BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
CLERK'S OFFICE
NOV 1) 2006
CITY OF GENEVA,
STATE OF ILLINOIS
)
Pollution Control Board
Petitioner,
)
v.
)
PCB
61
Water -
Ninety Day Extension
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent .
)
NOTICE
Dorothy Gunn, Clerk
Roy Harsch
Pollution Control Board
GARDON, CARTON & DOUGLAS
100 West Randolph Street
191 N
. Wacker Drive
Suite 11-500
Suite 3700
Chicago, Illinois 60601
Chicago, Illinois 60606-1698
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the Pollution Control
Board a
REQUEST FOR NINETY DAY EXTENSION OF APPEAL PERIOD
of the Illinois
Environmental Protection Agency, a copy of which is herewith served upon you
.
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
BySanjay
: K
. Sofat
°~ .,k
Assistant Counsel and Special Assistant Attorney General
Division of Legal Counsel
Dated
: November 15, 2006
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
(217) 782-5544
THIS FILING PRINTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARItLERK'S
RECEIVEDOFFICE
NOV 1 7 2006
CITY OF GENEVA,
STATE OF ILLINOIS
)
Pollution Control Board
Petitioner,
)
V .
>
PCB
Water - Ninety Day Extension
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent .
)
REQUEST FOR NINETY DAY EXTENSION
OF APPEAL PERIOD
NOW COMES Respondent, Illinois Environmental Protection Agency ("Illinois EPA"), by and
through one of its attorney, Sanjay K
. Sofat, Assistant Counsel and Special Assistant Attorney General,
and Petitioner, CITY OF GENEVA, located in the City of Geneva in Kane County, Illinois,
("Petitioner"), and pursuant to Section 40(a)(1) of the Illinois Environmental Protection Act
("Act")
(415 ILCS 5/40(a)(1)), respectfully requests the Illinois Pollution Control Board ("Illinois PCB") to
grant an extension of the thirty-five (35) day period for petitioning for a Board hearing in this matter
. In
support thereof, the Illinois EPA respectfully states
:
1 .
On or about October 13, 2006, the Illinois EPA issued a final determination on the
Petitioner's NPDES permit IL0020087
. (See attached Exhibit A)
2 .
On or about November 9, 2006, Petitioner made a written request to the Illinois EPA
asking that the thirty-five (35) day period for a hearing be extended to ninety days
(90).
(See attached Exhibit B)
3 .
The additional time requested by the parties may eliminate the need for a hearing in this
matter, or in the alternative, allow the parties to identify and limit the issues to be
2
addressed at the Board hearing that may be necessary to resolve this matter .
4.
Counsel for Petitioner has reviewed the request for the extension of the thirty-five (35)
day period and agrees with the contents of the request
.
WHEREFORE the parties respectfully request that the Illinois PCB, in the interest of
administrative and judicial economy, grant this request for extension of the thirty-five (35) day
appeal period for an additional period of time not to exceed ninety (90) days .
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY, Respondent
3
BySanjay
: K
. Sofat
Assistant Counsel and Special Assistant Attorney
General
1021 North Grand Avenue East
P .O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
THIS FILING PRINTED ON RECYCLED PAPER
STATE OF ILLINOIS
)
SS
COUNTY OF SANGAMON
)
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the attached
REQUEST FOR NINETY
DAY EXTENSION OF APPEAL PERIOD
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, Illinois 60601
SUBSCRlj3ED AND SWORN BEFORE ME
THIS
I
-~"
DAY OF November, 2006 .
THIS FILING PRINTED ON RECYCLED PAPER
4
Roy Harsch
GARDON, CARTON & DOUGLAS
191 N. Wacker Drive
Suite 3700
Chicago, Illinois 60606-1698
Ad r
A
"WA
,
sa . a
oaaeaaaaa~aaoaea
`'
NOTARY
BRENDA
POeIc,STATE
BOENNER
OFILLINOIS
a
MY COMMISSION EXPIRES 11-3-2009
::
217/782-0610
October 13, 2006
City
1800
of
South
GenevaStreet
Geneva, Illinois 60134
Re:
City of Geneva
Geneva
- W W TP
NPDES Permit No . IL0020087
Final Permit
Gentlemen :
Attached is the final NPDES Permit for your discharge . The Permit as issued covers discharge limitations,
monitoring, and reporting requirements . Failure to meet any portion of the Permit could result in civil and/or
criminal penalties . The Illinois Environmental Protection Agency is ready and willing to assist you in
interpreting any of the conditions of the Permit as they relate specifically to your discharge
.
Please note that we have removed the chlorine monitoring requirement from Special Condition 9, because the
chlorine monitoring is the same as in Special Condition 8 .
The Agency has begun a program allowing the submittal of electronic Discharge Monitoring Reports
(eDMRs) instead of paper Discharge Monitoring Reports (DMRs)
. If you are interested in eDMRs, more
information can be found on the Agency website, http://cpa.state.il.us/water/edmr/index .htrnl. If your facility
is not registered in the eDMR program, a supply of preprinted paper DMR Forms for your facility will be sent
to
instructions
you prior
will
to the
accompany
initiation
the
of
preprinted
DMR reporting
DMRs upon
under
their
the
arrivalreissued .
permit . Additional information and
The attached Permit is effective as of the date indicated on the first page of the Permit
. Until the effective date
of
You
any
have
re-issued
the right
Permit,
to appeal
the limitations
any condition
and
of
conditions
the Permit
of
to
the
the
previously-issued
Illinois Pollution
Permit
Control
remain
Board
in full
within
effecta
35
.
day period following the issuance date .
Should you have questions concerning the Permit, please contact Abel A
. Haile at the telephone number
indicated above .
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
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
. BLAGO)EVICH, GOVERNOR
DOUGLAS P . SCOTT, DIRECTOR
Alan
Manager,
Keller,
Permit
P.E
.
Section
Division of Water Pollution Control
SAK:AAH:06061404 .bah
Attachment: Final Permit
cc:
Records
RocRIOeo-430
Compliance
~)s aine~s
Assurance
Re io
Section
gm Veer, oc
o rd.I L (A103-18151987-7760 •
DVSPIAIMS-9511 W .HamsonSt .,DesPlaines,IL60016-(747)294-4000
Eu, - ,
Sf1th State, Elgin, IL 60123 - (847) 608-3131
PIORIA 5415 N . University SL,
Pnxia, IL 61614- ( .309) 693-5463
RukIArE or LANs - Pins NIl G0 N . University SI-, Peoria, IL 61614 -(309) 693-5462 •
CIIANE1'AIGN- 2125 South First Street, Champaign, IL 61820-(217) 2711-5800
Sruwanl n-4500 S . Sixth Slreel RcL, Springfield, II . 62706-(217)7H668')_)
•
CouINSVILLI -2009 Mall Street, Cnllinoville, IL 022t4-(618)346S120
MARION- 2319 W . Main St ., Suite 116, Marion, 11 . 629 59
- (618)99372(11)
NPUES Permit No . ILUU2UU8I
Illinois Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand Avenue East
In compliance with the provisions of the Illinois Environmental Protection Act, Title 35 of the III . Adm. Code, Subtitle C, Chapter I, and the
Clean Water Act (CWA), the above-named Per mittee 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 (IEPA) not
later than 180 days prior to the expiration date .
SAK
:AAH
:06061404
.bah
Alan Kel er, P.E
.
Manager, Permit Section
Division of Water Pollution Control
Post Office Box 19276
Springfield, Illinois 62794-9276
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
Reissued (NPDES) Permit
Expiration Date : October 31, 2011
Issue Date
: October - 13, 2006
Effective Date : November 1,
2006
Name and Address of Permittee :
City of Geneva
1800 South Street
Geneva, Illinois 60134
Receiving Waters : Fox River
Facility Name and Address :
Geneva - W WTP
602 Crissey Avenue
Geneva, Illinois 60134
(Kane County)
rage z
NPDES Permit No . IL0020087
Effluent Limitations, Monitorna . and Renortinq
FINAL
Discharge Number(s) and Name(s) :
001 STP Outfall
Load limits computed based on a design average flow (DAF) of 5.0
MGD (design maximum flow (DMF) of 12
.5 MGD) .
Excess flow facilities (it applicable) shall not
be utilized until the main treatment facility is receiving
its maximum practical
flow .
From the effective date of this Permit until the
expiration date, the effluent of the above discharge(s)
shall be monitored and limited at all
times as follows :
'Load limits based on design maximum
flow shall apply only when flow exceeds design average
flow. The load limits for CBOD
S and
Suspended Solids are computed based on design average
flow of 4.0
MGD and design maximum flow of 8 .0 MGD
.
"Carbonaceous BODS (CBODS )
testing shall be in accordance with 40 CFR 136 .
"'See Special Condition 9 .
****See Special Condition 10 .
Flow shall be reported on the Discharge Monitoring Report (DMR) as monthly average and daily maximum
.
Fecal Coliform shall be reported on the DMR as daily maximum.
pH shall be reported on the DMR as a minimum and a maximum
.
Dissolved oxygen shall be reported on DMR as minimum
.
LOAD LIMITS lbs/day
CONCENTRATION
OAF (DMFr
LIMITS MG/L
Parameter
Monthly
Weekly
Daily
Monthly
Weekly
Daily
Average
Average
Maximum Average Average
Maximum
Sample
Frequency
Sample
Type
Flow (MOD)
Continuous
CBODS '
667 (1334) 1334 (2669)
20
40
2 Days/Week
Composite
Suspended Solids
834 (1668)
1501 (3002)
25
45
2 Days/Week
Composite
Dissolved Oxygen
Shall not be less than 6 mg/L
2 Days/Week
Grab
pH
Shall be in the range of 6 to 9 Standard Units
2 Days/Week
Grab
Fecal Coliform"'
Daily Maximum shall not exceed 400 per 100 mL (May through
October)
2 Days/Week
Grab
Ammonia Nitrogen
as(N)
April-Oct
.
63 (156)
2 Days/Week
Composite
79 (198)
1 .5
1 .9
Nov .-Feb .
146 (365)
146 (365)
3 .5
3 .5
2 Days/Week Composite
March
63 (156)
146 (365)
1 .5
3 .5
2 Days/Week Composite
Copper1
.9 (4 .8)
0 .046
2 Days/Week Composite
rage
3
NPULS Hermit NO
. ILUUZUUtSI
kmuent Limitations
. Monltonnd . and Kepomnq
FINAL
Discharge Numbers) and Name(s)
: A01 Excess Flow Outfall
I hese flow facilities shall not be utilized until the main treatment facility is receiving its maximum practical flow
.
From the effective date of this Permit until the expiration date, the effluent of the above discharge(s) shall be monitored and limited at all
times as follows :
Total flow in million gallons shall be reported on the Discharge Monitoring Report (DMR) in the quantity maximum column
.
Report the number of days
of discharge in the comments section of the DMR .
Fecal Coliform shall be reported on the DMR as daily maximum .
Chlorine Residual shall be reported on the DMR as a monthly average concentration .
pH shall be reported on the DMR as a minimum and a maximum
.
BOD, and Suspended Solids shall be reported on the DMR as a monthly average concentration .
CUNGEN IRA I ION
LIMI IS mWL
Parameter
Monthly Average
Sample Frequency
Sample Type
I otal Flow (MG)
See Below
Daily When Discharging
Continuous
BOD,
30
Daily When Discharging
Grab
Suspended Solids
30
Daily When Discharging
Grab
Fecal Coliform
Daily Maximum Shall Not Exceed 400 per 100 mL
Daily When Discharging
Grab
pH
Shall be in the range of 6 to 9 Standard Units
Daily When Discharging
Grab
Chlorine Residual
0 .75
Daily When Discharging
Grab
rage 4
NPUES Permit No . ILUU2UU8/
Influent Monitoring, and Reoortinq
I he influent to the plant shall be monitored as follows
:
Parameter
Sample Frequency
.
Sample Type
Flow (MGD)
Continuous
8OD5
2 Days/Week
Composite
Suspended Solids
2 Days/Week
Composite
Influent samples shall be taken at a point representative of the influent
.
Flow (MGD) shall be reported on the Discharge Monitoring Report (DMR) as monthly average and daily maximum
.
BODS
and Suspended Solids shall be reported on the DMR as a monthly average concentration
.
Page 5
NPDES Permit No . IL0020087
special Conditions
SPECIAL CONUI I ION 1 .
This Permit may be modified to include different final effluent limitations or requirements which are consistent
with applicable laws, regulations, or judicial orders . The IEPA will public notice the permit modification .
SPECIAL CONDITION 2 .
The use or operation of this facility shall be by or under the supervision of a Certified Class 1 operator.
,SPECIAL CONDITION
3. The IEPA may request in writing submittal of operational information in a specified form and at a required
frequency at any time during the effective period of this Permit
.
SPECIAL CONDITION 4 . The IEPA may request more frequent monitoring by permit modification pursuant to 40 CFR § 122 .63 and
Without Public Notice in the event of operational, maintenance or other problems resulting in possible effluent deterioration
.
SPECIAL CONDITION 5 . The effluent, alone or in combination with other sources, shall not cause a violation of any applicable water
quality standard outlined in 35 fit . Adm . Code 302 .
SPECIAL CONDITION 6. Samples taken in compliance with the effluent monitoring requirements shall be taken :
A . For Discharge Number 001
- During dry weather flows (no excess flow discharge), samples shall be taken at a point representative
of the flows but prior to entry into the receiving stream
. During periods of excess flow discharge, CBODS, Suspended Solids, and
Ammonia Nitrogen, if Ammonia Nitrogen monitoring and sampling is required on the Effluent Limitations, Monitoring, and Reporting
Page of this Pemut, shall be monitored at a point representative of the discharge but prior to admixture with the excess flow . If Fecal
Coliform limits are different for Discharge Numbers 001 and A01, sampling shall occur at a point representative of the discharge and
prior to admixture, If hardware allows
. Other parameters may be sampled after admixture but prior to entry into the receiving stream
.
B . For Discharge Number A01
- Samples for all parameters shall be taken at a point representative of the discharge but prior to entry
into the receiving stream. If Fecal Coliform limits are different for Discharge Numbers 001 and A01, sampling shall occur at a point
representative of the discharge and prior to admixture, if hardware allows . The sampling point for other parameters may be at a point
after admixture with the dry weather flows .
SPECIAL CONDITION 7 .
This Permit may be modified to include requirements for the Permittee on a continuing basis to evaluate and
detail its efforts to effectively control sources of infiltration and inflow Into the sewer system and to submit reports to the IEPA If necessary .
SPECIAL . CONDITION 8 . For Discharge No. 001, any use of chlorine to control slime growths, odors or as an operational control, etc . shall
not exceed the limit of 0
.05 mg/L (daily maximum) total residual chlorine in the effluent . Sampling is required on a daily grab basis during
the chlorination process . Reporting shall be submitted on the DMR's on a monthly basis .
SPECIAL CONDITION 9 . Fecal Colfform limits for Discharge Number 001 are effective May thru October . Sampling of Fecal Colfform is
only required during this time period .
SPECIAL CONDITION 10 . The Permittee may collect data in support of developing a site-specific metals translator for copper . Total and
dissolved metals for a minimum of twelve weekly samples need to be collected from the effluent and at a downstream location indicative
of complete mixing between the effluent and the receiving water to determine a metal translator for these parameters
. The IEPA will review
submitted sample data and may reopen and modify this Permit to eliminate or include revised effluent limitations for the parameter based
on the metal translator determined from the collected data .
SPECIAL CONDITION 11 .
A .
Publicly Owned Treatment Works (POTW) Pretreatment Program General Provisions
1 . The Permittee shall implement and enforce its approved Pretreatment Program which was approved on September 3, 1985 and all
approved subsequent modifications thereto . The Pernittee shall maintain legal authority adequate to fully implement the Pretreatment
Program in compliance with Federal (40 CFR 403), State, and local laws . The Permittee shall :
Page 6
NPUES Permit No
. ILOO20O8/
Special
Conditions
Carry out independent inspection and monitoring procedures at least once per year, which will determine whether each
significant industrial user (SIU) is in compliance with applicable pretreatment standards ;
Perform an evaluation, at least once every
two (2) years, to determine whether each SIU needs a slug control plan . If needed,
the SIU slug control plan shall include the items specified in 40 CFR § 403
.8 (f)(2Xv)
;
Update its inventory of Industrial Users (IUs) at least annually and as needed to ensure that all SIUs are properly identified,
characterized, and categorized ;
d .
Receive and review self monitoring and other IU reports to determine compliance with all pretreatment standards and
requirements, and obtain appropriate remedies for noncompliance by any IU with any pretreatment standard and/or
requirement ;
e .
Investigate instances of noncompliance, collect and analyze samples, and compile other information with sufficient care as to
produce evidence admissible In enforcement proceedings, including judicial action
;
f .
Require development, as necessary, of compliance schedules by each industrial user for the installation of control technologies
to meet applicable pretreatment standards
; and,
9 .
Maintain an adequate revenue structure for continued operation of the Pretreatment Program .
2 . The Permittee shall issue/reissue permits or equivalent control mechanisms to all SIUs prior to expiration of existing permits or prior
to commencement of discharge in the case of new discharges
. The permits at a minimum shall include the elements listed in 40 CFR
§ 403 .8(fX I Xiii) .
3 . The Permittee shall develop, maintain, and enforce, as necessary, local limits to implement the prohibitions in 40 CFR § 403
.5 which
prohibit the introduction of specific pollutants to the waste treatment system from any source of nondomestic discharge .
4 .
In addition to the general limitations expressed in Paragraph 3 above, applicable pretreatment standards must be met by gill industrial
users of the POTW
. These limitations include specific standards for certain industrial categories as determined by Section 307(b) and
(c) of the Clean Water Act, State limits, or local limits, whichever are more stringent .
5 . The USEPA and IEPA individually retain the right to take legal action against any industrial user and/or the POTW for those cases
where an industrial user has failed to meet an applicable pretreatment standard by the deadline date regardless of whether or not such
failure has resulted in a permit violation
.
6 . The Permittee shall establish agreements with all contributing jurisdictions, as
necessary, to enable it to fulfill its requirements with
respect to all lUs discharging to its system .
7 . Unless already completed, the Permittee shall within
$ix (6l months of the effective date of this Permit submit to USEPA and ]EPA a
proposal to modify and update its approved Pretreatment Program to incorporate Federal revisions to the general pretreatment
regulations . The proposal shall include all changes to the approved program and the sewer use ordinance which are necessary to
incorporate the regulations commonly referred to as PIRT and DSS, which were effective November 16, 1988 and August 23, 1990,
respectively . This includes the development of an Enforcement Response Plan (ERP) and a technical re-evaluation of the Pemnittee's
local limits
.
8 .
The Permittee's Pretreatment Program has been modified to incorporate a Pretreatment Program Amendment approved on September
3,1985
. The amendment became effective on the date of approval and is a fully enforceable provision of your Pretreatment Program
.
Modifications of your
Pretreatment Program shall be submitted in accordance with 40 CFR § 403 .18, which established conditions
for substantial and nonsubstantial modifications.
Page
B . Reoortinc and Records Reouirements
1 . The Permittee shall provide an annual report briefly describing the permittee's pretreatment program activities over the previous
calendar year
. Permittees who operate multiple plants may provide a single report providing all plant-specific reporting requirements
are met
. Such report shall be submitted no later than April 28th of each year, and shall be in the format set forth in IEPA's POTW
Pretreatment Report Package which contains information regarding
:
An updated listing of the Permittee's industrial users.
b . A descriptive summary
of the compliance activities including numbers of any major enforcement actions, (i.e ., administrative
orders, penalties, civil actions, etc .), and the outcome of those actions. This includes an assessment of the compliance status
of the Permittee's industrial users and the effectiveness of the Permittee's Pretreatment Program in meeting its needs and
objectives .
C .
A description of
all substantive changes made to the Permittee's Pretreatment Program . Changes which are "substantial
modifications" as described in 40 CFR § 403
.180 must receive prior approval from the Approval Authority .
d .
Results
of sampling and analysis of POTW influent, effluent, and sludge .
e .
A summary of the findings from the priority pollutants sampling
. As sufficient data becomes available the IEPA may modify this
Permit to incorporate additional requirements relating to the evaluation, establishment, and enforcement of local limits for
organic pollutants. Any permit modification Is subject to formal due process procedures pursuant to State and Federal law and
regulation. Upon a
determination
that an organic pollutant is present that causes interference or pass through, the Permittee
shall establish local limits as required by 40 CFR § 403
.5(c) .
2 .
The Pernittee shall maintain all pretreatment data and records for a minimum of three (3) years . This period shall be extended during
the course of unresolved litigation or when requested by the IEPA or the Regional Administrator of USEPA . Records shall be available
to USEPA and the IEPA upon request .
3
. The Permittee shall establish public participation requirements of 40 CFR 25 in implementation of Its Pretreatment Program . The
Permittee shall at least annually, publish the names of all IU's which were In significant noncompliance (SNC), as defined by 40 CFR
§ 403
.8(f)(2xvii), in the largest daily paper In the municipality in which the POTW is located or based on any more restrictive definition
ofSNC that the POTW may be using .
4 .
The Permittee shall provide written notification to the Deputy Counsel for the Division of Water Pollution Control, IEPA, 1021 North
Grand Avenue East, P
.O. Box 19276, Springfield, Illinois 62794-9276 within five (5) days of receiving notice that any Industrial User
of its sewage treatment plant is appealing to the Circuit Court any condition imposed by the Permittee In any permit issued to the
Industrial User by Permittee
. A copy of the Industrial User's appeal and all other pleadings filed by all parties shall be mailed to the
Deputy Counsel within five (5) days of the pleadings being filed in Circuit Court
.
NPDES Permit No . IL0020081
Special Conditions_
Page 8
C .
Monitorino Reauirements
NPUES
Permit
No . IL002008'1
SDecial Conditions
The Permittee shall monitor its influent, effluent and sludge and report concentrations of the following parameters on monitoring
report forms provided by the IEPA and include them in its annual report. Samples shall be taken at annual intervals at the
indicated reporting limit or better and consist of a 24-hour composite unless otherwise specified below . Sludge samples shall
be taken of final sludge and consist of a grab sample reported on a dry weight basis .
* Influent and effluent only
""1 ng/L = 1 part per trillion .
"""
Other approved methods may be used for influent (composite) and sludge
Unless otherwise indicated, concentrations refer to the total amount of the constituent present in all phases, whether solid, suspended or
dissolved, elemental or combined including all oxidation states . Where constituents are commonly measured as other than total, the phase
is so indicated .
2
. The Permittee shall conduct an analysis for the one hundred and ten (110) organic priority pollutants identified In 40 CFR 122 Appendix
D, Table II as amended
. This monitoring shall be done annually and reported on monitoring report forms provided by the IEPA and shall
consist of the following :
a .
The influent and effluent shall be sampled and analyzed for the one hundred and ten (110) organic priority pollutants . The
sampling shall be done during a day when industrial discharges are expected to be occurring at normal to maximum levels
.
Samples for the analysis of acid and base/neutral extractable compounds shall be 24-hour composites .
Five (5) grab samples shall be collected each monitoring day to be analyzed for volatile organic compounds
. A single analysis
for volatile pollutants (Method 624) may be run for each monitoring day by compositing equal volumes of each grab sample
directly in the GC purge and trap apparatus in the laboratory, with no less than one (1) mL of each grab included in the composite .
Wastewater samples must be handled, prepared, and analyzed by GC/MS in accordance with USEPA Methods 624 and 625 of
40 CFR 136 as amended .
STORET
Minimum
CODE
PARAMETER
reDortnd limit
01097
Antimony
0 .07 mg/L
01002
Arsenic
0 .05 mg/L
01007
Barium
0 .5 mg/L
01012
Beryllium
0 .005 mg/L
01027
Cadmium
0 .001 mg/L
01032
Chromium (hex -
grab not to exceed 24 hours)'
0 .01 mg/L
01034
Chromium (total)
0 .05 mg/L
01042
Copper
0 .005 mg/L
00718
Cyanide (grab) (weak acid dissociablep
5 .0 ug/L
00720
Cyanide (grab) (total)
5 .0 ug/L
00951
Fluoride'
0 .1 mg/L
01045
Iron (total)
0.5
mg/L
01046
Iron (Dissolved)"
0 .5 mg/L
01051
Lead
0 .05 mg/L
01055
Manganese
0
.5 mg/L
71900
Mercury (effluent grab using USEPA Method 1631 or equivalent)"" 1 .0 ng/L**
01067
Nickel
0 .005 mg/L
00556
Oil (hexane soluble or equivalent) (Grab Sample only)`
5 .0 mg/L
32730
Phenols (grab)
0.005
mg/L
01147
Selenium
0 .005 mg/L
01077
Silver (total)
0 .003 mg/L
01059
Thallium
0 .3 mg/L
01092
Zinc
0 .025 mg/L
Page 9
NPDES Permit No . IL0020087
Special Conditions
b .
I
he sludge snail be sampled and analyzed for the one hundred and ten (110) organic priority pollutants
. A sludge sample shall
be collected concurrent with a wastewater sample and taken as final sludge
.
Sampling and analysis shall conform to USEPA Methods 624 and 625 unless an alternate method has been approved by IEPA
.
c .
Sample collection, preservation and storage shall conform to approved USEPA procedures and requirements .
3
. In addition, the Permittee shall monitor any new toxic substances as defined by the Clean Water Act, as amended, following notification
by the IEPA.
4
. Permittee shall report any noncompliance with effluent or water quality standards in accordance with Standard Condition 12(e) of this
Permit .
5. Analytical detection limits shall be in accordance with 40 CFR 136
. Minimum detection limits for sludge analyses shall be in accordance
with 40 CFR 503 .
SPECIAL CONDITION 12 .
During January of each year the Pemiittee shall submit annual fiscal data regarding sewerage system
operations to the Illinois Environmental Protection Agency/Division of Water Pollution Control/Compliance Assurance Section . The
Permittee may use any fiscal year period provided the period ends within twelve (12) months of the submission date
.
Submission shall be on forms provided by IEPA filled 'Fiscal Report Form For NPDES Pennittees' .
SPECIAL CONDITION 13 .
The Permutes shall conduct blomonitoring of the effluent from Discharge Number(s) 001 .
Biomonitorinq
1 . Acute Toxicity -
Standard definitive acute toxicity tests shall be run on at least two trophic levels of aquatic species (fish, invertebrate)
representative of the aquatic community of the receiving stream
. Testing must be consistent with Methods for Measuring the Acute
Toxicity of Effluents and Recelvino Waters to Freshwater and Marine Organisms (Filth Ed
.) EPA/821-R-02-012 .
Unless substitute tests
are pre-approved ; the following tests are required
:
a
Fish - 96 hour static LC
. Bioassay using fathead minnows (Pimephales promelas) ..
b .
Invertebrate 48-hour static LC . Bioassay using Ceriodaphnia
.
2
. Testing Frequency -The above tests shall be conducted using 24-hour composite samples unless otherwise authorized by the IEPA .
Samples must be collected in the 18th, 15th, 12th, and 9th month prior to the expiration date of this Permit .
3 . Reporting -
Results shall be reported according to EPA/821-R-02-012, Section 12, Report Preparation, and shall be submitted to IEPA,
Bureau of Water, Compliance Assurance Section within one week of receipt from the laboratory . Reports are due to the IEPA no later
than the 16th, 13th, 10th, and 7th month prior to the expiration date of this Permit
4 . Toxicity Reduction Evaluation -
Should the results of the biomonitoring program Identify toxicity, the IEPA may require that the Permittee
prepare a plan for toxicity reduction evaluation and identification . This plan shall be developed in accordance with Toxicity Reduction
Evaluation Guidance for Municipal Wastewater Treatment Plantg,
EPA/833B-99/002, and shah include an evaluation to determine which
chemicals have a potential for being discharged in the plant wastewater, a monitoring program to determine their presence or absence
and to identify other compounds which are not being removed by treatment, and other measures as appropriate . The Permittee shall
submit to the IEPA Its plan for toxicity reduction evaluation within ninety (90) days following notification by the IEPA The Permittee shall
implement the plan within ninety (90) days or other such date as contained in a notification letter received from the IEPA
.
The IEPA may modify this Permit during Its term to incorporate additional requirements or limitations based on the results of the
biomonitoring . In addition, after review of the monitoring results, the IEPA may modify this Permit to include numerical limitations for
specific toxic pollutants
. Modifications under this condition shall follow public notice and opportunity for hearing .
Page
10
NPDES Permit No
. IL0020087
Special Conditions
SPECIAL CONDITION 14 .
For the duration of this Permit, the Permittee shall determine the quantity of sludge produced by the treatment
facility in dry tons or gallons with average percent total solids analysis
. The Permittee shall maintain adequate records of the quantities
of sludge produced and have said records available for IEPA inspection
. The Permittee shall submit to the IEPA, at a minimum, a semi-
annual summary report of the quantities of sludge generated and disposed of, in units of dry tons or gallons (average total percent solids)
by different disposal methods including but not limited to application on farmland, application on reclamation land, landfilling, public
distribution, dedicated land disposal, sod farms, storage lagoons or any other specified disposal method
. Said reports shall be submitted
to the IEPA by January 31 and July 31 of each year reporting the preceding January thru June and July thru December interval of sludge
disposal operations .
Duty to Mitigate . The Permittee shall take all reasonable steps to minimize any sludge use or disposal in violation of this Permit
.
Sludge monitoring must be conducted according to test procedures approved under 40 CFR 136 unless otherwise specified in 40 CFR
503, unless other test procedures have been specified in this Permit
.
Planned Changes . The Permittee shall give notice to the IEPA on the semi-annual report of any changes in sludge use and disposal
.
The Permittee shall retain records of all sludge monitoring, and reports required by the Sludge Permit as referenced in Standard Condition
23 for a period of at least five (5) years from the date of this Permit .
If the Permittee monitors any pollutant more frequently than required by the Sludge Permit, the results of this monitoring shall be included
in the reporting of data submitted to the IEPA.
Monitoring reports for sludge shall be reported on the form titled "Sludge Management Reports" to the following address
:
Illinois Environmental Protection Agency
Bureau of Water
Compliance Assurance Section
Mail Code #19
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
SPECIAL CONDITION 15 .
The Permttee shall record monitoring results on Discharge Monitoring Report (DMR) Forms using one such
form for each outfall each month .
In the event that an outfall does not discharge during a monthly reporting period, the DMR Form shall be submitted with no discharge
indicated .
The Permittee may choose to submit electronic DMRs (eDMRs) instead of mailing paper DMRs to the IEPA
. More information, including
registration information for the eDMR program, can be obtained on the IEPA website, httpJ/
www.epa .state
.il .us/water/edmrAndex .html .
The completed Discharge Monitoring Report forms shall be submitted to IEPA no later than the 15th day of the following month, unless
otherwise specified by the permitting authority .
Permittees not using eDMRs shall mail Discharge Monitoring Reports with an original signature to the IEPA at the following address
:
Illinois Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
Attention
: Compliance Assurance Section, Mail Code # 19
'age 11 .
Attachment H
Standard Conditions
Definitions
cct means the Illinois Environmental Protection Act . 415 ILCS 5 as Amended
.
tgency means the Illinois Environmental Protection Agency .
bard means the Illinois Pollution Control Board
.
:lean Water Act (formerly relened to as the Federal Water Pollution Control Act) means
'ub
. L 92-500, as amended
. 33 U .S .C
. 1251 et seq .
IPDES (National Pollutant Discharge Elimination System) means the national program for
,sung, modifying revoking and reissuing, terminating
. monitoring and enforcing permits, and
mpoaing and enforcing pretreatment requirements, under Sections 307.402
.318 and 405
r the Clean Water Act .
JSEPA means the United States Environmental Protection Agency
.
laity Discharge means the discharge of
a pollutant measured during a calendar day or any
24-hour period that reasonably represents the calendar day for purposes of sampli g. Far
,ollutanis with limitations expressed n units of mass, the 'daily discharge' M calculated as
he total mass of the pollutant discharged over the day . For pokulants will limitations
expressed n other tab of measurements, the 'daily discharge Is
Calculated as the average
neasuremenl of the pollutant over the day
.
Maximum Daily Discharge Limitation (daily maximum) means the highest allowable dally
discharge.
Average Monthly Discharge Umitaton (30 day average) means the highest allowable
average of daily discharges over a calendar month, "isolated as the sum of
all
daily
discharges measured during a calendar month divided by the number of daily discharges
measured during that month .
Average Weekly Dlsiharge limitation (7 day avenge) means the highest elowable
average of
dally discharges war a calendar week, calculated as the aunt of all daily
discharges measured during a calendar week divided by the number of daily discharges
measured during that week
.
Best Management Practices (BMPS) meals schedules of acNkies. pramgbns
of
praatces,
maintenance procedures, and other management produces to prevent or reduce an peMbn
of waters of me Stale. Ships
also Include treatment requkanats, operating procedures, and
practices to contra plant site runoff, spillage or leaks, sludge or waste disposal, or drainage
from raw material stooge.
Aliquot memo a Sample of specified volume used to make
up a total composite Sample.
Grab Sample meat, an Individual sample of at least 100 Brightens collected at a rndomy-
selected time war a period owl exceeding 15 minutes .
24 Hour Composite Sample moms a combination of at least 8 sample aliquots a at least
100 millaers, collected at periodic intervals during the operating hours of a facility over a 24
hour period .
8 Hour Composite Sample means a combination of at least 3 sample a"S of at loom 100
milliners,
period .
collided at periodic intervals during the operating hours of a facility over son 8-hour
Flow Proportional Composite Sample means a combination of sample aliquots a at bast
100
milliliters collected at periodic Intervals such that ewer the time interval between each
aliquot
samplingor orhe
the
volume
total
of
steam
each
cow
aliquot
since
is
the
proportional
collection
to
of
either
the previous
the stream
aliquotflow
.
a the dime of
- (1) Duty to comply
. The pe mmee must comply with all conditions of this paint Any
permit noncompliance con Wales a violation of the Act and b grounds far adorcement
action, permit termination, revocation and reassurance, modt alton, or bar denial
of a
permit renewal application . The pamkltee shag comply with
effluent
Standards or
prohibitions established under Section, 307(a) or the Clean Water Ad for lose
pollaants within the tine provided in the regulations that establish Vaba, Standards or
requirementprohibitions,
even if
the permit has not yet been modified to Incorporate Mal
(2) Duty o reapply
. 0 the pemitee washes to continue an ad dly regulated by INS permit
Shelf the expiration date of this permit, the pennitlee must apply la and obtain a raw
permit . If the permtee submits a pope application as required by he Agency no later
than 180 days prior to the expiration date, this permit shag
continue
n full tome and
effect until be final Agency decision on the application has been made .
(3) Need
pemthee
to halt
n
anor enforcement
reduce activity
action thatnot a would
a
d efensehave .
been
ti sea
necessary
not be
to
a defense
fish or
fair
reducea
the permitted ad" n order to maintain compliance with the conditions of this per".
(4) Duty to mitigate
. The pemttee shall take ail reasonable steps to mnknhe a prevent
any discharge h violation of fed permit which has a reasonable likeaood of adversely
affecting human health or the environment .
(5) Proper operation and Maintenance
. The perrntee shag at sit fines properly operate
and maintain all facilities and systems of treatment and coned (and related
appurtenances) which are installed or used by he pennlaee to achieve compliance
with
performanceconditions
. adequate
of this permitfundng,
.
adequate
Proper operation
operator staffing
and mainlemonce
and trainingIncludes
. and
effectiveadequate
laboratory and process controls, including appropriale.quany assurance procedures .
This provision requires the operation of back-up, or auxiliary facielies . or similar
systems only when necessary to achieve comphaae with the conditions of
the permit .
(6)
(7)
(8)
(9)
Permit actions
. inspenmtmayoerrwomeo.levuncu
for cause by the Agency pursuant to 40 CFR 122 .62
. The fling of a request by the
pennltlee for a permit modification, revocation and reissuanee, w termination, or a
notification of planned changes or anticipated noncompliance, does not stay any
permit condition
.
Property rights
. This permit does not convey any property nghts
of
any son . or any
exclusive privilege .
Duty to provide Information
. The pennbtee snail furnish to the Agency within a
reasonable time, any
information
which the Agency may request to determine whether
"use exists for modifying, revoking and reissuing, or terminating this permit
. or to
determine compliance with the perms The pennttee shall also fumsh to the Agency,
upon request, copies of records required to be kept by this permit
.
Inspection and entry
. The pemnhee shag allow an authorized representative of the
Agency, upon the presentation of credentials and other documents as may be required
by low. to,
(a) Enter upon the permbtee's premises where a regulated facility or activity is
orated or
conducted, or where records must be kept under the conditions of this
permit:
(b) Have access to and copy, at reasonable times, any records that must be kept
randy the conditions of this permit
:
(d) Inspect at reasonable times any facilities, equipment (including monitoring and
contra equipment), practices, or
operations regulated or required under this
permit
; and
(d) Sample or monger at reasonable times, for the purpose of assuring permit
r rri hence, or as otherwise authorized by the Act
. any substances or parameter
a m y location.
(10) Monitoring and records .
(a) Samples and measurements taken for the purpose of monitoring shall be
representative of he monitored activity.
(b) The permittee shall retain records
of
all mongiciring Information
. Including all
calibration and maintenance records
. end all original strip chart recordings for
continuous monitoring Instrumentation . copies of all reports required by this
paint and records of all data used to complete flit application for this pemm, for
a period of a least 3 yeas from the date of this permit
. measurement, report or
appMnllon. This period may be extended by request of
the Agency M my time
(c) Records of Monitoring information shall Include
:
(1) The date, exact place, and time of sampling or
measurements :
(2) The etdMdual(s) who performed the sampling or measurements ;
(3) The dae(s) analyses were performed
.
(4) The ndividuags) who performed the mayses:
(5) The analytical techniques or methods used ; and
(6) The results of such analyses .
(d) Monkaag must be conducted according to test procedures approved
under 4D
CFR Pet 136, unless other text procedures have been specified n this permit .
Where no test procedure under 40 CFR Part 136 has been approved, the
pemlgee must submit to he Agency a test method for approval. The pemmtee
shall celebrate and perform maintenance procedures n all monitoring and
analytical nstwmentation at Intervals to ensure accuracy
of measurements .
(11) Signatory requirement Ak applications,
reports a informal submitted to the
Agency shat be signed and certified .
(a) Application
. All permit applications shag be signed as follows :
(1) For a corporation : by a principal executive officer
of M least the level a
vice president a e peen
or position having overek responskriky for
environmental matters for the corporation :
(2) For a partnership or sole proprieorship
: by a general partner ff the
proprietor, respectively ; or
(3) For ∎ municipality, State, Federal, or other public agency
: by either a
principal executive officer
or
ranking
elected official .
(b) Reports . AM reports requited by permits . or other information requested by the
Agency shag be signed by a person described
n paragraph (a) or by a duty
auhafzed representative of thin person
. A person is a duly authorized
representative unity 9 :
(1) The authorization Is made n
rifting bye person described in paragraph (a) .
and
(2) The authorization species either
an individual ore position responsible for
the overall operation of
the facility, from which
Via
discharge originates . Such
as a plant manager, superintendent or person of
equivalent responsibility
;
and
(3) The written authorization is submitted to the Agency .
Ige 12 .
(c)
Changes o1 Authorization . If an authorization under (b) Is no longer accurate
because a different Individual or position has responsibility for the airmail
operation of me facility, a new authorization satisfying the requirements of (b)
must be submitted to the Agency prior to or together with any opens, Information,
or applications to be signed by an authorized representative .
2) Reporting requirements .
Planned changes . The permntee shelf give notice to the Agency as soon as
possible of any planned physical alterations or additions to the permitted facility .
(b) Anticipated noncompliance
. The permittee shall give advance notice to the
Agency of any planned changes in the permitted facility or activity which may
result in noncompliance with permit requirements
.
(c) Compliance schedules, Reports of compliance or noncompliance with, or any
progress reports on, interim and foal requirements contained in any compliance
schedule of this palnit shall be submitted no later than 14 days foilowulg each
schedule date .
(d) Monitoring reports. Monitoring results shag be reported at the intervals
specified elsewhere h this permit
.
(1) Monitoring results must be reported on a Discharge Monitoring Report
(DMR).
(2) n the pestles nonhers any petulant more frequently than requited by the
permit, using test procedures approved unclear 40 CFR 136 or as specified
h the permit, the results of this morseling shall be Included h the calculation
and reporting of the date Submitted In the DMIR .
(3) Calculations far all limitations which require averaging of measurements
shad ulikze
an a forretic mean unless otherwise specified by the Agency In
the paned.
(e) Twenty-four hour reporting . The pelmitee shell report any noncompliance
which may endanger health or the environment. Any Information shall be
provided only within 24 hours loom the tine tit petrifies, becomes same of the
ciramlstances . A written submission Mall also be provided within 5 days of the
time live pernlttee becomes aware of the rlaanstances . The written submission
shall contain a description of the noncompliance and he cause ; the period of
noncompl ance, Including exact dates and tins; and a the noncompliance has riot
been corrected, the anticipated Nee lt Is expected
o
conikuro;
and
steps taken
or planned to reduce, atonal and prevent rearnarenee of the nancomplance .
The
hoursfollowing
:
shall be included as Informal which must be reported within 24
(1) Any unanticipated bypass which exceeds any effluent limitation in the
permit ;
(2) Violation of a maximum daily discharge gmitatlon for any of the pollutants
listed by the Agency In the permit to be reported within 24 hours .
The Agency may waive the written report on a case-by-case basis
If the am]
report has been received within 24 hours.
(f)
Other noncompliance . The pemMlee shall report all Instances of
noncompliance net reported under paragraphs
(12)(c), (d), a (e). at the time
monitoring reports am submitted. The reports shell contain the Information listed
in paragraph
(12)(0)
.
(9) Other Information
. Where he permutes becomes aware final 6 failed o submit
any relevant facts In
a permit application
. a submitted incorrect information h a
pennant application, or h any report to de Agency. It shall
promptly
submit such
fads or information .
3) Transfer of Permits . A permit may be automatically transferred to a new permntee
if:
(a) The cement permntee notifies the Agency at less( 30 days In advance of the
proposed transfer date :
(b) The notice includes awcaen agreement between lie existing end new permgtees
containing a spedfic date for transfer of permit responsibility, coverage and
liability between the current and new penreffI es ; and
ic)
The Agency does not notify the existing peemltlee and the proposed new
permmea of its intent to modify or revoke and reissue the permit . If this notice Is
not received, the transfer Is effective on
the date specified
in the agreement .
4)
All manufacturing, commercial, mining, and shvicuhural dischagers must notify the
Agency as soon as they know or have reason to believe :
(a) That any activity has o¢uned orvS occur which would result in the discharge of
any toxic pollutant Identified under Section 307 of the Clean Water Act which is
not limned in
me permit, If that discharge will exceed the highest of the following
notification levels'
(1) One hundred micrograms per fller(100ugh) ;
(2) Two hundred micrograms per mar (200 ugM for acoleln and acrylonnrtle ;
two hundred microgram per filer (500 ugh) for 2,4-0hnropheriol and for 2-
methyF4 .6 dlnltrophenol ; and ore
milligram
per her (I mgfl) for antimony .
(3) Five (5) times the maximum concentration value reported for that pollutant
In Me NPDES permit application ; or
(a)
(4) The level established by the Agency In this permit
.
(b) That they have begun or expect to begin to use w manufacture as an intermediate
or final product or byproduct any toxic pollutant which was not reported in Ins
NPDES permit applicallon .
(15) All Publicly Owned Treatment Works (POTWs) must provide adequate notice to the
Agency of the following : .
(a) Any new Introduction of pollutants Into that POT\N from an indirect discharge
which would be subject to Sectionr
. 301 or 306 of the Clean Water Act if it were
directly discharging those pollutants ; and
(b) Any substantial Mange In the volume or character of pollutants being inlroducud
Into that POTW by a source introducing pollutants into the POTW al the lime c'
Issuance of the permit
.
(c) For purposes
of this paragraph, adequate notice shall include information on (i)
the quality and quantity of effluent Introduced Into the POTW, and (Ii) ar.y
anticipated impact of the change on the quantity or quality of effluent to ce
discharged from the POTW,
(16) fl the permit is issued toe publicly owned or publicly regulated treatment works, the
pern8lee shall require any industrial user of such treatment works to comply with
federal requirements concerning :
(a) User charges pursuant to Section 204(b) of the Clean Water Act, and applicable
regulations appealing h 40 CFR 35 ;
(b) Toxic pollutant effluent standards and pretreatment standards pursuant to Section i
307 of the Clean Water AcL and
(c) Inspection. monitoring and entry pursuant to Section 308 of the Clean Water Act
.
Ban applicable standard or limitallon is promulgated under Section 301(1 and
(D), 304(b)(2), or 307(a)(2) and that affluent standard or limitation is more stringent
than any effluent limitation h the permit, or controls a pollutant not limned in the
perch, the permit shag be promptly modified or revoked, and reissued to contonn to
that effluent standard or limitation,
(18)
Any authorization to construct issued to the pennmee pursuant to 35 III
. Adm . Code
309.154 b hereby incorporated by reference as a condition of We peen
.
(19) The pemlaee sea not make any false statement, representation
or certification in any
appNStlon, record, report, plan or other document submitted to the Agency or the
USEPA, o requited to be maintained under this permit .
(20) The Clean Water Act provides that any person who violates a pianos condition
Implementing Sections 301, 302, 306, 307, 308, 318, or
405 of me Clean Water Act
Is subject to a civil penalty not to exceed $10,000 per day of such violation
. Any
person who wilfully or negligently violates penny conditions implementing Sections
3D1, 302,306,307, or 308 of the Clean Water Act is subject toe Me of not less than
$2,500 nor bore than $25,000 per day of violation, or
by imprisonment for net more
than one yea. or both .
(21)
The Clean Water Act provides that any person who falsifies . tampers with, or
knowingly renders Inaccurate any monitoring device or method required to be
maintained under permit shall, upon conviction,
be punished by a fine of not more than
310.000
per violation. or by anprismment far net more men 8 months per violation,
or
by both.
(22)
The Clean Water Act provides that any person who knowingly makes any false
s atement, representation, or certification in
any record or otherr decennial submitted
or required to be maintained under this permit shall, including monitoring reports
or
reports a compliance or non-taryfanca she,
upon conviction, be punished by a fine
of not more than $10,000 pa violation,
or by Imprisonment for not more man 6 months
per violation, a by both .
(23) Collected screening, elegies, sludges, and other seeds shelf be disposed
of in such
a manner as
o
prevent
entry
of those wastes
(or runoff from the wastes) into waters
of the State . The proper authorization fair such disposal shall be obtained from the
Agency and is incorporated as part hereof by reference
.
(24) In case of conflict between these standard conditions and any other condNOn(s)
Included in this parts, the other
condition(s)
shall govern.
(25) The per illee shall comply with
. In addition to the requirements of the permit, all
applicable provisions of 35 Ill . Adm. Code. Sualue C
. Subtitle D; Subtitle E, and all
applicable orders of the Board
.
(26) The provisions of this permit are severable
. and If aft provision of this pewit, or the
application of any provision of this permit is held invalid, The remaining provisions of
this permit shall continue in full force and effect .
(Rev. 3-13-981
GCD
f a1'dner Carton & Dougias
ROY M . HARSCH
(312) 569-1441
rha rsch@gcd .co m
Fax (312) 569-3441
VIA OVERNIGHT COURIER AND EMAIL
Sanjay K . Sofat
Assistant Counsel/Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Ave . East
P .O . Box 19276
Springfield, IL 62794-9276
191 N
. Wacker Drive, Suite 3700
Chicago, Illinois 60606-1698
Te l
312 569 1000 1 Fax 312 569 3000
www .gcd
.co
m
Re: City of Geneva
NPDES Permit No . IL0020087
Dear Sanjay :
As we discussed I represent the City of Geneva which was issued a renewal NPDES
permit on October 13, 2006 . They submitted a comment letter dated September 14, 2006
that was delivered by Federal Express on September 15, 2006 . A copy of this comment
letter is attached .
Geneva objects to inclusion of the Dissolved Oxygen and Copper limitations as set
forth in the comment letter . It is Geneva's understanding that the permit engineer, Abil A .
Haile, never saw the comment letter prior to finalizing the permit
. Geneva requests that the
Illinois Environmental Protection Agency submit a placeholder appeal request to the Illinois
Pollution Control Board that will allow time for Geneva and Illinois Environmental Protection
Agency to discuss these issues .
Please advise me as soon as possible regarding whether the Illinois Environmental
Protection Agency will submit such a placeholder appeal or not so I can have time to file an
appeal petition if required .
Very truly yours,
November 9, 2006
Roy M
. Harsch
cc:
Dan Dinges
Jim Huff
Washington, D .C.
Milwaukee, WI
Albany, NY
New York, NY
en :ner
Wc,!d L-
c, slob conefwork
of li,dapendanf
fin-b
fes
