    &
    riffles)
    high(primarily
    riffles)
    Bank
    Slope
    Right
    Bank
    0.3
    slight
    (3:1
    or
    less)
    0.6
    moderate
    (>3:1
    but
    <
    1:1.1)
    1.0
    steep
    (1:1
    to
    vertical)
    Left
    Bank
    0.3slight
    (3:1
    or
    less)
    0.6
    moderate
    (>3:1
    but
    <
    1:1.1)
    1.0
    steep
    (1:1
    to
    vertical)
    Access
    to
    Site
    at
    Transect
    Left
    Bank
    easy,
    moderate,
    difficult
    Right
    Bank
    easy,
    moderate,
    difficult
    Water
    Clarity
    Visual
    Observation
    Clear,
    murky,
    silty,
    turbid
    Photographs
    (digital
    andrecord
    photograph
    number):
    Looking
    Upstream
    of
    Transect____________
    Looking
    Downstream
    of
    Transect__________
    Photograph
    of
    Measuring
    Rod
    at
    Transect
    B_____
    Photograph
    of
    Right
    Bank_________
    Photograph
    of
    Left
    Bank
    1-12

    r
    Ou(fallj
    &
    cOM
    t3
    TraflseC
    NUmt
    Transeci
    Line
    Lref
    ¶sed
    nUtbC?$
    no4
    up$tve
    end
    0!
    reach
    Til
    Transect
    Transect
    A
    B
    C
    Wetted
    Width
    Stream
    Bottom
    TI
    13
    1-13

    2)
    Any
    observed
    wading?_____________
    3)
    Any
    observed
    water
    skiing?__________
    4)
    Any
    rope
    swings?_________
    5)
    Any
    bait
    buckets,
    wormcontainers
    to
    indicate
    fishing
    in
    the
    area?__________
    6)
    Anyother
    recreational
    use
    of
    the
    waterbody?
    If
    yes,
    please
    identif’:
    OtherObservations
    or
    Notes:
    1-14

    -
    -
    -
    -
    -
    -
    FP
    -__;‘_
    Figure
    B-i
    CSO
    Outfall
    007
    on
    Whipple
    Creek
    (Photo
    W203)
    -
    ::
    -‘
    I
    -
    .—,
    .
    .-,-.
    -
    D
    ‘‘-::‘
    -..
    e:-
    -
    3L-
    -
    -
    -;
    ‘:
    -
    ---.
    -
    -
    ;.
    e--
    -
    .-
    -
    -
    —.--/
    --
    ‘I’
    =
    -
    -
    -
    -
    I—
    Figure
    B-2-
    Looking
    Downstream
    CSO
    Outfall
    007on
    Whipple
    Creek
    (T-2)
    (Photo
    W202)
    coma
    1-15

    0)


    Figure
    8-7-
    Whipple
    Creek
    Water
    Depth
    Just
    West
    of
    3
    rd
    Street
    (T-8)
    (Photo
    W803)
    ‘I
    zcE*:z
    Figure
    8-8-
    Whipple
    Creek
    Channel
    Looking
    Upstream
    at
    T-11
    (Photo
    WilOl)
    1-18

    CD

    of
    CO
    Outfall
    002
    (Photo
    C201)
    coM
    1-20

    Figure
    C-
    4-
    100
    Feet
    Downstream
    of
    CSO
    Outfall
    002
    (T-3)
    (Photo
    W301)
    OM
    r
    .
    C-
    3-
    Looking
    Upstream
    at
    CL
    J
    Outfall
    0
    1-3)
    (ihoto
    C_
    -,
    -
    -
    :
    -
    -
    -
    -
    -
    -
    -
    ‘_
    *7.b
    g:36Apq
    1-21

    coM
    1-22

    C)

    *
    2aC-4t
    ttpk
    -
    -ct:::%
    S?--
    ad
    .
    c
    -4
    e
    -
    -
    -
    h_a
    -
    fla
    r
    ?-
    -f
    -.,
    -.
    -
    -.
    ‘-ë2
    --
    —-
    3tC—
    Figure
    C-
    9-
    Curtis
    Creek
    Streambedat
    T-5
    (Photo
    C503)
    4’
    *-?
    tft
    t-
    -
    ‘Z
    -
    ;.=&
    -
    4
    -
    fl—r
    -
    -
    r
    -
    -
    :
    -“r
    a
    •.
    -
    -.S
    If
    E
    j
    -
    ta-c
    Figure
    C-
    10-
    Water
    Depth
    in
    Curtis
    Creek
    at
    T-5
    (Photo
    C501)
    comi
    1-24

    Figure
    C-
    11-
    Left
    Bank
    of
    Curtis
    Creek
    at
    T-6
    (Photo
    C605).
    Figure
    C-
    li
    Curtis
    Cr
    Looking
    Upstream
    at
    T-7
    (Photo
    C702)
    1-25

    1-26
    Figure
    C-
    14-
    CurtisCreek
    Water
    Depth
    at
    T-8
    (Photo
    C801)
    2?
    10:15AM

    C-
    15-
    CurtisCreek
    Looking
    Upstream
    at
    T-j
    Figure
    C-
    16-
    Curtis
    Creek
    Looking
    Upstream
    at
    T-11
    (Photo
    C1104)
    DM
    1-27

    Figure
    C-
    18-
    Curtis
    Creek
    -
    at
    T-20
    1-28

    Date:
    21
    September
    2007
    Subject:
    Recreational
    Use
    Survey
    of
    Quincy
    Bay,
    City
    of
    Quincy,
    Illinois
    INTRODUCTION
    In
    my
    memo
    dated
    10
    September
    2007,
    I
    discussed
    the
    physical
    surveysconducted
    on
    Curtis
    Creek
    and
    Whipple
    Creek
    as
    they
    relate
    to
    potential
    listing
    of
    sensitive
    areas
    in
    the
    City’s
    Draft
    NPDES
    Permit
    (lL0030503).
    Quincy
    Bay,
    the
    receiving
    waters
    for
    Cedar
    Street
    CSO
    006,
    was
    also
    listed
    as
    a
    “sensitive
    area”
    in
    the
    City’s
    draft
    permit,
    but
    was
    not
    fully
    evaluated
    during
    the
    streamsurveys
    conducted
    in
    late
    August.
    In
    July
    2007,
    IEPA
    identified
    Quincy
    Bay
    as
    a
    sensitive
    area
    because
    it
    could
    potentially
    support
    primary
    contact
    recreation.
    METHODS
    To
    determine
    if
    the
    above
    situation
    applies
    to
    Quincy
    Bay
    as
    defined
    in
    the
    City’s
    Draft
    NPDES
    permit,a
    physical
    andrecreational
    survey
    was
    conducted
    where
    CedarStreet
    CSO
    enters
    into
    the
    Mississippi
    River
    (Figure
    1).
    When
    discharging,
    the
    Cedar
    Street
    CSO
    flows
    into
    the
    east
    side
    of
    the
    Mississippi
    River
    channel
    across
    from
    Quinsippi
    Island.
    This
    channel
    is
    hydraulically
    connected
    to
    the
    Mississippi
    River
    and
    is
    not
    anisolated
    backwaterchannel
    or
    bay.
    The
    backwater
    bay
    called
    Quincy
    Bay
    most
    likely
    begins
    justupstream
    of
    the
    Cedar
    Creek
    confluence
    with
    the
    Mississippi
    River
    channel
    and
    includes
    anopen
    water
    and
    floodplain
    area
    of
    approximately
    1,300
    acres.
    The
    average
    depth
    in
    Quincy
    Bay
    is
    approximately
    two
    feet
    (US
    Army
    Corps
    Map-
    27
    Aug
    2007)
    and
    appears
    to
    be
    silting
    in.
    Cedar
    Street
    CSO
    outfall
    is
    approximately
    1,800
    feet
    downstream
    of
    Quincy
    Bay
    and
    most
    likely
    does
    notbackflow
    into
    the
    bay
    during
    discharge
    events.
    However,
    flood
    events
    in
    the
    Mississippi
    River
    could
    create
    a
    backflow
    situation
    into
    Quincy
    Bay
    from
    the
    CedarStreet
    CSOwhen
    discharging.
    On
    September
    18
    th
    representatives
    from
    CDM
    and
    Klingner
    &
    Associates,
    P.C.
    conducted
    a
    boat
    survey
    of
    the
    Mississippi
    River
    channel
    from
    a
    point
    immediately
    north
    of
    Cedar
    Creek
    to
    the
    southern
    tip
    of
    Quinsippi
    Island
    (Figure
    2).
    An
    assessment
    of
    Art
    Keller
    Marina
    on
    the
    western
    portion
    of
    the
    channel
    was
    alsoconducted.
    Additionally,
    representatives
    from
    CDM
    conducted
    a
    walking
    assessment
    to
    determine
    recreational
    access
    to
    the
    channel
    from
    both
    the
    east
    and
    west
    banks.
    Key
    metrics
    to
    be
    evaluated
    during
    this
    assessment
    were
    public
    access
    to
    the
    waterway,
    water
    depth,
    visible
    signs
    of
    recreation
    (e.g.
    swimming,
    fishing,
    etc.),
    and
    proximity
    of
    residential
    and
    park
    areas.
    Within
    the
    marinaand
    park
    areas,
    metrics
    included
    number
    of
    docks,
    boats
    andjet
    skis,
    availability
    of
    ladders
    for
    access
    into
    and
    out
    of
    the
    water,and
    public
    access
    from
    the
    cDM
    1-1

    immediately
    upstream
    of
    Cedar
    Creek
    [39.95222N,
    91.420556W]
    and
    proceeding
    to
    the
    southern
    tip
    of
    Quinsippi
    Island
    [39.93533N,
    91
    .41675W].
    Attachment
    A
    contains
    photographs
    of
    the
    channel
    taken
    during
    the
    tour.
    Water
    clarity
    was
    noted
    as
    murky
    with
    visibility
    limited
    to
    less
    than
    1
    foot.
    Boating
    was
    limited
    primarily
    to
    the
    western
    and
    middle
    portions
    of
    thechannel
    due
    to
    shallow
    water
    depths
    along
    the
    eastern
    bank
    (Figure
    3).
    Three
    fishing
    boats
    were
    present
    on
    the
    western
    portion
    of
    Quinsippi
    Island
    across
    from
    the
    confluence
    of
    Cedar
    Creek.
    Attachment
    A
    contains
    photographs
    of
    fishing
    activities
    witnessed
    within
    this
    portion
    of
    the
    channel.
    East
    Bank
    Mississippi
    River
    Channel
    Approximately
    0.25
    miles
    downstream
    of
    the
    confluence
    is
    an
    All-American
    Park
    with
    a
    viewing
    area.
    Steps
    lead
    from
    the
    viewing
    area
    to
    the
    bank
    where
    fishing
    can
    occur.
    However,
    the
    bank
    has
    a
    steep
    slope
    into
    thewater
    and
    is
    composed
    primarily
    of
    dirtwith
    no
    vegetation.
    Further
    downstream,
    the
    Cedar
    Street
    CSO
    discharges
    into
    the
    channel
    on
    the
    south-side
    of
    the
    Quinsippi
    Island
    Bridge.
    This
    CSO
    is
    approximately
    1000
    feet
    upstream
    of
    Kesler
    Park.
    Kesler
    Park
    host
    boat
    launching
    and
    docking
    facilities.
    The
    area
    is
    popular
    for
    fishing.
    Several
    boaters
    were
    viewed
    using
    the
    boat
    ramps
    and
    boating
    through
    the
    channel
    to
    the
    main
    stem
    of
    the
    Mississippi
    River.
    Beyond
    the
    four
    boat
    ramps
    on
    the
    east
    bank,
    there
    are
    three
    small
    piers
    where
    fishing
    and
    picnicking
    were
    observed.
    In
    addition,
    there
    is
    a
    small
    playground
    along
    the
    bank
    with
    a
    fence
    separating
    it
    from
    a
    steep
    slope
    to
    the
    water.
    Thebank
    of
    the
    park
    is
    primarily
    a
    moderately
    steep
    bank
    with
    large
    rocks
    scattered
    throughout.
    Downstream
    along
    this
    bank
    is
    the
    Quincy
    Boat
    Club
    and
    a
    restaurant
    overlooking
    the
    Mississippi
    River.
    The
    eastern
    portion
    of
    the
    channel
    is
    heavily
    vegetated
    except
    for
    city
    park
    areas.
    While
    the
    parks
    contain
    boat
    ramps
    and
    piers,
    there
    are
    no
    ladders
    from
    the
    piers.
    Within
    Kesler
    Park
    there
    are
    areas
    of
    easy
    access
    to
    thewater.
    However,
    there
    are
    no
    established
    beaches
    or
    signs
    of
    primary
    contact
    along
    either
    bank
    of
    the
    channel.
    Based
    on
    water
    depths
    along
    the
    east
    bank
    of
    thechannel
    (Figure
    3),
    wading
    would
    be
    limited
    to
    within
    three
    feet
    from
    the
    shoreline.
    Photographs
    of
    these
    areas
    and
    the
    activities
    mentioned
    can
    be
    viewed
    in
    Attachment
    A.
    West
    Bank
    Mississippi
    River
    Channel
    The
    western
    portion
    of
    thechannel
    is
    heavily
    vegetated
    and
    has
    limited
    access
    to
    the
    waterway.
    The
    Quinsippi
    IslandBridge
    is
    the
    only
    connection
    from
    the
    mainland
    to
    the
    island.
    Roadways
    from
    the
    bridge
    allow
    automobile
    access
    solely
    to
    Art
    Keller
    Marina.
    Access
    to
    other
    regions
    of
    the
    island
    would
    have
    to
    take
    place
    by
    walking
    through
    primarily
    densely
    vegetated
    areas.
    With
    the
    exception
    of
    stairways
    leading
    to
    the
    marina,
    there
    were
    no
    visible
    paths
    to
    the
    water
    on
    the
    eastern
    portion
    of
    the
    island.
    Banks
    leading
    to
    the
    marina
    had
    a
    very
    high
    slope,
    limiting
    bank
    access
    mainly
    to
    the
    stairways
    leading
    directly
    to
    the
    docks.
    Art
    Keller
    Marina
    consists
    of
    two
    separate
    marinas
    with
    the
    larger
    of
    the
    two
    containing
    nine
    boat
    docks
    and
    thesmaller
    containing
    three
    boat
    docksand
    a
    fueling
    station.
    Several
    small
    cOM
    1-2

    body
    contact
    recreation
    (swimming,
    water
    skiing,
    wading,
    etc.).
    Primary
    contact
    recreational
    activity
    was
    identified
    by
    lookingfor
    rope
    swings,
    beaches,
    jet
    skis,or
    ladders
    into
    the
    water
    from
    piers
    and
    docks.
    In
    addition,
    the
    Mississippi
    River
    channel
    is
    a
    no
    wake
    zone
    and
    therefore
    would
    not
    permit
    waterskiing.
    DISCUSSION
    Results
    from
    this
    initial
    surveyshowthat
    existing
    uses
    in
    the
    Mississippi
    River
    channel
    are
    primarily
    recreational
    navigation
    and
    fishing.
    Canoeing
    and
    kayaking
    could
    exist
    within
    the
    channel
    to
    gain
    access
    to
    Quincy
    Bay
    and
    its
    backwaterwetlands.
    The
    City
    has
    no
    established
    beaches
    along
    the
    channel
    and
    physical
    access
    to
    the
    water
    is
    limited
    on
    the
    western
    bank
    of
    thechannel.
    Although
    the
    City
    maintains
    parks
    along
    the
    east
    side
    of
    thechannel,
    physical
    features
    (i.e.
    soft
    sediments,
    steep
    drop-offs,
    concrete
    banks,
    limited
    visibility)
    most
    likely
    make
    the
    channel
    an
    unsuitable
    place
    for
    swimming.
    Additionally,
    the
    Quincy
    Park
    District
    does
    not
    identify
    any
    of
    theparks
    along
    the
    Mississippi
    River
    channel
    as
    suitable
    for
    swimming.
    RECOMMENDATIONS
    Based
    uponaerial
    and
    topographical
    maps
    for
    the
    Cedar
    Street
    CSO
    006
    receiving
    waters
    and
    based
    upon
    the
    results
    of
    our
    site-specific
    survey
    and
    assessment,
    as
    well
    as
    our
    experience
    with
    other
    CSO
    designations
    statewide,
    the
    City’s
    permit
    should
    be
    revised
    to
    reflect
    that
    the
    actual
    receiving
    watersare
    the
    Mississippi
    River
    and
    not
    Quincy
    Bay
    andshould
    receivethe
    same
    designation
    as
    theother
    CSO
    outfalls
    to
    the
    Mississippi
    River.
    Combined
    sewer
    overflows
    in
    other
    in
    Mississippi
    River
    communities
    (e.g.
    Alton)
    are
    not
    designated
    as
    discharging
    to
    sensitive
    areas.
    In
    fact,
    a
    review
    of
    recently
    issued
    NPDES
    permits
    (Alton,
    Galesburg,
    Belleville,
    LaSalle,Hinsdale,
    and
    Marseilles)
    indicates
    that
    where
    communities
    discharge
    to
    major
    waterways,
    small
    streams,
    and
    creeks
    similar
    to
    those
    in
    Quincy,
    the
    receiving
    waters
    are
    designated
    non-sensitive
    areas.
    This
    survey
    along
    with
    theoneconducted
    for
    Whipple
    Creek
    and
    Curtis
    Creekwere
    done
    on
    a
    one
    time
    basis,
    and
    I
    would
    recommendexpanding
    these
    surveys
    into
    the
    2008recreational
    season
    to
    gain
    additional
    data
    regarding
    uses
    of
    these
    waterways.
    Surveys
    should
    be
    conducted
    once
    a
    month
    and
    include
    weekday
    and
    weekend
    observations.
    1-3

    woo

    c•
    1
    1-5

    coM
    1-6

    Figure
    3 — Depth
    Feet Chart:
    Mississippi
    River
    Channel
    in Quincy,
    Illinois
    (Source:
    Klinger
    and
    Associates)
    coM
    QUINSIPPI ISLAND
    V
    //
    —-
    /
    /
    /
    /
    /
    V
    V
    V
    1-7

    coM
    1
    1-8
    Figure
    A-i
    Cedar
    Creek
    confluencewith
    the
    Mississippi
    River
    Channel
    4
    confluence
    iver
    Channel
    downstream
    of
    the
    Cedar
    Creek

    .5.
    A
    -,
    -
    I,
    3S
    -
    -r---
    -
    -
    -
    --
    --
    09/tB/2007
    Figure
    A-3
    Fishing
    on
    the
    Mississippi
    River
    Channel,
    westof
    the
    Cedar
    Creek
    confluence
    Figure
    A-4
    Three
    fishing
    boats
    on
    the
    Mississippi
    RiverChannel,
    west
    of
    the
    Cedar
    Creek
    confluence
    colA
    1-9

    C

    Figure
    A-7
    View
    of
    trot
    lines
    set
    near
    All
    America
    Park
    --
    -
    Figure
    A-8
    Western
    bank
    acrossbay
    from
    All
    America
    Park
    coM
    1—11

    1-12
    a
    at
    2’
    entrance
    to
    Art
    Kc.s
    Marina
    ,
    4+.
    y
    A-1O
    Boat
    docks
    and
    fueling
    station
    at
    Art
    Keller
    Marina

    c)
    II •
    I
    I.
    I i
    .j;
    IH
    I

    r
    j
    —.
    -

    01

    ‘.l
    .I’!

    )11
    -.
    ¼.i.
    .
    c.
    z:.t
    -.
    -
    .—..:-.
    :..—
    -
    _..
    -
    —-t
    -
    -
    -r-
    -
    -‘
    -
    .
    _:Z-=-=.
    -
    -
    -
    .
    --
    -
    -
    --
    .e--
    -
    09/18/2007
    --
    -
    -
    -
    -.
    Figure
    A-22
    View
    of
    Quinsippi
    Island
    bank
    downstream
    of
    Lst
    entrance
    to
    Art
    Keller
    Marina
    I
    i:e’
    Figure
    A-23
    View
    downstream
    of
    Mississippi
    River
    Channel
    confluence
    with
    the
    main
    stem
    of
    the
    Mississippi
    River
    caM
    1-18

    Figure
    A-24
    View
    of
    Quincy
    Boat
    Club
    on
    the
    Mississippi
    River
    downstream
    of
    Kesler
    Park
    Figure
    A-25
    View
    of
    restaurant
    overlookingtheMississippi
    River
    Channel
    near
    the
    Memorial
    Bridge
    CM
    1-19

    coM
    A-26—
    View
    of
    the
    southern
    tip
    of
    Quinsippi
    Island
    Figure
    A-27
    Close-up
    view
    of
    sign
    located
    at
    the
    southern
    tip
    of
    Quinsippi
    Island
    1-20

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