fri\1o~iIVn~1I1XU
f\
I
RECEIVED
IL III~llI
DI
IMI
iAi
I
CLERK’S
OF~T/~
JONES,
DEC
-
42001
CHICAGO,
ILLINOIS
60601-1692
STATE
OF
ILLINOIS
TELEPHONE:
312-782-3939
•
FACSIMILE:
312-782-8685
Pollution
Control
Bocrr’~
(312) 269-4388
ctwehlar1d~jonesday.com
JP410531 :tw
083264-034010
December 3, 2001
Pollution Control Board, Attn: Clerk
100 West Randolph Street
James R. Thompson Center
Suite 11-500
Chicago, Illinois 60601-3218
Re:
Consumers Illinois Water Company’s Statement
In Support ofRequestedRelief in Docket No. ASO1-9
Petition ofRhodia,
Inc. and Thorn Creek Basin Sanitary District
Dear Clerk:
An original and nine duplicate copies of a statement in support ofrequested relief are
enclosed for filing in the referenced matter.
An additional copy is enclosed for you to
file stamp
and return to me in the enclosed self-addressed stamped envelope.
Please call me if you have
any questions.
Thanks for your assistance.
Sincerely,
Charles T. Wehiand
Enclosures
cc:
Boyd J. Springer
CH-1194711v1
ATLANTA
•
BRUSSELS
•
CHICAGO
•
CLEVELAND
•
COLUMBUS
•
DALLAS
•
FRANKFURT
•
GENEVA
•
HONG
KONG
•
IRVINE
•
LONDON
LOS
ANGELES
•
MADRID
•
MUMBAI*
•
NEW DELHI*
•
NEW YORK
•
PARIS
•
PITTSBURGH
•
SHANGHAI
•
SYDNEY
•
TAIPEI
•
TOKYO
•
WASHINGTON
*AN ASSOCIATE FIRM
RECEIVED
CLER~’S
OFFICE
BEFORE THE POLLUTION CONTROL BOARD
DEC
-
4
2001
OF THE STATE OF ILLINOIS
STATE OF IWNOIS
IN THE MATTER OF:
)
Pollution Control Board
)
ASO1-9
Petition of RHODIA, INC.
and THORN CREEK
)
(Adjusted Standard
-
Water)
BASIN SANITARY DISTRICT for an Adjusted
)
Standard from 35 Ill.
Adm.
Code
)
302.208
and 304.105
)
CONSUMERS ILLINOIS WATER COMPANY’S
STATEMENT IN SUPPORT OF REQUESTED RELIEF
Consumers Illinois Water Company (CIWC) believes that the relief requested by Rhodia,
Inc. and Thorn Creek Basin Sanitary District (Petitioners) in this proceeding should be granted.
Petitioners are requesting an adjusted water quality standard for dissolved solids and sulfates in
portions of Thorn Creek and the Little Calumet River.
CIWC operates a wastewater treatment
facility which discharges to
Deer Creek.
Deer Creekjoins Thorn Creek downstream of
Petitioners’ proposed discharge.
CIWC
operates pursuant to
an adjusted standard (AS 89-3) for dissolved solids in Deer
Creek and portions ofThorn Creek.
The Petitioners have requested relief that raises the
allowable concentration ofdissolved solids in Thorn Creek.
The requested reliefis
consistent
with current and projected future discharges to Deer Creek by CIWC.
The concentration
modeling used to
support the petition is conservative.
As a result, it accommodates projected
future growth ofthe Deer Creek discharge.
Based on preliminary discussions with industrial users, the discharges to Deer Creek
could have higher concentrations ofdissolved solids
and sulfates in the future.
Many ofthe
possible scenarios would not require any further change to the adjusted standard requested by the
Petitioners.
Ofcourse,
CIWC may need to seek adjustment ofthe standards for Deer Creek in a
separate proceeding if the projected changes to
the Deer Creek discharge become a reality.
CH-1 1 94702V1
In the meantime, CIWC believes the relief requested by the Petitioners should be granted.
It is necessary for the proposed discharge by the Petitioners and it accommodates potential future
growth ofthe CIWC discharge on Deer Creek.
Respectfully Submitted,
g~L
~w~i
Charles T. Wehland
Boyd J. Springer
JONES, DAY, REAVIS
& POGUE
77 West Wacker Drive
Chicago, IL 60601-1692
(312) 782-3939
Attorneys
For Consumers Illinois Water Company
CH-1 194702v1
CERTIFICATE OF SERVICE
I, the undersigned, certif~’
that I have served the attached Consumers Illinois
Water
Company’s Statement in Support ofRequested Relief, by first class, U.S. Mail, postageprepaid,
on December
3, 2001.
SERVICE LIST:
Illinois Environmental Protection Agency
1021
N. Grand Avenue
East
Springfield, IL
62794-9276
Roy M. Harsch
Sheila H. Deely
Gardner, Carton & Douglas
321 North Clark Street
Chicago, IL
60610
Attorneys for Rhodia, Inc. and Thorn Creek
Basin
Sanitary District
Illinois Department ofNatural Resources
524 South Second
Street
Springfield,
IL
62701-1787
Mike Klootwyk
Environmental/Safety Training Manager
Takasago International Corp.
University Park Plant
2600 Bond Street
University Park, IL
60466
CH-1 194702v1
