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BEFORE

IAUG

27’

7001

5~.•UtUt-

ILLINOIS

Pollution

Control Board

IN THE MATtER OF:

)

)

4501-9

Petition of RHODIA, INC.

and THORN CREEK

)

(Adjusted Standard

-

Water)

BASIN SANITARY DISTRICT for an Adjusted

)

Standard from 35

III. Adm. Code

302.208

and 304.105

)

NOTICE OF FILING

TO:

Clerk, Illinois Pollution Control

Board

Illinois Environmental

State of Illinois Center

Protection Agency

100 West Randolph Street

1021

N. Grand Avenue East

Suite 11-500

Springfield, IL

62794-9276

Chicago, IL

60601

Illinois Department of Natural Resources

524 South Second Street

Springfield,

IL

62701-1787

PLEASE TAKE NOTICE that

on

Monday, August 27, 2001, we filed the attached

Amended Petition for Adjusted Standard with

the Clerk ofthe Illinois Pollution

Control

Board, a copy of which is herewith served upon

you.

Respectfully submitted,

RHODIA, INC. AND THORN CREEK

BASIN SANITARY

DISTIRCT

By:

.

Roy M.

Harsch

Sheila H.

Deely

GARDNER, CARTON

& DOUGLAS

321 North Clark Street

Chicago, Illinois

60610

(312) 644-3000

THIS FILING SUBMITTED ON RECYCLED PAPER

---

STATE OF ILLINOIS

)

--

~

)

COUNTYOFCOOK

)

cOOl

0-

-

ILL

BEFORE THE POLLUTION CONTROL BOARD

L2u~p

~~701

13

OF THE STATE OF ILLINOIS

°Qrd

IN THE

MATTER OF:

)

Petition ofRHODIA,

INC.

and THORN CREEK

)

(Adjusted Standard

-

Water)

BASIN SANITARY DISTRICT for an Adjusted

)

AS 01-9

Standard from 35111. Adm.

Code

)

302.208

and 304.105

)

AMENDED PETITION FOR ADJUSTED STANDARD

Rhodia,

Inc.

(“Rhodia”) and the Thom Creek Basin Sanitary District (TCBSD), by their

attorneys, hereby petition the Board

for

an Adjusted Standard, pursuant to 35

Ill.

Adm.

Code

104.400

et

seq.

and

Section

28.1 ofthe Illinois Environmental Protection Act (Act).

Rhodia and

TCBSD request that the Board

grant an

adjusted standard from 35

III. Adm.

Code 302.208 and

35

Ill. Adm.

Code 304.105

as they apply to

the discharge of total dissolved solids and sulfates

to

TCBSD

from Rhodias proposed expansion ofthe silica plant at its

Chicago Heights facility and

to the discharge of total dissolved

solids and sulfates from TCBSDs treatment plant to

Thom

Creek and

from Thorn Creek into the Little Calumet River.

By Order dated July 26, 2001, the Board requested certain specific additional information

to be

included in an amended petition.

That information

is included herein.

This Amended

Petition references the Exhibit

1

that was submitted with Rhodia’s original Petition on April 30,

2001.

Original and additional attachments to respond to the Board’s Order are submitted with

this Amended Petition.

THIS FILING SUBMITTED ON RECYCLED

PAPER

---

Panics to the Proceedings

Rhodia owns and

operates a plant at

1101

Arnold Street, Chicago Heights,

Cook County,

which manufactures inorganic phosphate chemicals primarily for food use and precipitated silica

to be

used in the tire and toothpaste markets.

The plant currently has a wastewater discharge to

TCBSD.

Rhodia proposes to expand its silica plant, which manufactures silica through the

reaction of liquid sodium silicate and sulfuric acid.

The wastewater from this plant expansion is

also proposed to be discharged to TCBSD.

The TCBSD treatment plant discharges to Thom

Creek approximately

10.1

miles upstream of its confluence with the Little Calumet River.

The production ofsilica generates a waste

stream that has elevated levels oftotal dissolved

solids (TDS) and

sulfates.

The discharge to TCBSD is projected to contribute to excursions

from

the water quality standards

for TDS and sulfates in

Thom Creek and the Little Calumet River as

set forth

in Section 302.208.

Rhodiaand TCBSD request an adjusted standard from

Section

304.105

and Section 302.208.

The specific information required to be set forth in a petition for

adjusted standard pursuant to

35

Ill. Adm. Code

104

is set forth below.

Section

104.406(a):

Standard from Which Relief is Sought

Rhodia and TCBSD request an adjusted standard from

both

35111. Adm.

Code 304,105 and

302.208

as they apply to the water quality standards for TDS and

sulfates applicable to effluent

discharges from TCBSYs

sewage treatment plant to Thom Creek and from Thorn Creek into the

Little Calumet River.

While there are no specific effluent standards for TDS, Section 304.105

prohibits effluent

discharges that cause or contribute to violations of applicable water quality

standards.

Section 302.208(e) requires that concentrations of 1000 mg/L of TDS and 500

mg/L

ofsulfates shall not be exceeded in Thom Creek or the Little Calumet River’.

The effective date

The

portion ofThom Creek between its confluence with

Deer Creek

and the USGS

Gaging Station

located

on

Thorn

Creek approximately

15

miles

downstream ofthe discharge point

from the Consumers

Illinois

Water

-2-

---

of this regulation is May

17,

1979.

An adjusted standard was granted to Rhodia2 and TCBSD in

1994 for the same stream reaches for which Rhodia and TCBSD request the current adjusted

standard.

Thus, with respect to

Rhodia and TCBSD, the water

quality standards applicable for

TDS and sulfates for the subject stream reaches are as set forth in Exhibit

I at 2-11.

(hire

Petition of Rhone-Poulenc Basic Chemicals Co., AS No. 94-7 (Adjusted Standard),

1994 Ill.

ENV LEXIS 743

(June 23,

1994) and In re Petition ofRhone-Poulenc Basic Chemicals Co., AS

No. 94-7 (Adjusted Standard),

1994 Ill. ENV LEXIS 1030 (August

11,

1994) (Supplemental

Opinion and Order))

The water quality standards requested for Thom Creek in this Petition are

2,650

mg/L of

TDS forthe stream reach between TCBSD’s discharge point and the confluence with Deer Creek

(Reach #1), 2,620 mg/L from the confluence with Deer Creek

to the USGS Station 05536275 in

Thornton (Reach #2), and 2,360 mg/L

for the portion ofThom Creek between the USGS Station

05536225

in Thomton and the confluence of Thom Creek with

the Little Calumet River (Reach

#3).

The requested water quality standard for Reach #1

and Reach #2 ofThorn Creek is

1,350

mg/L

and

1,340 mg/L ofsulfates, respectively.

For Reach #3

it is

1,160 mg/L.

For the Little

Caluxnet River from its

confluence with Thom Creek to the Calun1et-Sag

Channel (Reach #4),

less relief is required.

Based upon projected maximum levels, a water quality TDS limit of 2,020

mg/L

and a sulfate limit of 1,000 mg/L

in

Reach #4 would provide the relief needed for this plant

addition, while still being protective ofthe environment.

Company in University Park, Illinois

is subject to an

adjusted standard

granted to

Consumers

Illinois

Water

Company, which establishes a TOS standard of 2,100

mg/L

(Board Proceeding, AS89-3)

2

Then known

as Rhone-Poulenc

Basic Chemicals.

-3-

---

The requested relief is shown below in table

form:

Parameter

Reach #1

Reach #2

Reach #3

Reach #4

TUS

2,650 mg/L

2,620

mg/L

2,360

mg/L

2,020 mg/L

Sulfate

1,350 mg/L

1,340 mgfL

1,160 mg/L

1,000 mg/L

Section

104.406(b):

Nature of

Regulation of

General

Applicability

The primary purpose of the regulations involved in this Petition is to

protect aquatic life

and to

safeguard the quality of waters ofthe state for crop irrigation and public water supply

purposes

There are no effluent standards for TDS or sulfates.

The Board

once adopted an

effluent standard of 3,500 mg/L TDS, (R70-18, 3

PCB 419,

January 7,

1972) which the Board

repealed after recognizing that the treatment processes for TDS are very expensive, consume

large amounts ofenergy, and produce dry salts, which still must be disposed of

(R76-21,

September 24,

1981).

Regulation ofTDS discharges was left to

the application ofwater quality

standards for TDS, chlorides and sulfates.

Id.

These water quality standards were

set in

1972, in

part by reference to then-current studies ofthe toxicity of the contaminants to aquatic life.

The Board’s water quality standards have been approved by U.S. EPA and are consistent

with the requirements of the Clean Water Act.

Thus,

in a sense, these standards exist pursuant to

Section 303(a) of the Clean Water Act.

Petitioners do not believe that the water quality

standards involved in this proceeding were adopted in whole or in part to implement the other

laws specified in Section 106.705(b): the Safe Drinking Water Act, the Comprehensive

Environmental Response, Compensation, and Liability Act, the Clean Air Act, or the state

programs concerning the Resource Conservation and Recovery Act, Underground Injection

Control, or the National Pollutant Discharge Elimination System (NPDES).

-4-

---

Section

104.406(c):

Specified Level of Justification

The regulations of general applicability from which Rhodia and TCBSD seek an adjusted

standard do not

specify a level ofjustification foradjusted standards.

Section

104.406(d):

Facility and Process Descriptions

The Rhodia Chicago Heights

plant

is located at

1101

Arnold Street.

The facility has been

in operation since

1902 when it was Victor Chemical Works.

Stauffer Chemical Company

bought Victor Chemical in

1959.

Rhone-Poulenc Basic Chemicals, Inc. purchased the Basic

Chemicals Division of Stauffer Chemical Company in December

1987.

The name was officially

changed to Rhone-Poulenc Basic Chemicals Co.

in September

1989.

In 1998, the name ofthe

company was changed again to Rhodia, Inc.

The facility currently employs 279 people and

manufactures inorganic phosphate chemicals and precipitated silica.

Most of the inorganic

phosphate manufacturing processes involve the chemical

reaction ofphosphoric acid with either

soda ash or slaked lime.

Wastewaters that fluctuate in pH and total suspended solids are

generated in both processes. The precipitated silica manufacturing process involves reacting

sodium

silicate with sulfuric acid to produce silica.

Wastewaters

generated in

this process

contain total dissolved solids and sulfates.

All process wastewaters are discharged to TCBSD.

Water Pollution Control Equipment.

Process-generated

water is separated from the

product by high-quality filtration equipment employing a cloth media, a water wash, and either

pressure or vacuum to dc-water the product (depending on the product).

All of the recyclable

filtrate is routed to a recovery tank and re-used in the reactor.

The remaining filtrate and wash

water are routed to the effluent handling system.

This system consists oftwo 20,000-gallon

water storage tanks,

an analysis section, and an adjustment section.

The primary effluent tank is

used to accumulate surges in the effluent and dampen the peaks in the flow.

The secondary tank

-5-

---

is used as a safeguard to control spills and contain reacted material that may not meet product

specifications.

See Diagram at Attachment D to this

Amended Petition.

All effluent is continuously monitored for pH and Total

Suspended Solids (TSS).

These

values are displayed on a Distributed Control System

(DCS), which is monitored by the process

control room operator.

When a reading exceeds a set point,3 an alarm immediately notifies the

operator ofthe condition.

The operator then looks at the appropriate

area on

the

DCS control

screen to

determine the type of excursion and determine the corrective actions. If the pH is high

or low, the operator initiates the pH adjustment loop to

add neutralizing agents to

the effluent

stream.

If the total suspended solids concentration is high, the operator immediately begins to

search for the cause and eliminates it, or diverts the stream to

the secondary effluent tank until

the problem is corrected.

Ifthe situation worsens, a hard-wired interlock automatically stops all

effluent flow from the unit and recirculates it to the primary effluent tank.

Proposed Expansion.

The proposed expansion to Rhodia’s

facility is to

its Silica Plant,

which produces precipitated silica.

Rhodiahas proposed this expansion at its Chicago Heights

plant because the plant

is ideally located relative to both the raw materials necessary for the silica

process and the receiving market.

The proposed expansionto the silica plant will increase

annual TDS discharges by 65

over the original design capacity.

A block flow diagram forthe

proposed expansion is

set forth at Figure 2-4 of Exhibit

1.

Multiple grades of silica are produced, and will continue to be produced at higher volumes

in the expansion.

The process begins neutralizing the sodium silicate solution with sulfuric acid

in

agitated reactors to produce precipitated silica.

Once the reaction is complete, the silica is

removed from the solution via filtration.

Filtrate

from the operation, which contains

The a~arni

points are set within permit ranges to give operators time to

correct the deviation before a

permit

excursion

occurs.

-6-

---

approximately 4

of dissolved sodium sulfate,

is diverted to the mother liquor tank.

The filter

cake is then washed with water and

squeezed to remove residual sodium sulfate, and the filtrate

is directed to

a 20,000 gallon equalization tank.

The TDS concentration ofthese streams

declines toward 0 percent sodium sulfate by the end of each filtration cycle.

Table 2-3, which has been revised to include additional information requested by the

Board, sets forth the projected discharge loadings.

Table

2-3 is

attached to this Amended

Petition

as Attachment F.

On an annual average, the expanded process will discharge 0.84

million gallons per day containing 137,400 lbs/day ofTDS.

On a monthly basis,

the flow will

average

1.1

million gallons per day, with

144,200 lbs/day ofTDS.

The peak daily TDS

discharge is projected to

be

151,700 pounds.

TCJ3SD.

TCBSD operates a wastewater treatment plant (WWTP) with a design average

flow of 15.9 mgd and design maximum flow of40.25

mgd.

The WWTP is located in

Chicago

Heights, Illinois,

and provides wastewater treatment for approximately

100,000 people from the

Chicago Heights, Park Forest, Flomewood, South Chicago Heights, Steger, and Crete

communities.

The WWTP has 39 employees,

6 ofwhom

are part time.

The treatment plant was

originally constructed in

1933 and

has undergone a number

of construction projects including

an

expansion to

accept flows

from the Homewood Regional Plant.

The TCBSD

WWTP has been cited as an exemplary treatment plant based on its

overall

efficiency and environmental control by both an independent engineering team of the Agency

and the Central States Water Pollution Control Association.

The WWTP represents a $40

million investment, including an on-site laboratory and computer monitoring and control.

A

schematic ofthe physicalfbiological WWTP is presented in Figure 2-3 of Exhibit

1.

From the

sewers, the influent passes through bar screens prior to being pumped

to the surface through grit

-7-

---

chambers followed by primary sedimentation.

From primary treatment, the wastewater flows

through a conventional plug-flow activated sludge process, followed by a second-stage

biological aeration process and tertiary clarifiers for nitrification.

The wastewater is then

filtered, and seasonal chlorination added followed by post aeration and seasonal dechlorination.

The fully treated effluent is then discharged to Thorn Creek.

Excess flow

is diverted through

separate excess flow clarifiers, which is then recombined with the complete treatment effluent.

The current dry weather flow through the WWTP

is

11.6 mgd based upon the average of

the lowest three months in

1998.

This is 4.3 mgd below the design average flow of 15.9 mgd.

Thus,

the treatment plant has available

capacity for future growth.

The TCBSD WWTP serves

861

industrial and

commercial users in addition to the 31,000 residential connections.

This

industrial and

commercial sector accounts for 2.7

percent of the users and 29 percent of the

influent

flowrate based upon

1999 values.

The major industrial users are manufacturing

facilities, including

steel manufacturing and stamping

facilities.

Among the industrial users

besides

Rhodia are Ford Motor Company, Calumet Industries, Chicago Heights Steel,

Rohm &

Haas, and Alpharma.

There arethree stream reaches on Thom Creek and a

fourth reach on the Little Calumet

River that will be

impacted by the proposed expansion, under

peak loading and low flow

conditions.

Reach #1

is from the WWTP to the merger with Deer Creek.

Reach

#2 continues

from the merger with Deer Creek to the USGS

Station at Thornton, while Reach #3

is from the

USGS

Station to the merger with the Little Calumet River.

The fourth reach is from

the Thom

Creek confluence with the Little Calumet River to the Calumet-Sag Channel.

TMDL Limits.

No TMDL has been prepared, nor is any study underway, for Thorn

Creek or the

Little Calumet River.

Reach #2, #3, and #4 ofThorn Creek are on the 303(d) list.

-8-

---

Reach #2 and #3 ofThom Creek are listed as highly impaired for nutrients and pathogens, but

slightly impaired for salinity.

To the best ofRhodia’s knowledge, this listing is without

consideration of the previously granted adjusted standard.

In addition, the existing water quality

data does not indicate that the stream is

impacted at these levels.

Work done

by Huff & Huff

shows uses of the stream are not impaired.

The Little Calumet River from the Calumet to the

Calumet-Sag Channel is listed as highly impaired for several constituents, but is not listed for

salinity.

The Little Calumet upstream of its confluence with Thom Creek

is listed as highly or

moderately impaired for several constituents, but only slightly impaired for salinity.

On the

305(b) list, the Little Calumct River from Thorn Creek to the Calumet-Sag Channel is listed as

impaired for a number ofconstituents,

but not for total dissolved solids or sulfates.

From the

confluence with Thom Creek upstream the Little

Calumet River is listed as impaired for a

number ofconstituents,

but not for total dissolved

solids or sulfates.

Reaches 2 and

3 of Thom

Creek are listed for total dissolved

solids and

sulfates, and Reach

1

is listed for a number of

constituents, but not total dissolved solids or sulfates.

An Exhibit with stream segments and the

relevant 303(d) listings

is attached to this Amended Petition as Attachment F.

Section

104.406(e):

Cost ofCompliance

and Compliance Alternatives

In order to comply with the regulation ofgeneral applicability

and the existing

adjusted

standard, some form ofpretreatment by Rhodia for TDS removal would be necessary.

The

expanded silica plant wastewater design characteristics lend themselves to

selected demonstrated

and proven TDS/sodium

sulfate removal and

disposal strategies.

Although the sulfate removal

processes discussed below are technically feasible, even the most economical solution for

sodium

sulfate removal to

comply with water quality standards would result in significant cost

penalties to Rhodia.

For example, in the evaporation process the cost of steam alone required to

-9-

---

dehydrate the sodium sulfate solution would result in a finished product cost

above current

market price for granular sodium sulfate.

This cost, together with the cost of initial and working

capital and annual operating fixedcosts would place Rhodia in a non-competitive price position

for its silica finished product.

Rhodia is submitting the additional cost

information requested by

the Board for this Amended Petition separately, and claims trade secret and confidentiality

protection for this

information.

Taking into consideration the flow and variability of the wastewater stream, Rhodia

considered the following technologies for pretreatment:

(1)

Electrodialysis;

(2)

Single/Multiple Effect Evaporation;

(3)

Evaporation with Mechanical Vapor Recompression (MVR);

(4)

Reverse Osmosis

followed by Evaporation with MVR;

(5)

Calcium Chlroide treatment followed by Evaporation with

MVR;

and

(6)

Biological

Process Reduction ofsulfates to elemental sulfur

Vendors informed Rhodia that Electrodialysis (in its various forms) has almost never been

found to be practical

in the United States

industrial chemical industry, especially for as dilute a

feed as Rhodia has.

Any evaporation scheme would require multiple effects (increasing cost) or

falling film technology, and much more steam that the plant

is capable of providing.

Biological

sulfate ion reduction to elemental sulfur was not found to be practical because the process uses

an organic compound and air to

create carbonate ions that replace the sulfate ions.

Although this

reduces sulfates, it does not appreciably reduce the TDS going to the stream.

Rhodia, therefore,

evaluated the remaining technologies:

(1)

Falling

film evaporation with MVR;

(2)

Reverse Osmosis followed by Evaporationwith MVR;

and

(3)

Calcium Chloride Treatment with falling film evaporation

with MVR.

A briefprocess description of the technologies evaluated follows.

-

10-

---

Falling Film Evaporation with MVR (Alternative 1)

This

technology produces dry sodium sulfate from

a dilute aqueous solution.

This is

achieved by concentrating and subsequently

crystallizing the sodium sulfate out of the process

liquor.

A single falling film

evaporator is employed.

The feed is pumped to the top ofthe

evaporator and falls through steam-heated tubes.

The feed stream is thus concentrated to

a point

where

it can be cooled to precipitate the sodium sulfate crystals in the forced feed crystallizer.

The water vapor from the evaporator and crystallizer is

compressed by a large compressor and

routed to the shell side of the falling-film tubes to become the heating steam.

This is an

efficient

use of energy

and that would keepthe plant from needing to

provide a new boiler.

The

crystallization outlet stream is sent to a centrifuge and the cake is

sent to

a dryer.

A simplified

process flow diagram for Alternative

1

is presented in Attachment A.

Reverse Osmosis

followed by Evaporation with MVR (Alternative 2)

This

technology also produces dry sodium sulfate from a dilute

aqueous solution by

concentrating and subsequently crystallizing the sodium sulfate out of the process liquor.

Again,

for energy conservation reasons, both evaporator and crystallizer vessels are used.

This process

is even more energy efficient since itperforms a four-fold concentration with

a reverse osmosis

(RU) unit, thus reducing the evaporation requirement.

However, the RU unit has very strict inlet

requirements

concerning foreign material, which

is residual silica in this case.

Thus,

magnesiumlcaustic pre-treatment and high-tech

filtration are accomplished to remove the affects

of foreign

material before evaporation begins.

Evaporation, crystallization, centrifugation

and

drying

are accomplished much the same as in Alternative 1, with the first two

steps being smaller

because ofthe RO unit.

A simplified process flow diagram for Alternative 2

is presented in

Attachment B.

-11-

---

Calcium Chloride Treatment

—

Falling Film Evaporation

—

MYR (Alternative

31

This technology

employs a lime treatment of the feed stream to

increase the effectiveness

of crystallizationlprecipitation.

The evaporation through drying steps are accomplished much the

same as in Alternatives

1

and

2.

A simplified process flow diagram for Alternative 3

is presented in Attachment C.

Cost Summary of ComplianceAlternatives

Each of the alternatives evaluated produces a dry sodium sulfate stream requiring ultimate

disposition or possible disposal.

For the purpose ofthis

analysis, however, disposal costs were

not included since sodium sulfate is a commodity chemical with some resale value.

A summary

comparison of the demonstrated sodium

sulfate removal systems discussed above is presented in

the following Table.

It contains critical process and technical considerations and provides a

summary including estimated capital and annualized capital and

operating costs for the three

alternatives studied.

COMPARISON OF SODIUM SULFATE REMOVAL

SYSTEMS

Alternative

I

Alternative 2

Alternative 3

Undesirable

Constituents

Silica

25 ppm

Silica

25 ppm

Impact

on Plant

-

Dispose Silica

Dispose Silica

Capital Cost

$6 Million

$4

Million

$4.2 Million

Total Annual

Cost

$915k

$600k

$670k

Total Annual

Cost!

Al

Ton ofProduction

$32

$21

$24

Treatment Cost as a

Percentage Product

Cost

6.2

3.8

4.4

-

12

-

---

Cost’IOOO gallon

watertreated

$11.90

$7.78

$8.70

of Cost of direct

VI

discharge to TCBSD

1190

778

870

Alternative

I

=

Falling film evaporation with MYR

Alternative 2

=

Reverse Osmosis followed by Evaporation with MVR

Alternative

3

=

Calcium Chloride Treatment

—

Falling Film Evaporation

A/

Based on New Production Capacity

B!

TCBSD charges the Chicago Heights plant $1 .00/1000 gallons treated.

As set forth

in Attachment A, Alternative I would require more than

11

times the normal

cost to discharge to the WWTP and would add 6 percent to the cost of the product

silica.

Alternatives 2

&

3

are more economical,

although they would still cost about

8 times

the normal

WWTP cost

and would add approximately 4 percent to the cost of the product silica.

See

Attachments B and

C.

Treatment Options at TCSBD facility.

Treatment of

dissolved

solids requires

concentration of the solids into a smaller stream, followed by either disposal

or reuse ofthe

concentrated stream in the original process.

Evaporationand reverse osmosis are the two

established technologies, and both

require the handling ofa concentrated waste stream.

Rhodia’s

analysis for treatment on-site found reverse osmosis followed by evaporation to be the

low cost

on site option at $4 million dollars capital, and $600,000 annual costs.

This equated to $7.78 per

1000 gallons treated.

Ifthe entire effluent

from the TCSBD is treated, this would equate to

the

treatment of 15 to 20 million gallons per day, or approximately 20 times the quantity treated if

Rhodia treated the TDS.

The reverse osmosis costs are a function of flowrate, while the

evaporator would be a function of the concentrate stream.

Assuming the evaporator costs are the

-

13

-

---

same as Rhodia’s

evaporator, but the reverse osmosis costs increases by the 0.6 power of the

flow and the reverse osmosis represents

50 percent ofthe costs at Rhodia, then, such as system at

TCSBD would be as follows:

Capital:

RO $2 million (2O)’~0.6=$12 million

Evaporator

=

$ 2 million

Total

=

$14 million

Clearly, if TDS and sulfates

are required to be removed, it is more cost-effective to remove them

near the source.

In addition to the above costs, disposal costs at TCSBD would be significant,

because ofthe other contaminants present in the wastewater.

Although technically feasible, even the most economical solution for sodium sulfate

removal to

comply with water quality

standards would result in significant cost penalties to

Rhodia.

Such significant cost penalties would result in a non-competitive price for its silica in an

increasingly competitive market.

Section

104.406(1):

Proposed Adjusted Standard

As described earlier, Rhodia and TCBSD seek modification ofthe existing adjusted

standard as an adjusted standard from the generally applicable water quality standards for TDS

and sulfates for that portion of Thorn Creekdownstream ofTCBSD’s discharge to the confluence

ofThom Creek with the Little Calumet River (Reaches #1, #2 and #3) and from that point to the

confluence with the Little Calumet River with the Caiwnet-Sag Channel (Reach #4).

The

adjusted standards

sought for TDS are:

2,650 mg/L in Reach #1;

2,620 mg/L in Reach #2;

and

2,360 mg/L

in

Reach #3

of Thom Creek

and 2,020 mg/L

in the Little Caluinet River(Reach #4).

The requested standards

for sulfates are

1,350 mg/L

in Reach #1;

1,340 mg!L

and Reach #2;

-

14-

---

and

1,160 mg/L in Reach #3 of Thom Creek, and

1,000

mg/L

in the Little Calumet River

(Reach #4).

Rhodia and TCBSD propose that the Board adopt the following language to

effectuate the

requested relief:

(I)

The water quality standard for TDS

shall be

2,650

mg/L for

that portion ofThom Creek between TCBSD’s discharge

point and Thorn Creek’s confluence with Deer Creek.

The

existing adjusted standard, which already exists for this

portion ofThom Creek of 2,100 mg/L TDS shall be

modified to the new adjusted standard.

The water quality

standard for TDS found at 35

Ill. Adm.

Code 302.208

shall

not apply to

this portion of Thom Creek.

(2)

The water quality standard for TDS shall be

2,620 mg/L

for

that portion of Thom Creek between it’s merger with Deer

Creek and the USGS Gaging Station 05536275

in

Thornton.

The existing adjusted standard, which already

exists for this portion of Thom Creek of 1900 mg/L TDS

shall be modified to

the new adjusted standard.

The water

quality standard for TDS found at 35

Ill. Adm.

Code

302.208

shall not apply to this portion of Thorn

Creek.

(3)

The water quality standard for TDS shall be

2,360 mg/L for

that portion ofThom Creek between the USGS Gaging

Station 05536275 in Thornton and

Thorn Creek’s

confluence with the Little Calumet River.

The existing

adjusted standard, which already exists for this portion of

Thorn Creek of 1,900 mgTh

TDS shall be modified

to the

new adjusted standard.

The water quality standard for TDS

found at 35

Ill. Adm.

Code 302.208

shall not apply to this

portion ofThom Creek.

(4)

The water quality standard for TDS for that portion ofthe

Little Calumet River from the confluence with Thom Creek

to the Calumet-Sag Channel shall be 2,020 mg/L.

The

existing adjusted standard, which already exists for this

portion of the Little Calumet River of 1,700 mgIL TDS

shall be modified to the new adjusted standard.

The water

quality standard for TDS found at 35

Ill. Adm.

Code

302.208

shall not apply

to this portion of the Little Calumet

River.

-

15-

---

(5)

The water quality standard for sulfates shall be

1,350

mg/L

for that portion of Thom Creek between TCBSD’s

discharge point and Thom Creek’s confluence with

Deer

Creek.

The existing adjusted standard, which

already exists

for this portion ofThom Creek of 1,000 mg/L sulfates shall

be modified to the new adjusted standard.

The water

quality standard for sulfates found at 35

Ill. Adm. Code

302.208

shall not apply to this portionof Thom Creek.

(6)

The water quality standard for sulfates shall be 1,340 mg/L

for that portion of Thorn Creek between Thom Creek’s

confluence with Deer Creek and the USGS Gaging Station

05536275

in Thornton. The existing adjusted standard,

which

already exists for this portion of Thom Creek of

1,000 mg/L sulfates shall be modified to the new adjusted

standard.

The water quality

standard for sulfates found at

35

Ill. Adm.

Code 302.208 shall

not apply to

this portion of

Thorn

Creek.

(7)

The water quality standard for sulfates shall be

1,160 mg/L

for that portion of Thorn Creek from the USGS Gaging

Station 05536275

in Thornton to Thom Creek!s confluence

with the Little Caluniet River.

The existing adjusted

standard, which already exists for this portion of Thom

Creek of 850 mg/L sulfates shall be

modified to the new

adjusted standard.

The water quality

standard for sulfates

found at 35

111.

Adm. Code 302.208 shall not apply to this

portion ofThom Creek.

(8)

The water quality standard for sulfates for that portion of

the Little Calumet River from

the confluence ofThorn

Creek

with the Calumet-Sag Channel shall be

1,000 mg/L.

The existing adjusted standard, which already exists for this

portion ofthe Little Calumet River of750 mg!L

sulfates

shall

be modified to the new adjusted standard.

The water

quality

standard for sulfates found at 35

III. Adm.

Code

302.208 shall not apply to this portion ofthe Little Calumet

River.

(9)

The requirements of35

Ill.

Adm. Code

304.105, as that

section relates to the water quality standards for TDS and

sulfates of35 III. Adm. Code 302.208, shall not apply to the

effluent discharges from the facilities of Rhodia and the

Thom Creek Basin

Sanitary District,

provided that the

water quality standards established in this adjusted standard

are met.

-

---

In order to comply with the proposed

adjusted

standard,

Rhodia would direct the

wastewaters from the expanded silica plant to TCBSD for treatment.

Since TCBSD has

adequate capacity to handle these wastewaters, there is no significant capital cost.

The annual

operating costs are the cost oftreatment.

TCBSD projected 2000 charges of $1 .00/1000 gallons

ofwastewater treated.

Since Rhodia’s annual average discharge is projected to be

75,000,000

gallons, the operating costs (and annual costs) would be approximately $600,000 per year.

Section

104.406(g):

Impact Comparison Between Compliance and Proposed Standard

Rhodia and TCBSD retained Huff& Huff, Inc. to perform an environmental assessment of

the impact ofthe TDS and sulfates

anticipated to be discharged from TCBSD.

The results of

Huff& Huffs study are presented in a report entitled “Environmental

Assessment for the

Proposed Increase in Total Dissolved Solids Discharge from the Thorn Creek Basin Sanitary

District” (Exhibit

1).

Huff& Huffs assessment included a review of Rhodia’s proposed silica

production processes as well as the existing treatment processes and influent and effluent flows

at TCBSD’s

WWTP.

Huff& Huff also reviewed the flows and

water quality of Thom Creek

from its headwaters in Monee to its

confluence with the Little Calumet River as well as the Little

Calumet River

from that point to

its confluence with the Calumet-Sag Channel.

With these data,

Huff& Huff was able to

model the projected water quality for TDS and sulfates in the various

reaches of Thorn Creek and the Little Calumet River.

Huff& Huff then reviewed available

acute toxicity data to determine whether the projected water quality would be anticipated to

result in any acute toxicity, and

it retained SF Analytical to perform chronic toxicity testing

using

Thorn Creek stream water spiked with various levels of TDS and sulfates to determine whether

any chronic toxicity would be anticipated.

The TDS

and sulfate sources included

both synthetic

sodium sulfate and Rhodia’s silica plant wastewater.

-

17-

---

Huff & Huff also

performed a biological assessment ofThorn Creek.

This included the

sampling of macroinvertebrates and fish

in Thorn Creek both upstream and downstream of

TCBSD outfall.

Using these data along with other existing data on the stream quality, Huff&

Huff was able to

establish a Macroinvertebrate Biotic Index (MBI) as well as the Index ofBiotic

Integrity (IBI) for Thorn Creek.4

This

information was then used to assess the existing

and

potential quality of Thom

Creek as an aquatic resource.

Based on these studies, Huff& Huffconcluded that Thom Creek, from upstream ofthe

TCBSD’s outfall to downstream

of

the Butterfield Creek confluence can be classified

as a “fair”

quality stream with classifications between a “limited” and

a “moderate” aquatic resource,

common classifications for urban streams.

(Exhibit

1

at 9 1-92).

The

1131 and MBI values for the

stream

reaches did

not change after the increase

in TDS discharge that occurred when the

existing

Rhodia

silica plant went on-line in October

1995.

The Board requested information on the proposed adjusted standard and the Illinois EPA’s

targeted potential for improvement as it affects Thom Creek and

the Little Calumet River.

The

characterization of

Thorn Creek as a “limited” to “moderate” aquatic resource with “fair” water

quality was based

on the stream macroinvertebrate

and fish

surveys

conducted both before and

after

the existing Rhodia Silica Plant went on-line.

This is supported by the IEPA and

IDNR

biological

stream characterization

ofa limited aquatic resource.5

The 2000 Illinois Annual

Water Quality Report assessed Thorn Creek “fair” water quality and the Little Calumet River as

“poor” water quality.

MW

values are used by the Illinois

Environmental

Protection Agency to assess stream water quality.

These values range from

0 to ii,

with 0

representing the best water quality and

lithe worst.

(Exhibit

I

at 62).

1W values are also used by the Illinois

Environmental

Protection Agency to assess stream

quality and are

based

upon the

fish assemblage

at a given

site.

Values of this index

range

from

0 to 60, with

60 representing the best

stream quality and 0 the worst.

(Exhibit

1

at 62).

Bertrand, WA., R.L. Rite,

and

D. Day.

1996.

Biological Stream

Characterization (BSC):

Biological Assessment

-18-

---

Huff & Huff concluded that given its proximity to

urban areas, there is

limited potential for

fixture improvements in the aquatic community in Thom Creek.

Similar conclusions were drawn

by Michael Ander of Dames & Moore (1990) during an environmental impact study

of Deer

Creek.

(Exhibit

I at

115).

Deer Creek, a tributary of Thorn Creek, was stated as having limited

potential uses due to

the limited amount ofwater and habitat available.

The Agency noted a

similar water quality classification in its annual water quality

report.

(JEPA

1992).

Id.

The

quality ofthe Little

Calumet River was classified in that same report as a non-support waterway,

a lower quality than in Thom Creek.

Huff & Huff determined

that there would be an

impact upon Thom Creek and the Little

Calumet River caused by Rhodia’s proposed discharge,

i.e.

TDS and sulfate levels will increase.

A

summary

of the projected peak concentrations

by Reach

is

set forth below:

Parameter

Reach

#1

Reach #2

Reach #3

TDS

2,650

2,620

2,360

Sulfate

1,350

1,340

1,160

1,000

(See Table 7-3

of Exhibit

1

at

111).

While the concentrations of TDS and sulfates are projected to increase in certain areas of

Thorn Creek and the

Little Calumet River, those increases

are not

anticipatedto have any

adverse environmental impact based upon the toxicity testing completed. In adopting the water

quality

standards for TDS and sulfates, the Board focused on three potential

areas of adverse

impacts:

aquatic life, crop

irrigation, and public water supplies.

The Huff & Huff report

addresses

each of these areas,

and Huff& Huffconcludes that crop irrigation and public water

supply uses do not exist and that there will be no adverse impact upon aquatic life.

Therefore,

of Illinois Stream

Quality through

1993.

IEPA/BOW/96-058.

-19-

---

there should be no adverse environmental

impact upon any of these uses from Rhodia’s proposed

discharge.

A TDS water quality limit of 2,100 mg/L was

supported for Reach #2 in

NutraSweetlClWCs Adjusted

Standard in part because of the Limited Aquatic Resource

Classification of Thom Creek, and in consideration ofthe low level oftoxicity of TDS.

A

biological assessment performed in support of the NutraSweetlClWC petition concluded a TDS

water quality level of 3,000 mg/L would not cause

any undue stress to the aquatic life (Dames &

Moore,

1981).

(Exhibit

I at

115).

This opinion was supported by the Agency (Studer,

Hearing

Testimony

in AS89-3,

1990).

Id.

Based upon the modeling work conducted by Huff& Huff, under worst case conditions the

TDS level during

operation of Rhodia’s proposed expanded silica plant

is projected to reach

2,650

mg/L and the sulfate level is projected to reach

1,350 mgtL in Thorn

Creek.

(Table 7-3 of

Exhibit

I at Ill).

No impact on the current aquatic community in Thom

Creek would be

expected from these levels based upon Huff & Huffs review of available acute and chronic

toxicity data and the bioassays conducted.

(See

Chapter 5

of Exhibit

1).

This conclusion with

respect to TDS

is also supported by the biological assessment

in the NutrasweetiClWC adjusted

standardproceeding (AS

89-3).

Due to lack of literature regarding chronic toxicity levels on sodium sulfate, a chronic

toxicity bioassay was conducted.

The bioassay used Thom Creek water, downstream ofthe

WWTP discharge, to evaluate the effects ofincreasing levels of sodium sulfate on the water flea

(Ceriodaphnia dubia) and the fathead minnow (j~imephales

promelas).

The Thom Creek water

was initially analyzed for sulfate and then spiked with sodium sulfate to obtain seven targeted

levels ofsulfate.

The targeted levels are percentages of the projected peak water quality sulfate

-

20

-

---

concentration of 1,350 mg/L.

The sulfate levels, based on the test conducted with Thom Creek

water spiked with Rhodia silica plant wastewater are as follows (see, Exhibit

I at

59):

Measured

Measured

Sulfate

of Projected

TDS

Level, mg/L

Peak Effluent Sulfate

Level,

mg/L

817

60

1870

1079

80

2180

1190

88

2310

1332

99

2530

1365

101

2690

During the chronic toxicity bioassay tests, no chronic toxicity was observed in

either the

waterflea or fathead minnow up to the highest sulfate concentration tested;

1,365 mg!L (with an

associated TDS value of 2,690 mg/L).

The

1,365

mg/L sulfate level is

101

of the projected

2!~ic

sulfate level anticipated.

Based upon these results along with the literature regarding acute

toxicity, there will be

no acute or chronic toxicity impact upon aquatic life in Thom Creek or the

Little Calumet River from the proposed Rhodia expansion project.

Furthermore, the request for

an adjusted standard to allow Rhodia to expand its

silica plant at its Chicago Heights facility

is

consistent with historical water quality levels and will not degrade the quality ofthe aquatic

community in Thom Creek.

Huff& Huff also concludes that there would be no adverse impacts upon crops.

The areas

surrounding Thorn Creek from TCBSD’s

outfall to the merger with the Little Calumet River are

limited

to forest preserves and developed areas.

No known owners/operators conduct crop

irrigation in the basin.

No commercial crops are grown,

and no evidence ofwater withdrawal

from Thom Creek for irrigation of crops was observed during the stream study performed by

Huff & Huff.

(Exhibit

I

at

109).

-21

-

---

Huff & Huff further concludes that there would be

no adverse impact upon public water

supplies.

Communities

along Thorn Creek downstream ofTCBSD’s outfall all

derive their water

supply from Lake Michigan, including

Chicago Heights, Flossmoor,

Harvey, Glenwood,

Homewood, South Holland, Thornton, Calumet City, Dolton, and Lansing.

Most water supply

wells have been capped and taken out of service in these communities.

Based upon this

investigation,

Rhodia’s proposed expansion project will not increase the TDS in any public water

supply.

(Exhibit

I at 109-10).

Compliance with rule of general applicability would result in cross-mediaimpacts.

For

example, pretreatment of TDS

would produce dry sodium sulfate that would have to be disposed

on land if it could not be sold, creating the potential for land pollution and for water pollution

should it leach

from a landfill to groundwater.

Also, pretreatment would necessitate increased

energy consumption, which not

only would deplete

energy resources,

but also potentially would

result in air pollution

from the generation ofthe necessary energy.

Thus, while TDS

and

sulfate

levels in Thom Creek and the Little Calumet River would increase under the proposed adjusted

standard, no

adverse environmental

impact would result, whereas if compliance with the

generally applicable standards were to

be required, there might

be

some adverse cross-media

impacts.

Impacts of Adjusted Standard

on

Other

Facilities

The Board requested information on the proposed adjusted standard as it impacts to other

facilities: the adjusted standard obtained by Nutrasweet in PCB

89-3, and the Thornton Quarry

Retention Project at the Calumet Filtering Plant.

Nutrasweet.

Petitioners request for relief will have no impact whatsoeveron Nutrasweet

or its Adjusted

Standard on Deer Creek.

Nutrasweet’s adjusted standard provides for a TDS

-

22

-

---

water quality standard of 2,100 mg/L.

Petitioners are proposing to increase TDS Reach #2 to

2,620 mg/L, which would include downstream ofNutrasweet’s tributary, Deer Creek.

To the

extent that Nutrasweet is compliant in

Deer Creek with its

Adjusted Standard of 2,100 mg/L

TDS, compliance in Reach #2 will not be an issue for Nutrasweet.

The Deer Creek tributary at

2,100 mg/L TDS can only reduce TDS levels when it is mixed with Thom Creek and Thom

Creek is above 2,100 mgIL TDS.

Nutrasweet’s TDS contribution was factored into Petitioner’s

requested relief.

Impact on Thornton Quarry Retention Project.

The Thornton

Quarry Water Retention

Project is a three-phase plan to reduce flooding and combined sewer overflow (CSO) discharges

to

streams within the Calumet River watershed.

The Transitional Reservoir, expected to be

in

operation in 2002,

is the first phase ofthe project.

This 9,600 acre-feet reservoir

will collect

floodwater from Thom Creek.

The collected water will then be fed to the Calumet Water

Reclamation Plant (WRP) along with the normal treatment plant influent for treatment and then

discharged

to the Little Calumet River.

This

section ofthe Little Calumet River is a secondary

contact water with a TDS water quality standard of

1,500 mg/L.

There

is no

secondary contact

water quality

standard for sulfate.

The parameters ofconcern for this Rhodia/Thom Creek

Environmental Assessment are

TDS and sulfates, both ofwhich

are present in dissolved form.

Therefore, there will be

no

suspended solids loading concern for the Calumet WRP associated with Petitioner’s request.

The Calumet WRP’s NPDES permit does not have effluent

limits set for TDS or sulfates, as

water quality impacts have not historically been identified.

The proposed increase in TDS

and

sulfates will therefore not

cause a violation of the NPDES permit.

-

23

-

---

The only remaining issue

is the potential of the Calumet WRP to

cause a water quality

violation in

the Little Calumet River as a result ofthis requested relief.

Based on reservoir

modeling conducted for the project, Thom Creek floodwaters will overflow to the Transitional

Reservoir at creek flows greater than

1,500 cfs (970 mgd).

At this flow rate, the increase in TDS

and sulfate concentrations due to the proposed Rhodia plant expansion are expected to be

II

mg/L and 7 mg/L, respectively.

This is based on the following loading assumptions used in the

Environmental Assessment:

Condition

TDS

Sulfate

Existing Rhodia Average Loading

66,000 lbs/d

45,300 lbs/d

Projected

Peak Rhodia Loading

151,725

lbstd

102,638 lbs/d

Incremental Increase

85,~25lbs/d

57,338

lbs/d

Thom Creek Conc. Increase Due to

.

Project (Based

on

1500 cfs)

11

mgIL

lmg!L

Given that the overflow ofThom Creek water will occur only

during flood conditions, the TDS

and sulfate levels in

the streams are not expected to reach the levels of the water quality

standards.

The anticipated increase of

11

mgIL TDS and

7 mg/L

sulfate, which will occur when

Rhodia is operating at peak capacity simultaneously with the flood conditions

is not expected to

cause a water quality violation in the Little Calumet River.

Rhodia Community Advisory Panel and Thorn Creek Ecosystem Partnership.

The

Board requested further information on the Thom Creek Ecosystem Partnership.

Thom Creek

Basin Sanitary District

is a member ofthe Thorn Creek Ecosystem Partnership

and has been

active in that organization for the past two years.

Together with other Thom Creek Basin

Industries,

Rhodia created a Community Advisory Panel

(CAP) in the spring of 1998.

This

panel was formed to address the need for community outreach and discussion within the Chicago

-

24

-

---

Heights portIon ofthe Thom Creek Area Assessment.

In addition to the local businesses, the

CAP consists ofrepresentatives

from

the Sierra Club, Thom Creek Ecosystem Partnership,

South

Suburban Citizens Opposed to Pollute your Environment (SSCOPE), Citizens for a Better

Environment,

and other special interest groups.

During the past three years, Rhodia has

participated in discussions related

to air, water, and land issues with this group.

Rhodia also

presented the Adjusted Standard Petition to the CAP prior to submission to the Illinois EPA and

the Board.

Subsequent to the Board’s Order requesting additional information,

Rhodia obtained the

Illinois Department ofNatural Resources publication “Thorn Creek Area Assessment”.

Contacts

made as a result ofreviewing this report confirmed that a Thom Creek Ecosystem Partnership

does exist and,

in fact, some members of the Partnership also

participate in the Rhodia CAP.

Rhodia contacted Professor

Karen D’Arcy ofthe Thom Creek Ecosystem Partnership and

spoke

to her about joining the group.

On August 10,

2001,

Rhodia became

an active member of the

Thorn Creek Ecosystem Partnership.

Section 104.406(h):

Justification

As noted under

Section 104.406(c) of this petition, the regulations ofgeneral

applicability

from which Rhodia and TCBSD seek

adjusted standards do not specif5t levels ofjustification for

adjusted standards.

Section 28.1(c) ofthe Act allows the Board to grant adjusted standards in the

absence of a specified level ofjustification if the Board determines, based upon adequate proof

by the petitioner that:

(1)

factors relating to

the petitioner are substantially

different

from the factors

relied upon by the Board in adopting the

1 general regulation applicable to that petitioner;

(2)

the existence of those

factorsjustifies an adjusted standard;

-

25

-

---

(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

of general applicability;

and

(4)

the adjusted standard is consistent with any

applicable

federal

law.

See also

35111. Adm. Code 301.108(c).

The factors relating to Rhodia and TCBSD are substantially

different from the factors

relied upon by the Board in adopting the general regulation.

As discussed above, in adopting the

general

regulations, the Board was concerned over potential adverse impacts upon aquatic life,

crop irrigation and water supplies.

Based upon the Huff& I-luff report,

no such adverse impacts

are anticipated should the requested relief be granted.

Further, the levels of TDS that already

exist in

some areas of Thorn Creek are higher than the water quality standard levels set in the

general regulation and the projected levels of TDS are within the historical variability of TDS

levels in

Thom Creek.

The Board recognized in

deciding to repeal the previously established

effluent

standard for TDS of

3,500

mg/L, that the treatment processes for TDS are very

expensive, consume large amounts of energy, and may produce concentrated brines that must be

disposed of.

Those high costs have been documented in this petition.

Finally,

the regulation of

general applicability was adopted based on the protection ofaquatic life in a receiving stream

that does not

already contain high background levels of TDS.

Thus, an adjusted standard for

TDS and sulfates in Thom Creek is justified.

The requested standard will not result in

environmental or health effects substantially

more

adverse than the effects considered by the Board in

adopting the rule ofgeneral applicability.

That rule was adopted to protect aquatic life.

Thorn Creek

is classified as a Moderate to

Limited

Aquatic Resource.

(Exhibit

1

at 91-92).

A biological assessment ofThom Creek done in

-

26

-

---

support ofthe NutraSweetlClWC petition concluded a TDS water quality level of3,000 mgJL

would not cause any undue stress

to the aquatic life (Dames & Moore,

1981).

Id.

This opinion

was supported by the Agency.

(Studer testimony in AS89-3,

1990).

Based upon modeling conducted by Huff & Huff, under worst case conditions the TDS

level is expected to

reach 2,650 mg/L and sulfate to reach

1,350 mg/L

in Thorn Creek

and lower

in the Little

Calumet River.

(Exhibit

I at

111).

Thus, based on the Moderate to

Limited Aquatic

Resource classification, the previous work by Dames & Moore (1990) and the stream surveys

conducted by Huff & Huff; no impact on the current aquatic community in Thom Creek or the

Little Calumet River is expected.

Id.

The adjusted standard is consistent with

federal law

in that under 40 C.F.R.

131.4,

“states

are responsible for reviewing, establishing

and revising water quality standards,”

These

standards are to be protective ofthe designated uses.

40

C.F.R. 131.5(b).

As stated above, the

adjusted standard would be protective of the present and potential uses, ofThorn

Creek.

In addition,

granting this adjusted standard is consistent with Section 27(a) ofthe Act,

taking into account the existing physical conditions, the character ofthe area involved, including

the character of surrounding land uses, which have been described herein, the zoning

classification of the area as industrial, and the nature ofthe existing receiving body ofwater, and

the technical infeasibility

and economic unreasonableness of reducing TDS and

sulfates.

In summary,

Petitioners’ justification for the proposed adjusted standards is that the

granting ofthe requested adjusted standard will not result in any significant adverse

environmental or health effects, while the cost of compliance is high and could be

associated

with adverse cross-media impacts.

As

notedabove, the purpose of the regulation from

which

-

27

-

---

Petitioners seek adjusted standards is primarily to protect aquatic life.

Such purpose will still be

served ifthe requested adjusted standards are granted by the Board.

Section 104.406(i):

Consistency with Federal Law and Federal Procedural Requirements

1.

Consistency with Federal Law.

Rhodia and TCBSD believe

that the granting ofthe requested adjusted standard would not

be

inconsistent with or violate any provisions ofthe Clean Water Act.

As explained above, the

requested relief is predicated solely upon potential exceedances of the TDS water quality

standard and the standard for sulfates.

There are no

applicable federal or state TDS or sulfate

effluent standards.

Under Federal law:

A water quality standard defines the water quality goals of a water

body, or portion thereof, by

designating the use or uses to

be made

of the water and by setting criteria necessary to protect the uses.

States adopt water quality standards to protect public health or

welfare, enhance the quality ofwater and serve the purposes ofthe

Clean Water Act (the Act),

“Serve the purposes ofthe Act”

(as

defined in

sections

101(a)(2) and 303(c) of the Act) means that

water quality standards should, wherever attainable, provide water

quality for the protection and propagation of fish, shellfish and

wildlife and for recreation in and on the water and take into

consideration their use and value ofpublic

water supplies,

propagation offish, shellfish, and wildlife, recreation in and on the

water, and

agricultural, industrial, and other purposes including

navigation.

40 C.F.R.

131.2.

Under 40 C.F.R.

131.4 “states are responsible for reviewing, establishing and

revising water quality standards.”

In turn, pursuant to 40 C.F.R.

131.5,

“EPA is to review and to

approve or disapprovethe State-adopted water quality

standards.”

These standards

are to

be

protective ofthe designated uses (~I3

1.5(b)) and, where those uses are not protected, this

must

be supported by

“appropriate technical and scientific data and analyses.”

(~

131.5(d)).

A

State

is

allowed to remove a designated use, which is not an existing use, if it “can demonstrate that

attaining the designated use is not feasible” because ofseveral enumerated causes.

(~

131.10(g)).

-

28

-

---

Rhodia and TCBSD believe that the granting of this adjusted standard will not impair any

beneficial

existing use ofthe receiving stream.

This has been established by the Huff &

Huff

study which has been made part of this Petition.

Even if the Board were to

find that some use is impaired, Petitioners believe that one or

more ofthe requirements for federal approval have been met as set forth

under

§

131.10(g) as

follows:

(1)

Naturally occurring pollutant concentrations prevent the

attainment ofthe use; or

(2)

Natural, ephemeral, intermittent or low

flow

conditions or

water levels prevent the attainment ofthe use, unless these

conditions may be compensated for by the discharge of

sufficient volume of effluent discharges without violating

State water conservation requirements to enable uses

to be

met; or

(3)

Human caused conditions or sources ofpollution prevent

the attainment of the use and cannot be remedied or would

cause more environmental damage to correct than to leave

in place; or

(4)

Dams, diversions or other types ofhydrologic

modifications preclude

the attainment of the use, and

it is

not feasible to restore the water body to

its original

condition or to operate

such modification in

a way that

would result in the attainment ofthe use; or

(5)

Physical conditions related

to the natural

features of the

water body, such as the lack ofa proper substrate, cover,

flow, depth, pools, riffles, and the like, unrelated to water

quality, preclude attainment of aquatic life protection uses;

or

(6)

Controls more

stringent than those required by

sections 301(b) and

306 ofthe Act would result in

substantial and widespread

economic and social impact.

Most particularly,

the portion of Thorn Creek referred to as Reach #2

is impacted by TDS

discharges from Consumers Illinois Water Company at its University Park facility.

Consumers

-

29

-

---

Illinois Water Company, which discharges to Deer Creek, is allowed, pursuant to an existing

adjusted standard, to

discharge TDS to a maximum of2,100 mg/L.

Elevated TDS levels exist

downstream ofDeer Creek’s merger with Thom Creek to the USGS Station

05536275

in

Thornton.

The Board established an adjusted standard for that portion ofThom Creek in part

because these levels ofTDS could not be remedied.

2.

Federal Procedural Requirements

Pursuant to U.S.

EPA’s current position on whether a hearing is required, Rhodia and

TCBSD do not believe that a hearing is necessary where an authorized states follow approved

state procedures, those procedures are federally acceptable.

Rhodia and TCBSD understand that U.S. EPA’s present position is that the fulfillment of

the state requirements fornotice and hearing is all that is required and that if the state allows for

waiver ofthe hearing requirement, hearing can be waived without conflict with federal laws.

35

Ill. Adm.

Code 104.406(j)

allows for waiver ofhearing.

Section 104.406(j): Hearing Waived

Rhodia and TCBSD hereby waive hearing in this matter pursuant to Section

104.406.

Section

104.406(k):

Supporting Documents

Supporting documents cited

in this Amended Petition are submitted with the original

Petition and additional

documents responsive to the Board’s Order dated July 26, 2001

are

appended hereto.

WHEREFORE, Rhodia, Inc. and the Thom Creek Basin Sanitary District request

the Board to grant an adjusted standard from

35

Ill. Adm.

Code 304.105

and 35

Iii. Adm.

-30-

---

Code 302.208 as they apply to proposed discharges ofTDS and sulfate from Rhodia’s proposed

expansion ofits silica plant to TCBSD’s sewer system and from TCBSD’s treatment plant to

Thorn Creek.

Roy M. Harsch, Esq.

Sheila H. Deely, Esq.

GARDNER, CARTON & DOUGLAS

321 North Clark Street

Suite 3400

Chicago, Illinois

60610-4795

(312) 644-3000

CHO2/22 141379.1

-31

-

---

CERTIFICATE OF SERVICE

The undersigned certifies that

a copy of the foregoing Notice of Filing and

Amended Petition for

Adjusted Standard was filed by hand

delivery with the Clerk of the

Illinois

Pollution Control

Board and served upon the parties to whom said

Notice is directed

by first

class mail, postage prepaid, by depositing in

the U.S. Mail

at

321

North Clark Street,

Chicago, Illinois on Monday, August 27, 2001.

•~/ZL.L

~(~L/~_

1

CUO1/12

149405.1

-2-

---

Exhibit

A

---

ALTERNATIVE I

purge

Ouik t,tci~

0

s~o

Cusi~er’?

Wash ‘eater

and misc.

L

effluent

Concept for Sodium

Sulfate Reco’~ery

---

Sales

28500

to&year

Configuration! Pet.

Drawing

P~Trealment

Alt.

1

Price

.

Installed

USS

$6,000,000

Footprint

L

x ‘N x

H

____________________

Power

kW

750

Oner

Duty

MMBTU/h

0.35

Major Equipment

OOM

Total

Installed

cost

56.000.000

S

4,800,000

to

S8,400,CCO

Annual

Operating

Costs

Falling Film

Evaporator

(Brine

Conc)

5k/year

Forced Circulation

Crystallizer (Brine

XL)

Power

329

MVR Compressor

Mainl

180

2

Condensate

pumps

Depre.

400

2 Evaporator

feed pumps

Gas

7

2 Evaporator

discharge pumps

SuIt sales

___________

Purge pump

Total

915

Conveyor

S/mt

32

Dryer

S/mt above 23000

166

Es~matesare 0DM

based on

evaporahon rates

above and

similar units built prSously

---

Exhibit

B

---

ALTERNATIVE

2

MgSC4

t’4a01-4

Feed

Na2304

to

bulk

truck

---

Sales

28500

toniyear

Configuration / Ref.

Drawing

Price

Installed

USS

Footprint

L

x W

c

H

Power

kW

Dner Duty

MMSTU/h

L________

750

________

0.35

Major

Equipment

OOM

Total Installed Cost

56.000.000

$

4,800,000

a

58.400,000

Falling

Film Evaporator

(Brine

Conc)

Forced

Circulation Crystallizer

(Brine XL)

MVR Compressor

2 Condensate

pumps

2 Evaporator

teed

pumps

2

Evaporator discharge pumps

___________

Purge pump

Total

915

Conveyor

S/mt

32

Dryer

S/nt above

23000L

166

Estimates

are 0DM

based

on

evaporation

rates above and

similar units

P-C Treatment

-

Alt.

I

56.000.000

Annual Operating

Costs

5k/year

Power

Maint

Depre.

Gas

SuIf

sales

329

180

£00

7

built previously

---

Exhibit

C

---

ALTERNATIVE

3

Na2504

to

bulk

truck

---

Sales

28500

ton/year

Configuration /

Ref.

Drawing

LP-C Treatment

.

Alt.

1

Price

.

Installed

USS

56.000.000

Footprint

LxWXH

_______________

Power

kW

750

Oner Duty

MMBTU/11

L

0.35

Major Equipment

0CM Total Installed

Cost

56.000.000

S

4,800,000

to

$8,400,000

Annual Operating Costs

Falling Film Evaporator

(Brine

Conc)

5k/year

Forced Circulation Crystallizer (Brine

XL)

Power

329

MVR Compressor

Mainl

780

2 Condensate pumps

Oepre.

400

2

Evaporator

feed pumps

Gas

7

2

Evaporator discharge

pumps

Suit sales

-

Purge pump

Total

915

Conveyor

S/nit

32

Dryer

S/mt above 23000k

186

Estimates are

0DM based on

evaporation rates above and similar units built previously

---

Exhibit

D

---

Filtrate

Wash

Water

To stay

with

in

permit

limits

Process

spills,

Ut

To

TCBSD

Analyze

forpH

and

TSS

Neutralizing Agents

---

Exhibit

E

---

Table 2-3

EXISTING AND PROJECTED LOADING FROM

RHODIA SILICA PLANT

Parameter

Annual Average

Monthly Average

Daily Maximum

Existing Plant Discharage

Flow mgd

0.59

0.62

0.76

105,

lb/day

66,000

82,000

146,853

Sulfates

tb/day

45,300

50,000

103,640

w/ Proposed

Expansion

Flow mgd

0.84

to 0.94

1.1

1.1

105, lb/day

137,375

144,200

151,725

Sulfates lb/day

92,750

97,500

102,638

---

Exhibit

F

---

LITTLE

CALUMET

RIvER

MIDLOTHtAN

CREEK

RB— 01

A

0

I

Son

BUTTERFIELD

CREEK

WAMPUM

LAKE

NORTH

CREEK

I-.’

,/

REACH IIBD—04

~1~

PARK

FOREST

THORN

CREEK

BASIN

SANITARY

DISTRICT

WWTP

5000’

I

0

z

HB—42

0

0phI

mO

o

~

cn

I

0Z~m

I

~U)

N.)

LI)

p R~

—~Jm

05°

11)

0

-H

V

HBD—05

ROAD

CADFILE:THORN— 10

---

ANNUAL ILLINOIS WATER QUALITY REPORT

(Clean

Water Act, Section 305(b) Requirement)

AI’PENIMX TABLE

A-I.

WATEEBODY SPECIFIC INFORMATION FOR

RIVERS AND

STREAMS IN THE GREAT LAKES/CALUMET

WATERSHEDS

1988

Waterbody

Segment

Size in

Cycle

ID:

ID:

Catalog Unit

Segment Name

Miles

in

Key Sample

Assessment

Designated Uses

Causes of

Sources of

Year

Date

TypeiMethods

Impairment

Impairment

ILI1A04

IA

04

07120003

LjL(Je

Calumet

RN.

2.02

200(1

01/01/1998

M1190,

191,

N20,

P1,

P44, X21

300,410,

100,

200,4000,

800

500,550,

7000,

7100,

7400,

560, 580,

7550,

7600, 7700,

900,910,

8500

920,

1200,

1220,

1500,

1600

JLJJAO4

HA 06

07120003

Little Calumet RN.

5.6

2000

01/01/1990

Ff150,

800

Fl, FM, P20, X21

1600

100,200,4000,

7000,

7100, 7550,

7600

ILHBDO4

FIBDO4

07120003

ThornCr.

7.85

2000

01(0111998

M1230,700,

N42,P1,P20

300,410,

200,4000.7000,

860

500,

530,

7100,

7550,

7700,

720, 750,

8500

900,910,

920, 930.

1300,

1320,

1600,2100

ILFIBDO4

FIRD

05

07120003

Thom Cr

11.25

2000

01/01/1994

MIS®

P1, P20

900, 920,

4000,7000,7350,

1200,

1220,

7400, 7550. 7700

1500,

1600

CR01/12 172761.1

---

Tabk 3-3.

Guidelines

for

Listing

Causes of

Aquatic Life

Use

Impairment in

Rivers

and Streams for

305(b) Assessments

Guidelines

0000

~

Unknown

I

Pc~1tcides

No identitiab~ecause

based upon available info~ation.(used with

discretion)

Sec

3000

for rria~inc

pesticides,

see 0300 for organocb!orine

pesuCIdes..

1

0300

~

P~ority Organics

From AWQMN

water data:

At least

I

violation DIG.

U.

Standard

in

three years,

From basin survey or

facility

survey water data:

Ar

east

I

violation of C.

U.

Standard.

From

sediment data:

Concentrations of

any organic Compounds at

highly elevated

levels.’

I

:

From ~shadvisory

reports:

Fish

consurnprzon

restricted due to organic compounds.

0410

f~CBs

From

sediment

data:

Concentrations

at highly

elevated level (180

ug/kg).

From flsh

advisory reports:

Fish

consumption restricted

due to ?CBs,

OSOO

0510

Metals

Arsenic

‘From AWQMN

water data:

At least

I

violation of 0.

U. Standard

for any metal

in three years.

,

•

:

0520

Cadmium

,

0530

Copper

0340

Chromium

0550

Lead

0560

Mercury

‘

0570

Selenium

Fron

basin survey

or facility survey

water

data:

At least

vidlation

ofG.

U.

Standard

for any

metaL

From sediment data:

Concentrations of any

metal at highly elevated

levels)

.

:

:

(

0580

Zinc

From

fish

advisory reports:

0500

cor

all others, indicate

hsh

consumption restricted

due to mercury.

specitic’metal

itt

fmerno

(laId

‘

:

0600

Ammonia

(un-ionized:

STORET

code’ólZ)

Front AWQMN

water

data:

At least.)

violation of 0.

U. Standard for ammonia

in three years.

:

:

‘

‘

From

basin

survey or

facility survey

water

data:

At

least

I

violation orG. ‘U. Standard

for ammonia.

,

32

---

I

II

L.uu.

—

Il

litton totil,e,tduali.jilorine

flldlblc

At

Cast

violation ofG.

U.

Siandard

For

total

residual chlorine.

L....

07!O

(yarlitle

F,ont AWQMN ~vater

data:

I

Fotat cyanide exceeds 0.01

mg/I in

at

least

I

sample

iii

three

ycacs:

1

Front

bnSIIt

srnvey

Or

facility survey

watcr data:

Total

cyanide

exceeds 0.01

mg/I

in

at

least

I

sample.1

iO750~l0itcs

Front

AWOMN

water

dma:

At

ieatt

I

violation

orG.

U, Standard

for selfales

in

Iltree

ycarc.

From

basin

survey nr

Foe

Ihly

survey

water

dal:,

Al

lea.t

violation oFO.

U

Standard

Ihr sui

(Ares.

k-----

‘-+-~~-—----

_____________________

9800

Un

norgz

RI

N

Front

A\VQM td water

data:

At least

I

violation

of Fluoride 0.

U.

Standard

it

h~

cc

yc:Ir.s.

(Fluoride

Front basin

survey or facility

survey water data:

L.

At

least

I

violation of Fktoride G. U,

Standard.

99(10

Nut

~I.I\ts

(19

U

Phosphorus

Frum

AWQM N water

data:

‘Focal

phosphorus

exceeds

0.61

mg/I

in

at

least

I

sample

in

three yeirt.1

Front

basat

survey

or

facility

survey

waler data:

Tutal

phosphnrus

exceeds

0.61

mg/I

in

at

least

Esample?

From

Sediment

data:

Phosphorus

in

sediment exceeds

2,800

mg/kg (highly elevated))

0~2t)

Nivogon

Front

AWQMN water

data:

Total

amnionia—N exceeds 0.41

mg/I

in

I

sample

in

three years,2

tSTORET

code 610)

Front basin

survey

or facility survey

water data:

Total

ammonia-N exceeds 0.4

mg/I

in

at

cost

I

sample.2

(STORE1’ codc

(,Ioj

Front Sediment

data:

Kjeldahl nitrogen

in

sediment exceeds

4,680 mg/kg (highly elevaled).1

(STOREF code 627)

1)910

Ninnies

Front AWQMN

water

data:

Nitrate-N exceeds 7.8 mg/I

in

I

sample

in

three years.

(STORET cock 630k

Front basin

survey or fac,lity survey

water data:

Ninate-N

exceeds

7.1

mg/l.

(SIOREL’ code 630)

Nor used.

1000

p11

From AWOMN

water data:

At

least

I

vtolation of G. U.

Standard

or

ph

in

three years

Font b~insurvey or l~e

ility survcy war~r

data:

/tt

ea~tI violation

ofO.

U. Standard irpi’i.

—

---

1100

I’roiu

I labitat

data:

Either transect data

indicates substrate 34

silt, mud:

Or

Front A WQM N

a

tier data:

lutol

suspended

.solids cs’ceetls

lb

mt/I

iii

‘it

/151

I

sample

in

tItt’ee yeti’s

From basin str’vey or

facility

sul-vey

‘voter

Iota:

1

SIRIl

sttspended

solids exceeds

I lb

ntg/l iii

at

least

one sample:

—H

Fi oi:t AWQMN

‘toter data’

At least

I s’tol’auon olU.

U.

Stoiidat’d Ibi

DO

itt three

vear:a.

:txtfll hasit suney

or factlity survey

water data:

At

-east

I

“iul;titon olU.

U

Stattdatd

liii

DO.

1mm basin

survey

or

facility

survey

water data:

At

east

I

viota;inn nEC.

U.

Standat’d

ibm 1 l)S (conductivity

1667

~nil to/cm tom c h lot des.

Used only

when

a

thermal point sottrce

is present.

(‘heck

or

cxenlptton of

temperature

standard

in

receiving stieunfl.

Front AWQMN

water data:

At least

I

violation of C.

U.

Standard

br temperature ui

three years.

Front

basin

stprvcy

nr

facility survey water data:

At

east

I

violation oIC. Ii.

Standat’d

br temperature.

Docttmentcd site specific

knowledge

(unnatural

low alterations

only.

e.g.. dams,

water

tvtthdrawals, etc.)

Frotit

I—la

ts it

at

data

St-lAP hank stability

score Intetrie ~9l

~8;

or SEIAI’ channel

alteration scorc

(nictric #l2j

4.

Documented

site

specific

kituwledee

used

only

when pathogens are a ktaown

cause of

fish

kills or are

known

to

hose other

itnpacts on aquatic

tIe).

Documented

site

specilic

knowledge

I used

only

when data

ts

tv:trtabte

to document

the

presence of this cause I.

Not used

as

a cause

br aquatic life

use impainiaC’.U.

From AWQMN water data:

Total suspended

solids exceeds ItO tug/I

in at least

I

sample

in

three yeats.’

From

basin

sun’cy or facility

survey water data’.

Total suspended solids exceeds IlLi mg/I

in

at

least one saniple:

S la tint,

I

200

(~ruat1,a’F ilnettnl,’ist

Lou

DIssolvetl

()\ytze’i

1301)

Satlintty, lot:tI

Dissolved

Suttdt.

f:hi.,i’ide~

I 400

Front

A WQMN

water

data:

At

least

I

‘solucioti ofU.

U.

StaIldal’d

bc 11)5

(conductivity

!

667

tllhi/cnt I ut chlorides

in

three years

Thcr:nal

Mctdi tications

l500

Flow Alterations

I

I 600

El:tbitat

Alterations

~Othertitan

tlotv)

1700

Patltogens

I 900

Oil

and Grease

2

100

2000

—

Taste

and odor

Sttcpendetl Solids

2660

2200

Noxious Aquatic

Plants

Documented

site specific

knowledge.

Documented

site

specific

knoivlcdge.

2210

t:xces.stve Algal

Growth’Chlorophvll

a

Exohc

Species

Itatroduced

spectes exclcadung coflinlon

Carp.

34

---

3000

I’esticideslIlJltUfC

Pc’elttnrnc.ry

stuter chct:csrrv

itidicatt,rs (chronic

value).

e9O days)

-rent

Pesticide

Monitnring Network

eater data:

Pesticide

exceeds chronic

vol

~te

ii

at

least one

‘amit

i Ut)

Atraxine

.0

3230

Cyanazile

3)) ~gd

3300

A loch or

00 ~g/l

3(00

Mctoinchlnt’

130 r~g/l

3500

Metribonn

800

ugh

3600

Trirlurnlirt

I.Opg/t

37(10

Iitiylate

50 pg/I

---

fabLe

3-4.

Guidelines

for

Listing Sources

of Aquatic

Life

Use (rnpairment in

Rivers

and Streams for 305(b)

Assessments

Guidelines

Iniosirsal point

see i-ce

dt sc has-ge

basee

upon lit

S

S

-

A gette

-act it

OMIt and-or

oUter existing data,

Montcipal point

source discharge

based

upon

FRSS. Agcncr etilueno

I

DMR ~nd/ot’

other existtng

data

Non-irrigated

crop

production

based ttpoti satellite

land use,

actual

observation

and/or other existittg data.

Irrigated crop production

based

tipon satelltie

land

use. actual

observation

anti/or other existing data.

Truck

farming, orchards, or honicultural

areas

based

upon

satcilit

Ia

ad

use, actual

observation and/or other ext Sting data.

Ripariar, and/or upland rasture)and

grazing based upon sarelttte

I-and

o.se. actual

observation atod/or other existThg

data,

Not

used.

Open

area

feedlots based upon

sareliitc

land

use, actual

observation

and/or other existing data.

Visit

production facility

based upon actual observation

and,’or othe:’

extstitig

data.

Atsima! holding bui)diiws and

iinpen’ious areas

based upnn satel)s:

land

use,

actual observation and/or otlter

existing data.

Act idetital/intentional

discharge

frotn tnanure Itolding logoobs

hosed

upon actual observation and/or other

existing data,

General

forest managentent related ruiiaffL’asied

upon

s’o’.ellite

I.ts,O

use, actual observation and/or otherexisting

data,

Genet-al

construction t’elaied activities based upon

actual observa::o)

andior other

existing

data.

Highway/road/bridge constnaction

activities based Upon

actual

ubservaoon and/or other existing data.

New residet,tjal/coni,,aei-cjat

eotfltraclwii activattes

tmscd

Upon actual

observation and,or other existing data.

Urban and

storm

sewer runoti based

upon actual observatint, and~c,r

other

existing data.

(ode

j

S.’,ur,:e

‘unit Sauce

020’!

Monte

io~ii

Point

Source

04i)0

(‘o:,shit,ed

Se~verOverflow

~•,,,,,,

j

U~0G

j

Cullectten

Sysac:in

Failure

C’onibtned

sanitary

and

storni

sewer os-crilow

based

upon

FRSS

-

Agettcy cI’fluent.

DMR

and/or othcr

cxtsting data.

Uroken sanitary

sewer

line or overflow

based

upun

FRSS.

.Ace:ie

L_H__

(0100

I

Wildcat

Se-wet’

effluent

andrnr other c

sting

data

——--~i

Wildcat

sew.o:’ dLscltargc

hosed

onnla

FRSS.

Agency ei’fluer.: ai’d;i’r

other

existing data.

Non-municipal

agent:

system based upon

FRSS. Agency

eileen’

-

09(50

Domestic

Wnstcwnter

Lagoon

DMR and/or

other exisdng data

General

agricultural related

actIvities based

upon satellite

true-

use,

actual

observation

and/or other existing data.

\gricultore

(‘top-Related Sources

Nnn-irrictated Crop

Production

Irrigated Crop

Pt ndoetiou

Specialty Cop

Production (e.g..

Iruele

Farininu, Orchards

5

(t

razing-Related

See

ices

Pasture Gt’a:’~Iig

lUnge Gt’azt:ig

Feed

Lots

-

All

‘Fypes

Afitiucu

tore

—Anitm,l

I toldittg/Managenaent

Uttirs

Martiare Lagoons

12Of)

/

,S (IL

I 35i)

,500

I t,tjn

I

NUt)

2D00

~

I

Conslruction

31(0

H ighwaysroatl/br4ue

.1?(

ti

Lai-tci

DC veiop~nan

I vie

tt Etut’c

(Irbian l(ttnofi7stcsrni

Sewet’s

---

____—.

5000

Re;ottrcc

d:Ii-act:ua’

Genera; ~.in:agact:

:

rased upon

satellite

land

use,

actual

obsen anon

an&a

r:;.’t’

existing

data.

5

iOU

Sttrflic-t

Mtnane

Surface

mtntnu

IC

:a.

iniestone)

activities

based upon

satellite

Lane

use,

actuaL

easer..,:

en and/or cther existing data,

5200

Sebsurrac-c

M,uing

Subsu.:’ace coal

m.—

.-;

activities based

upon satellite

land

u-se,

actual

obser.

anon

and-c’ :r

:xi$tin~

data.

53(10

PLacer

Mining

Not

used

5400

Dredge

M:ntng

Underwater nuntr

.

sand

and gravel)

activities based

ulsc.1

sate!l,:e

land

use,a:~,-.observation

and/or other existing data,

5500

i

r’:troleuiti

Activir:e’:

Ot!

and

~asproduc:

c

‘

activittes based

upon satellite

I-and

use,

aetna!

obser.

aric.n

and c’

: ‘~rexisting data,

5600

Mill

Tailings

M::ing operator: :c.~d

ttpnn

satellite land

use, actual observation

and’er other exts:.-e

cata

5700

Mine Tailings

\ltne

rrOCesstfl

ron

‘

-as

(e.g.,

gob

piles) based

uoo;i

sateltite

!:ti-,d

-

use,

actual

obser. a’

and/or other existing data.

5I~t)i)

I

Acid

Mtne

Drainage

LeA

pEl

and

iron

:.ro:-,ittoo due to

mine drainage

basea

upon iscttiat

observation order

ott’

existing data.

51)00

Abandoned Mining

Abandoned nlin-;

0-orations based upon actual

observation art:I/or

—

odier existing daa

—

laud

Disposal

General

land di~rc~.a

activities based

upon

satellite land

use,

actual

observation and,

-to

estier existing data,

0100

Sludge

Land

appltcatior

:5

edge

based

upon actual observation and/or

other

existing data.

02110

Wastewater

Spray

rdga:iort

:f

*ustewarer

based

upon satellite

land

use,

actual

oosen-at.on

anc

:c ::~er

existing data.

6300

Landfills

Leachace and’cr

—_r-cff from

landfills

based upon

acttaal observation

an&or other exn”.ye data,

6350

Inappropriate

Waste DisposaUwildeat

Illegal waste dascc.sai

sites based

upon

actual ohsenatinn

‘and/or artier

Dumping

extsting

data.

t

64)5)

Industrial

t..and Treatment

Land

appl icatrcn rf :ndustrial wastes

based upon

actual observation

and/or other ex

sraza

data.

0.500

On-site

W’asrewaterSystems (Septic

Septic system

‘eeaate or surface runoff based

upon actual

observatinn

Tanks, Etc.)

and/or other ex.sa:n; data.

6600

Hazardotts

Waste

Hazardous wa~r~

~achaLe

or surface runoff based

upon

actual

observation

arc-c’r other existing data.

-

6700

Septage

Disposal

Disposal of sexc

nnk sludge

based upon actual observation

‘aad,’ot’

other exisr1n~,ar,

---

7000

I’lydronrnd ifieatioti

General

aL eratioti uf

c hann:1 habita

I

based

upon

actual

ohserv~

t’otl

and/or other existing

data.

7100

Channeltiatton

St~tghteitiog

of stream

meor.deis based upon

artuat

observittiot’

and.’or other exi.~tttigdata

7200

Dredging

Deepenittu or

svrdentng ut ~:--ea’::

t-har:nclc

based

upon

aclurt

ohset’vatiot: and/or other cx:sttn~

data

7300

Dam C’orstructiou

Dana cunstructon

aclivttic

-

~.scdupon

actual

nhserv’alinn and/or

otbt.-’-

es

sttng

dat-a

-

7350

U psu-cana

I t’npoundnien;

F

LI pstrcana

tnlpoundment

hacc’~upon

act aa

c.bscrvat ion

and ‘or ot Oar

existing

data.

7400

Flow Regulation/tuodilicatten

Alteratioti of nomi’al fto~realnacs

(e.g

-

dams, channeltzatton

-

I

inlpen’ious surfaces,

water withdrawal,

etc

) based upon

acid

observation

andlor oilier exts;tr.g

data.

7500

Uridge

Construction

Bridge construction

ac0vttte,

(

e g

-.

channelizution.

tetriporary mac

construction.

etc

t based

e~.i

actual

observation and/or otner

existing

data.

7550

Habit-at

Mndtltcation

General alteration

of ripar.:n

nabitar

based

upon

actual

ubsun’ation

and/or other cx i.sting data

7600

Renaoval

of R

parian Vegetation

Removal of riparian

vegeration

based

upon

actual

observation

and/or

other existing data

7700

Bank or Shoreline

Bank

nicdiflcation/dcstab:’.:zotton

acits-ites (e.g

-

hank

erosiot:.

p

rap,

Modtflca:ion!destabiljzation

loss of habitat, etc,) based

upon actual observation

andur oIlier

existing data.

7800

Drainirg/ftl!ing of Wetlands

Draining/filling of wetl,inds

based upon

actual

ohscrvetion

and-cr

other existing data

8100

Atmospheric

Deposition

Atmospheric deposition

of nutrients. mtnercls. etc..

based

upon ncttiai

observation

and’nr other

s~istrig

data

8200

\Vaste

Storago/Stot’age ‘rank

Leaks

Leaks from above ground

s!crage

Iaiiks based

upon actual

ubsctvatton

and/or other existing data.

8~00

I-ltghway

Maintenance and

Runoff

Salt and

pesticide

ruitofi’ from highways.

roads

and

bridges

baser! upon

~ciualobservation

and’or other existing

data.

8400

Spills (Accidental)

Accidental

spills

based

upon

actual observation and/or other c”isttng

data.

8500

Contaminated Sedintents

High

concentrations of n~ta~s

and organic

compounds

n

se.dinaent

based

upon

actual

obser’s at-on and-or

other existing data.

8600

Natural

Sources

Refer

to

fOotnote’.

8700

Recteatioti

and

Tourism Activities

Turbulence

and ~s’avc

aertor, resulting

fine:

boat

tlsage and

spied

boat

rae

ne:

golf course

ri

toY

,i-:’

hawd

anon

actual

ehcervat inra-id/ot

othet

ci’ sung data

S9t10

Salt

S mr-age

S tees

Ftunofl’ front

salt

s oragc

‘‘‘s’t

tier

10

21

sc’a

ma in rem’icc

5:~

‘‘0

trc’lt

-

actual

observat

un

and’’~~

ott-or c.xi sting data,

9000

Source

Llnknosvn

No

identifiable

~ou’’ce

On;cd upon

available

intortliatiot’-.

—

38

---

TABLE

1.

Illinois 303(d) List and

Priority Ranking

WATEREODY

WATERBODy

SIZE MILES/

ASSESSMENT

DESIGNATED

RANK

W5II)

SCORE

SEGMENT

NAME

ACRES

LEVEL

USE

CAUSES

SOURCES

27

1L11B42

74

HB 42

Little

Calumet

kS,

7.33

M23, 3t

OlD, 02,

04D,

05M, 068,

0411,308,

05D

09H,

I IM,

328,

40M,

1211,

138,

708, 718,

1711

728,768

MB

01

Little

Calumet kS.

8.58

E15

OIN,

02,

(MM,

05M,

0911,

0211, 04M,

05N

llM,12M,

30M,32M,

16M,

l7H

40M,70M,

7M,

728

52

ILFIBDO4

25

HBD 04

Thom Cr.

7.89

M23, 3!

OIR,

02,

04k,

05S,

0911

02M,

308,

05k

lOS,

135,

32S,

4CM,

168,

1711

705, 718,

775

CHOI/t2t72773.l