BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
AMERICAN BOTTOM CONSERVANCY
Petitioner,
V
.
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY and UNITED STATES STEEL
CORPORATION -GRANITE CITY WORKS,
Dorothy Gunn, Clerk
Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 N. Grand Ave. East
P.O. Box 19274
Springfield, IL 62794-9274
NOTICE OF FILING
PCB 06-171
(3`d Party NPDES Permit
Appeal)
Maxine I. Lipeles
Interdisciplinary Environmental Clinic
Washington University School of Law
One Brookings Drive - Campus Box 1120
St. Louis, MO 63130-4899
Carolyn S. Hesse
Erika K. Powers
David T. Ballard
Barnes & Thomburg LLP
One North Wacker Drive
Suite 44000
Chicago, IL 60606
RE~ E
Olvlep
JUN 2
STATE OF ILLINOIS
Pollution Control Board
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the
Pollution Control Board an original and four (4) copies theAGENCY'S AMENDED RECORD
of the Illinois Environmental Protection Agency, a copy of which is herewith served upon you
.
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
By :
Sanjay K Sofat
Assistant Counsel
Division of Legal Counsel
Dated: June 20, 2006
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
(217) 782-5544
THIS FILING PRINTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROLBOARDRECEIVED
CLERK'S OFFICE
AMERICAN BOTTOM CONSERVANCY
)
JUN 2
2
2006
STATE OF ILLINOIS
Petitioner,
)
Pollution Control
Board
V .
)
PCB 06-171
(3rd Party NPDES Permit
Appeal)
ILLINOIS ENVIRONMENTAL PROTECTION
)
AGENCY and UNITED STATES STEEL
)
CORPORATION -GRANITE CITY WORKS,
)
Respondents .
)
MOTION FOR LEAVE TO AMEND RECORD INSTANTER
NOW COMES the Respondent, the Illinois Environmental Protection Agency ("Illinois
EPA" or "Agency"), by one of its attorneys, Sanjay K . Sofat, and pursuant to 35 Ill. Adm. Code
105.212 and 105.116, and hereby requests that the Illinois Pollution Control Board ("Board")
grant its motion to AMEND its Record instanter . In support of this motion, the Illinois EPA
states as follows
:
On May 8, 2006, American Bottom Conservancy ("ABC"), Petitioner filed a
third party permit appeal with the Board pursuant to 35 Ill. Adm. Code 105 Subpart B. Petitioner
appeals the issuance of an National Pollutant Discharge Elimination System ("NPDES") permit
to the US Steel (Permit No . IL 0000329) on March 31, 2006
.
2 .
Pursuant to 35 Ill. Adm. Code 105.116, the Agency Record is to be filed with the
Board within thirty (30) days after receipt of the petition. The Agency Record was timely filed
with the Board on June 2, 2006 and consists of approximately 643 pages
.
3
.
Later, the Illinois EPA noticed that the following documents were overlooked in
compiling the Agency's initial Record .
4
.
No prejudice will attach to ABC if the Agency is granted permission to amend its
Record, as ABC is already in possession of these documents that would constitute the amended
Agency Record
.
WHEREFORE, for the reasons stated above, the Agency hereby respectfully requests
that the Board accept the filing of this Amended Record instanter
.
Respectfully Submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
BY
:
„
Sanjay K. Sofat
Assistant Counsel
Division of Legal Counsel
DATED: June 20, 2006
1021 N. Grand Ave. East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
STATE OF ILLINOIS
COUNTY OF SANGAMON
I, the undersigned, on oath state that I have served the attached AMENDED RECORD
upon the persons to whom it is directed, by placing a copy in an envelope addressed to
:
Dorothy Gunn, Clerk
Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 N. Grand Ave. East
P.O. Box 19274
Springfield, IL 62794-9274
SUBSCRIBED AND SWORN BEFORE ME
THIS,-57(,% DAY OF JUNE, 2006 .
SS
PROOF OF SERVICE
Maxine I. Lipeles
Interdisciplinary Environmental Clinic
Washington University School of Law
One Brookings Drive -Campus Box 1120
St. Louis, MO 63130-4899
Carolyn S. Hesse
Erika K . Powers
David T. Ballard
Barnes & Thornburg LLP
One North Wacker Drive
Suite 44000
Chicago, IL 60606
~~
~CL
1CC_
-
1A~i~
\f
~1
Cc
OFFICIAL SEAL
c
•
%
CYNTHIA L. WOLFE
•:
1: NOTARY PUBLIC, STATE OF IWNOIS
My COMMISSION EXPIRES 362
THIS FILING PRINTED ON RECYCLED PAPER
AMENDED RECORD
84 .
Letter dated March 31, 2006, from Alan Keller to C . Daniel Baker Jr., U.S. Steel
Law Department; without attached permit. (p. 644)
85
.
Letter dated March 31, 2006, from Alan Keller to Kathleen Logan Smith, with
attached response letter dated March 24, 2006 . (pp. 645-647)
86 .
Letter dated March 31, 2006, from Alan Keller to American Bottoms
Conservancy, with attached response letter dated March 24, 2006 and NPDES
Permit No. IL0000329, reissued to United States Steel Corporation on March 31,
2006. (pp. 648-657)
THIS FILING IS SUBMITTED ON RECYCLED PAPER
IEPA EXHIBIT
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
No
.
Cal.+ .
1021
NORTH GRAND AVENUE EAST,
P.O. Box 19276,
SPRINGFIELD, ILLINOIS
62794-9276 - ( 217) 782-3397
JAMES
R .
THOMPSON CENTER,
100
WEST RANDOLPH, SUITE
11-300,
CHICAGO,
IL 60601 -(312) 814-6026
ROD
R .
BLAGOJEVICH, GOVERNOR
DOUGLAS P. SCOTT,
DIRECTOR
217/782-0610
March 31, 2006
C. Daniel Baker Jr .
United States Steel Law Department
600 Grant Street
Pittsburg, Pennsylvania 15219
Re :
United States Steel Corp . - Granite City Works
NPDES PermitNo. IL0000329
Rescission and Reissuance of NPDES Permit
Dear Mr. Baker
:
In order to be consistent with procedural regulations, the Agency has made the decision to rescind the Granite
City Works NPDES permit issued March 8, 2006 and reissue this subject permit on March 31, 2006
. The
effective date of the permit will remain April 1, 2006 . There will be no lapse in permit coverage since the
permit issued March 8'
is
not yet effective. Therefore, an administrative continuance of the expired NPDES
permit remains in effect until the effective date of the reissued NPDES permit . The reissuance of the Granite
City Works NPDES permit will reset the permit appeal time period so that parties who filed timely comments
on the draft NPDES permit, on or before January 18, 2005, will have a full 35 days with which to consider the
Agency's responses
.
The Agency appreciates your cooperation in this matter. If you have any questions or comments regarding
this issue please contact Blaine Kinsley of my staff at the address or telephone number listed above
.
Sincerely,
LKt
Alan Keller, P.E .
Manager, Permit Section
Division of Water Pollution Control
Enclosure :
NPDES permit
cc :
Records Unit
Collinsville Region
SAK:baka:\1296\dots\permits\gcsteelrescission.doc
ROCKFORD-4302 North Main Street, Rockford, IL 61103-(815) 987-7760
•
DES PLAINES-9511 W. Harrison St., Des Plaines,
IL
60016-(847) 294-4000
ELGIN-595 South State, Elgin, IL 60123-(847) 608-3131
•
PEORIA-5415 N. University St., Peoria, IL 61614-(309) 693-5463
BUREAU OF LAND
- PEORIA - 7620 N. University St., Peoria, IL 61614 - (309) 693-5462
•
CHAMPAIGN-2125 South First Street, Champaign, IL 61820- (217) 278-5800
SPRINGFIELD-4500 S Sixth Street Rd., Springfield,
IL
62706-(217) 786-6892
COLLINSVILLE-2009 Mall Street, Collinsville, IL 62234-(618) 346-5120
MARION-2309 W . Main St., Suite 116, Marion,
IL
62959-(618) 993-7200
844
IEPA EXHIBIT
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
No . 95
1021 NORTH GRAND AVENUE EAST, P .O. Box 19276, SPRINGFIELD, ILLINOIS 62794-9276-( 217) 782-3397
JAMES R. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601
- (312) 814-6026
ROD R. BLAGOJEVICH, GOVERNOR
DOUGLAS P. SCOTT, DIRECTOR
217/782-0610
March 31, 2006
Kathleen Logan Smith
Health & Environmental Justice-St. Louis
P.O. Box 2038
St. Louis, Missouri 63158
Re: United States Stee-Granite City Works
NPDES Permit No. IL0000329
Rescission and Reissuance of NPDES Permit
Dear Ms. Smith :
This letter is to inform you that in order to be consistent with procedural regulations the Agency has
made the decision to rescind the above referenced NPDES permit that was issued March 8, 2006 and
reissue this subject permit on March 31, 2006 . The reissuance of the Granite City Works permit will
reset the permit appeal time period so that you and other parties who filed timely comments on the
draft permit, on or before January 18, 2005, will have 35 days with which to consider the Agency's
responses . A copy of the Agency response letter to you dated March 24, 2006 is enclosed for your
convenience along with a copy of the reissued NPDES permit
.
Should you have any questions or comments regarding the above, please contact Blaine Kinsley of
my staff at the indicated telephone number and address. Thank you very much for participation in
the NPDES process
.
Sincerely,
6C,_
Alan Keller, P.E .
Manager, Permit Section
Division of Water Pollution Control
Enclosures
:
NPDES Permit
Response letter
Cc :
Collinsville FOS
Records
Binds
SAK:bak\L.:epa1269\docs\0000329rese .doc
ROCKFORD-4302 North Main Street, Rockford, IL 61103-(815) 987-7760
•
DES PLAINES-9511 W. Harrison St., Des Plaines, IL 60016-(847) 294-4000
ELGIN-595 South State, Elgin, IL 60123-(847) 608-3131
•
PEORIA-5415 N . University St ., Peoria, IL 61614 - (309) 693-5463
BUREAU
of
LAND
- PEORIA - 7620 N . University St., Peoria, IL 61614- (309) 693-5462
•
CHAMPAIGN - 2125 South First Street, Champaign, IL 61820- (217) 278-5800
SPRINGFIELD-4500 S Sixth Street Rd ., Springfield, IL 62706-(217) 786-6892
•
COLLINSVILLE-2009 Mall Street, Collinsville, IL 62234-(618) 346-5120
MARION-2309 W. Main St., Suite 116, Marion, IL 62959-(618) 993-7200
645
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 NORTH GRAND AVENUE EAST, P .O . Box 19276, SPRINGFIELD, It LINOIs 62794-9276
- ( 21 7) 782-3397
JAMES R. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60607 -(312) 814-6026
ROD R
.
BLAGO)EVICH, GOVERNOR
DOUGLAS
P. SCOTT,
DIRECTOR
217/782-0610
March 24, 2006
Kathleen Logan Smith
Health & Environmental Justice-St . Louis
P.O. Box 2038
St. Louis, Missouri 63158
Re: United States Stee-Granite City Works
NPDES Permit No. IL0000329
Response to Comment Letter
Dear Ms. Smith :
Thank you for your letter dated January 17, 2005 in which you express your concern for the
reissuance of the above referenced permit . The Illinois EPA apologizes for the delay in responding
to your concerns after the issuance of the permit . In response to your concern the Illinois EPA offers
the following responses
.
1. Horseshoe Lake impairment and concern over discharges of lead and ammonia by Granite
City Works (GCW) .
Response. As you are aware, lead is not listed as an impairment of Horseshoe Lake. Fish
consumption advisories have been issued for Channel Catfish and Carp because of PCB's
.
GCW is not listed as a source of impairment. The Illinois EPA has taken note of your
concern, both in your comment letter regarding GCW and in your comments during recent
303(d) hearings at the Agency. In addition, lead is not used as a raw material or an additive
in the steel making process . The increased load limit for lead is based on Federal Categorical
production standards. These standards must be placed in categorical discharge permits
regardless of the reasonable potential of any one parameter to exceed a water quality
standard. Regarding ammonia, the permit reflects revised ammonia water quality standards
which were not in place at the time of the last renewal
.
2. Compliance history of GCW .
Response. The Agency is aware of the compliance history of the GCW facility . The Agency
has taken, and will continue to take, all necessary and appropriate action regarding
compliance issues with this facility
.
Should you have any questions or comments regarding the above, please contact Blaine Kinsley of
my staff at the indicated telephone number and address . Thank you very much for participation in
the NPDES process .
ROCKFORD -4302 North Main Street, Rockford, IL 61103 - (815) 987-7760
•
DES PLANES -9511 W. Harrison St., Des Planes, IL 60016 - (847) 294-4000
ELGIN -595 South State, Elgin, IL 60123 - (847) 608-3131
•
PEORIA- 5415 N . University St., Peoria, IL 61614 - (309) 693-5463
BUREAU OF LAND
- PEORIA - 7620 N . University St., Peoria, IL 61614 -(309) 693-5462
•
CHAMPAIGN - 2125 South First Street, Champaign, IL 61820 -(217) 278-5800
SPRINGFIELD-4500 5 . Sixth Street Rd., Springfield, IL 62706 -(217) 786-6892
•
COLLINSVILLE- 2009 Mall Street, Collinsville, IL 62234 - 16181 346-5120
MARION - 2309 W . Main St., Suite 116, Marion, IL 62959 - (618) 993-7200
646
to the end of the public comment period . Specifically, the comment letter received from the
Washington University Civil Justice Clinic/Interdisciplinary Environmental Clinic dated December 9
2005. The Agency regrets that you were unable to attend a scheduled meeting on the above
mentioned issues on March 14, 2006. We are still willing to meet with you should you wish to
reschedule. Should you have any questions or comments regarding the above, please contact Blaine
Kinsley of my staff at the indicated telephone number and address . Thank you very much for
participation in the NPDES process
.
Sincerely,
zo-,
ak'-~
Alan Keller, P.E .
Manager, Permit Section
Division of Water Pollution Control
SAK:bak\L:epal269\docs\0000329.doc
Attachment: NPDES Permit
cc :
Binds
647
IEPA EXHIBIT
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
No.
NO
1021 NORTH GRAND AVENUE EAST, P .O
.
Box
19276, SPRINGFIELD, ILLINOIS 62794-9276-(217)782-3397
JAMES R. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601 - (312) 814-6026
ROD R. BLAGOIEVICH, GOVERNOR
DOUGLAS P .. SCOTT, DIRECTOR
217/782-0610
March 31, 2006
American Bottoms Conservancy
Health and Environmental Justice-St. Louis
Neighborhood Law Office
Sierra Club
Webster Groves Nature Society
C/o Kathy Andria
607 North 7 11 Street
East St. Louis, Illinois 62201
Re: United States Steel-Granite City Works
NPDES Permit No. IL0000329
Rescission and Reissuance of NPDES Permit
Dear Ms. Andria
:
This letter is to inform you that in order to be consistent with procedural regulations the Agency has made the
decision to rescind the above referenced NPDES permit that was issued March 8, 2006 and reissue this subject
permit on March 31, 2006 . The reissuance of the Granite City Works permit will reset the permit appeal time
period so that you and other parties who filed timely comments on the draft permit, on or before January 18,
2005, will have 35 days with which to consider the Agency's responses . A copy of the Agency response letter
to you dated March 24, 2006 is enclosed for your convenience along with a copy of the reissued NPDES
permit .
Should you have any questions or comments regarding the above, please contact Blaine Kinsley of my staff at
the indicated telephone number and address. Thank you very much for participation in the NPDES process
.
Sincerely,
Alan Keller, P .E .
Manager, Permit Section
Division of Water Pollution Control
Enclosures :
NPDES Permit
Response letter
Cc
Collinsville FOS
Records
Binds
ROCKFORD -4302 North Main Street, Rockford, IL 61103 -(815) 987-7760
•
DES PLAINES-9511 W. Harrison St, Des Plaines, 1160016 - (847) 294-4000
SAK:bak\L:6pelts26993das1f1 GW%tm8IL6e123-(847) 608-3131
•
PEORIA-5415 N . University St., Peoria, IL 61614-(309) 693-5463
BUREAU OF LAND-PEORIA - 7620 N. University St., Peoria, IL 61614-(309) 693-5462
•
CHAMPAIGN - 2125 South First Street, Champaign, IL 61820 -(217) 278-5800
SPRINGFIELD-4500 S. Sixth Street Rd., Springfield, IL 62706-(217) 786-6892
•
COwNSVILLE-2009 Mall Street, Collinsville, IL 62234 -(618) 346-5120
MARION-2309 W. Main St., Suite 116, Marion, IL 62959-(618) 993-7200
64 8
1021
NORTH GRAND AVENUE EAST,
P.O . Box 19276,
SPRINGFIELD, ILLINOIS
62794-9276 - ( 217) 782-3397
JAMES
R .
THOMPSON CENTER,
100
WEST RANDOLPH, SUITE
11-300,
CHICAGO,
IL 60601 -(312) 814-6026
ROD R .
BLAGOIEVICH, GOVERNOR
DOUGLAS
P. SCOTT,
DIRECTOR
217/782-0610
March 24, 2006
American Bottoms Conservancy
Health & Environmental Justice-St . Louis
Neighborhood Law Office
Sierra Club
Webster Groves Nature Society
C/o Kathy Andria
607 North 71h Street
East St. Louis, Illinois 62201
Re: United States Stee-Granite City Works
NPDES Permit No. IL0000329
Response to Comment Letter
Dear Ms. Andria
:
Thank you for your letter dated January 18, 2005 in which you express your concern for the
reissuance of the above referenced permit. The Illinois EPA apologizes for the delay in responding
to your concerns after the issuance of the permit . In response to your concern the Illinois EPA offers
the following responses .
1. Horseshoe Lake impairment and concern over discharges of lead and ammonia by Granite
City Works (GCW)
.
Response. As you are aware, lead is not listed as an impairment of Horseshoe Lake . Fish
consumption advisories have been issued for Channel Catfish and Carp because of PCB's
.
GCW is not listed as a source of impairment . The Illinois EPA has taken note of your
concern, both in your comment letter regarding GCW and in your comments during recent
303(d) hearings at the Agency. In addition, lead is not used as a raw material or an additive
in the steel making process. The increased load limit for lead is based on Federal Categorical
production standards. These standards must be placed in categorical discharge permits
regardless of the reasonable potential of any one parameter to exceed a water quality
standard. Regarding ammonia, the permit reflects revised ammonia water quality standards
which were not in place at the time of the last renewal
.
2. Compliance history of GCW
.
Response. The Agency is aware of the compliance history of the GCW facility. The Agency
has taken, and will continue to take, all necessary and appropriate action regarding
compliance issues with this facility
.
In addition to the responses to the above continents, which were received prior to the end of the
public notice period, responses are being generated for the comments that were received subsequent
ROCKFORD-4302 North Main Street, Rockford, IL 61103 -(815) 987-7760
•
DES PLANES- 9511 W. Harrison St., Des Plaines, IL 60016 -(847) 294-4000
ELGIN-595 South State, Elgin, IL 60123-(847) 608-3131
•
PEORIA-5415 N. University St., Peoria, IL 61614-(309) 693-5463
BUREAU OF LAND
- PEORIA - 7620 N . University St., Peoria, IL 61614-(309) 693-5462
•
CHAMPAIGN - 2125 South First Street, Champaign, IL 61820 -( 217) 278-5800
SPRINGFIELD -4500 S. Sixth Street Rd ., Springfield, IL 62706-(217) 786-6892
•
COLLINSVILLE - 2009 Mall Street, Collinsville, IL 62234-(618) 346-5120
MARION -2309 W. Main St., Suite 116, Marion. IL 62959 -(618) 993-7200
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
64 9
to the end of the public comment period. Specifically, the comment letter received from the
Washington University Civil Justice Clinic/Interdisciplinary Environmental Clinic dated December 9
2005. The Agency regrets that you were unable to attend a scheduled meeting on the above
mentioned issues on March 14, 2006 . We are still willing to meet with you should you wish to
reschedule. Should you have any questions or comments regarding the above, please contact Blaine
Kinsley of my staff at the indicated telephone number and address . Thank you very much for
participation in the NPDES process .
Sincerely,
Alan Keller, P .E .
Manager, Permit Section
Division of Water Pollution Control
SAK:bak\L:epal 269\docs\0000329.doc
Attachment: NPDES Permit
cc :
Binds
65 0
Expiration Date: March 31, 2011
Name and Address of Permittee
:
United States Steel Corporation
Granite City Works
20th and State Streets
Granite City, Illinois 62040
Discharge Number and Name
:
001
Treated Process Wastewater
A01
Coke By-Products Wastewater
B01
Cold Rolling Mill Wastewater
C01
Landfill Leachate Wastewater
NPDES Permit No. IL0000329
Illinois Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
Reissued (NPDES) Permit
Issue Date: March 31, 2006
Effective Date: April 1, 2006
6 5 1
Facility Name and Address
:
United States Steel Corporation
Granite City Works
20th and State Streets
Granite City, Illinois 62040
Receiving Waters :
Horseshoe Lake
In compliance with the provisions of the Illinois Environmental Protection Act, Title 35 of III . Adm. Code, Subtitle C and/or Subtitle D, Chapter
1, and the Clean Water Act (CWA), the above-named pennittee is hereby authorized to discharge at the above location to the above-named
receiving stream in accordance with the standard conditions and attachments herein
.
Permittee is not authorized to discharge after the above expiration date . In order to receive authorization to discharge beyond the
expiration date, the permittee shall submit the proper application as required by the Illinois Environmental Protection Agency (I EPA) not
later than 180 days prior to the expiration date
.
Alan Keller, P .E .
Manager, Permit Section
Division of Water Pollution Control
SAK:BMB:04090101 .bah
Page 2
NPDES Permit No . IL0000329
Effluent Limitations and Monitorinq
1 . From the effective date of this permit until the expiration date, the effluent of the following discharge(s) shall be monitored and limited
at all times as follows :
Outfall(sp. 001 Treated Process Wastewater
6 52
'For Ammonia as Nitrogen, Spring/Fall is April-May and September-October . Summer is June-August. Winter is November-February
.
Weekly average limits will apply . For Spring/Fall, weekly average limit is 7.0 mg/L (1460 lb/day) . Summer weekly average limit is 5 .5 mg/L
(1147 lb/day). March weekly average limit is 10 mg/L (2085 lb/day) . No weekly average limit for Winter .
"See Special Condition 10 .
LOAD LIMITS lbs/day
DAF (DMF1
CONCENTRATION
LIMITS mo/I
30 DAY
DAILY
30 DAY
DAILY
SAMPLE
SAMPLE
PARAMETER
AVERAGE
MAXIMUM
AVERAGE
MAXIMUM
FREQUENCY
TYPE
Flow (MGD)
See Special Condition 1
Measure When
Monitoring
pH
See Special Condition 2
6.0 -9 .0
2/Week
Grab
CBODS
2085
4170
10
20
2/Week
Composite
Total Suspended Solids
2502
5004
12
24
2/Week
Composite
Oil & Grease
1511
3492
15
30
2fWeek
Grab
Iron (total)
417
834
2
4
2/Week
Composite
Iron (dissolved)
209
I
2/Week
Composite
Lead (total)
5 .6
17
0.09
0 .4
1/Quarter
Composite
Zinc (total)
12
56
0.17
2/Week
Composite
Cyanide (total)
19
35
0.1
0.2
2/Week
Mathematical
Composite"
Cyanide (available by
1 .1
4.6
0 .01
0.02
2/Month
Mathematical
OIA 1677)
Composite"
Phenol (4AAP)
5 .0
10
0.1
2NVeek
Composite
Fluoride
Ammonia-Nitrogen'
834
4
2/Week
Composite
Spring/Fall
584
3128
2.8
15
2/Week
Composite
Summer
459
3128
2.2
15
2/Week
Composite
Winter
1501
3128
7.2
15
2fWeek
Composite
March
834
3128
4.0
15
2/Week
Composite
Page 3
NPDES Permit No. IL0000329
Effluent Limitations and Monitorinq
1 . From the effective date of this permit until the expiration date, the effluent of the following
discharge(s) shall be monitored and limited
at all times as follows
:
Outfall(s): A01, B01, C01
LOAD LIMITS lbs/day
CONCENTRATION
DAF (DMF) LIMITS mq/I
30 DAY
DAILY
30 DAY
DAILY
SAMPLE
SAMPLE
PARAMETER
AVERAGE
MAXIMUM
AVERAGE
MAXIMUM
. FREQUENCY
TYPE
Outfall A01 -Coke By-Products Wastewater
Flow (MGD)
See Special Condition 1
Continuous
Measure
Total Suspended Solids
Monitor
1/Month
Composite
Naphthalene
0 .10
2/Week
Composite
Benzo(a)pyrene
0 .15
2/Week
,
Composite
Outfall: B01
- Cold Rolling Mill Wastewater
Flow (MGD)
See Special Condition 1
When
Measure
Monitoring
Tetrachloroethylene
1 .1
2/Year
Grab
Naphthalene
0 .73
1/Month
Grab
Outfall : C01 - Landfill Leachate Wastewater
Flow (MGD)
See Special Condition 1
Continuous
Measure
653
Page 4
NPDES Permit No . IL0000329
Special Conditions
SPECIAL CONDITION 1
.
Flow shall be reported as a daily maximum and a monthly average, and shall be reported on the monthly
Discharge Monitoring Report Form .
SPECIAL CONDITION 2
.
Thee pH shall be in the range 6 .0 to 9.0. The monthly minimum and monthly maximum values shall be reported
on the DMR form .
SPECIAL CONDITION 3
.
If an applicable effluent standard or limitation is promulgated under Sections 301(b)(2)(C) and (D),
304(b)(2),
and 307(a)(2) of the Clean Water Act and that effluent standard or limitation is more stringent than any effluent limitation in the permit or
controls a pollutant not limited in the NPDES Permit, the Agency shall revise or modify the permit in accordance with the more stringent
standard or prohibition and shall so notify the permittee .
SPECIAL CONDITION 4
. The use or operation of this facility shall be by or under the supervision of a Certified Class K operator
.
SPECIAL CONDITION 5
.
For purposes of this permit, load limits for Phenol (4AAP) have been based on actual plant discharges, and load
limits for Ammonia (as N) have been based on water quality standards, and are included in accordance with a 301(g) variance of the Clean
Water Act approved by the USEPA . Any changes to these load limits can only be made following Public Notice and opportunity for hearing
.
SPECIAL CONDITION 6
.
The permittee may show that an apparent noncompliance of load limits for zinc is not a violation by applying
background credits for intake waters and by submission of calculations as defined below
.
The load calculations for comparison to Zinc load limits shall be made as follows
:
M = (Ce - C,) x F x 8.34
Where :
M = Outfall 001 load limit (lbs/day)
C~ = Outfall 001 effluent concentration (mg/I)
C, = Intake water concentration (mg/I)
F = Outfall 001 effluent flow (MGD)
Concentrations limits for outfall 001 are absolute and no background credit shall be allowed
.
SPECIAL CONDITION 7
.
The permittee shall record monitoring results on Discharge Monitoring Report (DMR) forms using one such form
for each discharge each month. Semi-annual monitoring results shall be submitted with the DMR forms for the months of June and
December, and shall be submitted to the IEPA no later than July 15 and January 15 unless otherwise specified by the Agency, to the
following address :
Illinois Environmental Protection Agency
Bureau of Water
Division of Water Pollution Control
Compliance Assurance Section, Mail Code #19
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-19276
SPECIAL CONDITION 8 .
The Permittee shall be required to conduct an effluent toxicity evaluation prior to the renewal of this permit
.
Elements of the toxicity evaluation should include but not be limited to the following
:
A
.
Aquatic Toxicity Screeninq
Acute Toxicity
- The initial acute toxicity testing should be run on at least three trophic levels of aquatic species (fish, invertebrates
and plants) which represent the aquatic community for the receiving stream . Suggested species include the Fathead Minnow
and Ceriodaphnia. All tests should be done in accordance with "Measuring Acute Toxicity of Effluents to Freshwater and Marine
6 54
Page 5
NPDES Permit No. IL0000329
Special Conditions
Organisms (Fourth Edition)", (USEPN600-4-90/027) and "Environmental Effects Tests Guidelines" (USEPA/560-6-82/002) . The
IEPA specifications and guidelines for these tests, given in "Effluent Biomonitoring and Toxicity Assessment
- Aquatic Life
Concerns,"" must also be met
.
Testing shall be conducted on fish over a 96-hour period while invertebrates should be tested over a 48-hour period . Test should be
performed on 100% effluent,
B .
Samplinq Freauencv
The test referenced above shall be performed during the final year of this permit. Upon completion, test results may be submitted with the
facility renewal application .
SPECIAL CONDITION 9
.
Samples taken in compliance with the effluent monitoring requirements for internal outfall A01 shall be taken
at a point representative of the discharge of Coke By-Products Wastewater, but prior to mixing with any other wastewater sources
.
Samples taken in compliance with the effluent monitoring requirements for internal outfall B01 shall be taken at a point representative of
the discharge of Cold Rolling Mill wastewater, but prior to mixing with any other wastewater sources . Samples taken in compliance with
the effluent monitoring requirements for internal outfall C01 shall be taken at a point representative of the discharge of Landfill Leachate
Wastewater, but prior to mixing with any other wastewater sources . Samples taken in compliance with the effluent monitoring requirements
for outfall 001 shall be taken at a point representative of the discharge, but before entering the receiving water
.
SPECIAL CONDITION 10 .
Samples for Cyanide (available by CIA 1677) and Cyanide (total) shall consist of a series of grab samples
collected over any 24-hour consecutive period, stored using methods consistent with 40 CFR 136, and combined after the collection of
the last grab sample . The combined sample shall be analyzed using methods consistent with 40 CFR 136, within 24 hours of the initial
sample collection
.
6 5 5
standard Co.Wton.
DefMRlaa
Act means the IMnois Envkonmental P,olectgn Act Ch. 111 '/2 Ii. Rev. Slat. Sec 100'-
1052
M
Amended
.
A icy mans do ekrois Erwironrrwrtal Protection Agency
.
,sand mean. the Ipnwi. Pollution Control goad.
Cede.
. Water Act Iformerly
r.ferred to a the Federal Waer Pollution Control Ad) means
Pub. I.. 92500, .s amended. 33 U.S.C
1251 et seqq
aeon
Ulaliodal Pollutant Discharge EYmwton Sytteml main, the rational program toy
snip modlyils revoking and rescuing, terminating . monitpGrg and enforcing permits, end
kr.poaip ate enforcing pre nelmenl requirements. under Sections 307, 402, 316 end 405
a
Se Clean War Ana.
UUPA mere dw United State EmiomenW Protection Agency
.
.
Deity D/arsaarge maw the discharge of a polutent measured dying a calendar day or any
24-hots period rest rueoneMy represents the calendar day for purposes of amphora For
poMdesta with limitations eapmaad in unite of meal, the 'deify discharge' is calculated ea
1M total mass of tlna polutant discharged
over the day. For peutants with imitations
epyesaS in otlr ants of neasuremena, rya "daly discharge"
s
calculated a the average
meeev nsew of the peutant over the ay
.
MeeMtevr Dally Dleclsege Llmisatlon Idaily mesimuml means the highest alowsbe data
dledsrge
.
Awege MenIMy Dladsrge ttnltaan 130 day average) meant
the highest stowed,
ev nge of daly discharges over a calerder month,
cakuletad a the sInn of
al deW
dlacfarges nreeersed during a calendar month divided by the numbs, of deity discharges
mepaed dialog that month .
Ave Weekly Dlectserge Umltsan 17 day average)
mane Use highest allowable
.veege of daily discharge. overs pWder week, calculated a the sum of all deifydischarges
"eereed during a pNnder week divided by the number of deify discharges matured durkp
that week,
Sees Menages,, Practices IBMPa)
men schedules of ecwlties, prohibitions
of
pastier a, meinterance pocedune, and other management practices to potent orreduce the
position of waken of the State. BMWs also include befnrst requirements. operating
pnocedlree, rd practice, to control plant site runoff,
epifege or leeks, aludge or wale
depot* or dnhep Iran few maleniel etorpd.
Allppt men e ample of specified volume used to nuke up a total compalla sample
.
GrM'Mmp/a neap en indlvidtW ample of al lava 100 mN
an collected et a randomty-
aaacted tine over a prod not exceeding 16 minus,
.
24 sled
. Conweelle Sea
le mans a cpndmtion of al least S ample aliquofa of at net
IDO mutes coiected
a
periodic intervals during the operating hares of . facdty over a 24-
s -.
S Ilea Correpte Sample melee . corMnetion of al Yeet 3 ample alquota of al least 10O
ena*e, collected at periodic intervals during the operating hoist of a facility over a 8-hour
prod
Flew Proportional Cernpplle Sample meat a combination of
sample aliquots of al least
100 ndllaere speeded et periodic intervals such that either the time interval between etch
alquor or the vdumo of each aquot iss proportional to either the strum flow at the time of
arnptirnp or the total stream flow since the coaectlon or the previous aquot
11)
' Duty to comply. Tb perming mat comply with et conditions of this permit
.
Am pnmit noncompliance constitutes a violation of the Act and b grourdt for
enforcement anon, permit termination, revocation end releNenoe,
modification
or tar denial of a permit renewal epplkaton. The permitW shed comply with
effluent standards or prohibitions estebahad under Salon 3071s1 of the Clean
Water Act for lank pollutants within the time provided . g the regulations that
atabah these standads
or prohibitions, even if the permit has not yet been
modified to incorporate the requirement.
12)
Duty b reapply . If the permtW wishes to continue an activity regulated by thin
permit after the aspiration dote of this permit, me pnsdna
must apply for end
obtain a new permit If the pnniDes submits a proper application a required by
the Agency no lets' than 180 days prior to the espe'apon date, chit permit that
conbnse Y full force and affect until the final Agency decision on
the application
ha been made
13)
Need to hall a reduce activity not a defense . t t shell not be a defense for
ermines in a en lortemat action that in would have been necessary
to hall or
reduce the per mined activity in ordem to maintain compliance with the conditions
of this permit
.
141 Duly to midgets . The prmnlee shall take all reasonable steps to minimize or
pavanl any J'schnp in vinlaton of this permit which hasaraeeonabts likelihood
of adversely aftecling human health or th endrunment
151
Prop.
. operation end maintenance Tlo genius
. shall al at times popery
mores, and mainrmn all tech
min end sysmms of treatment and control land
related appuruinnices) which ere mrlelbd
'rim .ed by the pmella to echYW
mplimince
with
the condiLnn .
OI
Ihts prm ;l. Proper operation and meint .nenca
etude
. elle:ove performance. adequalu tundiog . adequate opretor a W king and
uanlngg and adequate labOnlory and process
conlrom, aincludlng appropriate
Quality a
ace pocedurec This provision require . the operation of back-up, or
utitary facilities
.
or
similar systeme only when
nacacary i echiae
compl'unee with the cunditiona or Lhr permit
65 6
Po/
Psrndt action.. This permit may be modified, revoked andreialued, or tsnninaled
for caws by the Agency pursuant to 40 CFR 12282 . The fill-mg of a regptl by the
pwnrinee for a permit modiNCetion revocation and reiaauance,
a terminationn or a
notification of planned change, a anticipated noncompliance, does not stay any
penrnd condition .
(71
Property rghts. This perm) does not convey any popery rghte of any son, a
wry sodusive pvilege
.
It)
Duty to provide tntormation. The permutes shell furnish to
th e Agency within a
reasonable time, any inlorrnation which the Agency may request to determine
whether cause eeisb Ion modllyirp, revoking and reissuing,
or termipting this
pern4 or to determine compliance with the permit The prmittee shall also
Iumish to the Agency, upon request copes of records raquued
to be kept by this
pemnL
(91
Nupedloe end entry, The prminee shell allow en authorized
representative of
the Agency, upon the pntantation of padentwls and other docunwnb a may b
repded by law, lo :
LI
Enter upon the penmtlee's pemisee where a regulated facility or activity is
located or conducted, or where records must be kept under the conditions
of thin panic
lbl
Have access to and copy.
a t reasonable lame., any records that must be
kept under the condlliona of this permit ;
kl
tispcl al reasonable omee any Iecilities, equipment (including monitom5
and
control guipmentl, pacrices, or operelons regulated
or rpueed
under this permit ; and
Id)
Sample or monitor at reasonable urma, for line purpose of esaurirsg permit
compliance, or as otherwise authorizer) by
the Act, any subaences on
pnmeten al any ocetion,
(10) M.Nlerlng rd record
. .
•
Samples end maeeumnente taken for the purpose of monitoring shell be
representative of the montored activity.
•
The perrnalae
shell retain records of all monitoring infomation, including
all caibebon end medterunce
record s,
and all
original
strip chart
recordings for cmnunuoua monioring i sebumentalon, copies of at reports
regsdre0 by this permll and records of
all
data used to oonpYte the
apylkation for this prmlt for a period
of a
seat
3 year
. from the date of
this pvnnlt maauranenl repel
or
applicatlon. This prod may be
attended by request of the Agency al any tune.
•
Records of modYnng ofornalon abet
include
:
111
The date, sad piece, end time of camping or me.evement.
;
121
The irdividuabl who performed the sampling or measurement. :
(3)
The asala) analyses were pertormed
.
161
The Individuals) who performed the e ne tysea ;
151
The analytical Ychngwe or methods used
; sn
161
The reeulb of such emlyses .
N)
Monithrkp must b conducted according
to test prgceduru approved
under 40 CFR Pan t 35, unless other teal poceduns t%ava been specified
i n this permit
. Where no, teat procedure carne 40 CFR pan 138 ha t been
appro ved, the ermines must admit to the Agency a tea method Ip
epproesl. The permute shall calibrate
and perlprm maintenance
procedures on et monitoring and ensMicaf iretrunentsbn at isarvale to
mare accuracy of measuremen t s
.
If 11
Signatory IguIsement . At applications, reports or information submitted to the
Agency shell be signed and ce'thed
.
W
Appllcatlon. All permit applications shall be signed et follow,
.
Ill
For a corporetlon : by a principal ekaawe officer of so least the
level of vice president or a peon or position
having onset
responsibility for environments matters for the corpoestton
;
PRINTED ON RECYCLED PAPER
Is
01
The aothorisslion is made in wntng by a peon described
in
paragraph al; and
121 The authontaWn spcifles either
•
individual a a pstton
res ponsi ble for the overall operauon
of
the facility, Irons which the
discharge originates, such es e plant manager, aspaYae anent
or
person of equivalent responsibility, end
131
The wnnen eulhorlaalion to wbnittad
1o
the Agency .
121
For a prtnerahlp or sole pcopletonhlp : by a general partner or
the proprietor, respectively ; p
131
For a muadpllty, State, Federal,
or other pblo a
gency
. by
ether a pnaclpal etecubva officer or renting elected official.
Report. All reports required by permits, or otter intorn .sion requested by
the Agency shat b signed by
a person deacnbed
in peregrep
ta)
or by e
duly authorized rpr sentetiva of that person . Aprep ss
duty euthdiaed
reprasentetwe only
if :
web becaw a dlftereol irividuel or position has mpona4lity for the
overall opereuon of the facility, a new authomaton sebfying the
requirenserna of It, mutt b submitted to the Agency prior to
or together
with any report .. infomation. or epplrcauone to be signed by an authonsed
repeeentehve
.
1121 bportlngrpulementeg
lal
Pt nned change, The perminee shall glue notice to the Agency as soon
f possible of any planned physical albglions or additions to the
permit sd lacibp .
ml
AnlkIpeted nenooe lpllmce. The uarmitlee
.hall give advance notice to
the Agency of any panned changes in the permined facility or activity
which may mull In noncompliance with permit requiramino, .
Compliance sehadutes. Report. of compliance or noncompliance with, or
any progress sport, on interim end final requirement, contained in any
comptiancs schedule of this permit shall be submitted no later then 10
days following each schedule dal . .
Id)
MonNplng reports. Monitoring re,ulls shell be reported of the intervals
epecdled elsewhere in this permit
111
Monitoring remits must be reported on a Discharge Monitoring
Report IDMR1 .
(2)
h the peaminee monitors any pollutant more Irequently then
required by the permit, using lest procedures approved
under
40
CFR 138 or a, specified in the permit, the mutts of this monitoring
shell be included in the calculation end reporting of the date
submitted in the DM0 .
131
Calculations for all Ilmilelions which require averaging of
ants shall utilize s arithmetic mean tartlets olhenvge
specified by the agency in the permit .
Twenty 'tour hour sporting' The permitlee shall report any
ompience which may endanger health or the environment. Any
infonnatiion .han b provided orally within 24 hours from the time the
permittee becomes aware of the circumstance.. A written submission shell
also be provided within 5 days of Ihe time the raemgotee becomes aware of
the circumstance.. The wdten submission shell contain a description of
the encompience and lie cause: the
period of
noncompliance, including
exact delta and time.: and if the noncompliance hM not been collected,
the anticipated time it is expected to continue : and seeps lessen or planed
to reduce elim'uud, end prevent reoccunene of the noncompliance . The
following than b included es information which must be reported within
24 hours
111
Any unenlkipeted bypass which eacaeda any effluent limitation in
the pnnili
121
Violation of
•
maximum daily discharge limitation for any of the
pfutenla titled by the Agency in the permit to be reported within
24 hours:
let
The Agency may waive
the
written rtporr on a case-by-vase betas if the
oral report has been rapeived within 24 hours
.
(11
Other noncompliance The permute shall report all instances of
noncompliance not reported under paragraphs 112114, Id), or eel, al the
limp monitoring reports are submitted . The reports shall contain the
information haled in paragraph 1121(e) .
191
Other information. Where the prmrtue becomes
aware
that it tailed to
Submit any relevant facts in a permit aoplicellp, or submitted in tact
Information in a permit appricelion, or in any report ro the Agency . if shell
promptly submit such facts or information
.
1131 Trenaler of permits. A permit may be automatically Iranstaned to a new
prminee it :
(a)
The current permdlee notifies the Agency el toast 30 days m advance of
the propeed transfer data,
Ill
Tin notice includes a written agreement between the eslning'and n
petmillees mnuiuing a spmillc date llur transfer of permit responsibility
.
coverage arid rabaity tetween the currant end new permitees : end
Id
The Agency does not notify the ewaling permnlee end the proposed new
prnanee of Ilair, tans to modify or revoke and raise ue the permit. If this
notice m not
.cowed . II.
Irensfor
is nitective on the dale epeufled in the
egreemenl
1141
All m nulecturingi
co
cial, mining_ and 1Jv¢ulluml dlschargers must notify
the A5ancy a soon as they Snow or love m.ann to belies .
:
That
any
aurvity has a
nod a will
tt
which would result in the
discharge tat army to c plWmnl de,niimwl under Section 301 of de Clean
War Act which a
of
limited in time permit
ml that discherpe will weed
the highest of the lollowmg notitgaine levels
.
I
n
One hundred n,ieroprems put titer 1100 ugfl
857
ecrybniuile', fIra burred mcrogreme per liter 1600 uglb to. 2 .l-
dinisophenot and for 2rrnelhyl-<,e.dinruopnenol : end err enillgram
per liter 11 ono/1) for antimony
:
131
Five
IS) rimes the maximum concentneon value reported
toe
that
pollutant in the NPOES pemtr d
epp4ica Lion: or
141
The level established by the Agency in this permit .
Ill
Thet they have begun or aspect to begin to v ise or manufeclure e
n
inbrnedub or foul podud or byproduct any toxic pollutant which was
not reported in the NPO(S permit application
.
IIS) All Publicly Owned Treatment
Work,
(POTWt) mull provide adequate notice to
the Agency of the following-
.
Id
Any new introduction
of
pollutants
into that POTW from en id'necl
dtachergar which would b subject
to Sections 301 or 306 of the Clean
Water Act d it wen directly d'ncherginp those pllutante : and
It,)
Any substanriel charge in ft-se volume or character of poaunantt be i n g
introduced into that POTW by s
tarot introducing pllutanb Into the
POTW cotta time of issuance of the permit
.
(d
Forprprrsea of thin peregreph, adequate notice shell include Infonneton
on lit the quality and Quantity or efficient introduced into me POTW . sod bit
any emkipeted impact of the change on the quantity or quality of elfluant
to b discharged tom the POTW
.
Itel 11 the perm) is issued to a publicly owned or pblicty r iovleted lnatment worse
.
the presume MNI rapve arty indu. VIM war of such yaalnsent worst m comply
wins
federal requwwnenu concerning',
.11)
User charge, pursuant to Section 2041b1 of the Clan Water Attend
applicable regu4bna appearing M 40 CFR 36 :
121
Tosbc pollutant efllcMnt standard . and pretreatment standard. pwauent to
Section 307 of the Clean Water Act : end
131
Inspection. monitoring end entry prsuent to Section 306 of the Clean
Water Act .
(17) flan applicable standard or tmitetion ii promulgated under Section 30t Ib)1211C)
end
ID),
304W112), or 3071.1(2) and that eflh»nt standard or limitation ie more
abirgent than any affluent limitation in the permit or oontrolt a pWtant not
tiled in the permit the permit shall b pompW modified
or revoked, and
rwaeraed to conform to that effluent standard or limitation,
Ill) Any wRwriaetion to construct issued to the pemtinw pursuant to 35 b . Adm
.
Cod 309 154 is hereby incorporated by reference se a condlon of tot permit.
1191 Thepermrlteethat rio t make inyfalse etaMnentnpeaenblunorcMMkalbn'm
any
eppicetion, record, report plan or other document submitted to the Agency or
the USEPA, or required to be rintaied under Ihi. permit .
120) The Clean Water Act provide, that any person who v'rotaeaa apa pnit condition
ess$emmting Sections 301, 302, 308, 307. 309, 316, or 406 o Ftf
a
Cbn W aer
Act ie subject ro a civil penalty rriot to exceed $10,000 per day of iuch v'gtetpn .
Any
person who willfully
or
negligently viclotee permit conditiop implem.nbg
Section, 301 . 302, 308, 307, or 306 of the Clean Water Act a subject to a lip
of not lass then $2,500, nor more then $25,000
per
day
of violation, or by
imprisonment for riot more than one year, or both
.
(211 The Clean Water Act provides that any person who faltitles . tampers with, or
knowingly render, inaccurate any monitoring device or method required to be
maintained
undo
permit shall, upon convection, be punished by a tine or not mole
then $10,000 per violation, or by imprisonment for not more then 6 months per
violation, or by both.
(221 The Clean Water Act provides that any person who knowingly malice any felt .
statement, representation, or certification in any record or other document
submitted p required to be maintained under this permit thall, including
monitoring reports or reports of compllenca or non-compliance shell, upon
conviction, b punished by a fine of not more men $10,000 per violation, or by
t mpieonment
for not more then 6 months per viotanort or by both
.
(23) Collected screening . sluntea, sludge., end other fotbds shell b disposed of In such
s to pre vent entry of (hots wastes lot runoff Itom the wa s tes ) into
waters of me State. The proper euthorisetion for such disposal .halt be obtained
from the Agency end is incorporated a pert hereof by reference .
(24) In case of conflict lot eeen'these standard conditions end
any
other conditionlsl
included in this permit, the other condltionls) shell govern .
(251 The prmitlee shall comply with, in addition to the tquiremenb of the prmil all
aoplsabe provision of 35 tit. Adm. Cod. Subtitle C, Subtitle O, Subtitle E, end all
applicable order of the Board
.
128) The pro v isions of this
permit en aevereble, and if any poyisgn
of
the pmrit or
the applicat ion or any proviagn of the permit is held invalid the
e.nuuting
pout. out of this permit shell continue in run force and enactt
me', 12-1-661
