1. BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
      2. NOTICE OF FILING
      3. BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
      4. PETITIONER'S SECOND MOTION TO SUPPLEMENT THE RECORD
      5. CERTIFICATE OF SERVICE
  1. IEPA EXHIBIT
  2. IEPA EXHlBIT
  3. IEPA WHlBIT
  4. IEPA EXHIBIT
    1. NO.&
      1. VIII
  5. BEPA EXHIBIT
    1. Memorandum
  6. HEW EXHIBIT
  7. IEPA EXHIBIT
      1. XVII
    1. NO.&
      1. XVIII
  8. lEPA EXHIIT
      1. XXVIII
  9. lEPa EXHIBIT
  10. EPA EX=
  11. From: Blaine Kinsley NO.
      1. XXXVI
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
AMERICAN BOTTOM CONSERVANCY,
Petitioner,
1
Case No. PCB 2006-171
1
(3rd Party NPDES Permit Appeal)
ILLINOIS ENVIRONMENTAL PROTECTION
)
AGENCY, and UNITED STATES STEEL
1
CORPORATION
-
GRANITE CITY WORKS
)
Respondents.
NOTICE OF FILING
PLEASE TAKE NOTICE that on November 6,2006, I filed with the Office of the Clerk
of the Pollution Control Board Petitioner's Second Motion to Supplement the Record
I filed the above document electronically with the Clerk of the Pollution Control Board
and with Carol Webb, Hearing Officer, at
wehhc@,ipch.state.il.us.
In addition, I served copies of
the foregoing electronically upon Sanjay
K. Sofat, counsel for respondent Illinois Environmental
Protection Agency, at
Saniav.Sofat@epa.state.il.us, and Erika K. Powers, counsel for respondent
United States Steel Corporation
-
Granite City Works, at Carolyn.Hesse@,btlaw.com.
Counsel for Petitioner
Interdisciplinary Environmental Clinic
Washington University School of Law
One Brookings Drive Campus Box
11 20
St. Louis, MO 63130-4899
Phone: (314) 935-8760;
Fax: (314) 935-5171
ejheisel@wulaw.wustl.edu
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
AMERICAN BOTTOM CONSERVANCY,
1
Petitioner,
1
1
Case No. PCB 2006-171
(3rd Party NPDES Permit Appeal)
ILLINOIS ENVIRONMENTAL PROTECTION
)
AGENCY. and UNITED STATES STEEL
CORPORATION
-
GRANITE CITY WORKS
j
1
Respondents.
1
PETITIONER'S SECOND MOTION TO SUPPLEMENT THE RECORD
Petitioner American Bottom Conservancy (ABC) moves the Illinois Pollution Control
Board (Board) to again supplement the incomplete record compiled by the Illinois
Environmental Protection Agency (IEPA). In response to
ABC's discovery requests, IEPA
produced 37 pages of agency documents that were generated during the period that the agency
was deliberating on whether to renew U.S. Steel's water pollution discharge permit.
See
Exh. A.
Both IEPA and U.S. Steel have expressed their agreement that the record should be amended to
include the 37 pages of documents produced by IEPA.
WHEREFORE, Petitioner American Bottom Conservancy requests that this Board grant
its Second Motion to Supplement the Record.
Dated: November
6, 2006
Interdisciplinary Environmental Clinic
Washington University School of Law
One Brookings Drive Campus Box 1120
St. Louis, MO 63130-4899
Phone: (314) 935-8760; Fax: (314) 935-5171
eiheisclidwu1aw.wustl.edu
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
CERTIFICATE OF SERVICE
I, Edward J. Heisel, certify that on November 6, 2006, I filed the Petitioner's Second Motion to
Supplement the Record electronically with the Clerk of the Pollution Control Board and with
Carol Webb, Hearing Officer, at
webbc@,i~cb.state.il.us. In addition, I served copies of the
foregoing electronically upon
Sanjay K. Sofat, counsel for respondent Illinois Environmental
Protection Agency, at
Saniay.Sofdt~;cpa.state.il.us,
and Carolyn Hesse, counsel for respondent
United States Steel Corporation
-
Granite City Works, at Carolyn.Hesse@btlaw.com.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
Page
11

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IEPA
EXHIBIT
From:
Blaine Kinsley
To:
Carl. Cannon,
Date:
512212003 8:01:41
AM ,
Subject:
Re: USS
8
NSC Wastewaters
Thanks
darl,
I'm hoping that if the the permit is left the way it is, that the continued discharge of leachak and
stormwater will not be an issue. I don't know why you couldn't monitor the
leachate on your own, without
modificalion, if the intent is solely to be abledefend a hazardous waste determination for other
wastestreams? Did you envision these internal monitoring poinls to have limits associated
wilh them?
I'll let you know as soon as I know something.
Blaine
>>> "Cannon, Carl"
cCCannon@nationalsteel.wm>
05122103 06:59AM
>>>
Blaine-
The initial discussions I had with Toby Frevert and
Al
Keller were directed at the issue we discussed
yesterday. Specifically,
I ask if
USS
would be able to accept NSC's landfill leachate end stormwaters.
Their response to me was that as long as the
leachate and stormwater were identified in the NPDES
.permit application (which they are), USS wuld accept the waters under the current permit. At that point
the discussion was directed to the internal
moniloring points that USS wanted to be incorporated into the
permit.
I hope lhis helps with your discussion this morning.
Carl
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
From:
Blaine Kinsley
To:
Foxworth, Ukanno
Date:
512212003 8:08:58
AM
Subject::
Granite City Steel
Can
Ukanno.
you tell
.
me the status of the renewal of this permit. I don't know if you knew, but US Steel has
I
recently purchased
this faci1ity.a~ part of banc~pt~y
proceedings, except for the landfill and some of the
property. However, there
is an agreement that would allow Ule continued discharge of leachate to the
lreatment plant.
Blaine
I
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
Fmm:
Toby Frevert
IEPA
EXHIBPT
To:
Foxworth, Ukanno
Date:
Mon. Jun 16.2003
528 PM
No.
A
Subject:
~.~.'~teel-
&nite
Ci
Works
Ukanno
Subsequent to National
City Steel's bankruptcy, US Steel bought most of the facility but did not take over
the portion of the property that conatins two landfills. Their internal lawyen advised them to not accept the
IandSII leachate through their treatment process so they are cornming ion next Thursday June 26 to
discuss an expedited NPDES permit request
tocover that discharge separately They will be here in the
afternoon,
I think
1:00
or 1:30. Hopefully you will be available to attend in the meeting'with me.
Thanks,
Toby
CC:
Kinsley, Blaine
I
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
---A
,
.--
- . - . - . . .- . . - . .. - . . - - - . - .
[.
~oby
, -.
'~iitje~~~%?i6lciiy~t~ting
----
-
-.
-. -. - - . - -- .-- - -. ..
Page
- -.
I
. . . I

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IEPA
EXHlBIT
From:
Toby Frevert
To:
FoxworU1, Ukanno
Date:
Fri, Jun 20,2003 8:40 AM
Subject:
Granite City Steel meeting
No.
A.
4
Carl Cannon called and asked that we move the meeting next Thursday
frm
afternoon lo morning. They
will be here at 830 am.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
( dl i(ellerTFrdi
Oi
:Gh.-
"-:
- -.
.- . - .
. ..
. .. .
-
--
. - . . - - . - - - - . -- - - - - . - - - - . . -. Page
. . - 1 . . I
IEPA
EXHlBIT
From:
Al
Keller
NO.-
To:
Garretson. Mike
Date:
Wed, Jan 19.2005 11:Ol AM
As.
I
Subject:
Mike, we may need
Fwd:
some
NPDES
input by
IL 0000329.
CAS on this
Notice
letter.
No.
Is
BMB:04090101.bah
this facility under some VN or enforcement letter?
I
>>> "Kathy Andria" <abc@prairienet.org> 01118105 4:37 PM >>>
Attached is letter from herican Bottom Conservancy. Health
8
Environmental Justice-St. Louis,
Neighbomood Law Office. Sierra Club and Webster Gmves Nature Study Society requesting a public
hearing for the above-entitled NPDES permit
for U.S. Steel.
Kathy
Andria
American Bottom Conservancy
614
N. 7th
,
East St. Louis. IL 62201-1372
(618) 875-9960
Fax (618) 271-0835
abc@prairienetorg
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
7
Page
1 1
From:
Beth Burkard
To:
Kinsley. Blaine
Dale
212312005 2:55:00
PM
Subject:
Granite City Steel

Back to top

IEPA
WHlBIT
Blaine:
Regarding the Public Hearing request, should I be trying to assemble a meeting7 If so, wiU1 whom? Also,
I
are there anv other
~~bliC
hearings or meetings that Imuld attend so I can knowwhat to exDect ifmen
there is oneior ~ranite City stee'?
-
Thanksl -beth m burkard
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
. . . . .. ... . - . - - - . . . . - .- . . -.
. . - .
-
. -. -
, Marcia Willhite
. .
- comments
. . . . - . .
to
..
U.S. Steel
...-...-A
draft NPDES permit
. .--.
. - - - - . . .
. . . - - . . -
Page
- - .
1

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IEPA EXHIBIT
From:
"Sarah Rubenstein"
~sw~benstein@wulaw.wust~.edu~
To:
<jbrunsvold@dnrmail.sbte.il.us>. <henry.timothy@epa.gov>,
NO.&
- -
cron.burke@epa.state.il.us>
Date:
121912005 1:09:54 PM
Subject:
Comments lo U.S. Steel draft NPDES permit
~Itached~lease
find the comments of American Bottom Conservancy to U.S. Steel Granite City Works
drafl NPDES permit No. lL0000329, public notice No. BMB:04090101 .bah. ,Please direct any questions
or comments to Maxine Lipeles, Director. Interdisciplinary Environmental Clinic. (314) 935-5837, or
milipele@wulaw.wustl.edu.
-
Sarah Rubenstein
Clinic Attorney
Interdisciplinary
~nvironmenial Clinic
Washington University School of Law
Campus Box 1120
One Brookings Drive
St. Louis, MO 63130
314-935-6426
314-935-5171 (fax)
swrubenstein@wulaw.wustl.edu
CC:
<ka.abc@prairienet.org,
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
. - - .. - - - ... -. ...... .- .. -- - - . - .. .- .
. .
...
. .- - . . -. .- . .-
i
...
Marcia ~illhite'-
.
Fwd: timments to U.S. Steel draft NPDES permit
..
.
From:
Marcia Willhite
NO.
Ah
To:
Keller, Al; Kinsley. Blaine
Date:
12/9/2005
1:15:50 PM
Subject:
Fwd: Comments to U.S. Steel draft NPDES permit
Not sure who is the project engineer for this.
>>> "Sarah Rubenstein"
~swrubenstein@wulaw.wustl.edu~
12/9/2005 1:08 PM >>>
Attached please find the comments of American Bottom Conservancy to U.S. Steel Granite City Works
draft NPDES permit No. lL0000329, public notice No. BMB:04090101 .bah. Please direct any questions
or comments to Maxine Lipeles, Director, lnterdisciplinary Environmental Clinic, (314) 935-5837, or
mili~ele@wulaw.wustI.edu.
Sarah Rubenstein
Clinic Attorney
Interdisciplinary Environmental Clinic
Washington University School
of Law
Campus Box 1120
One Brookings Drive
St. Louis. MO 63130
314-935-6426
314-935-5171 (fax)
swrubenstein@wulaw.wusti.edu
Marcia T. Wlllhite
Chief
Bureau of Water
IL Environmental Protection Agency
Marcia.Willhite@epa.state.il.us
Phone: 2171782-1 654
Fax: 21
71782-5549
VIII
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
Fmm:
A1 Keller
To:
Page. Ken
Date:
Wed,
Dec 14.2005 1:13
PM
Subject:
Fwd: Re: Granite Cily Steele

Back to top

BEPA
EXHIBIT
NO.
A9
Ken, can you meet at 3 tomormw?
Blaine Kinsley 12/14/2005 11:58 AM >>>
I can't meet tomorrow until at least 3pm.
>>> Al Keller 12/14/05 11:37 AM >>>
Blaine is out this pm. Let's plan to meet tomorrow at 10:30 if you are available.
'
>>> Ken Page 12/14/2005 1058 AM >>>
Al,
I would like to meet with you and the people invoked in the NPDES permit for Granite City Steele. I would
like to discuss their
draft NPDES permit and the comments received from Washington University and
American Bottom Conservancy.
liank you.
Ken Page.
CC:
Kinsley, Blaine
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
ILLINOISENVIRONMENTAL PROTECTION AGENCY
1021
NORTH GUND
AVENUE
EAST, P.0. BOX
19276,
SPRINGFIELD, ~lllNO15
62794-9276
- (
21 7) 782-3397
JAMES
R.
THOMPSON
CENTER. 100
WEST
RANDOLPH,
SUITE
11-300, CHICAGO,
IL
60601
-
(3121 814-6026
Roo R. BLAGOIEVICH, GOVERNOR
DOUGLAS
P. con', DIRECTOR
Memorandum
Date:
February
8,2006
To:
Marcia Willhite
From:
Toby Freyert
.TF/S~L
Subject:
U.S. Steel-Granite City Works (NPDES Permit No. lL0000329)
This memo serves to recommend that the United States Steel; Granite City Works, (USSGCW) NPDES
(No. 1L0000329) be issued without any further delay. The reasons for this recommendation are that the issues
raised by environmental groups regarding permit limits and past violations are easily answered, and the overall
concerns for Horseshoe Lake have been and continue to be addressed in
303(d) discussions and hearings that
have opportunity for public participation. The comments do not provide any additional information the
Agency
would use for inclusion in the reissued permii.
The Agency received a comment letter from the American Bottoms Conservancy (ABC) et a1 before the close of
the Public Notice period, and continues to receive comments from The ABC (Kathy
Andria) and its associates at
the Washington University Civil
Justicdnterdisciplinary Environmental Clinic. Since only comments received
prior to the close of Public Notice can be considered
in determining the merits for granting ofpublic Hearing, the
discussion herein will focus on those points. However, it should be noted that responses to all comments and
.
questions will be generated and disseminated to the interested parties.
The concerns expressedby ABC in its letter to Marcia Willhite, dated January 18,2005 center on USSGCW's
discharge to Horseshoe Lake. Specifically, the comments cite impairments to the lake as detailed in the 303(d)
report and couple the impairments with the observation that Horseshoe Lake provides some sustenance to low
income persons in the area who consume fish
from the lake. The comments also take issue with the Draft
NPDES permit in that it allows for
an increase in the loading of lead and ammonia to the lake. With regard to the
lead concern, it should be noted that lead is not listed as an
impairment of Horseshoe Lake. The iisted fish
consumption concern is due to PCB's. In Addition, USSGCW does not use lead
in its processes or as a raw
material. A lead limit appears in
theNPDES permit solely due to Federal Categorical regulatory requirements
that would apply to any steel mill in that category. The permit limits for categorical steel mills are production
based. Therefore, any increase in production would necessitate a corresponding increase in limits for all
categorical parameters (including lead in this case). This creates a paper increase,
whichis confusing to citizens,
and advocacy groups. With regard to ammonia, the difference in the limits in the draft permit and the current
permit reflects a revision in the water quality criteria used to develop standards. The same flow was used to
calculate the limits in both the current permit and the draft. Back-sliding of the limits is not an issue due to the
compliance history of the facility. In addition, the comment letter discusses potential violations of the current
pennit. The Agency is aware of the issues and has taken action to resolve them.
As a final note, it should be mentioned that the American Bottoms Conservancy did
varticivate in a recent
hearing
rehardin%303(d) listed watdr bodies and did make spedific comments re kdin '~orsdshoe
Lake.
Ra~roao
-
4 2 Nonh
am
Street. Rockford. 11 61 103 -(815) 987.7760
.
DCI PWNB
-
951 1 W. Harrison St..
Ck
PlaiZlL 60016
-
1847) 294-4000
ELGIN
-
595
bulh
Stale. Elgin, IL 60123
-
18473 608-3131
.
PEOVJA- 5415 N. Univenity
3..
Peoria. IL 61 614
-
(309) 693.5463
Bvauv
Cf
hwo. holm
-
7620
N.
Univerriw St.. Peoria. IL 61614 -(3ffll693.5462
.
CHWAIGN
-
2125 SOYI~ First Sweet Champaign, 11 61820 -(I171 278-5800
Ssawcnrlo
-
4500 5. Sixlh Slreet Rd.. Sorinotield.lL 62706-12171 786-6892
.
Cow~rvtur
-
2009 Mall Street. Callinrville. IL 62234
-
16181 346-5120
I
. "~.
~~ ~~~ ~
-.~~~~-.
-... ~ -....-.
M*am~- 2309
W.
~ain
SL. Suite 116. Marion.
IL
62959
-
(6181 993-7200
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
-~ -. . ~. . . . - .. .. ~
.
IEPA EXHOBIT
:
From:
Blaine Kinsley
To:
Elzinga. Shenie
NO.
A I\
Date:
2/24/2006 1 :06:01 PM
Subject:
Re: Granite City Steel
Hello Sherrie.
Last time I saw it was in Toby's ofice with a note from Marcia.
Blaine
>>> Sherrie Elzinga 02/24/06 12:00 PM >>>
Blaine:
Any movement on Granite City Steel? Sherrie
XI
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
. - -.
. . . -- . . . . . . . .. - . .- . .- . - - . - - -. . . - - . .
. . . -. . . . . - . . - - . . -
.
Marcia
.
~iilhite
. . . .
- NPDES
. ... ..
permit
. . .
for
-. .
U.S.
--
Steel-Granite City
.
- . .
-.
Page
-
I i
From:
Marcia Willhite
NO.
A
la
To:
Scott. Doug
Date:
2/27/2006 3:20:05
PM
Subject:
NPDES permit for
U.S. Steel-Granite City
Doug, we received a hearing request on the renewal of this permit last year. Regrettably, due to staff
losses, a year has passed since we public noticed the permit. Yet this request
is still outstanding. We
would like to move forward to issue the permit and recommend that a meeting with the environmental
group be held instead of a public hearing.
American Bottoms Conservancy (Kathy
Andria, principal) requested the hearing due to concerns about
increased loading of pollutants to Horseshoe Lake. There will be no actual increase in loading--the limits
in the
draft renewal permit are different than the previous permit for reasons that are easily explained.
Since hearings are held at the discretion of the Director. I'm asking if you would be comfortable with us
denying the hearing request, bul having a meeting and issuing the permit as quickly as possible.
Marcia
T. Willhite
Chief
Bureau of Water
IL Environmental Protection Agency
Marcia.Willhite@epa.stale.il.us
Phone:
2171782-1654
Fax:
2171782-5549
CC:
Elzinga. Sherrie; Frevert, Toby: Killian. Bemie
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
,
,
Marcia
_.
~illhite
.
-
~e:
U.S. :
From:
To:
Date:
Subject:
Blaine Kinsley
Willhite. Marcia
31312006 1:14:05
PM
Re: U.S. Steel-Granite City
No.
A 13
Thanks. Will do.
>>> Marcia Willhite
03103106 12:41
PM >>>
Doug directed us to move ahead on issuing the permit. Blaine, follow Toby's approach of contacting
Kathy
Andria and ofiering to meet.
Marcia
T. Willhite
Chief
Bureau of Water
IL Environmental Protection Agency
~arcia.~illhite@eoa.state.il.~
Phone: 21
71782-1654
Fax:
21 71782-5549
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006

Back to top

HEW EXHIBIT
From:
Toby Frevert
To:
Elzinga, Sherrie
Date:
Fri. Mar 3.2000 2:49 PM
Subject:
Granite City Stel Permit
No.
A
lL\
Sherrie,
I
tried to call Helen Hawkins but only got a voice mail message. I will
by
again in an hour and leave a
message if I do not get a live person then.
Toby
XIV
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
~T&~~F~~~~~~~~---G~~~~~~~~cJ-~~s~~I-~~~~~~~<~
-2
,---
,
-,
---- -. .
. . -- -. ,
-
page-13

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IEPA
EXHIBIT
From:
Blaine Kinsley
@\5
1
To:
Elzinga, Sherrie; Frevert, Toby; Keller.
Al;
Willhite, Marcia
No.
Date:
Thu. Mar 9.2006
25%
PM .
Subject:
Granite
City
Steel meeting
There will be a meeting at the Agency on March 15th with Kathy
Andria todiscuss Horseshoe Lake. Frank
Holten State Park and issues regarding the Granite City Steel NPDES permit. I called Helen Hawkins
(Madison County Board Member) and invited her to the meeting, but she had to decline due to other
commitments. I agreed to send her a summary of the meeting and she saidshe was confident that we
would work things
out.
Blaine
Please let me know if there is something else that needs to be done in this matter.
I
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
I
.-.
Al
-
Keller
- P
_
- Fwd:
_____
--
--
... . ,
-. .-
--
-pa.-.
. . . . - .
.
-.
. .
Page
-
.
..
. -..
.. -
17
. . .
From:
Sanjay Sofat
To:
Keller, Al; Kinsley, Blaine
Date:
Thu. Mar 9.2006 323 PM
Subject:
Fwd:
AI
+ Blaine:
I received the attached email from Jenny who is working for ABC on this permit. Please take a look.
Thisemail, and any documents attached or included hereto, is a confidential attomeyclient, attorney
work product
and/or predecisional FOlAexempt document intended solely for the use of the individual to
whom it is addressed, and should be handled accordingly.
If you are not the intended recipient, be advised that you have received this e-mail in error and that any
use, dissemination, forwarding, printing or copying of this e-mail is strictly
prohibited. If you have received
this e-mail in error, please
notify:
Sanjay Sofat
Assistant Counsel
Illinois EPA
1021 N. Grand Ave. East
P.O. Box 19276
Springfield,
IL 62794-9276
(217) 782-5544
(217) 782-9807 (Fax)
E-mail address: Sanjay
.Sofat@epa.state:il.us
>>> "Jeremy HerwiW'
<jhherwitt~ulaw.wustl.edu~
31912006 3:25 PM >>>
Dear Sanjay,
Thank you for returning my call yesterday. To summarize briefly, the
Interdisciplinary Environmental Clinic at Washington University
represents the American Bottoms Conservancy
("ABC"). ABC is concerned
with draft NPDES permit No. 110000329 for U.S. Steel
- Granite City
works.
We understand that currently this permit
Is pending final'approval with
the director. ABC's primary concern at this time is that the linal
permit will issue without the opportunity for a public hearing. ABC has
submitted several requests to
IEPA to grant a public hearing on this
permit that have not yet been honored as of this date. Furthermore, a
number of other citizen groups have signed on to comments submitted by
ABC
--
relatino.to
--
the ~ublic hearino reouest Based on IEPA reoulations.
specifically section 309.115(a)(lj of iitle 35. Subtitle C. chapter I,
we feel that there has been a sufficiently demonstrated public interest
to warrant a hearing on thls matter.
ABC kindly requests that your office grant a public hearing prior to the
issuance of a final permit
I have attached the comments recently
submitted by ABC on the draft 303(d) Integrated Report, as well as two
sets
~ ~~~
of
~
comments
--
submitted bv ABC on the draft NPDES
Dermit for vour
additional consideration. We iope these comments will p'rovidefurthkr
insight to our position on U.S. Steel and Horseshoe Lake, the affected
water body. Your attention to these
conwms is greatly appreciated.
Please do not hesitate to contact me if you require additional
,
XVI
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
information or have further questions. Thank you.
Regards.
Jeremy
Hewin
Jeremy Hewin
Washington University School of Law
(314) 239-9466
~~ilto:JHHewid~ulaw.wusll.edu>
JHHewitt(awulaw.wusI.edu
XVII
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
From:
.
"Peter Goode"
<pwgoode@wulaw.wustl.edu~
To:
"Blaine Kinslef
<Blaine.Kinsley@epa.state.il.us>
NO.&
Date:
311012006 2:38:15 PM
Subject:
Re: Fwd:
U.S..Steel -Granite City Works NPDES permit
Blaine.
No, I will not be able to make the meeting on the 15th.
I think we
will have
one'of our student consultants at the meeting.
Thanks.
Peter
Peter
Goode. P.E.
Environmental Engineer
Interdisciplinary Environmental Clinic
Washington University in St. Louis
.
314-935-4507
pwgoode@wutaw.wustl.edu
>>> "Blaine Kinsley"
<Blaine.Kinsley@epa.state.il.us>
3/1012006 2:19:24
PM >?>
Peter.
Thanks for the update.
I did gel coples of this information from
Sanjay: Will you be coming to the meeting here on the 15th?
Blaine
>>>"Peter Goode"
~pwgoode@wulaw.wustl.edu~.03/10/06
8:13 AM >>>
Blaine.
Just wanted to let you know
that we that we have. been pursuing the
public hearing issue on Granite
Cily Steel with Sanjay. Below is an
email from one of our student attorneys to him.
Thanks.
Peter
Pete'r Goode, P.E.
Environmental Engineer
lnterdisciplinaryEnvironmental
Clinic
Washington, University in
St..Louis
314-935-4507
pwgoode@wulaw.wustl.edu
>>> "Jeremy Herwitl'
<jhherwitt@wulaw.wustl.edu>
31912006 6:13 PM >>>
I apologize if you. received this message twice.
1
was unsure:that it
went through. the first time.
Dear
Sanjay.
Thank you for returning my call yeslerday. To summarize briefly, the
Interdisciplinary Environmental Clinic at Washington University
'represents the American Bottoms Conservancy
('ABC).
ABC is concerned
with drafl NPDES permit No. lL0000329 fofU.S. Steel -.Granite City
XVIII
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
Works.
We understand that currently this permit is pending final approval
.
with
the director.
ABC's primary concern,at this time is. that the. final
permit
will issue without the opportunity for a public hearing. .ABC
has
submitted several requests to
IEPA to grant a public hearing on this
permit that have not
yet been honored as of this date. Furthermore, a
number of other ciliien. groups have signed onto comments submitted by
ABC relating to the public hearing request.. Based on
IEPA
regulations,
specifically Section 309.1
15(a)(l) of Title 35. Subtitle C, Chapter I.
we feel that there has, been a sufficiently demonstrated public
interest
to warrant a hearing on this. matter.
ABC kindly requests that your oMce grant a public hearing prior.to
the '
issuance of a final permit.. I have attached thecomments recently
submitted by ABC on. the draft
303(d) Integrated Report, as well as two
sets of comments submitted by ABC on the draft NPDES permit, for your
additional consideration. We hope these comments will provide
further
insight to our position on U.S. Steel.'and. Horseshoe Lake,. the affected
water body. Your attention to these concerns is. greatly appreciated.
. Pleasedo not hesitate tocontact me if you require additional
information or have further questions. Thank
you:
Regards,
Jeremy
Herwilt
Jeremy Herwilt
Washinglon University School. of Law
(31 4) 239-9466
<mailto:JHHerwitl@wulaw.wustl.edu> JHHerwitt@wulaw.wusU.edu
XIX
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
Fmm:
Ken Page
IEPA
EXHIBIT
To:
Kathy Andria
Date:
Tue, Mar 14.2006 3:18 PM
NO.
6
\R
Subject:.
Re: Horseshoe Lake EJ meeting
Kathy,
As discussed this was an EJ meeting to discuss the subsistence fishing issues at Horseshoe Lake that
you raised.
I will infon everyone of your decision. Thank you.
Kenneth L. Page, Manager
Office of Compliance Assistance and Environmental Justice
Illinois EPA
1021
N. Grand Ave. East
P.0.Box 19276
Springfield, Illinois 62794-9276
217-524-1284
>>>"Kathy Andria" <abc@prairienetorg> 3/14/2006 1:24 PM >>>
. Ken: I regret to say we will be unable to come to Springfield for this
meeting. Some of the people
from the community were unable to attend on
such short notice because of scheduling conflicts. Others felt the
meeting should be held locally
so that more people fmm the wmmunity
wuld attend. They also thought the Agency should hold a public hearing
on the Granite City Steel NPDES discharge
penit into Horseshoe Lake and
that this meeting muld be viewed as an attempt
to circumvent that. We
are unsure as to the status of the NPDES and our repeated requests for a
public hearing.
Could you help to clarify the purpose of the meeting you are proposing?
I
do appreciate the Agency's desire to address subsistence fishing at
Horseshoe Lake and Frank Holten State Park. But, as you are well aware,
we need to
be inclusive of those most affected. Thank you. Kathy
> Ken Page, Bruce Yurdin,
Al
Keller and Tom Homshaw. Maybe Ron Burke and
other staff
hom bureau of water. Thanks.
>
> KPage.
>
>
>>>> "Kathy Andria" <abc@prairienet.org> 3/7/2006 10:47 AM >>>
>Thanks, Ken, for scheduling the meeting. I have forwarded it on to olhers
>working on this issue. Who all from the Agency will be at the meeting?
> I
>would also like to inciude Frank Holten State Park in the discussion. Kathy
>> Kathy,
>> The Agency has scheduled the Environmental Justice meeting for
>>Wednesday, March 15th at
10:OO am here at Headquarters in
.
> Springfield.
>> We will discuss subsistence fishing at Horseshoe Lake. Hopefully
> this
>> time works for you. This Is the time that I could bring the key
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
1
~~~~ie~~~H~~h~~k^e-€~~i~~ting
-
-
. .- . . -. . ..
Pa---
g!%2]
i
>
people
>>
in the Agency together. Please let me know if there are any
>
problems.
>>
Thank you.
>>
Kenneth L. Page, Manager
>>
Office of Compliance Assistance and Environmental Justice
>>
Illinois EPA
>>
1021 N. Grand Ave. East
?>
P.0.Box 19276
>>
Springfield, Illinois 62794-9276
>>
217-524-1284
>
XXI
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
Fmm:
Ken Page
To:
Al Kellw; Bruce Yurdin; Ron Burke; Thomas Homshaw
NO.
A 1s
Date:
Tue, Mar 14,2006 321 PM
Subject:
Fwd: Re: Horseshoe Lake EJ meeting
Please
be
advised that Kathy Andria has canceled the meeting at the last minute (not uncommon for her).
I guess they are upset with the Agency's decision on the NDPES permit I will note that the Environmental
Justice Officer extended a meeting with her to discuss her
EJ issues regarding Horseshoe Lake. Thanks
to each of you for the support.
KPage.
>>> "Kathy Andria" <abc@prairienet.org> 3/14/2606 1:24 PM >>>
Ken: I regret to say we will be unable to come to Springfield for this
meeting. Some of the people from the community were unable to attend on
such short notice because of scheduling conflicts.
Others felt the
meeting should
be
held locally so that more people from the community
could attend. They also thought the Agency should hold a public hearing
on the Granite City Steel NPDES discharge permit into
Horseshoe Lake and
that this meeting could be viewed as an attempt to circumvent that We
are unsure as to the status of the NPDES and our repeated requests for a
public hearing.
Could you help to clarify the purpose of the meeting you are proposing?
I
do appreciate the Agency's desire to address subsistence fishing at
Horseshoe Lake and Frank Holten State Park. But, as you are well aware.
we need to
be inclusive of those most affected. Thank you. Kathy
> Ken Page, Bruce Yurdin, Al Keller and Tom Homshaw. Maybe Ron Burke and
other staff fmm bureau of water. Thanks.
>
> KPage.
>
>
>>>> "Kathy Andria" <abc@orairienet.org> 3/7/2006 10:47 AM >>>
>Thanks, Ken, for scheduling the meeting. I have forwarded it on to others
> working on this issue. Who
all
from the Agency will be
al
the meeting?
> I
>would also like to include Frank Holten State Park in the discussion. Kathy
>> Kathy.
>>The Agency has scheduled the Environmental Justice meeting for
>> Wednesday, March 15th at 10:OO am here at Headquarters in
> Springfield.
>> We will discuss subsistence Ftshing at Horseshoe Lake. Hopefully
>this
>> time works for you. This is the time that I could bring the key
> people
>> in the Agency together. Please let me know if there are any
> problems.
>> Thank you.
>> Kenneth L. Page, Manager
>> Office of Compliance Assistance and Environmental Justice
>> Illinois EPA
>> 1021 N. Grand Ave. East
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
1
Ai'~ill~F~d~~R~~~h~~ak~~Ej~~eeting
- . - -. - - ---. . . . . . . . - -
. . - -.---.-
, -- - - - - - - - -
Page I
Fmm:
Al Keller
To:
Kinsley. Blaine
Date:
Tue, Mar 14.2006
4:01 PM
NO. A
a?
Subject: .
Fwd: Re: Horseshoe Lake EJ meeting
fyi, we need to send the letters to this group
>>> "Kathy ~ndria" <abc@prairienet.org> 3/14/2006 1:24 PM >>>
Ken: I regret to say we will be unable to come to Springfield for this
meeting. Some of the people from the community were unable to attend on
such short notice because of scheduling conflicts. Others
felt the
meeting should be held locally so that more people
from the community
could attend. They also thought the Agency should hold a public hearing
on the Granite
City
Steel NPDES discharge permit into Horseshoe Lake and
that this meeting could be viewed as an attempt to circumvent that. We
are unsure as to the status of the NPDES and our repeated requests for a
public hearing.
Could you help to clarify the purpose of the meeting you are proposing? I
do appreciate the Agency's desire to address subsistence fishing at
Horseshoe Lake and Frank Holten State Park. But, as you are well aware,
we need to
be inclusive of those most affected. Thank you. Kathy
> Ken Page, Bruce Yurdin,
Al
Keller and Tom Homshaw. -Maybe Ron Burke and
other staff from bureau of water. Thanks.
>
> KPage.
>
>
>>>> "Kathy Andria" <abcfE?~rairienet.orq
3/7/2006 10:47 AM >>>
>Thanks, Ken, for scheduling the meeting. I have forwarded it on to others
>working on
this
issue. Who all from the Agency will be at the meeting?
> I
> would also like to include Frank Holten State Park in Me discussion. Kathy
>> Kathy,
>>The Agency has scheduled the Environmental Justice meeting for
>>Wednesday. March
15th at 10:OO am here at Headquarters in
> Springfield.
>> We will discuss subsistence fishing at Horseshoe Lake. Hopefully
> this
>> time works for you. This is the time that I could bring the key
> people
>> in the Agency together. Please let me know if there are any
> problems.
>> Thank you.
>> Kenneth L. Page, Manager
>> Office of Compliance Assistance and Environmental Justice
>> Illinois EPA
>> 1021 N. Grand Ave. East
>> P.0.Box 19276
>> Springfield, Illinois 62794-9276
>> 217-524-1284
>
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
From:
"Peter Goode"
<pwgoode@wulaw.wustl.edu>
To:
"Blaine Kinsley
<Blaine.Kinsley@epa.state.il.us>
~o.Ad\
Date:
312012006 10:02:18 AM
Subject:
,
Re: Granite City Steel Permit
Thanks. Blaine.
I appreciate it.
Peter
Peter
Goode,
P.E.
Environmental Engineer
Interdisciplinary Environmental Clinic
Washington University in St. Louis
31
4-935-4507
pwgoode@wulaw.wusll.edu
>>> "Blaine Kinslev
cBlaine.Kinsley@epa.state.il.us>
312012006 953 AM
>>>
Peter,
I was waiting to send it to youat the same time as the response to
the
December letter. It's just taking me a little longer than
I
anticipated. I'm hoping lo have the response done today, but if for
some reason
I don't, I'll send. the permit anyway. Sorryfor the
delay.
Blaine
>>> "Peler. Goode"
<pwgoode@wulaw.wustl.edu>
03120106 9:38 AM >>>
Blaine.
Any chance you could send me the permit today?
Thanks for your help.
L
Peter
Peler
Goode, P.E.
Environmental Engineer
Interdisciplinary Environmental
Clinic
Washington University in St. Louis
31
4-935-4507
pwgoode@wulaw.wustl.edu
>>> "Blaine Kinsler
<Blaine.Kinsley@epa.slate.il.us>
311412006 10:26
AM >>>
Sure. I'm also drafting up a response letter Ulat I hope to have done
today.
Blaine
>>>"Peter Goode'
<pwgoode@wulaw.wusll.edu>
03113106 10:15 AM >>>
Blaine.
1,understand that the final NPDES Permit for Granite City Steel was
issued last week. .Could you
email me a copy of the final permit?
Thanks.
Peter
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
Peter Goode, P.E.
Environmenlal Engineer
Interdisciplinary Environmenlal Clinic
Washinglon Universily in
St. Louis
314-935-4507
pwgoode@wulaw.wustl.edu
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
-..
.- - ---- -- - - . ..
-
Page I
!I

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lEPA EXHIIT
From:
AI Keller
No.
Aaa
To:
Kinsley. Blaine; Sofat, Sanjay
Date:
Fri, Mar 24,2006 3:29
PM
Subject:
Fwd: Re: NPDES Permit for US Steel
- Granite City Works
The responses have been sent today.
>>> Sanjay Sotat 312412006 2:40 PM >>>
MI
This e-mail, and any documents attached or included hereto, is a confidential attorneyzlient, attorney
work product and/or
predecisional FOlAexempt document intended solely for the use of the individual to
whom it is addressed, and should
be handled accordingly.
If you are not the
intended'recipienf be advised that you have received this mail in error and that any
use, dissemination.
fotwarding, printing or copying of this e-mail is strictly prohibited. If you have received
this e-mail in error, please notify:
Sanjay
Sofat
Assistant Counsel
Illinois EPA
1021 N. Grand Ave. East
P.O. Box 19276
Springfield.
IL 62794-9276
(217) 782-5544
(217) 782-9807 (Fax)
E-mail address:
~aniav.~ofatm)e~a.state.il.us
>>> "Maxine Lipeles"
~mili~ele@wulaw.wusti,edu>
3/24/2006 239 PM >>>
Sanjay,
Thanks for your attempt to get us more info.
I just sent the attached letter. Please stay in touch.
Maxine
Maxine
I. Lipeles
Director, Interdisciplinary Environmental Clinic
Wqshington University in St. Lwis
Campus Box 1120
One Brookings Drive
St Louis, MO
83130-4899
(314) 935-5837 (phone)
.
(314) 935-5171 (fax)
milicale@wulaw.wustl.edu
>>> "Sanjay soil'
<Saniav.Sofat&w.state.iI.us>
03/23/06 635 PM >>>
Dear Ms. Maxine.
Sony, I could not get back to you earlier. I couldn't find out much
other than that Blaine Kinsley is working on the
ABC's comments and is
expected to have them finished soon. Today Blaine was in'chicago on a
work related matter, he will be in his office tomorrow.
Thank you
Sanjay
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
,
A[K6
llFrTF $&..
RB:NPDESSPa*ititfo~."SSSii&I
.-GraniiQ
CC~woor~sss.sss.sssss'-
--
. . . . -
- --
-- ----- - Page - -.
211
This e-mail, and any documents attached or included hereto, is a
confidential
attorneyclient, attorney work product andlor
predecisional FOlA-exempt document intended solely for the use of the
individual to whom it is addressed, and should be handled accordingly.
If you are not the intended recipient, be advised that you have received
this e-mail in error and that any use. dissemination, forwarding,
printing or copying of this e-mail is strictly
prohibited. If you have
received this e-mail in error, please notify:
.
Sanjay Sofat
Assistant Counsel
Illinois EPA
1021 N. Grand Ave. East
P.O. Box 19276
Springfield.
lL 62794-9276
(21 7) 782-5544
(217) 782-9807 (Fax)
E-mail address:
Saniav.SofatfOe~a.state.il.us
>>> "Maxine Lipeles"
<mili~ele@wulaw.wustl.edu>
03120/06 520 PM >>>
Dear Mr. Sofat:
.
The reason for this e-mail is to inquire as to the final date on which
the
abovereferenced NPDES permit has been or will be issued. Here is
the basis of our confusion:
By e-mail dated Friday. March 10. 2006, you kindly notified Jeremy
Herwitt of our Interdisciplinary Environmental Clinic, representing
American
Bottom Conservancy (ABC), thqt you had learned that the IEPA
granted the abaove-referenced permit on March
8. 2006. You provided
thatanswer in respo'nse to Jeremy's inquiry as to whether the IEPA would
be holding a public hearing, as had been requested, prior to permit
issuance.
On Monday, March 13. Peter Goode of our Clinic contacted Blaine Kinsley,
the permit writer,
Lo
ask for a copy of the permit On Monday, March 20,
Mr. Kinsley faxed us a (barely-legible) copy of the permit. He also
indicated to Mr.
Goode that the IEPA has not yet completed its Response
to Comments.
The permit states that it
wasissued on March 8,2006. However,
although ABC submitted two
sets of comments on the draft permit, ABC did
not receive the permit until March 20, 2006. Moreover. even at this
point we do not have
and do not know when we will hae the Response
to Comments, withoutwhich it is difficult to evaluate the merits of a
possible appeal.
We would appreciate it if the IEPA could clarify
when is the "final
agency action" regarding the issuance of the above-referenced permit for
purposes of triggering the appeal clock. Further, we would suggest that
in this case the final agency action should not be until the public,
particularly those
members of the public who commented on the permit,
receives both the permit AND the
IEPA's Response to Comments.
Thank you for your assistance.
XXVIII
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
~~~,~~ll~~~d~~~~~N~~~s~Pe~f~Us~St~i~~~f~c;l~w~k-5--'~-'-
- - - -- - -
Page
. -
3il
- .
Sincerely yours,
Maxine Lipeles
Maxine I. Lipeles
Director, interdisciplinary Environmental Clinic
Washington University in
St Louis
Campus Box
1120
One Brookings Drive
St Louis, MO 63130-4899
(314) 935-5837
(phone)
(314) 935-5171 (fax)
mili~ele~law.wustl.edu
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
Frum:
Marcia Wilhite
NO.
Aa3
To:
Frevert. Toby; Tonsor. Connie
Date:
Tue, Mar 28,2006
1052
AM
Subject:
Re: Granite City Steel Permit - Wash U School of Law letter
Let's do the latter. IF DLC can find a way they feel comfortable with
to take the procedural issue off the
table,
I suspect that is what Doug would advise, anyway.
Marcia T.
Wllhite
Chief
Bureau of Water
IL Environmental protection Agency
Marcia.Wllhite@epa.state.il.us
Phone: 217R82-1654
Fax: 21 7R82-5549
*>> Toby Frevert
3/28/2006
10:23 AM >>>
I spoke Gth Maxine Lipeles (Wash U. School of law) this morning regarding her letter to Director Scot
asking that we "re-issue" this
perml because the response letter to Kathy Andrea's comments were not
issued until several days
aRer the actual permit issuance date: She was very concerned that the delay
puts her and her client at a disadvantage because it cuts into the
35 day time allowance for filing an
appeal.
Since she has not received our response letter to Kathy yet,
I committed to faxing
it
and told her I wwld
consun our attorneys regarding options to address her concem over the time lapse between permit
issuance and response issuance.
It was clearly obvious to me that she had no intention to dmp this issue.
I suggest we find a way to give
her a full 35 days for review and possible appeal. She also mentioned addition concerns she has over
the permit that were not raise during the comment period but submitted under separate
letter several
months after close of the comment period. Response to that letter is still under preparation.
My suspicion is that it is very likely they will find something to appeal but
I would like to take the procedural
issue off the table. We should be able to defend our actions on the substantive issues so lets find a way to
take the procedural complaint off the
Iable.
Connie,
I want to contact the steel company, get their concurrence to either an extension of the allowed time
period or somehow actually reissue the permit so the
35 day allowance gets re-started. I want to give her
an answer ASAP,
.
so
.
lease let me know what vou think.
Marcia,
Do we need
to consun the front office and get
-
their Ok or merely handle this and notify them of our
actions?
Toby
Keller, Al; Kinsley. Blaine; Sofat, Sanjay
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
1
Page 1 1 ,
From:
PJ Gebhardt
NO.
A
a4
To:
Kinsley, Blaine
Date:
3/29/2006
3:07:09 PM
Subject:
U.S. Steel Corp-Granite City Works lL0000329
Hi Blaine.
Is there any way you can
fix the language in Special Condition #7 to slate the due date for the monthly
DMR reports? Currently, the only due dates listed in Special Condition
#7
are for Me one semi annual
parameter
(Tetrachloroethylene). I told Victoria to talk to you about this. She did not know if this was
going to be changed or not. Thanks.
Victoria
& Mike.
I have this permit at my desk. We are to wait for the reissued permit before going any further on it. Blaine
will check with Toby about the dates we have in PCS. Thanks.
CC:
Garretson. Mike; McKinnon. Victoria
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
7
Page
1 1

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lEPa EXHIBIT
From:
Blaine Kinsley
To:
Frevert. Toby; Keller.
A1
Date:
3/29/2008 3:11:47 PM
Subject:
Granite City Steel
NO.
9
as'
I left a message for Carl Cannon regarding our. earlier meeting about revoking and reissuing
the
NPDES
permit and the reasons for that action.
I also spoke to compliance about the PCS issue. What
1
was told was that they had started working with
some of the
oulfalls. but that nothing had been finalized in PCS as yet. I told PJ that the effective date
would remain
the same as the permit issued March 8, but that the issue date would change. Did you want
CAS to hold off of any further work on entering the
penit into PCS?
Blaine
CC
:
Garretson, Mike; Gebhardt. PJ
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
I
.
Toby
-. . -
.- Frevert
-. -
- Re:
-
Granite
- -
CisGI'-
. .
-.
- - . - . -- . - . . .
' '
---..~a9e.%l

Back to top

EPA
EX=
From:
Toby Frevert
No.
A
aco
To:
Kinsley, Blaine
Date:
Wed, Mar 29,2006
338
PM
'
Subject:
Re: Granite City Steel
It is probably wise to asked them to set it aside for a day or two. I hope we can get this resolved this week.
Pmceed with finalizing th other response letter and whatever cover letter is necessary to reissue under a
new date (hopefully
3-31).
Thanks,
Toby
>>> Blaine Kinsley 03/29/06
311
PM >>>
I left a message for Carl Cannon regarding our earlier meeting about revoking and reissuing the NPDES
permit and the reasons for that action.
I also spoke to compliance about the PCS issue. What I was told was that they had started working with
some of the
outfalls, but that nothing had been finalized in PCS as yet. I told PJ that the effective date
would remain the same as the permit issued March
8, but that the issuedate would change. Did you want
CAS to hold
off of any further work on entering the permit into PCS?
Blaine
XXXIII
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
)~oel Johnson
-
Fwd: Re: Granite City Steel
Page 1
(

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From:
Blaine Kinsley
NO.
Garretson, Mike; Gebhardt, PJ
A
a7
To:
Date:
312912006 3:55:10 PM
Subject:
Fwd: Re: Granite City Steel
As I suspected. Toby wants to hold off on any more work on Ule permit for at least the rest of the week.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
(
).loel Johnson -Granite City Steel
Page 1
From:
Blaine Kinsley
To:
Frevert. Toby. Tonsor. Connie
Date:
313012006 3:54:51 PM
Subject:
Granite City Steel
NO.
A
a%
here's the lener
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
From:
Blaine Kinsley
To:
Cox, Karen
Date:
313112006
11:57:20AM
.Karen.
.
after lunch.
Dear Ms. Lipeles.
Thank you for
he letter regarding the recent re-issuance of the NPDES permit (lL0000329) for the
U.S.Steel facility in Granite City. Due to internal workload and operational complications, issuance of
response to public comments for lhis permit was delayed two weeks beyond the issuance date for the
permit. This is a departure from our
normal operating practices and as you correctly pointed out, is
contrary to state and. federal procedural requirements for the NPDES program.
. .
TheAgency has subsequently provided full response.to all timely filed coinments and transmitted them to
the interested parties. To remedy. this departure from applicable procedures, we reissued the permit on
March 31, 2006. All comments on the record were answered prior to
that date and the oficial date of
request.
Should you
haveany additional questions or comments, please. feel free. to contact Toby Frevert in our
.
Division of water Pollution Control. His telephone number is 21 7-558-2012..
Sincerely,
.
.
Doug Scott
.
>>>.Toby Frevert 03/31/0610:21.AM
>>>
.
,
Thanks,
Toby
Dear Ms.
Lipeles,
!
Thank. you for the letfer regarding the recent re-issuance ofthe NPDES permit (ILOO
..... )
for the U.S.Stee1
facility in Granite City. Due to internal workload and operational complications, issuance of response to
.
public comments for this permif was delayed several days beyond the issuance date for the permit. This is
i I
a departure from our normal operating practices and as you correctly pointed out, is contrary to slate and
I
federal proceduial requirements for the NPDES prugram.
I
The Agency has subsequently provided full response to all timely #led comments and transmitted
Ulem
to
.
the interestedparties. To remedy this departure from applicable procedures, we reissued the permit on
March 31, 2006. All comments on the record were answered prior to that date and the
ofricial date 01
issuance for permit #/LOO..
..
for purposes of establishing the 35 day third pafly appeal timeframe is
March31; 2006.
Once again thank you for calling
lhis matter to my attention and I trust our action has honored your
request.
Should you have any additional questions or comments, pleese feel free to contact Toby Frevert
in our
Division of water Pollution Control. His telephone number is 21
7-558-2012.
XXXVI
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006
Sincerely,
~oug
$con
CC:
Frevert, Toby
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 6, 2006

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