35111. ADM. CODE 302.208,

and 304.105

RECEYiVED

CLERK’S

OFr~CE

NOV

2

9

20Q1

STATE OF ~LUNO!S

Pollution

~ontroJBoard

NOTICE OF FILING

Division ofLegal

Counsel

Illinois Environmental Protection Agency

P.O. Box

19276

Springfield, IL 62794-9276

Attn:

Deborah J. Williams, Esq.

Office ofLegal Services

Illinois Department ofNatural Resources

524

S.

Second Street

Springfield,

IL 62701-1789

PLEASE TAKE NOTICE that on November 29, 2001

we have filed with the Office of

the Clerk ofthe Illinois Pollution Control Board the attached

PETITION FOR ADJUSTED

STANDARDS ofMaterial Service Corporation, a copy ofwhich is attached.

Dated: November 29, 2001

Richard R. Elledge

Gould & Ratner

222 North LaSalle Street

Chicago, IL 60601

(312) 236-3003

(312) 236-3241 Facsimile

Richard R. ~l1edge,

as attorney for Material Service Corp

ILLINOIS POLLUTION CONTROL BOARD

)

AS

O~r~

)

(Adjusted Standards-Water)

)

)

)

/144004.v

1

SUBMITTED ON RECYCLED PAPER

---

CERTIFICATE OF SERVICE

I certify that on this

29th

day ofNovember, 2001

I served the attached Notice

ofFifing

and

Petition for Adjusted Standards

ofMaterial Service Corporation by mailing copies thereof

first class mail, postageprepaid to:

Division ofLegal Counsel

Illinois Environmental Protection Agency

P.O.

Box 19276

Springfield, IL 62794-9276

Attn: Deborah J. Williams, Esq.

Office ofLegal

Services

Illinois Department ofNatural Resources

524

S.

Second Street

Springfield, IL 62701-1789

~~tElledF~~

/144019.v I

---

RECEIVED

CLER~cgOFRCE

ILLINOIS POLLUTION CONTROL

BOARD

NOV

2

9

2Ooi

STAfl~OF

Pollution

Controj

Board

In the matter of:

)

)

AS_____

Material Service Corporation

)

(Adjusted Standards-Water)

Petition for Adjusted Standards From

)

35 III.

ADM. CODE 302.208, 406.202

)

and 304.105

)

PETITION FOR ADJUSTED STANDARDS

Material Service Corporation (“Material Service”), by its attorneys, petitions the Illinois

Pollution Control Board, pursuant to

§28.1

ofthe Illinois Environmental Protection Act (the

“Act”) and 35 Ill. Adm. Code

104.400,

et seq.,

for Adjusted Standards from the Water Quality

1~

Standards set out in 35 Ill.

Adm. Code 302.208

and for relief from the provisions of35 Ill.

Adm.

Code 406.202 and 304.105.

Petitioner’s Request

Federal Quarryis

a 300 foot deep quarry located in the Village ofMcCook, Illinois, from

which Material Service quarries the dolomite bedrock to produce crushed

stone products.

To

operate,

Federal Quarry must be de-watered ofgroundwater seepage and storm water at

an

estimated average rate of 3,600,000 gallons per day.

This water is discharged into the McCook

Drainage Ditch, a three mile long ditch with an

estimated average flow, including the Federal

Quarry discharge, of5,800,000 gallons per day.

The drainage ditch collects

and transports waste

water from the storm sewer system ofthe Village ofBrookfleld, then receives the water pumped

from Federal Quarry plus several other industrial

discharges downstream ofFederal Quarry, and

directs those waters to

the Summit Conduit.

The Summit Conduit then transports those waters

/141156

SUBMITTED ON RECYCLED PAPER

---

under the Des Plaines River and discharges them into the Sanitary and Ship Canal approximately

500 yards west ofHarlem Avenue.

The discharge from the quarry is covered by NPDES Permit ILG 840029, which

sets no

effluent limits for either sulfate or total dissolved solids.

That permit expires on May 31, 2002.

Illinois

EPA has concluded that the waters ofthe McCook Drainage Ditch are general use waters

ofthe State ofIllinois, subject to the water quality standards for general use waters ofthe state as

set out in

§302.208, 35 Ill. Adm. Code 302.208.

The groundwater that Material Service pumps

from Federal Quarry tends to exceed the sulfate and total dissolved solids limits established by

that regulation.

Material Service requests that the water qua.lity standards applicable to the McCook

Drainage Ditch be adjusted by increasing the limits set out in §302.208(g) for sulfate from 500

mg/L to 850 mg/L and increasing the limits fortotal

dissolved solids from

1,000 mg/L to

1,900

mg/L.

Material Service also requests relief from

§406.202 and

§304.105 which prohibit any

“mine discharge” (406.202) or any “effluent” (304.105) from causing a violation ofany

applicable water quality standard.

In support ofthis Petition

a technical evaluation prepared by DAI Environmental titled

“Technical Evaluation for an Adjusted Standard Petition, Material Service Corporation

—

Federal

Quarry, McCook, Illinois”, dated November 28, 2001, referred to hereafter as DAT Report, is

attached hereto as Exhibit

3.

Standards From Which Petitioner’s Seeks Adjustment

Subpart B ofPart 302,

35

Ill. Adm. Code 302.100,

et seq.,

establishes general use water

quality standards to be met in waters ofthe state for which there is no

specific designation.

The

regulation at issue here, §302.208(g), establishes limits for sulfate at 500 mg/L

and limits for

2

---

total dissolved solids at 1,000 mg/L.

There are no

applicable general effluent standards for

sulfate and total dissolved solids.

Please see

§406.106, Effluent Standards for Mine Discharges,

35 Ill. Adm.

Code 406.106.

§302.208 is consistent with the mandate of~303(c)ofthe Clean Water Act and might be

described as implementing that provision offederal law.

However, §302.208

does not

appear to

implement any provision ofCERCLA, the Clean Air Act, 33

U.S.C.

13 13(c), or the state

programs concerning RCRA, UIC or NPDES.

Level ofJustification

The regulation ofgeneral applicability, §302.208, does not specify a level ofjustification

required to qualify for an adjusted standard.

Therefore, the level ofjustification required in

this

proceeding would be thejustification set out in §28.1(c) ofthe Act, 45 ILCS

5/28.1(c):

1.

“Factors relating to.

.

.petitioner are substantially and

significantly different

from the factors relied upon by the Board in adopting the general regulations

applicable to..

.

petitioner;

2.

The existence ofthose factorsjustifies

an adjusted standard;

3.

The requested standard will not result in environmental or health effects

substantially and significantly more adverse than the effects considered by the

Board in adopting the rule ofgeneral applicability; and

4.

The adjusted standard is

consistent with any applicable federal law.”

Description of Plaintiffs Activity

Federal Quarry is located on a 176 acre parcel, Material Service’s Yard

19, in the

northwest corner ofthe Village ofMcCook.

The Village ofBrookfield is to the north and the

Village ofLaGrange is to the west ofthe quany.

The lands to the south and east of the quany

are zoned heavy manufacturing and include the former Reynolds Aluminum Plant and the site of

3

---

the former GM Electro Motive Division Plant.

Figure

1, attached to the DAT report, depicts the

site location and the general area.

The origins ofFederal Quarry appear to dateback to the l9~”

century.

Material Service

has operated thequarry for over 60 years.

The quarrying process has not changed significantly

over those years.

After removing the overburden from the bedrock, benches ofrock are blasted

from the quarry face.

The shot rock is collected on the quarry floor, approximately 300 feet

below surface grade.

The shot rock is fed through a primary and

secondary crusher on the quarry

floor and onto conveyor belts that transport the material up to

surface grade and the plant.

Inthe

plant, the stone is crushed, screened and sorted into a variety ofsize combinations to meet

different commercial specifications.

From the plant, the finished product is transported to the

stockpile area where the different products are stored pending pickup by the customers’ cartage

trucks for delivery to the customers’ work sites.

A daily average of325 loaded cartage trucks

pass through the gates ofYard

19 during the construction season.

Material Service employs

approximately 60 professional, technical,

clerical and skilled people to run this operation.

The quarry floor is below the

local watertable and groundwater seeps from the quarry

face.

The groundwater seepage and storm water are drained to a pair ofsettling ponds on the

quarry floor.

From there, the water is pumpedup to

another pond on an intermediate grade and

then up to a tank at grade and led through culverts to the McCook Drainage Ditch.The estimated

average volume ofthe discharge from Federal Quarry into the McCook Drainage Ditch is

approximately 3,600,000 gallons per day.

DAI Report, Table 2,

p.1 1.

After a storm event, the

volume approaches 6,000,000 gallons per day.

id.

Sampling ofthe groundwater seeping into Federal Quarry at points on the quarry floor

near thebase ofthe wall indicates an average TDS level of 1,345 mg/L, with TDS levels

4

---

regularly exceeding 1,400 mg/L.

The indicated average level ofsulfate is 425 mg/L, with

occasional incursions above 500 mg/L.

DAT Report, p.15, Appendix G.

The source ofthe

groundwater seeping into Federal Quarry has been identified as a shallow aquifer flowing

through dolomite formations ofthe Silurian Age.

This is the formation being quarried at Federal

Quarry.

Review ofthe technical literature by DAT Environmental has both confirmed

and

explained the sampling results.

There are several independent studies ofthe groundwater quality

in this aquifer in the west and southwest portions ofCook County and the collar counties that

reportlevels ofTDS and sulfate that exceed the levels set for TDS and

sulfatein §302,208(g) for

general use water quality standards.

DAT Report, pp.

7, 8.

Levels ofTDS in the shallow

dolomite aquifer in the vicinity ofFederal Quarry are indicated in the range of 1,200 mg/L to

1,600 mg/L as shown in Figure 2 attached to the DAT Report.

Levels ofsulfate are indicated in

the range of500 mg/L to 700 mg/L, as shown in Figure 3

attached to the DAI Report.

An estimated 68,493

gallons per day are pumped from the system to the plant for use in

washing the product.

Thatwater is then returned to the settling ponds.

This is a relatively small

volume ofwater compared to the estimated average of 3,600,000 gallons per day that Material

Service pumps out ofthe quarry.

The use ofthis water in the plant does not have a significant

impact on either the sulfate orthe total dissolved solids content ofthe water discharged to the

McCook Drainage Ditch.

DAT Report, pp.

12,

13.

Other than the settling ponds, the

groundwater and storm waterreceive no treatment prior to discharge.

Periodically, storm water

acts to dilute the concentrations ofsulfate and TDS in the groundwater before it is

discharged

into McCook Drainage Ditch.

Historically, for purposes of NPDES permits, Material Service has consideredthe waters

pumped from Federal Quarryto be discharged into the waters ofthe Sanitary and Ship Canal.

5

---

The average flow ofthe Sanitary and

Ship Canal at the point where the Summit Conduit

discharges is reported to be 603,000,000 gallons per day.

DAI Report, p.

17.

The concentrations

ofsulfate and TDS found in the Federal Quarry discharge would have little impact on the sulfate

and TDS concentrations in the 603,000,000 gallonsper day flow ofthe Sanitary and Ship

Canal.

DAI computes the waters from Federal Quarry to contribute a

6 mg/L increase in TDS and a 3

mg/L increase in sulfate in the Sanitary and Ship Canal.

DAI Report, p.

17.

For the purposes ofcurrent NPDES permits, Material Service must now consider the

receiving waters for the Federal Quarry discharge to be the waters ofthe McCook Drainage

Ditch, deemed to be general use waters,

ratherthan the waters ofthe Sanitary and Ship Canal,

designated as secondary use waters.

Sec.

303.401.

Material Service’s flow measurements

indicate that, on average, the Federal Quarry discharge represents approximately 61

ofthe total

flow ofthe McCook Drainage Ditch at the Summit Conduit, DAI Report, p.

11, Appendix D.

Monitoring ofthe Federal Quarry discharge into the McCook Drainage Ditch indicates

an

average TDS level of 1,299 mg/L in the effluent, with a range

from 1,070 mg/L up to

1,400

mg/L, and an indicated average sulfates level of427 mg/L in the effluent, with a range from 351

mg/L up to 524 mg/L.

DAI Report p.

15,

Appendix H.

Recently, Material Service wished to

expand the quarrying operations southerly into new

stone reserves

adjacent to

the faces then being quarried.

However, these reserves did not lie

withinthe boundaries ofthe permit area specified in the existing NPDES permit, Permit No. ILG

840029.

Therefore, Material Service applied for a new NPDES permit to

cover storm water

collected in and

discharged from the proposed expansion area.

Illinois EPA issued NPDES

Permit No. IL 0001945 as ofSeptember

25,

2000.

This permit sets effluent limits of 1,000 mg/L

for TDS and 500 mg/L for sulfate, reflecting the impact ofthe Federal Quarry discharge on the

6

---

waters ofthe McCook Drainage Ditch and the mandate of §406.202.

Quarrying in the permit

area forNPDES Permit No. IL 00001945

will not encounter groundwater for several years and,

therefore, there will be no discharges ofgroundwater from this permit area for several years.

Compliance Alternative

In theory, there appear to be fourtreatment options for lowering TDS and sulfate levels in

the Federal Quarry discharge to meet §302.208 standards.

Dilution:

Material Service could, in theory, purchase Lake Michigan water from the City

ofChicago to dilute the Federal Quarry discharge before sending it into the McCook Drainage

Ditch.

DAT estimates that 2,000,000 gallons per day ofLake Michigan water would be needed,

on average, to provide sufficient dilution.

DAT Report, pp. 20,

21.

Assuming that the City of

Chicago were free to supply this much water and assuming that the Summit Conduit could

contain this additional flow, the potential impact ofso large an additional flow on both the ditch

itself and the several bridge structures over the ditch, especially during storm events, would

render this option unacceptable, regardless of cost.

Deep Well Injection:

A

second option would be to inject the groundwater seeping from

the shallow

aquifer into a deeper stratum.

Based on the volume offlow, DAT calculates that this

would require 8

to

10 wells,

each with a minimum

8 inch diameter. In addition, each well would

need to be located several hundred feet away from its nearest neighbor.

DAT Report, p. 21.

DAT

further reports that deep well injection does not typically work well for water with high dissolved

solids and low suspended solids.

Assuming that such a system could be made to operate reliably

and assuming that Material Service could obtain land for such an array ofwells,

DAT estimates

that capital costs from $19,000,000

to $26,000,000 with annual operating

costs as high as

$16,000,000 to

$20,000,000.

DAI Report, p. 21, Appendix J.

7

---

Reverse Osmosis and De-ionization.

Using either

ofthese technologies, one would

treat to remove the dissolved minerals from a portion ofthe total flow and, after treatment,

reinsert the treated flow into the system.

To achieve sufficient

dilution to meet the TDS and

sulfate limits, one would treat approximately 40

of the Federal Quarry discharge and return the

treated waterto the system.

Thebrine would then need to be disposed of, probably using

injection wells.

DAI computes the capital costs of either treatment method from $2.3

to $3.2

million with annual and operating costs ranging from $2.3 to

$5.6

millionper annum.

DAT

Report,

p. 22, Appendix J.

To these

costs, however, must be added the costs ofdisposing ofthe

brine, a cost that DAT estimates at $1.6

to

$2.2 million in capital costs with annual and operating

costs ranging from $1.4 to $1.9 million.

DAT estimates the twenty year operating costs using

reverse osmosis (the less expensive option) from $81

to $113 million.

DAT Report, p. 20,

Appendix J.

Conclusion.

The Board’s January 6,

1972 Opinion,

In The Matter ofEffluent Criteria,

et.

al.,

Nos. R70-8; 7 1-14; 7 1-20, explains the Board’s decision to adopt no

effluent standard for

chloride or for sulfate and to rely instead on an effluent standard of3,600 mg/L for TDS.

The

Opinion states:

“It is clear that such a standard for

chloride or sulfate

would impose the highest

treatment costs ofany under consideration in order to

do the least good.

While

such techniques as distillation, reverse osmosis and

electro-dialysis are certainly

feasible, Weston gives their cost at five to ten times that ofthe precipitation and

filtration that are adequate to remove most ofthe contaminants in the table.

Moreover, all ofthese methods produce a brineresidue that is itself a serious

disposal problem.

On the other side ofthe

coin, these contaminants are by far the

most innocuous

on the list.”

Slip opinion, p.

10.

Clearly, the circumstances presented in this proceeding validate that analysis.

The treatment

options that are technically possible are extraordinarily costly, prohibitively costly.

It would not

8

---

be economically feasible or reasonable to treat the flow ofgroundwater that collects in Federal

Quarry to meet the water quality standards set out in Sec. 302.208(g) for sulfate and TDS.

Proposed Adjusted Standards

Material Service requests that thewater quality standards specified in 35 Ill. Adm.

Code

302.208(g) for concentrations ofsulfate and TDS be increased to reflectthe background

concentrations ofsulfate and TDS in the groundwater that enters the quarry. The highest

concentration of sulfate found in the Material Service samples was 660 mg/L whereas the

acquifer studies reported concentrations ofsulfate ranging up to 2,515

and 864 mg/L.

DAT

Report p. 27.

The highest concentrations ofTDS found in the Material Service samples was

2,450 mg/L and the highest concentrations found in the acquifer studies were 2,500, 2,100

and

1,832 mg/L.

DAI Report p.

26

Therefore, Material Service requests that the limit for

concentrations of sulfate be increased to

850 mg/L and the limit for concentrations ofTDS be

increased to

1,900 mg/L, as applicable to the waters ofthe McCook Drainage Ditch for its entire

length from the

47th

Street culvert to the Summit Conduit.

Material Service petitions the Board to adopt the following language to

establish the

proposed adjusted standards:

1.

The concentrations ofsulfates (STORET No. 00945) shall not exceed 850

mg/L in the waters ofthe McCook Drainage Ditch for its entire length from

the

~

Street culvert to

the Summit Conduit.

The water quality standards for

sulfate as set out in 35

Ill. Adm. Code 302.208(g) shall not apply to the waters

of the McCook Drainage Ditch.

2.

The concentrations of TDS (STORET No. 70300) shall not exceed

1,900

mg/L in the waters ofthe McCook Drainage Ditch for its entire length from

the

47th

Street culvert to the Summit Conduit.

The water quality standards for

TDS as set out in 35 Ill. Adm. Code 302.208(g) shall not apply to the waters

ofthe McCook Drainage Ditch.

3.

The requirements of35

Ill. Adm. Code 406.202 and

35 Ill.

Adm. Code

304.105, to the extent those requirements address mine discharges or effluent

9

---

discharges into the waters ofthe McCook Drainage Ditch, shall not be

applicable to the water quality standards for sulfates or TDS set out in 35 Ill.

Adm.

Code 302 .208(g), but rather shall be applicable to

the adjusted water

standards for sulfate and TDS

set out in this Order.

Impact of Proposed Adjusted Standard

Material Service does not seek adjusted standards in order to accommodate any change in

the operations ofFederal Quarry or any expansion ofFederal Quarry.

Rather, Material Service

seeks adjusted standards to

accommodate the characterization ofwaters ofthe McCook Drainage

Ditch as general use waters of the state and to permit the continued operation ofFederal Quarry.

As far as volume offlow in the McCook Drainage Ditch is

concerned, the Federal Quarry

discharge is

a significant, if not a dominant, contributor to regular flow in the ditch.

During

periods oflow precipitation, the Federal Quarry discharge may be the only flow component that

fosters any permanent aquatic ecosystem in the McCook Drainage Ditch.

DAT Report, p.

15.

DAT has evaluated the impact ofthe sulfate and TDS levels in the Federal Quarry

discharge on the McCook Drainage Ditch under a variety of flow and concentration scenarios.

Based on these scenarios, DAT predicts average sulfate concentrations in the waters of the ditch

in a range from 215

to 512 mg/L,

and average TDS concentrations in the waters ofthe ditch in a

muchbroader range, from 865 to

1,787 mg/L.

During the winter when substantial volumes of

road salt runoff enter the ditch, contributing high TDS-CL values, the Federal Quarry discharge

would tend to stabilize those peak winter concentrations ofTDS.

DAI Report, p.

19.

DAI

concludes that under normal conditions with average flow and average concentrations the

Federal Quarry discharge appears to increase sulfate and TDS concentrations in the McCook

Drainage Ditch by approximately 169 mg/L and 346mg/L, respectively, over average

background concentrations.

DAT Report, p. 20, Appendix I.

10

---

The DAT Report evaluates the impact ofthe sulfate and TDS levels downstream ofthe

Federal Quarry discharge (which the proposed adjusted standard would authorize) on indigenous

organisms ofthe waters ofthe McCook Drainage Ditch.

Dueto

the nature ofthe ditch

and due

to thedifficulties ofobtaining adequate access to the ditch, DAI based its evaluations on a

literature review covering typical fresh water fish.

DAI notes, however, that it is very unlikely

that there is any significant population ofblue gill, large mouthbass or channel catfish in this

ditch.

DAT notes that the LC50 mortality rate for those species in concentrations ofsulfate based

TDS is reported to range from 14,000 to

17,500 mg/L

and for sulfate is reported to range from

10,000 to

11,000 mg/L.

DAI supplemented their literature investigation by reviewing the recent study by Huff

and Hufffor Rhodia, Inc.

filed with the Board in connection with Rhodia’s Petition for Adjusted

Standards forTDS and sulfate in Thorn Creek,

In the Matter ofPetition ofRhodia, Inc.,

et a!.,

No. AS-01-9.

The Huff and Huff study reported on chronic toxicity tests for TDS and sulfate on

a species ofwater flea and on the flathead minnow.

The Huff and

Huffstudy concluded that the

“no observed effect concentration” was 2,790 mg/L for TDS and

1388 mg/L for sodium sulfate.

DAI concludes that the TDS and sulfate concentrations in the Federal Quarry discharge

does not have any significant deleterious effect on existing aquatic life in the McCook Drainage

Ditch.

DAT further concludes that the proposed adjusted standards of 1,900 mg/L forTDS and

580 mg/L for sulfate is less than those shown to be protective ofaquatic life.

DAT Report, pp.

25,26.

11

---

Justification for Proposed Adjusted Standards

Material Service finds itself in a regulatory cleft stick.

A substantial flow of

groundwater seeps continuously into Federal Quarry.

This water must be pumped from the

quarry.

Ifthe pumping stops, the quarry fills and Federal Quarry closes.

On theone hand,

§406.103 of Part 406, Mine Waste Effluent and Water Quality

Standards, 25 Ill Admin Code 406.103 states:

“Because the effluent standards

in this part are based upon concentrations

achievable with conventional treatment technology that is largely unaffected-by

ordinarylevels of contaminants in intake water, they are absolute standards that

must be met without subtracting background concentrations.

However, it is not

the intent ofthese regulations to require users to

clean up contamination caused

essentially by upstream sources or to require treatment when only traces of

contaminants are added to the background.

Compliance with the numerical

effluent standards is therefore not required when effluent concentrations in excess

ofthe standards result entirely from the contamination ofinfluent before it enters

the affected land.

Background concentrations or discharges upstream from

affected land are rebuttably presumed not to have caused a violation ofthis part.”

On the otherhand,

§406.20 1 ofthe same Part,

35 Ill. Adm.

Code 406.20

1 provides:

“In addition to the other requirements ofthis Part, no mine discharge or non-point

source mine discharge shall, alone or in combination with other sources, cause a

violation ofany water quality standards of35 Ill.

Adm. 302 or 303.”

And §309.141 of Part 309, Permits, 35 Ill.Adm. Code 309.141

states:

“In establishing the terms and conditions of each issued NPDES Permit, the

Agency shall apply and ensure compliance with all ofthe following, whenever

applicable:

d) Any more stringent limitations, including those:

1) necessary to meet

water quality standards.

..“

The area ofthe quarry into which the groundwater seeps and the point at which these

waters are pumped from the quarry into McCook Drainage Ditch (discharge 001) are covered by

NPDES Permit No. ILO 840029, which is

expiring.

The most recent expansion area ofthe

quarry and the two potential point sources for that area (discharges 002 and 003) are covered by

12

---

NPDES Permit No. IL 0001945, issued last year with effluent limits for sulfate at 500 mg/L and

for TDS at

1,000 mg/L.

Material Service proposes to modify the later permit to

include the area

ofNPDES Permit No. TLG 840029, including discharge 001, under NPDES Permit No. TL

0001945.

In this proceeding, Material Service petitions the Board for Adjusted Standards for the

waters ofMcCook Drainage Ditchso that the Agency will be in a position to increase the

effluent limits in Permit No. IL

0001945 to

850 mg/L for sulfate and

1,900 mg/L forTDS and to

modify that permit to include the full area ofquarry and the discharge point for the groundwater

discharge into the McCook Drainage Ditch.

Generally, we have found nothing in the Board’s opinions in the Water Quality Standards

proceedings, Nos. R70-8, R7l-l14 and R7l-20 to suggest that the Board necessarily intended

that the general use water quality standards would cover the waters ofa

3 mile drainage ditch,

tributary to the Sanitary and Ship Canal, running through an urban industrial area, with limited

public access, “constructed and operated forthe purpose ofcollecting

and transporting waste

water or land run off, or both.”

.35

Ill.

Adm. Code 301.390, 301.440.

Specifically, the Board’s March 7,

1972 Opinion in the matter of

Effluent Criteria,

et. a!.,

Nos. R70-8; R71-l 14

and R7l-20 based the 500 mg/L water quality standard for sulfate on

levels desirable to protect stock watering and fish, as well as the protection ofthe public water

supply, Slip

Opinion, p. 4.

The lands through which the McCook Drainage Ditch runs is zoned

“heavy manufacturing”.

There is no stock watering in the vicinityofthis ditch and none is

permittedunder the McCook zoning ordinance.

The waters ofthis ditch, flowing into the

Sanitary and Ship Canal, have no obvious impact on any public

water supply.

The factors

13

---

present here, therefore, would seem to be far different than the factors relied on by the Board in

its March

7,

1972 Opinion.

The same opinionbased the

1,000 mg/L for TDS on the protection ofaquatic life, Slip

Opinion, p.

11.

As

far as we can determine, the testimony does not seem to have addressed

aquatic life in a ditch such as the McCook Drainage Ditch.

There are elevated concentrations ofsulfate and TDS in the groundwater flowing into the

Federal Quarry.

This water is discharged from Federal Quarry at orbelow background levels.

DAT’s evaluation demonstrates that adjusting the standards for sulfate and TDS, to reflect

background concentrations ofsulfate and

TDS found in the Federal Quarry discharge, does not

result in environmental orhealth effects substantially and significantly more adverse than the

effects considered by the Board in its March

7,

1972 Opinion.

It is not be economically reasonable to reduce the background levels ofsulfate and TDS

contained in the Federal Quarry discharge to 500 mg/L for sulfate and 1,000 mg/I for TDS.

Taking into account the existing physical conditions, the character ofthe areainvolved including

the character ofsurrounding land uses and zoning classification ofthe area as well as the nature

of the receiving body ofwater, and taking into account that the alternative would be to shut down

Federal Quarry, adjusting the water quality standards applicable to the waters of the McCook

Drainage Ditch to the levels requestedby Material Service is fully justified.

Consistency with Federal Law and Federal Procedural Requirements

The Board, acting forthe

State, has the primary authority and responsibility to establish

water quality standards forthe waters ofthe McCook Drainage ditch.

33 U.S.C

1251, 40 CFR

131.4(a).

The Clean Water Act gives the Board the authority and responsibility to designate

appropriate uses (including industrial uses) for the waters ofthe state and the criteria to foster

14

---

those uses.

33

U.S.C. l3l3(c)(2)(A), 40 CFR

131.2(a).

The waters ofthe McCook Drainage

Ditch are not suitable forrecreation or for animal husbandry.

The waters ofthe McCook

Drainage Ditch do not have a significant adverse impact on the waters ofthe Sanitary and Ship

Canal into which they flow.

The adjusted standard requested by Material Service for

concentrations ofsulfate and TDS will reflect the existing conditions and will continue to be

protective ofthe public health and welfare.

The adjusted standards requested by Material

Service comply with the Federal requirements.

Procedurally, the provisions of Sec.

104.420 ofthe Board’s regulations give any person

the right to request public hearing in this proceeding.

The provisions of Sec.

104.408 regarding

the publication ofnotice, require public notice that advises that any person has theright to

request public hearing.

These provisions appear to

fully satisfy the mandate ofthe Clean Water

Act regarding public participation.

33 U.S.C.

125 1(e).

Waiver of Hearing

Material Service hereby waives hearing in this matter as permittedby

§

104.406.

Supporting Documents

The supporting documents are collected as part ofthe DAT Report, which is attached

hereto as Exhibit 3.

15

---

WHEREFORE, Material Service petitions the Board to grant adjusted standards from the

water quality standards of 35 Ill. Adm. Code 302.208(g) for concentrations ofsulfate and TDS,

as those standards apply to the McCook Drainage Ditch and to

grant relief from the provisions of

35 Ill. Adm.

Code 406.206 and 403.105 with regard to the Federal Quarry discharge.

Respectfully submitted,

MATERIAL SERVICE CORPORATION

~

Richard R.

Elledge

Gould &

Ratner

222 North LaSalle Street

Chicago, IL 60601

(312)236-3003

16

S

---

AFFIDAVIT OF MICHAEL D. MELTON

I, Michael D. Melton, being first duly sworn on oath, depose and say:

1.

I havebeen employed by Material Service Corporation for over six years and

currently I am Project Manager in the Environmental Services Department of

Material Service Corporation.

As such, I am familiar with the operation ofthe

Federal Quarry in McCook, Illinois, and with the matters set out in the foregoing

Petition for Adjusted Standards.

2.

I haveread the foregoing Petition for Adjusted Standards and the facts asserted

therein are,

to the best ofmy knowledge and belief, true and correct.

Michael D. Melton,

Project Manager

Sworn to before

t~c~SEA~

~

GAYLE

A.

COSENTINO

~

NOTARY PUBLiC

STATE OF ILLINOIS ~

/144029.v

1

EXHIBIT

1

---

AFFIDAVIT OF JEFFREY

S. WOELFER

I,

Jeffrey S. Woelfer, being first duly sworn on oath, depose and

say:

1.

I am employed by DAI Environmental Inc., as Senior Project Manager.

My

educational background and professional experience are presented in my Curriculum

Vitae, attached hereto.

2.

During the course ofthe past year, I have conducted an investigation

and technical

evaluation on behalf ofMaterial Service Corporation concerning the matters covered

in the Petition for Adjusted Standards by Material Service Corporation regarding its

Federal Quarry and the McCook Drainage Ditch.

3.

The results ofthat technical evaluation are set out in the document titled “Technical

Evaluation for an Adjusted Standard Petition, Material Service Corporation

—

Federal

Quarry, McCook, Illinois”, dated November 28, 2001, to be filed in this proceeding.

The information

and conclusions presented in that document are true and accurate to

the best ofmy knowledge, and the opinions presented therein are mine.

Subscribed

and Sworn to before

me

Is

29th

day ofN

vember, 2001

~

Notary Pu~c

“

OFFICIAL

SEAL

/144025.v

.1

2

---

E

N

~AEIT

A

L

Environmental

Engineers, Geologists and Scientists

Tel

847.573.8900

Polo

Park Business Center

Fax

847.573.8953

27834

N.

Irma

Lee

Circle

Lake

Forest,

Illinois 60045-5130

TECHNICAL EVALUATION

FOR

AN

ADJUSTED STANDARD PETITION

MATERIAL SERVICE CORPORATION

YARD

19 QUARRY

MCCOOK, COOK COUNY, ILLINOIS

November 28, 2001

Material Service Corporation

Corporate Office

222 N. LaSalle Street,

12th

Floor

Chicago, IL 60601-1090

Environmental Services Department

4226

South Lawndale Avenue

Lyons,

Illinois 60534-1199

Prepared by:

DAI Environmental, Inc.

Polo Park Business Center

27834 N. Irma Lee Circle

Lake Forest, IL

60045-5

130

---

TABLE OF CONTENTS

1.0

INTRODUCTION

1

1.1

Purpose

~

1

1.2

Facility

Location

1.3

Facility Description

1.4

Regulatory Setting

.3

2.0

BACKGROUND

....~:

3

2.1

Local Setting

~

.3

2.2

NPDES Permit History

4

2.3

Description of the McCook Drainage Ditch

5

3.0

GROUNDWATER

AND

SURFACE WATER QUALITY

6

3.1

Literature Review

6

3.2

Groundwater Sources

~

.6

3.3

Groundwater Quality

.7

3.4

Surface Water Quality

.9

4.0

CHARACTERISTICS OF THE MCCOOK DRAINAGE DITCH

10

4.1

Source of the Mc Cook Drainage Ditch

10

4.2

Storm Water Runoff

11

4.3

Flow Measurements

~.

11

5.0

CHARACTERISTICS OF MSC’S DISCHARGE TO THE MCCOOK DRAINAGE

DITCH

12

5.1

Source of Discharge

.~

12

5.2

Volume of Discharge

~

14

5.3

Quality of Groundwater

Seepage

16

5.4

Comparison of Groundwater Seepage Data to Local Groundwater Conditions

16

5.5

Quality of MSC’s Discharge

17

6.0

IMPACT TO

RECEVING

WATERS

17

6.1

Impact to the Chicago Sanitary and Ship Canal

18

6.2

Impact to the Mc Cook Drainage Ditch

18

7.0

TREATMENT OPTIONS

21

7.1

Available Technologies

21

7.1.1

Dilution

..~.

22

7.1.2

Deep Well Injection

..

22

7.1.3

On-Site Treatment

...

23

8.0

CHEMISTRY

AND

TOXICOLOGY

24

8.1

Toxicity ofTDS

24

8.2

Toxicity of Sulfate

~

26

9.0

PROPOSED ADJUSTED STANDARDS

27

10.0

REFERENCES

30

Technical Evaluationfor an Adjusted Standard Petition

November28,

2001

Material Service Corporation

—

Yard 19

-

i

-

DAiProject 6219

McCook, CookCounty, Illinois

DOCUMENT

PRINTED

ON RECYCLED PAPER

---

FIGURES

Figure

1:

Site Location Map

Figure 2:

Area! Distribution of Total Dissolved

Solids

Figure 3:

Area! Distribution of Sulfate

Figure 4:

Water Collection System

TABLES

Table

I:

Average Concentrations of TDS and Sulfate in Surface Water

Table

2:

Flow Measurements

from the McCook Drainage Ditch

Table

3:

Comparison of Average TDS Concentrations in Groundwater

Table

4:

Average Surface Water Concentrations

Table

5:

Summary of Background Surface Water Concentrations

Table

6:

Predicted TDS and Sulfate Concentrations

Table

7:

Proposed NPDES Adjusted Standard Concentrations

APPENDICES

Appendix

A:

NPDES Permits

Appendix B:

Site Photographs

Appendix C:

Background Surface Water Quality Data

Appendix D:

McCook Drainage Ditch Flow Measurements

Appendix E:

Aggregate Washing Data and Calculations

Appendix F:

Yard

19

Quarry Pumping Calculations

Appendix G:

Groundwater Seepage Chemistry Data

Appendix H:

McCookDrainage Ditch Sampling Results

Appendix

I:

Impact to Receiving Water Calculations

Appendix J:

Treatment Cost Summary

Technical Evaluationfor

an

Adjusted Standard Petition

November28,

2001

Material Service

Corporation

—

Yard 19

-

ii

-

DA!Project

6219

McCook, Cook County,

Illinois

DOCMENTPRIN TED ON RECYCLED PAPER

---

TECHNICAL EVALUATION

FOR

AN NPDES ADJUSTED STANDARD

MATERIAL SERVICE CORPORATION

-

McCOOK, ILLINOIS

November 28, 2001

1.0

INTRODUCTION

1.1 .Purpose

DAI

Environmental,

Inc.

(DAI)

has

been

retained by

Material

Service Corporation

(MSC)

to

complete a technical evaluation to support an adjusted standard petition for water discharges from

their Yard

19

stone quarry.

Currently, water discharges consisting ofgroundwater seepage, storm

water runoff,

storm

water run-on, and minor

amounts of water used to

wash aggregate products

are

discharged

from

the

Yard

19

quarry

into

the

McCook

Drainage

Ditch

under

a National

Pollutant

Discharge

Elimination

System

(NPDES)

Permit.

Analysis

of

water

samples

from

MSC’s

discharge,

for

the

most

recent

NPDES

Permit

modification

application,

were

found

to

contain

concentrations of

total

dissolved

solids

(TDS)

and

sulfate above

the standards

required

for general use waters in State of Illinois.

The

following

report represents

the

technical information collected

in support

of the petition

to

seek a TDS and sulfate adjusted standard for MSC’s water discharges into the McCook Drainage

Ditch.

The purpose of this study

is

to demonstrate

that:

(1) the

TDS

and sulfate

concentrations

found

in

MSC’s

discharge

are

naturally

occurring,

and

are

not

significantly

increased

by

the

quarry operation; (2) though treatment alternatives theoretically exist to reduce the concentrations

of TDS

and sulfate to

compliant

levels,

that treatment is

economically

overly burdensome;

and

(3) there are no significant adverse or detrimental impacts associated with MSC’s water discharge

to

the McCook Ditch.

Technical Evaluationfor an Adjusted Standard Petition

November28,

2001

Material Service Corporation

—

Yard 19

-

1

-

DAIProject 6219

McCook, Cook county,

Illinois

DOCMENT PRiNTED ON RECYCLED PAPER

---

1.2 Facility Location

MSC’s Yard

19

quarry

is

located in

the northwest corner of McCook~CookCounty,

Illinois.

The

facility can be further defined as

being found

in Section

10, Township

38 North, Range

10 East.

Figure

1

is a topographic map that shows the

location ofthe MSC facility

1.3 Facility Description

MSC’s

Yard

19

facility

in

McCook

is

an

operating

quarry

producing

a

variety of aggregate

products

derived

from

the

Silurian

dolomite

bedrock.

Historically,

it

is

believed

that

the

area

occupied by MSC’s Yard

19 facility originally consisted of three smaller quarries, which were in

production as early

as the late

1800’s.

In

the late

1 930s, MSC purchased two of the quarries and

consolidated

them

into

what is now known as

the

Yard

19 facility.

Aggregate reserve land was

later acquired and added to the facility, which currently consists of approximately 176 acres.

The

facility

obtains

the

aggregate

from

mining

and processing

a

local

near surface

deposit of

bedrock.

The

bedrock

is

prepared

for

mining

by

first

removing

the

unconsolidated

glacial

overburden.

Then

the

bedrock

is

mined,

and processed

into

a

saleable

aggregate product via

crushing,

sizing

(i.e.

screening),

along

with

some

washing

when

required

by

customer

specification.

The

finished aggregate

products

are

stockpiled

and shipped via cartage trucks to

local

and

regional

users.

The

Yard

19

office,

scale,

stone

processing

plant

and

aggregate

stockpiles are located at surface grade.

The mining operations are located within the open stone

pit

quarry.

The

stone

quarry

penetrates

as

deep as

300’

into

the bedrock

deposit.

In

order to

operate, the quarry needs

to be dewatered of ground and

storm water accumulations.

Presently,

MSC’s Yard

19

facility

is

a major producer of construction

aggregate products in the

region

with an

annual production of over

2

million tons

per year.

The

facility is

an

important

employer

in

the

area

with

a

sizable

payroll

of the

approximately

60

professional,

technical,

clerical,

and skilled workers required to

maintain operations.

The facility also utilizes

local

and

regional suppliers of materials and services as needed to support

onsite operations.

Technical Evaluation for an Adjusted Standard Petition

November28,

2001

Material Service corporation

—

Yard 19

-

2

-

DAI Project 6219

tvlcCook, Cook County, Illinois

DOCMENTPRIN TED ONRECYCLED

PAPER

---

1.4 Regulatory

Setting

IEPA regulations (Title

35,

Subtitle A, Chapter I,

Subpart D, Section

104.4)

provide guidance as

to

the

technical

information

needed

to

apply for

an adjusted

standard,

which

is summarized

as

follows:

-

Existing physical conditions of site and surrounding area;

-

Character of the area involved, including

o

Surrounding land uses,

o

Zoning classifications,

o

Nature of the

existing receiving body of water,

o

Technical

feasibility and economic reasonableness ofreducing the pollution,

and

o

The universe of affected sources and facilities and the economic impact of

the proposed change.

2.0

BACKGROUND

2.1

Local Setting

The

northwest corner

of Village

of McCook is

situated south of Lyons

and Brookfield, and east

of LaGrange and

Countryside.

Land usage

in McCook

is

almost entirely industrial/commercial

with

a small

residential

population

of approximately 300 located

near

the

center of the

village.

The

Village

of McCook

utilizes

Lake Michigan

exclusively

as

a

potable

water

source.

The

Village of McCook does

not

utilize

groundwater as

a potable water

source.

According to

Mr.

Pete

Lacoursio

of the

McCook

Water

Department,

there

are

no

groundwater

supply

wells

in

McCook.

The

McCook Drainage

Ditch originates

from

storm

drains located

along

the

south

side

of 47~”

Street

near

the

intersection

of Plainfield

Road.

Based

on

information provided

by

Mr.

Wally

Callahan

of the Village of Brookfield,

sanitary sewers along the

47Lh

Street corridor are routed to

the

Stickney

water treatment plant

operated by

the Metropolitan

Water Reclamation

District of

Greater Chicago

(MWRD).

Therefore,

the

drains feeding the

ditch

appear to

carry only

storm

water from the areas of Brookfield near the intersection

0f47th

Street and Plainfield Road.

Technical Evaluationfor an Adjusted StandardPetition

November28,

2001

Material Service Corporation

—

Yard /9

-3

-

DAIProject 6219

McCook, Cook County,

Illinois

DOCMENT PRINTED ONRECYCLED PAPER

---

2.2

NPDES

Permit History

MSC ‘s Yard

19

quarry

has been dewatered of storm and groundwater seepage flows since the late

1930s with discharge

into the McCook Drainage Ditch.

More recently, MSC began washing fine-

grained stone particles from some aggregate products to meet certain product

specifications.

The

water used for this

washing is obtained from the quarry dewatering system.

The water containing

stone

fines

after

aggregate

washing

is

routed

tO

on-site

basins

to

settle

out

the

solids

prior to

returning the water to the dewatering system.

Prior

to

1975,

MSC received a permit from the Illinois Environmental Protection Agency (IEPA)

to discharge quany

water under

Illinois Pollution Control

Board

(IPCB)

Rules

and Regulations,

Chapter

4,

Mine

Related

Pollution.

Chapter

4

was

later

replaced

by

Title

35

Illinois

Administrative

Code, Subtitle

D,

Mine Related Waste Water.

Authorization

to discharge under

IPCB

Chapter

4 and later

35

IAC,

Subtitle •D, was

incorporated into

subsequent permits

by

the

IEPA.

In

1975, MSC obtained the first NPDES

discharge permit from the United

States Environmental

Protection

Agency (USEPA) under

No.

IL000l945.

The application for the

initial permit noted

that

the water discharge contained

concentrations of TDS at

1015 mg/L and sulfate at 350 mg/L.

The USEPA issued the

initial permit as discharging into the Chicago Sanitary and Ship Canal

via

the LaGrange and McCook Storm Sewer Systems.

The

IEPA

was

delegated

NPDES

program

authority

in

1977.

The

IEPA

processed

MSC’s

subsequent permit

renewal

application for

Yard

19

as

a

discharge

into

the

Secondary

Contact

Waters

of the

Chicago

Sanitary

and Ship

Canal.

In

1987, the

IEPA issued

a permit renewal

as

MSC

discharging

into

the

McCook

Drainage

Ditch.

In

1992,

the

JEPA

determined

that

the

facility

falls under

a NPDES

General Permit

for non-coal

mines

and issued the General

Permit

No. ILG840029

for the facility.

MSC renewed the General NPDES Permit in

1997.

In

2000,

MSC submitted

a permit

modification application,

which contained updated

discharge

analysis.

This

application contained

concentrations

of TDS

at

1360

mg/L

and sulfate

at

514

mg/L.

The IEPA considered the receiving waters to

be the McCook Drainage Ditch rather than

the Chicago

Sanitary and

Ship Canal

and

considered the McCook Drainage

Ditch

to.

be

general

use waters of the State of Illinois.

Therefore,

the IEPA declined to process this application for the

Technical Evaluationfor

an

Adjusted Standard Petition

November28, 2001

Material Service Corporation

—

Yard 19

-

4

-

DAI Project 6219

McCook, Cook County,

Illinois

DOCMENT PR/NTED

ON RECYCLED PAPER

---

entire

facility

without

MSC

first

acquiring

an

adjusted

standard

for

TDS

and

Sulfate

concentrations

reported in the water discharge.

MSC determined that the TDS

and sulfate concentrations

in the discharge

were attributed to the

background

quality

of

groundwater

seeping

into

lower

horizons

of

the

quarry.

This

was

communicated to the IEPA.

The JEPA then processed the application for a portion of the facility

where mining would occur above

the local water table aquifer.

This new permit was issued with

the

original

NPDES

permit

identification

(No.

1L001945)

and allows MSC

to

discharge

storm

water from the portion of the quarry where mining

is above the aquifer.

Therefore,

MSC currently

has two NPDES permits

for the facility.

Permit

No. ILG840029

was

last issued in June

1997, will

expire in May 2002,

and calls for monthly monitoring of discharge

flow,

pH,

and Total

Suspended

Solids

(TSS).

Permit

No

ILOO 1945

was

issued

in

September

2000, will

expire

in August 2005, and calls

for monthly monitoring of discharge

flow, pH,

TSS,

TDS, and sulfate.

As

general

use

water,

the

McCook

Drainage

Ditch

would

be

subject

to

applicable

discharge

standards

found

in

35

IAC,

Subtitle

C

and D.

These discharge

standards

limit

total

dissolved

solids

(TDS)

to

1000

milligrams

per

liter

(mg/l)

and

sulfate

to

500

mg/I.

The

groundwater

seeping

into

the

Yard

19

quarry

has

been

found

to

have

naturally occurring

concentrations

of

TDS and sulfate that are often greater than the discharge concentrations

allowable under

the new

permit.

The mineralized nature of the aquifer contributing groundwater flow into Yard 19

is also

reported

in several

regional

studies

completed

by

the Illinois

State

Water Survey.

It

is

MSC’s

intent to

obtain

an

adjusted

standard

for

the

naturally

occurring

background

concentrations

of

TDS

and

sulfate found

in

the

groundwater

seeping

into

the

quarry,

and

then

submit a permit

renewal application to capture both permits into a single permit (Permit No.

ILOO 1945).

Copies

of the MSC’s NPDES permits

are included in Appendix A.

2.3

Description ofthe McCook Drainage Ditch

The

McCook

Drainage

Ditch

flows

in

a

south-southeasterly

direction

across

privately

owned

industrial and commercial properties for its entire

3-mile length.

Consequently,

public access to

the

ditch

for any

detailed

scientific

purposes

is restricted to

only

several

short

reaches

located

where

public

roadways

cross

over

the

ditch.

The

closest

residential

areas

to

the

McCook

Drainage Ditch are found in Brookfield, north

0f47th

Street.

It is our estimation that access to the

Technical Evaluation for an Adjusted Standard Petition

November28,

2001

Material Service Corporation

—

Yard 19

-

5

-

DAJProject 6219

McCook, Cook county,

Illinois

DOCMENTPRINTED ON RECYCLED PAPER

---

McCook

Drainage Ditch can

only

be gained

by trespass

on private

property and that the

Ditch

does

not

appear

to

be

either

accessible

or

suitable

for

recreational

use.

Photographs

of the

McCook Drainage Ditch are included in Appendix B.

The

size of the

ditch

channel typically ranges from only

1 to just over

10 feet across with a depth

that

varies

from

a few

inches

up

to

approximately

two

feet.

Just

as

with

the

ditch

origin,

the

McCook Drainage Ditch

terminates where the

water

enters

a

culvert.

A

1929

plat by

the

then

Sanitary District of Chicago identifies this culvert

as the

Summit Conduit.

The

ditch

water that

flows into the Summit Conduit is routed under the Des Plaines River and then discharges

into the

Chicago

Sanitary

and

Ship

Canal

approximately

five

hundred

yards

west

of Harlem

Avenue.

Figure

1 is topographic map that shows the location of the McCook Drainage Ditch.

3.0

GROUNDWATER

AND

SURFACE

WATER QUALITY

3,1

Literature Review

DAI

and MSC have conducted a review of groundwater and surface

water quality in the vicinity

of

the

MSC’s

Yard

19

in

McCook.

Several

references

were

identified

regarding

naturally

elevated

concentrations

of

TDS

and

sulfate

in

the

groundwater

from

the

regional

shallow

dolomite aquifer also present in the McCook area.

DAT also completed a Freedom of Information

Act (FOIA) request to the Metropolitan Water Reclamation District of Greater Chicago (MWRD)

in an effort to review available surface water quality for the Chicago Sanitary and Ship Canal and

Des Plaines River.

A summary of this information is provided

below.

3.2 Groundwater Sources

The

shallow

dolomite

aquifer

is one

of

four

significant

aquifer

systems

commonly

utilized

in

Northeastern Illinois

(Willman,

1971).

Groundwater resources in the Northeastern Illinois are as

follows:

1)

Unconsolidated sand and gravel deposits in the glacial drift (when present),

2)

Shallow dolomite formations, mainly of Silurian Age,

3)

The Cambrian-Ordovician aquifer, known as

the deep sandstone aquifer, of which the

Ironton-Galesville and Glenwood-St.

Peter sandstones are the most productive

formations, and

Technical Evaluationfor an Adjusted Standard Petition

November28,

2001

Material Service Corporation

—

Yard 19

-

6

-

DAJ Project 6219

McCook, Cook County,

Illinois

DOCMENT PRINTEDON RECYCLED PAPER

---

4)

The Mt. Simon aquifer consisting of sandstones of the Mt. Simon and lower Eau

Claire Formations of Cambrian age.

Silurian rocks form the bedrock surface in the entire

Chicago region outside of several void areas

located

in

the

far

western

and

southwestern

portions

of the

collar

counties

(McHenry,

Kane,

Kendal,

and Will).

The

shallow

Silurian

dolomite

has

been

mined

in

the region

for

over

150

years at locations where the

bedrock is at or very near the surface (Mikulic,

1990).

The shallow

dolomite aquifer consists of Silurian-aged units known as the Niagaran Formation.

The thickness

of the

Silurian

dolomites ranges

from

less than

50 feet

in McHenry County

to

over 450

feet

in

eastern Will County.

Due to the presence of only a thin glacial

drift deposit on

the near surface

Silurian

bedrock,

the

unconsolidated

glacial

drift aquifer

is

absent

in

the

McCook

area

where

Yard

19 is located.

Groundwater in the shallow dolomite aquifer occurs in joints, fissures,

and solution

cavities.

The

upper zones

of the formation

tend to be more permeable than

the

lower

zones.

Recharge to

the

shallow dolomite aquifers is derived locally from vertical leakage through unconsolidated glacial

drift deposits that are

in turn recharged by precipitation.

Loosing reaches from rivers and streams

as

well as

leakage

from

the

unconsolidated

aquifer

(where

present)

could

also

recharge

this

aquifer.

Shallow

dolomite

wells

in

northeastern

Illinois

range

from

15

to

450

feet

deep,

and

yields from these

wells may exceed 500 gallons

per minute

(gpm) in some

areas (Brower et

a!,

1989).

3.3 Groundwater Quality

Most of the villages

in the vicinity of McCook rely

on Lake Michigan water for potable

supply;

however, a few villages in the area have co-mingled water produced from shallow dolomite wells

with Lake Michigan water to augment supply.

For example, a well at

Riverside located within 2

miles

from

the

facility

has

water

that

contains

825

mg/l

TDS

and

is

co-mingled

with

Lake

Michigan water that typically contains

165

mg/i TDS.

Groundwater

quality from

the

shallow

dolomite

aquifer in the McCook area has

been

reported

(Sasman et al,

1981;

Schicht

et al,

1976)

as

containing

elevated concentrations

of TDS,

sulfate

and other related compounds.

Additionally, the shallow dolomite aquifer was found to have areas

of high

TDS

and sulfate concentrations

in a study

(Roadcap

et al,

1993) conducted

in Will and

southern Cook Counties.

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Schicht

et

a!

reported

129

water

samples

from wells

jn

the vicinity of McCook were

found

to

contain a median value for TDS of

1,431.5

mg/l with a range from 875

mg/I to 2,100 mg/l.

As

will

be

shown

later

in

the

report,

this

value

is

similar,

if

not

slightly

higher,

than

TDS

concentrations

observed

in

groundwater

seeps

from

the

floor

and

walls

of the

MSC

Yard

19

quarry in McCook.

Sasman

et al reported TDS

concentrations

from

shallow

dolomite wells

in DuPage

County

and

western Cook County ranged from

259 mg/i

up to

1,832

mg/I with

a median

value of 625

mg/l.

The

highest

concentrations

of

TDS

were

noted

from

a

well

in

LaGrange

Park,

located

approximately

1.5 miles northwest of McCook.

Figure 2 shows the spatial distribution of TDS

in

groundwater in the vicinity of the MSC facility in McCook.

Sasman et al reported sulfate concentrations

from the dolomite aquifer in the DuPage and western

Cook County

was

found to

range

from 0.1

mg/i

to

864 mg/I

with a median

value of

166

mg/I.

The highest concentration of sulfate was also found in the well located in LaGrange Park.

Figure

3 is a map

that shows the spatial distribution of sulfate in groundwater in the vicinity of the

MSC

facility in McCook.

Roadcap et al reported that 186 samples from shallow dolomite aquifer wells

in Will

and southern

Cook Counties were

found to contain a median value ofTDS of 670 mg/i

with a range from 227

to

2,515

mg/i.

In the same

186-sample set, sulfate was found to contain a median value of

167.5

mg/l with a range from less than 0.9 to

1,543

mg/i.

Though

the boundaries of this study were no

closer than 7 miles from Yard

19, it did overlap some of the

areas covered in

both the Schicht et

al and Sasman et al studies.

Based

on

the

background groundwater

information

reviewed

by

DAI,

it

is

our

professional

opinion

that

sulfate

and

TDS

exist

at

naturally

elevated

concentrations

within

the

shallow

dolomite aquifer in the vicinity of the MSC’s Yard

19 quarry.

The

mineralized condition of the

shallow dolomite aquifer appears to be of a regional nature.

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3.4 Surface Water Quality

In

response to

a FOIA

request to the

MWRD,

DAI received

TDS

and

sulfate

data

for

the past

several

years

from

several

locations

along

the

Chicago

Sanitary

and

Ship

Canal

and

the

Des

Plaines River.

DAT received TDS and sulfate concentrations

covering a five-year period (1996-2000) from three

monitoring statiOns

on the Chicago Sanitary and Ship Canal.

The monitoring stations are located

at

Cicero

Avenue

(furthest east),

Harlem

Avenue

(approximately

500 yards

up-gradient

of the

confluence with the McCook Drainage

Ditch), and Highway 83

(down-gradient of the McCook

Drainage Ditch confluence and approximately

10 miles west of Harlem Avenue).

TDS concentrations over this period from the three monitoring stations ranged from a low of240

mg/i

up

to

1,463

mg/l.

TDS peaks were consistently noted in the winter months, which is likely a

reflection

of

salt

application

on

the

roads

in

the

vicinity

of

the

canal.

Average

TDS

concentrations

in

the

Chicago

Sanitary

and

Ship

Canal

from

the

two

stations that

bracket

the

McCookDrainage Ditch confluence were 581

mg/l and 578 mg/I.

The

average TDS

concentration

in

the Des Plaines River at Ogden

Avenue

was

reported at

713

mg/l, which is about

30

higher than the average concentration of TDS

in

the Chicago Sanitary

and Ship Canal.

Sulfate concentrations

from

the

monitoring

stations

on

the

Chicago

Sanitary

and

Ship

Canal

ranged

from

a

low of 25.7

mg/I

up

to

111

mg/I.

The

average

concentration of sulfate

in

the

Chicago Sanitary and Ship

Canal

is

63.1

mg/I.

The average

sulfate concentrations

from the two

monitoring stations that bracket the McCook Drainage Ditch confluence are

72.4

mg/I

and

70.4

mg/I.

The

average sulfate concentration (81.9 mg/I) in the

Des Plaines River was also 30

higher than

the values

found in the Chicago Sanitary and Ship Canal.

Elevated concentrations of dissolved minerals

in the Des Plaines River may be related to several

factors.

The Des Plaines

River receives

water from tributary streams,

storm flows, groundwater

discharge

and point source

discharges.

The

Des Plaines

River does

not receive

Lake Michigan

waters.

The elevated TDS and sulfate concentrations

in the Des

Plaines River may be attributed

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to

receiving a

significant

flow

component from

groundwater

discharge, including

the

Silurian

dolomite aquifer. In comparison,

the Chicago

Sanitary and Ship

Canal receives

water from Lake

Michigan, storm

flows,

tributary streams,

groundwater

discharge,

and point

source

discharges.

Lake Michigan water is known to contain

low concentrations

of dissolved minerals.

The average concentrations of TDS and sulfate in the Chicago Sanitary and Ship Canal, based

on

approximately

60

readings

over a

five-year

period,

are

summarized

in

the

table

below.

The

surface

water

data

provided

by

the

MWRD

and

associated

concentration

vs.

time

plots

are

included in Appendix

C.

TABLE

1

AVERAGE TDS

AND

SULFATE CONCENTRATIONS IN

SURFACE WATER

PARAMETER

CSSC

CSSC

@

Hwy

CSSC

@

Cicero

Des

Plaines

R.

Harlem Ave.

~L83

Ave.

@ Ogden Ave.

TDS (mg/i)

581.0

578.2

484.3

712.6

Sulfate (mg/i)

72.4

70.4

46.6

81.9

CSSC

=

Chicago

Sanitary & Ship Canal

4.0 CHARACTERISTICS OF THE McCOOK DRAINAGE DITCH

4.1

Source of the McCook Drainage Ditch

The McCook Drainage Ditch originates at a culvert beneath

47th

Street that appears

to discharge

storm water runoff.

The

McCook Drainage Ditch then

follows

a

south-southeasterly

course for

approximately

3

miles

to

its

discharge point

into the

Chicago

Sanitary and

Ship

Canal

located

approximately 500 yards

west of Harlem Avenue.

Figure

1 shows

the

flow path of the McCook

Drainage Ditch.

Select photographs ofthe McCook Drainage Ditch are

shown in Appendix B.

The McCook Drainage

Ditch appears to be

fed from storm water run-off, groundwater seepage,

and industrial

discharges.~ According

to

Waily

Callahan

with

the

Village

of Brookuield,

the

sanitary

and storm sewers in Brookfield are separate.

Sanitary sewers are routed

through a

15-

inch main

line to the

east along

47th

Street to the Metropolitan

Water Reclamation District water

treatment plant in Stickney.

Storm water drains for several blocks along

47th

Street

feed into the

McCook Drainage Ditch at the headwaters.

Storm drains as

far north

as

Gerritsen Avenue

(two

blocks

north of

47th

Street)

appear

to

flow south toward the McCook

Drainage Ditch.

Drainage

north

of Gerritsen

Avenue

appears

to be

routed to

the

north

and apparently

toward

Salt

Creek.

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The McCook Drainage Ditch provides drainage for an area that covers approximately two

square

miles.

The drainage area

is depicted on Figure

1.

4.2 Storm Water Runoff

Several other industrial properties utilize the McCook Drainage Ditch for storm water discharges,

including

McCook Metals,

Vulcan

Materials,

and Universal

Oil

Products.

DAT

completed

a

FOJA

request

to

the

IEPA

to

review

the

NPDES

permits

of these

facilities.

Each

of these

facilities

currently discharges

storm

water

to

the McCook

Drainage

Ditch

in

accordance with

their NPDES permits.

Rainfall in the McCook area

is estimated to average approximately 36

inches

per year.

Based on

this volume

of rain and inferred

low infiltration rates

in the area,

it

is estimated that the average

flow

of

the

McCook

Drainage Ditch

where

it

flows

into

the pipe under

the

Des

Plaines

River

would

be

approximately

2,320

gallons

per

minute

(gpm).

With

the

addition

of groundwater

seepage

and

other

industrial

discharges,

the

actual

flow

is

expected

to

be

significantly

greater

than this amount.

4.3 Flow Measurements

MSC

personnel

took flow measurements from

the McCook Ditch at two

locations

over a five-

month period from

March to

July

2001. The

flow

measurements were taken

at

the

head of the

McCook Drainage Ditch near ~

Street and near the end of the McCook Drainage

Ditch where

the flow enters the

Summit Conduit that extends beneath the Des Plaines River.

The flow at the

head of the McCook Ditch, consisting of storm water runoff from areas near Plainfield Road and

47th

Street,

averages

approximately

129

gpm.

The

flow

near the

end of

the

McCook

Ditch,

approximately 2

miles

down gradient of MSC’s

discharge,

averages

approximately

4,031

gpm.

Flow

volume within the

ditch varies

considerably and is largely a function of precipitation run-

off,

the

rate of

groundwater

recharge

in

loosing

reaches of the

ditch,

the

rate of groundwater

discharge in gaining reaches of the

ditch, and the

contribution of industrial

discharges.

Table

2

shows

the

McCook

Ditch

flow

data

and

rainfall

amounts

on

the

days

when

the

flow

was

measured.

Discharge flow measurements and calculations are included in Appendix D.

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TABLE 2

FLOW MEASUREMENTS FROM THE

MC COOK DRAINAGE DITCH

Date

Mc Cook

Drainage

Ditch

at 47th

Street

MSC’s

discharge

into Mc

Cook

Drainage

Ditch

McCook

Drainage

Ditch

at

Summit

Conduit

Rainfall

Data

~

Discharge

(GPM)

Discharge

(GPM)

Discharge

(GPM)

Discharge

(inches)

3/13/01

N/A

1,722

1,966

0.005

3/20/01

N/A

4,082

4,774

0

3/26/01

N/A

2,052

2,593

0

4/3/01

N/A

3,172

3,189

0

4/6/01

52

157

2,130

.

0.26

6/1/01

284

3,282

9,095

0.93

6/8/01

152

2,218

10,132

0

6/12/01

210

3,913

5,050

0.2

6/18/01

271

2,753

2,970

0.06

6/26/01

10

1,477

2,288

0

7/6/01

25

3,277

1,723

0

7/13/01

25

1,498

2,467

0

Average

129

2,467

4,031

NA

1

Flow rates measured

by MSC.

Rainfall data source is the Illinois State Climatologist Office.

5.0

CHARACTERISTICS OF MSC’s DISCHARGE TO McCOOK DRAINAGE DITCH

5.1

Source of the Discharge

The source of MSC’s discharge

is

groundwater seepage

and storm water with a minor fraction of

aggregate

wash

water that

is

pulled

out and then

added

back

to the

quarry

dewatering

system.

Groundwater seeps

into MSC’s Yard

19

quarry from numerous

fissures

and prominent joints

at

multiple locations along the walls and floor of the

quarry.

Portions of the quarry have penetrated

approximately 300 feet into the dolomite bedrock.

Most of the groundwater flow into the quarry

is

found to

occur along the quarry walls within 25

feet of the quarry

floor.

As

the

groundwater seeps into the

quarry,

it

follows

several

established drainage

pathways

that

feed

into two

drainage

basins

that

are aligned

in

series

and located

on

the

floor of the

quarry.

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These basins provide

retention

to

allow

solids

to

settle out of suspension.

From

these

settling

basins,

the water is pumped

to another holding sump

located approximately halfway up

the

300-

foot

wall of the

quarry.

From there two pumps

are

utilized to

lift the

water out of the

quarry.

Once

out of the quarry,

the water

is piped

approximately 2,000

feet until

it discharges

into

the

McCookDrainage Pitch at a point approximately

0.5

miles south

0f47t~1

Street.

Water collection

and flow within the

quarry are depicted on Figure 4.

Photographs of groundwater seepage

and

water collection are included in Appendix B.

A small portion of MSC’s water discharge is utilized

in an aggregate washing operation prior to

being

returned

to the

quarry

dewatering

and

discharge

system.

The volume

of water

used

for

aggregate washing has been conservatively

estimated to average less than 25,000,000

gallons per

year or 68,493

gallons per day (gpd).

The water estimated to be used to wash aggregate products

is approximately 1.4

to

1.9

of MSC’s total

estimated quarry discharge flow.

MSC has

collected water samples

directly from the aggregate washing

operation and

found that

the aggregate washing does

not significantly

increase TDS

and

sulfate

concentrations.

On

two

separate

occasions

(6/1/01

and

7/13/01),

three

(3)

samples

of

aggregate

wash

water

were

collected and analyzed after hold

times ranging

between 4

and 21

days.

The samples

collect on

6/1/01

were found

to contain

an

average

of

1,283

mg/l

of TDS

and

514

mg/i

sulfate,

while

the

samples collected

on

7/13/01

were

found

to contain

an

average of

1,387

mg/I of TDS

and 445

mg/l

of sulfate.

The TDS concentration in aggregate wash samples collected on 6/1/01

were only

slightly higher (73

mg/I) than TDS concentrations (1,210

mg/l) reported that same day for a water

sample collected upstream of the aggregate wash station.

Additionally, the sulfate average of 514

mg/I

was slightly

less (10 mg/i) than what was

found that day (524 mg/I)

in the sample collected

upstream of the aggregate

wash station.

The aggregate wash samples collected on

7/13/01

were

actually found to contain lower concentrations

of TDS and sulfate than was

reported in the water

upstream of the aggregate washing operation.

The results pf the two sampling events indicate the

average

increase

in

TDS

associated with

the

aggregate

washing

operation

is

5

mg/I,

while

the

average decrease in sulfate concentrations

was determined to be

12.5 mg/l.

With an average of nearly

18,500 mg/l, the water coming out of the aggregate washing operation

is high in Total Suspended Solids.

The

aggretage wash water

is routed to the retention ponds in

the quarry to allow settling of the solids from suspension.

After suspended solids are settled out,

the wash water

is returned to the quarry dewatering and discharge system.

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The

aggregate

washing

operation

uses a small

amount

of water

(2)

relative to

MSC’s

total

discharge

flows.

This

water

already

has

naturally elevated

concentrations

of TDS and

sulfate

prior

to

being used

for

aggregate

washing.

Contact between

the wash

water

with

fine-grained

stone

particles

during

washing

operations

and

in

the

settling

basins

does

not

contribute

appreciable amounts of TDS and sulfate.

If 2

ofMSC’s total

quarry discharge flow

is first used

for aggregate washing operations and aggregate wash water returning into the system contains an

average

5

mg/l higher TDS that that found in the

input water, then aggregate washing operations

would

theoretically

only

increase

MSC’s

final

discharge

by

0.1

mg/I

TDS.

Since

sulfate

was

found

in

lower

concentrations

after

aggregate

washing

operations,

this

operation

would

not

increase

sulfate concentrations

in MSC’s quarry discharge.

Therefore,

the aggregate washing operation does

not

have a significant affect on concentrations of

TDS

and sulfate in MSC’s final discharge.

This would

hold true ifMSC were to increase

future

aggregate washing operation

significantly

based

on

future

market demands.

If future

demands

require 50

increase

in washed aggregate from the facility, this would theoretically only increase

MSC’s discharge by an additional

0.15 mg/I TDS above

current levels.

Aggregate washing data

and calculations are included in Appendix E.

5.2

Volume of the Discharge

Water

discharges

from

the

quarry of groundwater

seepage

and

storm

flows

into

the

McCook

Drainage

Ditch have been

a routine component of mine operations for

approximately a

hundred

years.

Groundwater,

with

naturally elevated

concentrations of TDS

and

sulfate,

seeps

into

the

mine

pit continuously

through

fissures

in the

dolomite. During

rain

events,

storm water runoff

from precipitation is added to the discharge.

Based

on

information provided by MSC, Yard

19

discharges

an

average

of 3.6

to

5.03

million

gallons per day (mgd) into

the McCookDitch under NPDES Permit No. ILG840029.

The

5.03 mgd flow rate is derived from the total hours of operation of the two pumps

installed

in

the

mid-level

quarry

sump

and

used

to

discharge

to

the

McCook Drainage

Ditch.

The

meter

readings

during

1,508

days

from

1997

to

2001

were

used

along with

rated pump

capacities

to

calculate this discharge rate.

This flow rate has not been adjusted down to account for any of the

known

losses to the system.

These losses include pump wear and system leaks,

as well as

water

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pulled

out of system

for use

by

MSC.

Presently,

MSC

does

not

have any means to

accurately

quantif~’

these losses.

•Flow

monitoring of the

quarry

discharge, conducted

by

MSC

from March

through

July

2001,

produced an

estimated average flow of 3.6

mgd into the McCook Drainage

Ditch.

This

is

based

on

12

instantaneous

flow

measurements.

The

flow

measurements along

with

cross-sectional

areas provided a discharge

that ranged from 0.35 to 9.09

cubic feet per second.

This equates to a

theoretical discharge of 0.2 to 5.9 million gallons per day (mgd) ifthe measured flow rate remains

constant for

a 24-hour period.

However,

the pumps

do

not operate constantly

(i.e.

activated by

high-level floats in the sump) and there are periods

when the pumps cycle off resulting in a short-

term discharge that may approach zero.

MSC’s average

discharge rate to

the McCook Drainage

Ditch for the twelve

instantaneous measurement events

was determined

to be 2,467 gpm or

3.6

mgd (see Table 2).

The

daily

MSC discharge volumes

vary and are

linked to groundwater seepage and storm flows.

The pumps at the Yard

19 facility have the capacity to pump

up

to an estimated rate of 7.2 mgd,

if

both pumps installed

in the

mid-quarry

sump operate continuously for a 24

hour-period at their

rated capacity.

The maximum pumping capacity

would typically be needed only on a short-term

basis

following excessive precipitation events.

Pumping calculations are included in Appendix F.

The

McCook

Drainage

Ditch

also

receives

run-off

and

industrial

discharges

at

various

points

from other facilities in the area that contribute significantly to the total flow within the

ditch.

As

part

of the

gauging

of the McCook

Drainage

Ditch

at

the

point of where

it

flows

into

the

Summit Conduit under the Des Plaines River, MSC has also recorded

12 discharge estimates over

the past five months (March to July 2001).

Over this

period

the discharge rate varied from a low

of

1,966

gpm up to

10,132

gpm, which equates to a flow

ranging from 2.8 up to

14.6 mgd.

The

average

discharge rate into

the Chicago

Sanitary and

Ship Canal

over the monitoring period

was

approximately 4,031

gpm or

5.8

mgd (see Table 2).

During

the

flow

monitoring period,

MSC’s discharge

accounted for approximately

61

of the

flow

within the McCook Drainage Ditch,

as

measured

at the end of the ditch where water flows

into

the

culvert

installed

under

the

Des

Plaines

River.

MSC

appears

to

be

a

significant

or

dominant

contributor

of

the

regular

flow

within

the

McCook

Ditch.

Since

the

only

other

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permitted discharges are of storm water, MSC’s discharge may be

the only flow component that

fosters

any permanent aquatic

ecosystem

in the McCook

ditch during periods

of low

or absent

precipitation.

5.3 Quality of Groundwater Seepage

Starting

in February 2000, MSC began monitoring the quality of the quarry groundwater seepage

and

discharge.

Groundwater seepage

samples were

initially

collected

directly from the

wall at

several locations, but this practice has since been discontinued for safety reasons.

The concentrations of TDS in groundwater seepage samples collect from the wall or at the base of

the wall were

found to be 1,345

ppm (average of 58 samples).

MSC

also collected samples from

the drainage ways and

settling ponds prior to discharge and

found the concentrations

of TDS

to

be

1,272

mg/l

(average

of

75

samples).

Dilution

by precipitation

is

likely

the

reason

that

the

concentration

of

TDS

decreases

as

the

water

travels

away

from

the

seepage

point.

Sulfate

concentrations

exhibit a similar trend:

averaging 425 mg/I

at or near the wall and 405

mg/i

from

the

drainage

ways

and

settling

ponds.

These

data

indicate

that

MSC’s

operation

and

water

• handling process does

not contribute to the naturally elevated concentrations

of TDS and sulfate.

A summary table of groundwater seepage data

is included in Appendix G.

Comparison of groundwater

seepage

analytical

results

to

the

new

permit

limits

indicates

the

concentrations

of TDS

consistently

exceed the permitted value of

1,000 mg/I,

while only

a few

groundwatersamples were

found to contain sulfate at a concentration greater than 500 mg/i.

5.4

Comparison of Groundwater Seepage Data to Local Groundwater Conditions

Comparison of MSC’s

groundwater seepage data to known groundwater concentrations

indicates

that

the

average

TDS

concentrations

are

similar

or

slightly

lower

than

the

average

TDS

concentrations

reported

from

wells

drawing

from

the

shallow

dolomite

aquifer

that

were

documented in various ISWS studies.

Table

3 below illustrates this comparison.

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Comparison of Average TDS Concentrations in

Groundwater

SOURCE

TDS,

mg/I

# of samples

Groundwater from Wells

set

in Shallow Dolomite

1,431.5

129

Groundwater seepage in

MSC’s Yard

19

Quarry

1,345

58

This

comparison

indicates

that

the

TDS

concentrations

found

in

the

groundwater

seepage

of

MSC’s

Yard 19 Quarry

are consistent with background concentrations of TDS documented from

wells set into shallow dolomite aquifers.

5.5

Quality of MSC’s Discharge

MSC

has

collected

samples

from

the

discharge

pipe

prior

to

entering

the

McCook

Drainage

Ditch.

The concentrations of TDS and sulfate from these samples have been reported at relatively

consistent concentrations.

TDS has

been reported to

range from

1,070 up

to

1,400 mg/i

with an

average

of 1,299 mg/l, while sulfate concentrations

have ranged from 351 up to 524 mg/l with an

average

of 427

mg/l.

The

pH

of the

discharge

has

averaged

7.8,

and

concentration of Total

Suspended

Solids

(TSS)

in

the

discharge

has

averaged

17

mg/i.

A

summary

table

of water

quality data for the MSC’s discharge and the McCook Drainage Ditch

is included in Appendix H.

Comparison

of concentration of TDS

and

sulfate

in

MSC’s

discharge

to

the new permit

limits

indicates the concentrations

of TDS consistently exceed the permitted value of 1,000 mg/I, while

only

20

of the

samples

were

found

to

contain

sulfate

at

a

concentration

greater

than

the

permitted value of 500 mg/l.

6.0

IMPACT TO

RECEIVING

WATERS

Based on the known concentrations of TDS and sulfate in MSC’s discharge, a comparison can be

made

to

the

concentrations

of those

constituents

found

in

the

McCook

Drainage

Ditch

and

Chicago Sanitary and Ship Canal.

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6.1

Impact to the Chicago Sanitaryand Ship Canal

The McCook

Drainage Ditch

discharges

into

the Chicago

Sanitary and

Ship Canal

at a location

approximately

500

yards

west

of Harlem Avenue,

after

being

piped

beneath

the

Des

Plaines

River.

DAT

calculated the

potential

impact to

the

Chicago

Sanitary and

Ship

Canal

assuming

MSC’s

discharge

is

direct

to

the

Chicago

Sanitary

and

Ship

Canal.

Actual

water

samples

collected at the

end

of the McCook Drainage Ditch

indicate that TDS and sulfate

concentrations

in

MSC’s

discharge

are

diluted

by

20-25

prior

to

discharge

to

Chicago

Sanitary and

Ship

Canal.

The following table compares average concentrations

of TDS and sulfate in surface water.

TABLE 4

AVERAGE

SURFACE WATER CONCENTRATIONS

PARAMETER

MSC

IMSCHARGE

McCook Ditch

Prior to

Discharge into

CSSC

CSSC

@

Harlem:

up-gradient of

McCook Drainage

Ditch discharge

CSSC

@

Hwy

83:

down-gradient of

McCook Drainage

Ditch discharge

TDS

1,299 mg/I

1,018

mg/I

581

mg/I

578 mg/I

SULFATE

427 mg/I

329 mg/l

72

mg/I

70

mg/l

Based on

flow rates for the Chicago Sanitary and Ship Canal (603 mgd) provided

by the MWRD,

it

is estimated that the MSC’s discharge (estimated at approximately

5

mgd)

is limited to less than

1

of

the

total

flow

within

the

canal.

Based

on

this

information,

the

impact to

the

Chicago

Sanitary

and

Ship

Canal

can

be

calculated.

Based

on

these

volumes

and

concentrations

it

is

estimated that MSC discharge contributes a 6-mg/l increase

in TDS and 3-mg/l increase in sulfate

in

the Chicago Sanitary and Ship Canal.

This calculation

is included in Appendix

I.

6.2

Impact to the McCook Drainage Ditch

To evaluate the

impact to the McCook Drainage

Ditch,

DAI calculated

the average background

concentration of TDS and sulfate in surface water from the McCook Drainage Ditch (up-gradient

of MSC’s Discharge)

and that

found

in

the nearby

Des

Plaines

River.

Data

from the

Chicago

Sanitary and Ship

Canal was not

used in the background calculation because the contribution of

low TDS water from Lake Michigan is not representative of surface water in the McCook area.

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MSC collected

two surface

water samples

from the head of the

McCook Drainage

Ditch during

February 2001.

The TDS concentration in these two samples averaged

1,810 mg/l.

The elevated

concentration in the winter months is likely related to the application of road salt along

47th

Street

and adjoining side

streets.

During

the same

sampling

events, the

TDS

concentration in

MSC’s

discharge

averaged

1,300

mg/I.

Sulfate

concentrations

in

surface

water

remained

consistent

through

the

winter

months.

The

table

below

provides

the

basis

for

determining

the

average

background

concentrations

of

TDS

and

sulfate

in

surface

water.

Appendix

H

provides

a

summary table of McCook Drainage Ditch sampling results.

TABLE

5

SUMMARY OF BACKGROUND SURFACE WATER CONCENTRATIONS

BACKGROUND

CONCENTRATIONS

TDS, mg/I

SULFATE, mg/i_J

McCook Drainage

Ditch Calculated

Average (less MSC’s

discharge)

703

183

McCookDrainage

Ditch Concentration

Up-gradient of MSC’s

Discharge (non-winter

months only)

745

167

Des

Flames

River

~

Ogden Avenue

713

82

AVERAGE

BACKGROUND

CONCENTRATION

720

144

Based on these average

background concentrations, concentrations in MSC’s discharge, and flow

data

collected

by

MSC

from

the

McCook

Drainage

Ditch,

DAI

evaluated

the

impact

to

the

McCook Drainage Ditch under a variety of flow and concentration scenarios.

Extreme scenarios

were

evaluated

to assess

impact to

the

McCook Drainage

Ditch

during

specific events,

such

as

periods of draught,

heavy rain, and peakdischarge concentrations.

The various scenarios can also

be used to predict seasonal fluctuations in flow and concentration.

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The flow/concentration scenarios evaluated

by DAI included the following predictable events:

•

Spring Rain Events,

•

Summer Draught,

•

Summer Rain,

•

Winter Run-Off, and

•

Normal Conditions.

For the Spring Rain and Winter Run-Off scenarios, background concentrations of TDS within

the

McCook Drainage

Ditch

are assumed to be elevated due to contributions

from road

salt

as

was

documented by MSC sampling data at the head of the McCook Drainage Ditch.

Summer Draught

and Summer Rain

scenarios

were

constructed

using

“low

flow/peak concentrations”

and “high

flow/average concentrations”,

respectively,

to evaluate

impacts

from these

events.

The Normal

Conditions

scenario utilizes

average

flow

rates and average concentrations

of TDS and

sulfate.

The

results

of the predicted TDS

and sulfate concentrations

in the

McCook Drainage

Ditch are

summarized in the

following table.

TABLE

6

PREDICTED TDS

AND

SULFATE

CONCENTRATIONS

MODEL

SCENARIO

TDS, mg/I

SULFATE, mg/i

Winter Run-Off

•

1,562

339

Spring Rains

1,787

263

Summer Draught

1,393

520

Summer Rains

865

215

Normal Conditions

1,066

313

The

above concentrations

indicate that TDS concentrations

vary over a relatively wide range as a

result

of seasonal

fluctuations, while

the

sulfate

values

are

relatively

consistent

throughout

the

year.

During

the

Winter Run-Off and Spring Rain scenarios,

the TDS

values

are

elevated

due

primarily due to the contribution of road salt run-off into the McCook Drainage Ditch, which may

exceed

2,000

mg/I

TDS

(primarily

chloride).

Under these

conditions,

MSC

discharge

actually

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helps

stabilize

these

periods

of

peak

winter

concentrations

of TDS.

MSC’s

discharge

may

dominate the flow within

the

McCook Drainage Ditch during Summer

Draught conditions since

groundwater continues to seep regardless of precipitation and concentrations

in the discharge may

be elevated due to evaporation.

Under normal conditions (average

flows/average concentrations),

it

appears that TDS and sulfate

concentrations

in the McCook Drainage Ditch are increased by approximately 346 mg/I

and

169

mg/I,

respectively, over

the

average

background

concentrations.

Based

on

this evaluation,

the

impact of MSC’s discharge to the dissolved chemical constituents found in the McCookDrainage

Ditch

water is

minimal, and well below documented concentrations

that may result in biological

impairment.

The

toxicity

of the

TDS

and

sulfate

is

discussed

in

Section

8

of

this

report.

A

summary table for the above calculations is

included in Appendix I.

7.0

TREATMENT OPTIONS

DAI

completed

a review of available

treatment technologies

that

could

be

utilized to

maintain

compliance

with

NPDES

permit

limitations

of

1,000

mg/l

TDS

and

500

mg/l

sulfate.

In

developing the

treatment technologies

and associated cost

estimates,

DAI utilized

average flow

rate that is assumed to range between 3.6 and 5.0 mgd.

This volume

range was selected because

it

is

representative of recent flow measurements and

long-term pumping volumes

as measured by

MSC.

Consequently, the treatment costs

outlined in this section would be increased substantially

during periods of heavy rainfall when the MSC’s discharge may reach 7.2

mgd.

7.1

Available Technologies

As

part of the

requirement of

the

applying

for

an

adjusted standard,

it

is necessary

to

evaluate

available

treatment

options.

The

evaluation

is

designed

to

identif~’technically

feasible

and

economically

reasonable

approaches

to

treat the

discharge. DAI

has

identified several

possible

remedial solutions which are as

follows:

•

Dilution;

•

Deep well injection;

•

Reverse Osmosis; and

•

De-ionization.

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7.1.1

Dilution

The

Village

of McCook

purchases

Lake

Michigan

water

from

the

City

of

Chicago.

Lake

Michigan water typically exhibits low concentrations of TDS (less than 200 mg/i).

To

lower TDS

and

sulfate

concentrations

in

MSC’s

discharge

below permitted

limits,

approximately

2

mgd

(1,500 gpm)

of Lake Michigan water would needto be purchased from the City of Chicago.

Dilution

would

substantially

increase

the

flow,

and

consequently

the

erosive

power,

of

the

McCook Drainage

Ditch.

This

could also

adversely impact the

man-made structures

at various

road and rail

crossings as

well

as

the capacity of the ditch

to

carry water

during storm

events.

Based

on

the

volume

of

water

required,

dilution

does

not

appear

to

represent

a

reasonable

technological

or

aesthetically pleasing

approach.

Consequently,

DAT

will

not

further pursue

an

economic evaluation of this option.

7.1.2

Deep Well Injection

The maximum flow that a deep well typically can accept

from injection is 500 gpm (Brower et al,

1989).

Based

on

the

volume

of

discharge

from

the

MSC

facility,

a

series

of laterally

spaced

injection

wells

(8-10

wells) would

be

required.

The

wells

would

need

to

be

large diameter

(minimum

8-inch

diameter)

and likely would

need

to

be

completed

several hundred

feet below

the floor of the quarry to avoid re-circulation of the injected water.

A significant problem with this

strategy

is that deep well

injection

does

not

typically work well

with water that contains

high

dissolved solids and

low suspended

solids.

It is quite possible that

the

water would

need

to be pre-treated

or diluted prior

to injection.

Without pre-treatment,

the

injection wells would

likely require

frequent cleaning and re-development to

maintain acceptable

injection rates.

Several back-up wells would be necessary when wells are shutdown for cleaning,

repairs,

and

re-development.

To

avoid over-injection of the reservoir, the injection

wells would

have to be widely spaced (several hundred feet apart).

MSC

does not own sufficient property

at

this

location to accommodate

a large array of injection wells.

DAT

reviewed

the

cost

associated

with

is

technology and found

that

the

capital

investment

for

well injection

would range from

19 to 26 million

dollars, with annual and operating costs running

as

high as

18 to 26

million dollars (Brower et

al,

1989).

Given the

large flow rate requirement,

incompatible chemistry, and space limitations,

deep well injection

does not appear to be a viable

treatment option.

Although, deep well injection can

be economically feasible at lower flow rates,

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and could be used

in

conjunction with

other technologies

that may reduce the volume requiring

injection.

7.1.3

On-site Treatment

DAI

contacted

several

water

treatment

vendors

to

assist

in

an

evaluation of on-site

treatment

options.

Available technologies that have been used successfully to treat TDS and sulfate include

reverse osmosis and de-ionization.

Using

these technologies, the entire

discharge stream would

not require treatment.

A split that represents approximately

1,000

to

1,400 gpm, or about 40

of

the

total

flow, would need to be treated and re-introduced

to the main flow in

ordet to dilute

the

concentrations

in the discharge to below permit levels.

U.S.

Filter provided

DAI

with pricing based

on

the

above

scenario, and

additional

independent

references were checked to verify the approximate costs associated with the above technologies.

The

capital

expenditure

for

these

options

would

range

from

2.3

to

3.2

million

dollars,

which

includes

engineering

design,

equipment,

and

construction

costs.

Operating

and

annual

costs

would range from 2.3

to 5.6 million dollars.

Operating and annual costs

include the cost of labor

to

operate and maintain

the equipment, materials,

fuel, chemicals,

and power, while annual costs

include overhead, taxes, insurance, administrative costs, depreciation, and interest.

The

most

significant problem

with

these

technologies

is that they generate a new waste

stream

that would

require treatment

or disposal.

The

waste stream would

consist of brine that

would

require on-site treatment

or disposal.

Treatment options vary from solidification and disposal

to

deep-well

injection.

The most economic

way to treat

the

brine would

likely involve

deep well

injection.

A low-flow rate brine (less than

100

gpm)

effluent could be diluted and injected

into a

deep

well.

Capital

cost

associated

with

establishing

a deep

well brine

disposal

unit

would

be

approximately

1.6

to 2.2

million dollars,

with annual and operating costs ranging

from 1.4 to

1.9

million dollars.

Due to lower operating and annual costs, reverse osmosis in conjunction with deep well injection

of

the

brine

effluent

would

be

the

most

economic

approach

to

treating

MSC’s

discharge;

however, the 20-year operating cost of this approach is estimated to range from

81 to

113 million

dollars.

A cost summary table of treatment options analyzed by DAI is included in Appendix

J.

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Based on our review the available technologies to treat MSC’s discharge, it

is DAT’s professional

opinion that direct treatment of the discharge is not economically feasible at current and projected

future

cost considerations.

8.0

TOXICITY IMPACT OF TDS

AND

SULFATE TO RECEIVING WATERS

An

important

part

of

the

Adjusted

Standard

assessment

is

an

evaluation

of

the

impact

the

proposed standard will have on indigenous organisms in the receiving water.

Due to the nature of

the

receiving

water along

with

nearly

non-existent

access

locations,

a

biological

survey

of

the

McCook Drainage Ditch has not been conducted.

Alternatively, the IEPA recommended

that the

impact or toxicity of TDS and

sulfate could be evaluated based

on

a literature review relative to

typical freshwater fish species,

such

as bluegill,

large-mouth bass,

and channel catfish and other

species likely to be present.

It is important to note that due to the size

and nature of the McCook

Drainage Ditch, it

is unlikely that abundant or large populations of these common

fish species are

supported.

Therefore,

the toxic response by

these species to elevated concentrations of TDS

and

sulfate

is

reviewed

and presented

here

as

an

indicator response

for these

and other

related fish

species and macro-invertebrates.

Additionally,

a

similar

Adjusted

Standard

Petition

has

been

submitted

for

elevated

TDS

and

sulfate discharges planned for Thorn Creek (Illinois Pollution Control

Board Case No. AS-Ol-9).

This petitioner

submitted

a

report

that addressed

the issue

of TDS

and

sulfate

toxicity to

small

vertebrate and macro-invertebrate species

that would

be

expected to

be

present in

the McCook

Drainage Ditch.

8.1

Toxicity of TDS

TDS

consists of a

summation of cations

and

anions;

therefore

the

toxicity of TDS

may vary

depending on

the concentration of specific cations and anions present in solution.

TDS comprise

inorganic

salts

(principally calcium,

magnesium, potassium,

sodium,

bicarbonate, chlorides

and

sulfates)

and small amounts

of organic

matter that are dissolved

in the

water.

TDS

in drinking

water originate

from natural geological sources, sewage,

urban run-off, and industrial wastewater.

Salts used for road de-icing

also contribute to the TDS content of surface water and groundwater.

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Concentrations

of

TDS

in

water

vary

considerably

in

different

geological

regions

owing

to

differences

in

the

solubilities

of

minerals.

As

discussed

previously

in

this

report,

the

TDS

concentrations

in MSC’s discharge

are

naturally

occurring concentrations

that

are

characteristic

of groundwater produced

from the

shallow

Silurian

dolomite aquifers

in

the

region.

Based on

prior

laboratory

analysis

conducted

by

MSC,

the

TDS

in

their

discharge

appears

to

consist

primarily of sulfate (TDS-S04) with lower concentrations

ofchloride

(TDS-Cl).

Reed and Evans (1981) conducted a series of acute toxicity tests for TDS-S04 and TDS-Cl using

three common

freshwater

fish

species:

bluegill

fry

(Lepomis

macrochirus),

large-mouth

bass

fingerlings

(Micropterus

salmoides),

and

the

channel

catfish

fingerlings

(Ictalurus

punctatus).

Bioassays

were

conducted

for a period

of

14

days

with various

combinations

of fish sizes

and

water temperatures.

The dilution water for these tests consisted of well water with relatively high

alkalinity

and the

salts of calcium and

magnesium.

From

this

data,

acute

toxicity

curves

were

developed

for

each

fish.

The

acute

toxicity

curve

shows

the

time

at a

given

concentration

at

which the population experiences a 50

mortality rate (LC50).

The reactions of catfish, bass, and bluegill to concentrations of TDS-SO4 indicate all three species

are

similarly sensitive

to

the

toxicant.

The

LC50

concentration at

14

days

was

found

to

range

from

14,000

to

17,500 mg/I.

Of the

three

species,

the

channel

catfish

is

the most

sensitive

to

TDS-S04.

The reactions of catfish, bass,

and bluegill

to concentrations of TDS-Cl

indicate all three species

are

similarly

sensitive to

the

toxicant.

The

LC50

concentration

at

14

days

was

found

to

range

from

13,000 to 15,000

mg/i,

which indicates TDS-CI is slightly more toxic to fish than TDS-S04.

Of the three species, the channel catfish

is the most sensitive (14 day LC50

=

13,000 mg/l) and the

large-mouth bass is the least sensitive (14-day

LC50

=

15,000 mg/l) to TDS-Cl.

Reed

and

Evans

(1981)

concluded

that

TDS

is

not

a

sensitive

indicator

of acute

toxicity

for

fishes.

The

tolerance to TDS varies

by species

and is dependent upon

the principal anion, either

chloride or sulfate, comprising the TDS.

The USEPA “Red Book” of water quality criteria (USEPA,

1976) reported results from an earlier

study

conducted

by

Rawson

and

Moore

(1944)

that

found

several

common

freshwater

fish

Technical Evaluationfor an Adjusted Siandard Petition

November28,

2001

Material Service Corporation

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Yard 19

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IvlcCook, Cook County, Illinois

DOCMENTPRJNTED ON RECYCLED PAPER

---

survived

10,000

mg/l

TDS.

Rawson

and Moore

also

concluded

that

TDS

concentrations

in

excess of 15,000 mg/I were unsuitable for freshwater fish.

8.2 Toxicity of Sulfate

Sulfates

occur

naturally

in

numerous

minerals

and are

used

commercially,

principally

in

the

chemical

industry.

They

are discharged

into water in industrial

wastes and through

atmospheric

deposition;

however,

the

highest

concentrations

usually

occur

in

groundwater

and

are

from

natural

sources.

Sulfate

is

one

of the

least

toxic

anions;

however,

catharsis,

dehydration,

and

gastrointestinal irritation have been observed at relatively high concentrations.

The reactions of catfish,

bass, and bluegill to concentrations of SO~indicate all three species are

similarly sensitive

to the toxicant.

The

LC50 concentration at

14

days

was

found to

range from

10,000

to

11,000

mg/i.

Of

the

three

species,

the

channel

catfish

and

bluegill

are

the

most

sensitive to TDS-S04 and the large-mouth bass is the least sensitive. Based on these results, Reed

and Evans

(1981)

concluded that concentrations of sulfate

at

1,000 mg/I

would

be a

reasonable

water quality standard for protection of aquatic life.

In a similar study,

Dowden and Bennet

(1965) conducted

acute toxicity tests with sodium sulfate

using

two

species

of

fish:

bluegill

and

goldfish

(Carassius

auratus).

The

bluegill

(24-hr

LC50”17,500 mg/i) was

determined to be more sensitive to sodium sulfate concentrations

than the

goldfish (24-hr LC50=20,040 mg/i).

A parallel study of TDS

and sulfate

in the area has been

completed

for Rhodia,

Inc.

by Huff &

Huff

(Environmental Assessmentfor

the ProposedIncrease

in

Total Dissolved Solids Discharge,

2000) for

an Adjusted Standard petition for Thom

Creek (Illinois Pollution

Control

Board Case

No.

AS-01-9).

Thorn Creek

is located

approximately

18

miles southeast of the subject property.

Huff & Huff (2000) conducted

a chronic toxicity test

for TDS and

sodium sulfate

using a water

flea

(Cheriodaphnia

dubia)

and

the

flathead

minnow

(Pimephales

promelas).

Chronic

toxicity

was

not

observed

at

any of the

TDS

or

sulfate

concentrations

evaluated

for

either

organism.

Therefore,

the

“No

Observed

Effect

Concentration

(NOEC)”

was

assumed

to be

the maximum

measured

concentration of sulfate and TDS used

in the test, which was reportedat

1,381 mg/i and

2,790 mg/l, respectively.

Based on these results, Huff& Huff concluded there should be no acute

or chronic effects experienced

in

Thorn Creek associated with effluent

introduced at or below the

test values.

TechnicalEvaluation for an Adjusted Standard Petition

November28, 2001

Material Service

Corporation

—

Yard 19

-

26

-

DAt Project 6219

McCook, Cook County,

Illinois

DOCMENT PRINTED ON RECYCLED PAPER

---

Based on the toxicity data reviewed by DAT for TDS and sulfate,

it appears unlikely

that the TDS

and

sulfate concentrations

in MSC’s

discharge would have any significant

deleterious effect

on

aquatic life in the McCook Drainage

Ditch.

Since MSC’s discharge

appears to be the dominant

flow component to the McCook Ditch and said discharge

is into

the upper

reaches of the

ditch,

the aquatic

organisms that

are established in the ditch are

likely tolerant to

the TDS and sulfate

concentrations

found

in

MSC’s

discharge.

Furthermore,

MSC’s

discharge

is

the

only

regular

flow component that could likely foster a permanent aquatic ecosystem in the McCook Ditch.

In

conclusion,

the

adjusted

standard values

requested

by

MSC

for

TDS and

sulfate

are

less

than

those shown to be protective ofaquatic life in prior related

studies.

9.0

PROPOSED ADJUSTED STANDARD CONCENTRATIONS

MSC’s

quarry discharge consists primarily of groundwater seepage from the dolomite

aquifer at

the site.

Additional discharge flow components consist of contributions from precipitation events

along

with

minor

amounts

of

recycled

aggregate

wash

waters.

The

dolomite

aquifer

is

documented to naturally contain elevated concentrations of TDS and sulfate

in the vicinity of the

facility.

Analysis of groundwater seeping

into the quarry has verified

the mineralized condition

of the aquifer.

MSC’ s aggregate washing operations is not

contributing to an increase of TDS or

sulfate concentrations

in the facility discharge.

Though MSC could treat

the

naturally occurring elevated TDS

and sulfate concentrations

found

in the quarry discharge, this alternative to compliance is demonstrated

to

be overly economically

burdensome

to the

company.

In

fact,

the economic

impact indicates

that

the

facility

could not

maintain

a

viable operation if treatment

of the

discharge

to

achieve

general

use

water

quality

standards

is

required.

This

would

be

true

for

current

as

well

as

projected

future

economic

conditions.

Finally, MSC’s quarry discharge contains

naturally

occurring

concentrations

of TDS and sulfate

that would not have an adverse impact to the aquatic ecosystem of the McCook Drainage Ditch.

Therefore, MSC has

a justifiable position to petition

the Illinois

Pollution

Control Board for

an

adjusted

standard

of water

quality

standards

as

they relate

to

the

concentration

of TDS

and

Sulfate

in their discharge.

The adjusted standard request should consider two factors.

Technical Evaluationfor an Adjusted Standard Petition

Nove,nber28,

2001

Material Service Corporation

—

Yard 19

-

27-

DAt

Project

6219

McCook, Cook County, Illinois

DOCMENTPRINTED

ON RECYCLED PAPER

---

The

concentrations of the TDS and sulfate

found at Yard

19 during this study should be

evaluated against the potential concentration of TDS and sulfate documented

to occur in

the shallow dolomite aquifer.

The maximum TDS from quarry sampling was 2,400 mg/l.

The

maximum

aquifer

TDS

concentration

was

2,500,

2,100,

and

1,832

mg/l

from

the

three referenced studies.

The maximum sulfate from the quarry sampling was 660 mg/I.

The maximum sulfate found

to occur from the aquifer was

2,515

and 864 mg/l in two of

the three studies.

Though

these

studies are

regional

and some of the

high

concentrations

are

from

wells

some

distance

from MSC’s

facility, the highest

TDS and

sulfate

aquifer concentrations

documented

in

one of the

studies

(Sasman et

al)

was

from

a well

in

LaGrange Park.

LaGrange Park

is located about

1.5

miles northwest of the quarry.

2

The

proposed adjusted

standard

should

not

exceed

the

TDS

and sulfate

concentrations

that would be protective of the aquatic environment in the receiving water.

The USEPA

“Red Book” of water

quality criteria (USEPA,

1976) reported

results from

an

earlier

study

conducted

by

Rawson

an4 Moore

(1944)

that

found

several

common

freshwater fish survived

10,000 mg/I TDS.

Rawson and Moore also concluded that TDS

concentrations

in excess of 15,000 mg/i were unsuitable for freshwater fish.

The

Huff and

Huff study

determined

that

there

was

no

adverse

impact

related

to

the

maximum TDS and sulfate concentrations

proposed for an Adjusted Standard Petition

for

Rhodia,

Inc.

and the

Thorn Creek

Sanitary

District.

The

maximum

concentrations

for

this petition include 2,790

mg/I for TDS and

1,381

mg/I forsulfate.

The

Reed

and

Evans

study

indicated

that TDS

is

a poor

water

standard

for protecting

certain aquatic ecosystems.

The study focused upon the dominant ionic component in the

water and found that for sulfate dominant waters

an appropriate sulfate standard would be

1,000

mg/l.

It

is DAI’s

professional

opinion that,

though

lower TDS and sulfate concentrations

are

found in

the

groundwater currently flowing

into

the

quarry, MSC

should request

adjusted

standards

that

Technical Evaluationfor an Adjusted Standard Petition

November28,

2001

Material Service Corporation

—

Yard 19

-

28

-

DAI Project 6219

McCook, Cook County, Illinois

DOCMENTPRIN TED ON RECYCLED PAPER

---

are

reflective of the

conditions documented

from

the

aquifer.

This

would

ensure

compliance

should more

mineralized waters

flow into

the quany

or if evaporation of the groundwater once

captured in the quarryalso elevates these constituents.

Therefore,

DAT

recommends

that

MSC

request

an

adjusted

standard

for

TDS

and

sulfate

concentrations

of

1,900

mg/l

for TDS and

850 mg/l

for sulfate.

These

concentrations

for

TDS

and

sulfate

would

attain

compliance

for

the

facility

at

concentrations

that

are

reportedly

protective

of

the

aquatic

environment

of

the

McCook

Drainage

Ditch.

The

discharge

concentrations

are summarized below:

•

TABLE

7

PROPOSED

NPDES ADJUSTED STANDARD CONCENTRATIONS

E-

~

~

~

~

CURRENT

NPDES

DISCHARGE

LIMITATIO

NS

(mg/I)

MAXIMUM

CONC.

OBSERVED

AT THE

YARD

19

QUARRY

(mg/I)

MAXIMUM

CONC.

OBSERVED

FROM

THE

SILURIAN

AQUIFER

(mg/I)

MAXIMUM

CONC.

OBSERVED

IN MSC’s

DISCHARGE

TO

DATE

(mg/I)

CONC.

THAT ARE

PROTECTIVE

OF

AQUATIC

ECOSYSTEMS

(from Huff and

HufQ,

(mg/I)

PROPOSED

NPDES

ADJUSTED

STANDARD,

(mg/I)

1,000

2,450

2,515

1,400

2,790

1,900

E-

~

~

~

rJD

500

660

1,543

524

1,381

850

Technical Evaluationfor an Adjusted Standard Petition

November28, 2001

Material Service Corporation

—

Yard 19

-

29

-

DAIProject

6219

McCook,

CookCounty,

Illinois

DOCMENTPRINTED

ON RECYCLED PAPER

---

10.0

REFERENCES

Brower, Ross D.,

and Visocky, Adrian,

Evaluation of UndergroundInjection ofIndustrial

Waste

in Illinois,

Illinois

State

Geological

Survey,

Illinois

Scientific

Surveys

Joint

Report

2,

1989.

Huff

&

Huff,

Incorporated,

Environmental

Assessment

of

the

Proposed

Increase

in

Total

Dissolved

Solids Discharge from

the

Thorn

Creek Basin

Sanitary

District,

November

2000.

Mikulic, Donald G.,

Cross Section of the Paleozoic Rocks of Northeastern Illinois: Implications

for SubsurfaceAggregate Mining,

Illinois State

Geological Survey,

Illinois Minerals

106,

1990.

Rawson,

D.S.

and

J.E.

Moore,

The

Saline

Lakes

of

Canada,

Canadian

Journal

of

Research

22: 141,

1944.

Reed, Paula and Evans, Ralph, Acute Toxicity ofChlorides, Sulfates, and Total Dissolved Solids

to Some Fishes in Illinois, State Water

Survey Division, State Water Survey Report 283,

1981.

Roadcap, George S., Cravens, Stuart

J., and Smith,

Edward C.;

Meeting the Growing Demandfor

Water: An Evaluation of the Shallow Ground-Water Resources

in

Will and Southern

Cook Counties, Illinois,

Research Report 123, Illinois State Water Survey, Urbana,

1993.

Sasman, Robert, T.,

Schicht,

Richard

J.,

Gibb, James

P.,

O’Hearn, Michael,

Benson,

Curtis

R.,

Ludwigs,

R.

Scott;

Ver~flcationof the

Potential

Yield

and

Chemical

Quality

of the

Shallow Dolomite Aquifer

in DuPage

County,

Illinois;

Circular

149, Illinois

State Water

Survey, Champaign,

1981.

Schicht, Richard

J.,

Adams,

J.

Rodger,

and Stall, John B.;

Water Resources Availability,

Quality,

and Cost in Northeastern Illinois,

Report of Investigation 83,

Illinois State Water Survey,

Urbana,

1976.

United

States

Environmental

Protection

Agency,

Quality

Criteria

for

Water,

USEPA,

Washington, D.C.,

1976.

Willman,

H.B.,

Summary ofthe Geology ofthe Chicago Area,

Illinois State

Geological Survey,

Circular 460, 1971.

Technical Evaluationfor an Adjusted Standard Petition

November28,

2001

Material Service Corporation

—

Yard 19

-

30-

DAI Project 6219

McCook,

Cook County,

Illinois

DOCMENTPRINTED ON RECYCLED PAPER

---

TABLE

OF CONTENTS

1.0

INTRODUCTION

1.1

Purpose

~

1.

1.2

Facility Location

2

1.3

Facility Description

2

1.4

Regulatory Setting

~.

3

2.0

BACKGROUND

..

3

2.1

Local Setting

3

2.2

NPDES

Permit History

.•..~•

~

4

2.3

Description of the McCook Drainage Ditch

3.0

GROUNDWATER

AND

SURFACE WATER QUALITY

6

3.1

Literature Review

6

3.2

Groundwater Sources

~

6

3.3

Groundwater Quality

7

3.4

Surface Water Quality

9

4.0

CHARACTERISTICS OF THE MCCOOK DRAINAGE DITCH

10

4.1

Source of the Mc

CookDrainage Ditch

10

4.2

Storm Water Runoff

11

4.3

Flow Measurements

.... .~

~li

5.0

CHARACTERISTICS OF MSC’S DISCHARGE TO THE MCCOOK DRAINAGE

DITCH

12

5.1

Source of Discharge

..

12

5.2

Volume of Discharge

14

5.3

Quality of Groundwater Seepage

16

5.4

Comparison of Groundwater

Seepage Data to Local Groundwater Conditions

16

5.5

Quality of MSC’s Discharge

6.0

IMPACT TO

RECEIVING

WATERS

1.7

6.1

Impact to the Chicago Sanitary and Ship Canal

18

6.2

Impact to the Mc CookDrainage Ditch

..

18

7.0

TREATMENT OPTIONS

2.1

7.1

Available Tecimologies

~.

.

~

21

7.1.1

Dilution

~

.22

7.1.2

Deep Well Injection

7.1.3

On-Site Treatment

8.0

CHEMISTRY

AND TOXICOLOGY

~...

24.

8.1

Toxicity of

TDS

-

24.

8.2

Toxicity ofSulfate

.....

26

9.0

PROPOSED

ADJUSTED

STANDARDS

27

10.0

REFERENCES

30

TechnicalEvaluation for an Adjusted Standard Petition

November 28, 2001

Material Service Corporation

—

Yard 19

-

i

DAiProject 6219

McCook, Cook County, Illinois

DOCUMENTPRINTEDON RECYCLED PAPER

---

FIGURES

---

~bO~r.

EN

Vfr~W94’

—.--..---———-~

DRAINAGE

AREA

McCOOK

DITCH

DISCHARGE

L219_O1B

~T

A L

y/,r/~

NPDES

MATERIAL

M

ADJUSTED

STANDARD

SERVICE

CORPORATION

YARD

19

cCOOK,

ILLINOIS

Fl

SITE

CURE

1

LOCATION

I

7’~ft

Sc~1:3,OOODe~iJ~!3.O

DatlmL~WG$S4

---

MATERIAL

SERVICE

CORPORATION

NPDES

ADJUSTED

STANDARD

McCOOK,

tLLINOIS

FIGURE

2

AREAL

DISTRIBUTION

OF