Illinois Department
af
Transportation
2300 South Dirksen Parkway
1
Springfield, lllinois 162764
June 6,2007
Ms. Dorothy Gunn
Clerk of the Board
lllinois Pollution Control Board
1021 North Grand Avenue East
P.O. Box 19274
Springfield,
IL 62794-9274
Re: East Saint Louis -St. Clair County
lllinois Department of Transportation, District 8
Bowman Avenue Pump Station
- Deep Well System
IEPA NPDES Permit No. ILD0070955
Petition for an Adjusted Standard from 35 111. Adm. Code 302.208(g)
Dear Ms. Gunn:
Submitted herein is a petition of lllinois Department of Transportation, District
8 for an adjusted standard from 35 lllinois Administrative Code
(Ill. Adm.
Code)
302.208(g).
If you have any questions or require further information, please contact Lance
Jones at
2171782-3215.
S:\GEN\WPDOCS\GOBELMAN\D~~~C~~\O~S~~~\PSI\~~~~~~WS~\O~
adjusted Standard lelter to IPCB.doc
Enclosures
cc: Steven Gobelman, lllinois Department of Transportation
- Bureau of Design and
Environment
- S~rinafield. Illinois
Mary Lamie. Attn: ~effre~
~e:m - lllinois Department of Transportation - District 8 -
Collinsville, lllinois
Lance Jones, lllinois Department of Transportation -Office of Chief Counsel -Springfield,
Illinois
Kenneth W. Liss - Andrews Engineering, inc.
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
ANDREWS
ENGINEERING INC
3300 Ginger Creek Drive
Springfield,
Illinois 627 1
1
Tel: (217) 787-2334
Petition for an Adjusted Standard
ILLINOIS DEPARTMENT OF TRANSPORTATION
-
DISTRICT 8
BOWMAN AVENUE PUMP STATION AND DEEP WELL SYSTEM
EAST ST. LOUIS, ST.
CLAlR COUNTY, ILLINOIS
NPDES PERMIT NO.
lL0070955
June 2007
By:
Illinois Department of Transportation
Bureau of Design and Environment
2300 South Dirksen Parkway
Springfield, Illinois 62764
Submitted to:
Illinois Pollution Control Board
102 1 North Grand Avenue East
P.O.
Box 19274
Springfield, Illinois 62794-9274
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
TABLE OF CONTENTS
INTRODUCTION AND BACKGROUND
..........................................................................
1
A
.
STATEMENT OF STANDARD OF GENERAL APPLICABILITY FROM
WHICH RELIEF IS SOUGHT
................................................................................. 2
B . IMPLEMENTATION OF FEDERAL LAW ............................................................... 3
C . LEVEL OF JUSTIFICATION REQUIRED ............................................................... 3
D
. NATURE AND DESCRIPTION OF ILLINOIS DEPARTMENT OF
TRANSPORATION ACTIVITIES ........................................................................... 4
Individual Well Systems
................................................................................
4
Tri-Level System
................................................................................
5
1-64 System
............................................................................................. 5
h
25'
Street System
..................................................................................
5
Missouri Avenue System
.........................................................................
5
Operations
........................................
6
Pumping Results
.....................................................................................
6
Historical Groundwater Results
................................................................... 7
Chloride, Total
..................................................................................
7
Fluoride, Total
.........................................................................................
8
Sulfate. Total
.....................................................................................
8
Total Dissolved Solids (TDS)
..................................................................
8
Combined Equivalent Effluent
.......................................................................
8
Combined Actual Effluent
.............................................................................
9
E .
EFFORTS THAT WOULD BE NECESSARY TO ACHIEVE
COMPLIANCE AND ALTERNATIVES ....................................................................
10
F
.
DESCRIPTION OF PROPOSED ADJUSTED STANDARD (35 ILL . ADM .
CODE SECTION 104.406(F)) ...................... ..
.....................................................
12
G .
DESCRIPTION OF PETITIONERS' IMPACT ON THE ENVIRONMENT
(35 ILL
.
ADM . CODE SECTION 104.406(G))
.........................................................
13
Analyses of Discharge Characteristics
...................................................... 13
Sulfates
................................................................................................
13
Total Dissolved Solids (TDS)
.................................................................... 13
Toxicity of Discharge
..................................................................................
13
H . EXISTING PHYSICAL CONDITIONS (DESCRIPTION OF RECEIVING
STREAM)
............................................................................................................. 14
I
.
THE CHARACTER OF THE AREA INVOLVED INCLUDING
SURROUNDING LAND USE AND ZONING CLASSIFICATIONS ..........................
15
J
. JUSTIFICATION FOR PROPOSED ADJUSTED STANDARDS (35 ILL .
ADM . CODE SECTION 104.406(H)) ...................................................................
16
K . ADDITIONAL JUSTIFICATION FACTORS .......................................................... 16
Bowman Avenue Pump Station
................................................................ 17
Material Service's Federal Quarry
...............................................................
17
Services and Training Center of Exelon
......................................................
18
/DOT
Bowman Avenue Pump Station
Andrews Engineering. Inc
.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Rhodia. TCBSD. and Consumers Illinois Water
..........................................
19
L
.
FUNDAMENTALLY DIFFERENT FACTORS .........................................................
20
M
. WAIVER OF HEARING (35 ILL . ADMINISTRATIVE CODE SECTION
104.406(J)) .............................................................................................................
21
N . CONCLUSIONS ........................................
21
REFERENCES
.......................................................................................................
22
/DOT
Bowman Avenue Pump Station
Andrews Engineering. Inc .
Petition for Adjusted Standard
June 2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
FIGURES
Figure 1 - Schematic of Bowman Yard Discharge ........................................................
23
Figure 2 - Location of East St. Louis Dewatering Sites .................................................
24
Figure
3 - Locations of Dewatering Wells at the 1-70 Tri-Level, 1-64 and 25Ih Street
Sites
....................................................................................................
: ....... 25
Figure
4 - Locations of Dewatering Wells at Missouri Avenue Site ............................... 26
APPENDICES
Appendix A Site Location Map .......................... ..
...................................................
A
Appendix B Geologic Cross Sections ..........................................................................
B
Appendix C Bowman Avenue Pump Station and Missouri Avenue Well Field Historical
Water Quality Data
.................................................................................. C
Appendix D Bowman Avenue Pump Station and Missouri Avenue Well field Graphs of
Parameters versus Time ............................................................................
D
Appendix E Individual Deep Pumping Wells Historical Water Quality Data ...................
E
)DOT
Bowman Avenue Pump Station
Andrews Engineering. Inc.
iii
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
1
PETITION OF ILLINOIS DEPARTMENT OF
)
AS
07-
TRANSPORTATION FOR AN ADJUSTED
)
STANDARD FROM 35 111. ILLINOIS
1
ADMINISTRATIVE CODE 302.208(G)
FOR THE BOWMAN AVENUE PUMP
1
)
STATION AND DEEP WELL SYSTEM IN
)
EAST ST. LOUIS, IL
1
Petition for an Adjusted Standard
INTRODUCTION AND BACKGROUND
The Illinois Department of Transportation
(IDOT) is submitting a petition for an adjusted
standard from 35 Illinois Administrative Code
(Ill. Adrn. Code) 302.208(g) for sulfates and
total dissolved solids.
In
order to prevent flooding and structural damage to the Interstate
Highway system in the East St. Louis area, groundwater levels are kept pumped down by
four separate groundwater pumping systems. Three of the systems discharge to the
IDOT District 8 Bowman Avenue Pump Station (Bowman) where they are pumped to a
discharge sewer. The Bowman discharge is combined with the final system discharge
from the Missouri Avenue Pumping system and the combined effluent discharges to an
unnamed drainage way. The discharge is regulated by effluent standards from 35
111.
Adrn. Code 304 and an Illinois Environmental Protection Agency (Illinois EPA) National
Pollutant Discharge and Elimination System (NPDES) Permit. Due to the naturally
occurring concentrations of the various parameters, the groundwater pumped from the
well systems may cause exceedences of water quality standards as set forth in 35
111.
Adm. Code 302.208. The groundwater in this system is not known to have been
contaminated by any human activity.
/DOT
Bowman Avenue Pump Station
Andrews Engineering,
Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
The NPDES Permit requires the discharge waters meet parameter effluent limits that
are derived from water quality limits. The sulfate constituent may have occasionally and
the total dissolved solids (TDS) parameter has routinely exceeded the respective
permitted NPDES effluent limits.
Therefore, IDOT seeks an adjusted standard for
sulfates and TDS.
This discharge has been the subject of a previous adjusted standard in AS 96-12, for
iron, suspended solids and color. On October 3, 1996, the Illinois Pollution Control
Board (IPCB) issued an order granting IDOT relief for the aforementioned parameters.
Pursuant to Section 28.1, the Illinois Environmental Protection Act (Act) provides a
means for a petitioner to ask and receive approval for a revised environmental standard
from the IPCB that varies from a standard the petitioner is regulated by. The purpose of
the standards for which adjustment is sought in this petition is to protect aquatic life,
safeguard the quality for crop irrigation, and to protect the streams as a potential public
water supply. It is believed the regulations were promulgated, in whole or in part, to
implement the provisions of the Clean Water Act.
A.
STATEMENT OF STANDARD OF GENERAL APPLICABILITY FROM WHICH
RELIEF IS SOUGHT
IDOT seeks adjusted standards from the
IPCB's regulations for constituents contained
in 35
111. Adm. Code 302.208(g). The additional regulations 35 111 Adm. Code 304.105
(regarding compliance with water quality standards) and 35
111. Adm. Code 304.141
(regarding compliance with limits in the permit) were evaluated to see if they should
also be adjusted. The IPCB found in AS 03-1
(Exelon Generation Company) that if 35
Ill. Adm. Code 302.208 was adjusted, it is not necessary to adjust 35 111. Adm. Code
304.105. If the water quality standards were changed, and the petitioner could meet
the new standard, then there would be no need to provide additional relief from meeting
that standard. Using similar logic, IDOT has decided not to petition the IPCB regarding
35
111. Adm. Code 304.105. While not addressed in the above referenced decision (AS
03-I), the applicability of 35
111. Adm. Code 304.141 is analogous. If the water quality
standard changes, then the permit can be changed to reflect the adjusted standard;
therefore, relief will not be requested for this standard either. The standard from which
an adjusted standard is being sought is:
/DOT
Bowman Avenue Pump Station
Andrews Engineering, Inc.
Petition For Adjusted Standard
June 2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Section 302.208 - Numeric Standards for Chemical Constituents
g) Concentrations of the following chemical constituents shall not be exceeded
except in waters for which mixing is allowed pursuant to Section 302.102.
STORET
CONSTITUENT
UNITS
NUMBER
STANDARD
Sulfate
mg/L
00945
500
Total Dissolved Solids
mglL
70300
1000
Where: mg/L = milligrams per liter
B.
IMPLEMENTATION OF FEDERAL LAW
The
IDOT does not believe the granting of an adjusted standard proposed in this matter
would be inconsistent with Section
303(a) of the Clean Water Act, if the Board finds the
proposal to be protective of human health and welfare. It is also noted here that the
Illinois EPA has conducted a triennial water quality standards review required under
section
303(c)(l) of the Clean Water Act and as a result proposed revised standards for
the substances being addressed here in
R007-009. The existing discharge would meet
the standards of R007-009 if that proposal passes as proposed. The
IDOT's NPDES
permit could be modified to incorporate the adjusted standard, and
IDOT could comply
with any such permit.
C.
LEVEL
OF JUSTIFICATION REQUIRED
The regulation of general applicability does not specify a level of justification required of
a petitioner to qualify for an adjusted standard. Therefore Section
28.l(c) of the Act
allows the
IPCB to grant individual standards upon adequate proof by petitioner that:
1. Factors relating to that petitioner are substantially and significantly different from
the factors relied upon by the
IPCB in adopting the general regulation applicable
to that petitioner;
2. The existence of those factors justifies an adjusted standard;
3. The requested standard will not result in environmental or health effects
substantially or significantly more adverse than the effects considered by the
IPCB in adopting the rule of general applicability; and
[DOT
Bowman Avenue Pump Station
Andrews Engineering, inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
4. The adjusted standard is consistent with any applicable federal law
This petition provides material to address all four demonstrations.
D.
NATURE
AND
DESCRIPTION
OF
ILLINOIS
DEPARTMENT
OF
TRANSPORATION ACTIVITIES
Deep wells were installed as early as 1973 for the purpose of dewatering shallow
groundwater in order to lower the water levels to a safe depth below the designed road
grades. The
IDOT District 8 Bowman Avenue Pump Station is located adjacent to
Exchange Avenue (Exit 3 from lnterstate 55/70) in East St. Louis, St. Clair County, Illinois
(See Appendix A). There are typically three employees at the Bowman Yard facility. The
pump station is part of the
IDOT District 8 Bowman Yard maintenance facility. The pump
station receives water from three well fields and various stormwater drainage ways.
Another well field discharge combines with the discharge from the Bowman pump station
and together they go to a drainage way (See Figure 1). The well fields are located
adjacent to low pavement areas near Interstates 55 and 70 (Tri-level), lnterstate 64
(1-64),
the 25Ih Street underpass to 1-64, (25Ih) and the 1-5511-70 underpass near Missouri Avenue
(Missouri). The water from Bowman Yard maintenance facility includes the pump station
discharge and the Missouri discharge and is discharged into a drainage way, which flows
approximately 1,750 feet to the Schoenberger Creek, thence to the Cahokia Canal, and
finally to the Mississippi River at Mile 180.6 (See Figure 1 and Appendix A).
Individual Well Systems
Forty-nine wells produce groundwater from four well fields that pump to the Bowman
Yard. On average, 13 to 16 of the 49 wells are operational at any given time. The four
well fields are identified as the Tri-Level (15 wells), 1-64 (20 wells), 25th Street (10
wells), and Missouri Avenue (4 wells) dewatering sites (See Figure 2). These deep
wells are equipped with submersible pumps to control the water table in areas of low
pavement elevation. Without the systems of pumping wells, the respective interstate
and intercity routes would flood and be impassable, ultimately requiring closure or
modification in roadway grades.
The groundwater from the pumping wells is transferred via 6-inch to 42-inch diameter
gravity
and/or pressure collection systems to intermediate pump stations located at each
well field. From the intermediate pump stations, the fluids are transported by 60-inch to
72-inch sewers. The groundwater from the Tri-level, 1-64, and
25Ih street dewatering
/DOT
Bowman Avenue Pump Station
Andrews Engineering,
Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
sites goes to the Bowman Avenue Pump Station and is discharged to a 72-inch (RCP)
sewer. The Missouri Avenue dewatering site discharge is conveyed to the Bowman
Yard where it combines with the pump station discharge.
Tri-Level System
The Interstates 55 and 70 Tri-Level System is located southwest of the Bowman Avenue
Pump Station at the interchange of
1-5511-70 and 1-64 (See Figure 3). The Tri-Level
System consists of 15 deep pumping wells ranging in depth from 90 to 110 feet (see
geologic cross sections A-A' and
6-6' in Appendix 6).
To attain sufficient drawdown in
the Tri-Level area, approximately seven of the fifteen wells need to pump at any given
time. If significant groundwater recharge occurs due to precipitation and runoff,
additional pumping wells can be turned on to maintain adequate water levels.
1-64 System
The 1-64 System is located southeast of the Bowman Avenue Pump Station and the Tri-
Level interchange (See Figure 3). The 1-64 network is made up of 20 wells ranging in
depth from 90 to 110 feet (See geologic cross sections
6-8' in Appendix 6). The
roadway grades at the Tri-Level are lower than the 1-64 surface elevations. The
Tri-
Level groundwater drawdown is sufficient enough to adequately maintain potentiometric
levels for most of the 1-64 System roadway grades except for the far southeastern
elevations. Therefore, only one or two southern wells at 1-64 require pumping to attain
sufficient drawdown.
25th Street System
The 251h street System is located approximately one and a quarter miles southeast of
the
1-5511-70 Tri-Level and 1-64 interchange (See Figure 3). This system is located on
25Ih Street which exits from 1-64. Low road grades at 251h Street were required to gain
access below an 1-64 overpass and a St. Louis Metro Transit System rail bridge. The
25'h Street System consists of 10 deep pumping wells ranging in depth from 110 to 115
feet (See geologic cross sections C-C' in Appendix
8).
To attain sufficient drawdown in
the vicinity of the
25Ih Street low pavement elevations, approximately four of the ten wells
need to pump at any given time.
Missouri Avenue System
The Missouri Avenue System is located approximately one mile west-southwest of the
Bowman Avenue Pump Station and the Tri-Level interchange (see Figure
3 and
IDOTBowman Avenue Pump Station
Andrews Engineering, lnc.
Petition for Adjusted Standard
June 2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Appendix A). The low pavement elevations along 1-5511-64/1-70 at the Missouri Avenue
overpass include a network of four wells ranging in depth from 75 to 110 feet (see
geologic cross sections D-D' in Appendix B). To attain sufficient
drawdown at the
Missouri Avenue area, generally two to four of the wells need to pump at any given time.
The flow from this system goes to the Bowman Yard where it mixes with the discharge
from the Bowman Pump Station.
Operations
Generally, between 13 to 16 of the 49 wells are pumping into the Bowman Avenue Pump
Station system.
The electrical circuitry of each pump is hooked up to a local control
center. Each control center is self-contained and securely locked. Each well field system
has one or more control centers that enable one to manually turn
onloff the pumps and to
monitor the status of each pumping well hooked up to the respective control center. When
any number of wells need to be turned on or off due to
welllpump repairs or to modify the
water level (raise or lower), the control center for the respective
system(s) are accessed.
Water levels are monitored by taking measurements from piezometers or observation
wells located within each well field. The low pavement areas require a predetermined
potentiometric level. When the water level measurements attained from the piezometers
or observation wells in a given system indicates a need to increase or decrease the water
levels, the number of wells to be turned
onloff are modified based on the need. The
number of wells from each system that pump at any given time include approximately 6-7
of the 15 wells at the Tri-Level area, generally 1 or maybe 2 southern wells at 1-64,
generally 4 of the
10 wells at 25th Street, and between 2 and 4 wells at Missouri Avenue.
Pumping Results
The NPDES permit application from 2001 provided estimated average flow (volume) of 19
MGD (13,000 gprn) with maximum levels of 26 MGD (18,000 gpm) from the Tri-Level,
I-
64, Missouri Avenue, and 25Ih Street sites.
During the sampling of the individual wells from October 2003 to February 2005, the
Tri-
Level, 1-64, Missouri Avenue, and 25" Street operated an average of six, one, three and
four wells, respectively, to maintain adequate water levels at each site. Based on the
estimated pumping rates and the average number of wells operating, the Tri-Level pumps
between 2,700 and 3,600 gprn, 1-64 pumps between 450 and 600 gpm, Missouri Avenue
pumps between 3,250 and 3,700 gpm, and
251h Street pumps between 1,800 and 2,400
gpm, totaling an estimated 8,200 and 10,300
gpm (or 11.8 to 14.8 MGD). Based on the
IDOT
Bowman Avenue Pump Station
Andrews Engineering, Inc.
Petition for Adjusted Standard
June 2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
average number of wells pumping and estimated pumping rates, the percent groundwater
volumes that contribute to the Bowman Avenue Pump Station from the Tri-Level is
37%, 1-
64 is 6%, Missouri Avenue is 33%, and 25" Street is 24%.
Historical Groundwater Results
A revised Illinois EPA NPDES permit became effective January 1, 2003. The revised
NPDES permit requires monthly sampling of pH, total suspended solids (TSS), iron
(dissolved and total), TDS and sulfate, and semiannual sampling of manganese, boron.
fluoride and ammonia. Of these parameters, TDS and possibly sulfate have exceeded
the respective effluent standards.
To comprehensively evaluate the effluent quality, including sulfate and TDS,
IDOT
collected and compiled data at a greater frequency than required by the permit. All of
the monthly and semi-annual parameters were sampled twice a month from the
Bowman Avenue Pump Station between February 2003 and January 2005. From
February 2005 to present, the pump station has been sampled on a monthly basis. The
table provided in Appendix
C summarizes the water quality results for total dissolved
solids and sulfates from the Bowman Avenue Pump Station grab samples. Graphs
showing the trends of the individual parameters from the grab samples are given in
Appendix D.
In addition to the bimonthly, monthly, and semi-annual sampling at the Bowman Avenue
Pump Station, groundwater sampling was collected during eight events from individual
wells from October 2003 through February 2005 for comparison with the grab sample
results and characterization of the originating groundwater. Analyzing the groundwater
from the individual wells contributing to the pump station was conducted to determine
the potential
source(s) of the sulfate and TDS. The table in Appendix E shows the water
quality data for individual deep pumping wells within the Bowman Avenue Pump Station
system and Missouri Avenue well field. The data show there is significant variability
between well fields and between individual wells in any given field.
Chloride, Total
Total chloride is not required as part of the site NPDES monitoring program. However,
TDS is a primary constituent in the NPDES permit. Since the chloride contributes to the
TDS, it was sampled for during the same events as the individual wells. The chloride
levels for the individual well samples were low (33-336
mg/L) and well below the
/DOT
Bowman Avenue Pump Station
Andrews Engineering, Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
concentration limits of
35
111. Adm. Code
302.208 (500
mg/L). The individual wells show
concentrations below
500
mgIL, with most data results below
100
mg1L. See Appendix
E.
Fluoride, Total
The total fluoride levels of the Bowman Station and individual well samples are generally
below the
35
111. Adm. Code
302.208
standard of 1.4 mg/L. All of the Bowman Station
samples were below
1 mglL while only two wells from the 1-64 system had regular
detections above
1.4 mg1L. See Appendix E.
The NPDES permit for the facility does
not include a concentration limit for total fluoride.
Sulfate, Total
The
35
111. Adm. Code
302.208
water quality standard and NPDES concentration limit for
total sulfate is
500
mg1L. The grab sample levels for all sampling points for total sulfate
are generally below
500
mglL. However, occasionally the concentrations exceed the
sulfate limits. A few individual wells show total sulfate concentrations exceeding the
limit. 1-64 wells
19
and
20.
and
25'h
Street well
2,
experienced total sulfate exceedences
relatively consistently, while 1-55 wells
1
IA,
12A,
and
13,
and Missouri Avenue well
2
recorded one to three exceedences out of the eight sampling events (see Appendix E).
Total Dissolved Solids (TDS)
The 35 111. Adm. Code
302.208
water quality standards and NPDES concentration limit
for total dissolved solids is
1,000
mglL. The grab sample levels for TDS are frequently
above
1,000
mglL. A few individual wells from the Tri-Level,
251h
street, and Missouri
Avenue sites and all of the sampled wells at 1-64 show high TDS concentrations. The
Bowman Station TDS concentrations, despite the
well-to-well variability, are relatively
consistent, generally with TDS levels between
1,050
mglL and
1,130
mglL (See
Appendix D). The grab and individual well sample TDS levels are attributable to
naturally occurring conditions.
Combined Equivalent Effluent
Historically, the final outfall discharge to the drainage way has not been sampled.
However, the pump station (which includes the 1-64.
2dh
Street and Tri-level well fields),
and the Missouri well field have been sampled as previously noted. The analytical
results of the Bowman pump station and the Missouri well field have been
mathematically added using estimated flow data to create a combined equivalent
IDOTBowman Avenue Pump Station
Andrews Engineering, Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
effluent (CEE). The Bowman data represents one sampling point (representing three
well fields). The Missouri data represent results from all the wells in that field.
A statistical analyses of results from
2003 until the end of 2005 has been conducted to
determine various numerical characteristics of the groundwater sampling results. Both
the mean and the
95% upper confidence limit (UCL) are presented.
The mass was
calculated using flow and concentration figures. The CEE concentration was calculated
using combined mass and flow. The tables below show the results of this analysis.
For sulfates, concentrations at the Bowman Station were greater than
500 mgll three
times, but there has only been one sample result greater then
500 mgll from the
Missouri Avenue field. These excursions did not occur at the same time so it is unclear
as to whether the CEE would have ever exceeded the
500 mgll limit.
Sulfates, Total
Flow.
Concentration
mg/l
Mass Lbslday -
MGD
(flow x
conc x 8.34)
Mean
Max 95%UCL
Mean
95%UCL
Bowman Station
9.504
381
580
496
30,199
39,315
Missouri Well field
5.328
291
642
445
12,931
19,774
Combined equiv.
14.832
349
478
43,130
59,088
effluent - massl(flow x
8.34)
For TDS, it is estimated that the CEE for both the mean and the 95% UCL would have
exceeded the
1,000 mgll level.
Total Dissolved Solids
Flow,
Concentration
mgll
Mass, Lbslday - (flow
MGD
x
conc x 8.34)
Mean
Max 95%UCL
Mean
95%UCL
Bowman Station
9.504
1,097 1,280
1,178
86,952
93,372
Missouri Well field
5.328
912
1,390
1,121
40,525
49,812
Combined equiv.
14.832
1,031
1,158
127,477
143,184
effluent - massl(flow x
8.34)
Combined Actual Effluent
Starting in the fall of 2006, the discharge to the drainage way has been sampled for
parameters consistent with the NPDES permit. Results for key parameters are listed
/DOT
Bowman Avenue Pump Station
Andrews Engineering, Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
below. The mean for sulfate is 341 mgll, and TDS is 1047 mg/l. These levels seem to be
consistent with what is expected.
Units
9/13/06
10/24/06
1 1/28/06
Mean
Sulfates
Mgll 397
300
326
341
TDS
Mgll
1070
1020
1050
1047
Chloride
Mgll 94.4
-
82.8
86.6
Hardness
Mgll
639
639
E.
EFFORTS THAT WOULD BE NECESSARY TO ACHIEVE COMPLIANCE AND
ALTERNATIVES
This discharge was also the subject of a
IPCB action in 1996, in the matter of AS 96-12
regarding suspended solids iron and color. As part of that proceeding,
IDOT evaluated
two alternatives
-- treatment of the discharge and direct discharge to the Mississippi
River. While the treatment cost for the parameters evaluated then are not applicable to
TDS and sulfates, they were nonetheless very high; $14,120,000 to
$21,550.000. The
cost for river
outfall and diffusion system, which remains an applicable alternative, was
estimated at that time to be $5,690,000 to $9,630,000. Using the lmplicit Price Deflator,
the estimated costs in the 1994 Horner
& Shifrin report associated with the river
outfallldiffusion system alternatives have been updated for inflation. To update the
estimate costs for inflation, an inflation factor derived from the lmplicit Price Deflator for
Gross Domestic Product as published by the U.S. Department of Commerce was
calculated. Tables of the lmplicit Price Deflator can be downloaded from the U.S.
Department of
Commerce,
Bureau of
Economic Analysis'
website
at
htt~:llwww.bea.doc.qov/bealdnlnipaweblindex.as. The lmplicit Price Deflator for Gross
Domestic Product table contains the lmplicit Price Deflators in Annual or Quarterly
formats. As of the writing of this report, the latest lmplicit Price Deflator was published in
fourth quarter 2006.
The inflation factor can be derived in one of two ways: (1) the inflation factor is the result of
dividing the current deflator by the deflator for the previous reporting period, or (2) the
inflation factor is the result of dividing the current deflator by the deflator for the reporting
period you wish to start from.
The Horner
& Shifrin estimates were submitted in 1994.
JDOTBowman Avenue Pump Station
Andrews Engineering, Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
The 1995 implicit price deflator is 92.106. The fourth quarter 2006 implicit price deflator is
116.857.
Thus, the inflation factor is 1.2687
(i.e., 116.857 + 92.106 = 1.2687). Costs
today are approximately 26.9% higher than they were in 1995. Therefore, the updated for
inflation estimated costs for the river
outfallldiffusion system alternatives range between
$7,219,033 and $12,217,581, respectively.
There are other types of treatment available, such as reverse osmosis,
electrodialysis,
and others. These are not considered conventional treatment technologies and would
be expected to be more expensive than conventional technologies. In other proceedings
before the
IPCB petitioners have evaluated such technologies and determined them to
be economically unreasonable. The
IPCB has concurred.
In the current regulatory proceeding, R-26-04, regarding a TDS change for the Des
Plaines River, Mobil Oil investigated both sulfate and TDS removal and found the only
potentially effective technology would be
evaporationlcrystallization. Applied to a small
200ppm (.288MGD) stream, the costs would be $36 million to $56 million, not including
operation costs. Projected flows for this project would be over
19MGD.
In a similar situation, in adjusted standard proceeding, AS 02-1 Material Service Corp.
pumped a lesser flow
3.6MGD, but it was groundwater with high TDS and sulfates, and
discharged to Summit Ditch. In 2001, Material Service estimated the 20-year costs of
reverse osmosis to be $81 million to $113 million.
in adjusted standard proceeding, AS 01-9, Rhodia
Inc., a pretreatment discharger to the
Thorn Creek Sanitary District, evaluated reverse osmosis followed by evaporation with a
mechanical vapor recompression, for a
0.59MGD discharge. Capitol costs were $4
million and annual operating costs were estimated at $600,000. This was estimated at
$7.7811,000 gallons. IDOT acknowledges that this cannot be correlated with its
discharge, but nonetheless, the IDOT discharge will be 32 times greater than Rhodia's.
In adjusted standard proceeding, AS 99-5, Abbott Laboratories estimated the cost to
use reverse osmosis was $750,000 capitol and
$500,00O/yr operating costs.
Given the widely accepted known high costs of treating TDS and sulfates, IDOT feels
that the river discharge option is still the least expensive. Even at the lower end of the
estimate, $7.2 million, IDOT feels this cost is economically unreasonable, especially
given the fact that there would be no improvement to the environment.
IDOTBowman Avenue Pump Station
Andrews Engineering. Inc.
Petition
for
Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Due to the high cost of the conventional water treatment plant and the outfallldiffusion
system alternatives, the option to seek adjustment of the standard(s) has been selected.
Thus, to achieve compliance,
IDOT is seeking an adjusted standard from the IPCB.
F.
DESCRIPTION
OF
PROPOSED ADJUSTED STANDARD
(35
ILL. ADM. CODE
SECTION
104.406(F))
Due to the complicated nature of this situation, a system of 49 wells with varying water
quality, operating at varying flows, from an uncontrolled groundwater source,
determining the appropriate adjusted standard involved the evaluation of several factors.
For sulfates, it is arguable as to whether there has even been an exceedence, since the
combined Bowman Station and Missouri Avenue discharge has not been sampled after
mixing, but rather before mixing and averaged mathematically. The current mean and
95% UCL do not exceed 500 mgll, and the highest estimated concentration may not
have ever exceeded
500mgll. However, since individual sample results may have
exceeded 500 mgll, it is felt that the maximum value recorded of 642 mgll is
appropriate.
For TDS the current mean and 95% UCL exceed the 1,000 mgll limit. Therefore, the
present
95%UCL of 1,128 mgll should be the appropriate adjusted standard.
The following language is proposed:
The General Use Water Quality Standard for total dissolved solids and sulfates
shall not apply to the drainage way that receives the Bowman Yard facility discharge
from the point of discharge approximately
1,750 feet to the drainage way's confluence
with Schoenberger Creek, and
in
Schoenberger Creek approximately 5,000 feet to its
confluence with Cahokia Canal. Instead, the
portions of waterway mentioned above
shall be subject to a total dissolved solids standard of 1,128 mgN, and a sulfates
standard of
642 mgN.
Internally and separate from the Bowman Avenue Pump Station situation with effluent
concentrations, the Illinois
EPA is reviewing the sulfate and TDS water quality standards
as part of statewide NPDES discharge requirements. The Illinois EPA has petitioned
the
IPCB in R007- 009 with a proposal to modify the existing effluent standards by:
a. Removing TDS;
b. Keeping the current chloride standard at 500
mgll;
c. Increasing the sulfate concentration limits;
d. Using the combined chloride and sulfate limits to replace TDS.
/DOT
Bowman Avenue Pump Station
12
Andrews Engineering. Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
If the lllinios EPA's petition were to be adopted as proposed, there would be no need for
the adjusted standard proposed in this case. The proposed sulfate standard is
calculated to be over 2,000 mgll for this discharge (see Toxicity of discharge
- sulfates
section below). If this becomes the new standard then no adjusted standard is needed.
If the TDS standard is eliminated then no adjusted standard is needed in this case
either.
G. DESCRIPTION OF PETITIONERS IMPACT ON THE ENVIRONMENT (35
ILL.
ADM. CODE SECTION 104.406(G))
Analyses of Discharge Characteristics
The concentrations representative of the pumping wells are not known to have been
contaminated by any human activity and are representative of naturally occurring
conditions. The NPDES permit identifies one discharge point, 001. This point is
actually the combination of the discharge from the Bowman pump station and the flow
from the Missouri System. Grab samples have been collected individually of the three
groundwater systems that go through the Bowman Avenue pump station (the Tri-level,
the 1-64, and the
25'h Street), the Bowman Station discharge and the Missouri Avenue
system. The final discharge represents a combination of the Missouri Avenue and the
Bowman Pump Station. In order to mathematically combine the discharges, nominal
flow rates based on pump designs were used. Actual flow rates have not been
collected, but had they been, they would have been less and would not have changed
any recommendations made herein. These data are summarized in the table in Section
3.
Sulfates
The mean concentration from Bowman station was 381 mgll and the 95% upper
confidence limit of the data (UCL) was 496
mgll. When the Missouri Avenue data is
added, the CEE mean becomes 349 mgll and the
95% UCL is 478 mgll. While
individual wells may have exceeded 500
mgll, it is unclear whether the CEE has ever
exceeded the threshold; therefore any impact would be minimal, if at all.
Total Dissolved Solids (TDS)
The mean concentration was 1,031 mgll and the 95% UCL is 1,158 mgll.
/DOT Bowman Avenue Pump Station
Andrews Engineering, Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
discovered that the existing TDS standard is unnecessary as the toxicity of each
constituent rather than the sum, is the essential factor ensuring protection of
aquatic life. With toxicity based sulfate and chloride standards in force, a TDS
standard is unnecessary as it is incapable of predicting the threshold of adverse
effects to aquatic life." Having said this, the Illinois EPA has proposed
eliminating the TDS standard. Thus, it is not felt the TDS limits proposed here
represent a threat to aquatic toxicity, per se. The discussion below will address
the likelihood of toxicity resulting from sulfate and chloride levels.
Chlorides - As noted in sec. 3.1 .I the chloride levels are well below the current
standard of 500
mgll; they are typically below 100 mgll. The most recent
samples were 82.8, and 94.4
mgll. thus chlorides exhibit no indication of toxicity.
Hardness - Hardness data is not collected routinely but was included as part of
the last NPDES submittal. The hardness data submitted ranged from 454 to 898
mgll (mostly over
500mgll). Recent data shows hardness of 639 mgll.
Sulfates - In Illinois EPA studies and follow up research by Dr. David Soucek.
the toxicity was found to be related to hardness and chloride levels. The
relationship is explained in formulae proposed by the Illinois EPA in R07-009.
The standards are determined by these formulae as "concentrations not to be
exceeded at any time." Using recent hardness data of 639 mgll and chloride
values of 82
mgll and 94 mgll, the sulfate standard would be 2,000 mgll. Even if
more historical values (using hardness of 454 mgll and chlorides of 80
mgll)
were evaluated, the sulfate standard would still be greater than 2,500 mgll. The
table in
sec. 3.2 shows the sulfate average (mean) to be 349 mgll and the
95%UCL of 478mgll - both considerably below the toxicity based sulfate
standards proposed by the Illinois EPA. The
IDOT feels that the research
information presented in the Statement of Reasons and the historical data
demonstrate the discharge is not toxic to aquatic life.
H.
EXISTING PHYSICAL CONDITIONS (DESCRIPTION OF RECEIVING STREAM)
The Bowman discharge and the Missouri Avenue discharge combine in a sewer and go
thence to the Bowman Pump Station drainage way. This drainage way is a channelized
ditch that also takes stormwater flow from the Interstate System near
Collinsville Road.
This ditch goes 1,750 feet to the reported Schoenberger Creek. Schoenberger Creek at
/DOT Bowman Avenue Pump Station
Andrews Engineering, Inc.
Petition for Adjusted Standard
June 2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
this point is channelized also and goes about 5,000 feet to Cahokia Canal. Cahokia
Canal is also channelized and goes to the Mississippi River. Flow data are not kept on
all these waterways, but it is suspected that during non-rainy weather most if not all of
the flow in the drainage way is from the
IDOT flows. The Pfizer Co. also reportedly
discharges to Schoenberger Creek. This discharge was the subject of a
IPCB action in
AS 81-29.
There are no known users of the receiving drainage way or Schoenberger Creek for
drinking water or other purposes.
The entire receiving water system from the discharge point to the Mississippi River is
channelized and habitat limited. This system serves as a stormwater control system for
this area, and is not known as a recreational area.
I.
THE CHARACTER OF THE AREA INVOLVED INCLUDING SURROUNDING
LAND USE AND ZONING CLASSIFICATIONS
This area covers a number of political jurisdictions including East St. Louis, Madison,
Fairmont City and unincorporated St. Clair County. The Bowman Yard facility is in East St.
Louis and is reported zoned as "unknown". The areas immediately to the northeast and
northwest are zoned
"R-3"
or multifamily. The property to the east from the facility from
Bowman Station to the discharge point is "M-2" or heavy manufacturing and industrial.
Adjacent areas are zoned
R- 1A single family. The drainage way to which to outfall
discharges and Schoenberger Creek from the outfall to the confluence with Cahokia Canal
are in unincorporated St. Clair Co. and are zoned
"8-2
or general business. At least part
of the area near the confluence of Schoenberger Creek and Cahokia Canal is in Madison
(zoned as "planned commercial"), and Fairmont City (zoned as highway business). The
drainage way and Schoenberger Creek are located in largely undeveloped, uninhabited
areas. There are no known uses of these waters for potable or agricultural uses. To the
east of the drainage way is the highway system, including exchanges and overpasses,
and to the west is a vacant undeveloped field. To the east of Schoenberger Creek is a
vacant field and several hundred feet further is the Gateway International Raceway. To
the west is a vacant field for several hundred feet. The area further to the west contains
industrial facilities, including waste management activities, and is fairly flat, allowing water
to pond (in undeveloped areas) during wet period.
IDOTBowman Avenue Pump Station
Andrews Engineering, Inc.
Petition
for
Adjusted Standard
June 2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
J.
JUSTIFICATION FOR PROPOSED ADJUSTED STANDARDS
(35
ILL. ADM.
CODE SECTION
104.406(H))
In the aforementioned R81-29 matter the IPCB recognized the impact of IDOT's
discharges and stated "...for purposes of this decision, the Board will accept the IDOT
discharge as a fundamental, irreversible change in the stream." Given the IPCB's
position, the fact an adjusted standard was granted for this discharge in AS 96-012 in
1996, and the data presented,
IDOT still represents that there is no adverse impact on
the environment.
The typical sulfate discharge meets the
500mgIl standard and could only be expected to
rarely, if ever, exceed it. Additionally, the
IEPA's petition indicates there is no adverse
impacts at this level (considering chlorides and TDS as well). Thus, it is not felt that
there is any adverse impact related to sulfates.
The TDS average is only slightly greater than the
1,000mgll standard (1,031 mgll ave.
and 1,158
mgll for 95% UCL). It has also been noted that the Illinois EPA intends to
recommend of the elimination of the TDS standard in the future because there is no
relationship to toxicity.
It is
IDOT's opinion that since the discharges either meet or
almost meet the standards now, the receiving waters are severely habitat limited, and
the Illinois EPA intends on eliminating the standard, there is no impact on the
environment, nor will there be one in the future.
K.
ADDITIONAL JUSTIFICATION FACTORS
Various sites have been granted approved adjusted standards similar to the requested
constituents, discharge type, and concentration limits of Bowman Yard. An outline of
several of these sites is provided below to illustrate that the proposal to adjust the
standards of total sulfate and total dissolved solids is viable and justifiable. These
decisions also confirm that the proposed adjusted standard would be consistent with
federal law.
/DOT
Bowman Avenue Pump Station
Andrews Engineering. Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Bowman Avenue Pump Station
Petitioner - lllinois Department of Transportation
Facility - Bowman Avenue Pump Station and associated IDOT deep well system
Location - East St. Louis, St. Clair County, lllinois
Case No. -AS 1996-012
Case Type - Adjusted Standard
Approval date: October 3, 1996
Media Type -Water
Proposal to adjust standards of iron (dissolved) from 1 mglL to 10 mgIL, iron (total)
from 2 mglL to 20
mglL and total suspended solids from 15 mglL to 40 mg1L.
lllinois EPA Response - The lllinois EPA recommended a grant of the requested
adjusted standards.
The Illinois EPA asserted that the requested alternative levels
should provide relief with a margin of safety for compliance.
IPCB granted IDOT an adjusted standard from 35 111. Adm. Code 302.208 and
304.124 as they apply to the discharge of iron (dissolved), iron (total) and total
suspended solids in its discharge from the
FAI-55170-FAI-64 system; and 35 111.
Adm. Code 302.203 as it applies to color resulting from oxidation and
biotransformation of naturally occurring iron.
Material Service's Federal Quarry
Petitioner - Material Service Corporation
Facility - Material Service's Federal Quarry and associated McCook Drainage Ditch
(from the 47th Street culvert to the Summit Conduit).
Location -Village of McCook, Cook County, lllinois
Case No. -AS 02-1
Case Type -Adjusted Standard
Approval date: June 6, 2002
Media Type - Water
/DOT
Bowman Avenue Pump Station
Andrews Engineering, Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Proposal to adjust effluent limits of sulfate from 500 mg/L to 850 mglL and total
dissolved solids (TDS) from 1,000
mglL to 1,900 mglL. The groundwater seepage
into the quarry is a shallow dolomite aquifer with sulfate and TDS levels ranging from
500
mg/L to 700 mglL and 1,200 mg/L to 1,600 mg/L, respectively.
Illinois EPA Response - The Illinois EPA recommended a grant of the requested
adjusted standards. The Illinois EPA agreed
andlor asserted that (1) the discharge
levels of sulfate and TDS are not likely to have any adverse or detrimental effects on
the aquatic life that resides in the ditch, (2) the proposed adjusted standard limits are
lower than necessary to protect the aquatic life, and (3) the sulfate and TDS
standards were established to protect domesticated livestock watering, which the
ditch does not support as a use.
IPCB granted Material Service an adjusted standard from 35 111. Adm. Code 304.105
and 406.202. However, the
IPCB did not grant the petitioners an adjusted standard
from 35
111. Adm. Code 302.208 because such relief was unnecessary.
Services and Training Center of Exelon
Petitioner - Exelon Generation Company
Facility - Services and Training Center (STC) of Exelon (located on Essex Road)
and associated small drainage ditch tributary to Horse Creek, about 3.5 miles
upstream of the confluence of Horse Creek with the Kankakee River.
Location -South of Braidwood, Will County, Illinois
Case No. - AS 03-1
Case Type -Adjusted Standard
Approval date: June 19,2003
Media Type -Water
Proposal to adjust effluent limits of total dissolved solids (TDS) from 1,000 mglL to
1,900
mglL. The discharge from the STC includes domestic and cafeteria waste
streams, as well as pollution control waste produced in the electrodialysis reversal
process used to treat the brackish groundwater to potable standards. The
concentrations of TDS from the groundwater range from 1,300
mg/L to in excess of
1,600
mglL.
/DOT
Bowman Avenue Pump Station
18
Andrews Engineering, inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
lllinois EPA Response - The lllinois EPA recommended the IPCB grant Exelon the
requested adjusted standard from the general use water quality standards (Section
302.208) for
IDS. The lllinois EPA agreed that (1) the discharge levels of TDS are
not likely to have any adverse or detrimental effects on the aquatic life in the
receiving stream, (2) the unnamed tributary and the area of confluence with Horse
Creek are not public water supplies, (3) TDS is not the limiting factor in the receiving
stream, (4) decreasing the concentrations of TDS in the STC effluent would not
necessarily improve the biological communities in the receiving stream, (5) the TDS
concentrations in the unnamed tributary have no impact on Horse Creek due to the
water flow at the confluence of the unnamed tributary and Horse Creek, and
(6)
Exelon's request for an adjusted standard from the IPCB's TDS water quality
standard (Section
302.208(g)) is consistent with federal law.
However, the lllinois
EPA argues that granting an adjusted standard from the
!PCB's effluent limits
(Section 304.105) is not consistent with federal law.
Therefore, the lllinois EPA
recommended the
IPCB deny an adjusted standard from Section 304.105.
IPCB granted Exelon Generation Company an adjusted standard from 35 111. Adm.
Code 302.208.
Rhodia, TCBSD, and Consumers Illinois Water
Petitioner - Rhodia, Inc., the Thorn Creek Basin Sanitary District (TCBSD), and
Consumers lllinois Water Company.
Facility - Rhodia's proposed expansion of their existing silica manufacturing plant
and the TCBSD treatment plant.
Location - Chicago Heights, Cook County, lllinois
Case No.
- AS 01-9
Case Type -Adjusted Standard
Approval date: January 10. 2002
Media Type - Water
Proposal to adjust effluent limits of sulfate and total dissolved solids (TDS) for the
following locations:
IDOTBowman Avenue Pump Station
Andrews Engineering. Inc.
Petition for Adjusted Standard
June 2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
a. Thorn Creek from the TCBSD WWTP discharge to the confluence with Deer
Creek for sulfate from 1,000 mglL to 1,350 mgIL and total dissolved solids (TDS)
from 2,100
mglL to 2,650 mgIL.
b. Thom Creek from the confluence with Deer Creek to USGS Gauging Station
05536275 at
Thornton for sulfate from 1,000 mglL to 1,340 mglL and total
dissolved solids (TDS) from 1,900 mglL to 2,620
mg/L.
c. Thorn Creek from USGS Gauging Station 05536275 at Thornton to Thorn
Creek's confluence with the Little Calumet River for sulfate from 850
mg1L to
1,160 mglL and total dissolved solids (TDS) from 1,900
mglL to 2,360 mg/L.
d. Little Calumet River from the Thorn Creek confluence to the Calumet-Sag
Channel for sulfate from 750 mglL to 1,000 mglL and total dissolved solids
(TDS) from 1,700
mglL to 2,020 mgIL.
Illinois EPA Response - The Illinois EPA recommended a grant of the requested
adjusted standards. The Illinois EPA agreed that granting the adjusted standards for
sulfate and TDS will have no measurable adverse effect on aquatic life in Thorn
Creek and the Little Calumet River.
IPCB granted the petitioners adjusted standards from 35 111. Adm. Code 304.105.
However, the IPCB did not grant the petitioners an adjusted standard from 35 111.
Adm. Code 302.208 because such relief was unnecessary.
L.
FUNDAMENTALLY DIFFERENT FACTORS
The Environmental Protection Act at
ILCS 5/28.1(c) provides that if the regulation of
general applicability does not specify a level of justification, the Board may grant individual
adjusted standards whenever the Board determines that: "...factors relating to the
petitioner are substantially and significantly different from the factors relied upon by the
Board in adopting the general regulation". Factors in this situation are fundamentally
different from factors relied upon by the Board in promulgating the current rule in many
aspects. Firstly, the discharge waters are all naturally occurring, not waste waters
contaminated by anthropogenic activities as is the case with other wastewater discharges.
IDOT has absolutely no control over the nature of the discharge. Also, unlike other
discharges the purpose of this discharge is not to get rid of water because it is
contaminated, but it has to be moved form its underground location in order to prevent
/DOT Bowman Avenue Pump Station
20
Andiwws Engineering, Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
flooding and potentially significant structural damage to a major urban highway system.
Flooding of the interstate system would create a major safety hazard to the general public.
Attempting to move the discharge to go directly to the Mississippi River would cause an
enormous financial burden on the citizens of Illinois for no improvement in the
environment. This is a very unique situation, unlike anything typically contemplated in
rulemaking, and unlike any other in the State.
M.
WAIVER OF HEARING
(35
ILL. ADMINISTRATIVE CODE SECTION 104.406(J))
The IDOT waives hearing on this petition.
N.
CONCLUSlONS
The IDOT District 8 Bowman Yard receives water from several well field systems and
discharges to a drainage way, thence to Schoenberger Creek, thence to the Cahokia
Canal, and finally to the Mississippi River. The discharge is regulated by effluent
standards from
35 111. Adm. Code 304 and an Illinois EPA NPDES permit. Sulfate and
TDS have or may have exceeded the respective permitted NPDES effluent limits and
require an adjusted standard so that the IDOT facility will stay in compliance with
applicable regulations. The discharged water, including concentrations of sulfate and
TDS, is representative of naturally occurring conditions and is not known to have been
contaminated by any human contact. IDOT believes that the above factors are
substantial and significantly different from the factors relied upon by the
IPCB in
adopting the general regulation, and justify an adjusted standard. The proposal to
adjust the standards was chosen over the other compliance alternatives
(i.e. treatment
at the facility versus pumping or piping discharge to the Mississippi River) because of
the substantial cost.
/DOT Bowman Avenue Pump Station
Andfews Engineering, Inc.
Petition for Adjusted Standard
June
2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
REFERENCES
Andrews Environmental Engineering, Inc., 2003, Compliance Schedule Plans and
Specifications for
/DOT District 8 Bowman Avenue Pump Station At FA1 55flFAI-
64 Deep Well System,
?
and Bowman, East St. Louis, St. Clair County, Illinois,
Consultant's report to lllinois Environmental Protection Agency Bureau of Water
pursuant to
IEPA NPDES Permit No. lL0070955.
Anliker, M.A., and R.D. Olson, 2003, Dewatering Well Assessment for the Highway
Drainage System at Four Sites in the East St. Louis Area, lllinois (FYOO-Phase
17),
lllinois State Water Survey Contract Report 2003-08, 53 p.
Bergstrom, R.E., and T.R. Walker, 1956, Groundwater Geology of the East St. Louis Area,
Illinois, lllinois State Geological Survey, Report of Investigations 191, 44 p.
Consoer
Townsend Envirodyne (CTE) Engineers, Inc., 2004, Mainline Drainage Report
-
Final Submittal lllinois
-
FAP 999 Section 81-2 82 R, Project: 1-55170/64 Tri-Level
Interchange, St. Clair County IL, Consultant's report to lllinois Department of
Transportation District 8, Job No. D-98-067-00, 9 p.
Horner
&
Shifrin, Inc., 1994. Stage I
-
Existing Condition and Analysis for Groundwater
Treatment Facilities Route
FAI-55/64/70 Tri-Level Complex and Missouri Avenue
in East St. Louis and IL Route 3 Railroad Viaduct in Venice, Consultant's report to
lllinois Department of Transportation District 8, Job No. D-98-120-93, 47 p.
lllinois Environmental Protection Agency
-
Division of Water Pollution Control, December
18, 2002, NPDES Permit No.
IL0070955 for /DOT District 8 Bowman Avenue
Pump Station.
lllinois Pollution Control IPCB, October
3, 1996, Petition of lllinois Department of
Transportation, District 8 for an Adjusted Standard from 35
111. Adm. Code 302.208,
304.124 and 302.203, AS 96-12 (Adjusted Standard -Water).
Layne Western Company, 2003, Computer Simulation of Groundwater Flow lllinois
Department of Transportation Dewatering Wellfield, East St. Louis lllinois
-
FAP
999 Section
81-2 82 R (1-55170/64) Tri-Level Interchange, St. Clair County IL,
Consultant's report for Consoer
Townsend Envirodyne Engineers, Inc. and lllinois
Department of Transportation District 8, Job No.
D-98-120-93,47 p.
Sanderson, E.W., A.P. Visocky, M.A. Collins, R.D. Olson, and C.H. Neff, 1984,
Dewatering Well Assessment for the Highway Drainage System at Four Sites in
the East St. Louis Area, lllinois (Phase
I), Illinois State Water Survey Contract
Report
341,48 p.
Schicht, R.J., and A.G. Buck, 1995,
Ground-WaterLevels and Pumpage in the Metro-East
Area, Illinois,
1986-1990, Illinois State Water Survey Circular 180, 44 p.
/DOT
Bowman Avenue Pump Station
Andrews Engineering,
Inc.
Petition
for
Adjusted Standard
June 2007
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
IDOT Bowman Avenue Pump Station
23
Petition for Adjusted Standard
Andrews Engineering, Inc.
June 2007
Figure 1
Schematic of Bowman Yard Discharge
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
lle:
J:\lDO~OO6\lDoTZoO6-OO3\DWG\WO-OO3
WPrevl-26-07.dwg
Tob: Schernotlc
User: rnnguyen
Plotted: Jun 04. 2007
-
1:35 PM
FROM MISSOURI AVENUE
WELL FIELD
5.3 MGD
~-----------*------
1
I
I
I
I
I
I
I
I
I
FROM TRI-LEVEL, 1-64 AND 25th
STREET WELL FIELDS 9.5 MGD
EXISTING STORM
-7-
SEWER
EXISTING
AVENUE
PUMP
STATION
I
TO UNNAMED TRIBUTARY OF THE
I
SCHOENBERGER CREEK THENCE TO
I
CAHOKIA CANAL 14.8 MGD
I
EXISTING
72"
DIA.
GRAVITY DISCHARGE
PIPE
NOT TO SCALE
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
IDOT Bowman Avenue Pump Station
24
Petition for Adjusted Standard
Andrews Engineering, Inc.
June 2007
Figure 2
Location of East St. Louis Dewatering Sites
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
IDOT Bowman Avenue Pump Station
25
Petition for Adjusted Standard
Andrews Engineering, Inc.
June 2007
Figure 3
Locations of Dewatering Wells at the I-70 Tri-Level,
I-64 and 25th Street Sites
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
IDOT Bowman Avenue Pump Station
26
Petition for Adjusted Standard
Andrews Engineering, Inc.
June 2007
Figure 4
Locations of Dewatering Wells at Missouri Avenue Site
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
File: ~\IOOT2006\IDOT2006-003\DWG\WO-003
Wrevl-26-07.dwg
Tob: Figure4
User:
rnnguyrn
Plotted: Jon 26. 2007
-
10:03 AM
SCALE:
IN FEET
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
IDOT Bowman Avenue Pump Station
A
Petition for Adjusted Standard
Andrews Engineering, Inc.
June 2007
Appendix A
Site Location Map
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
3
SITE LOCATION MAP
PLANS PREPARED FOR
ILLINOIS DEPARTMENT OF TRANSPORTATION
@
AND
BOWMAN
ASSOCIATED
AVENUE
DEWATERING
PUMP STATION
SITES
INTERSTATES 55670
&
64
FAST ST 1 nlll$ ST PI A1 CnllNN I1 I INnlS
%
a$
qSs5
$!sf
$*
P
s8
ANDREWS ENGINEERING, INC.
REMIONS
3300 Clnger
03
Drive. Sprlngfleld, L 62711-7233
Tel (217) 787-2334
Fox (217) 787-9495
Kntlac, IL
.
Napmille, IL lndlanapolls, IN
.
Worrenton, MO
DE~CRIP~
BY
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
IDOT Bowman Avenue Pump Station
B
Petition for Adjusted Standard
Andrews Engineering, Inc.
June 2007
Appendix B
Geologic Cross Sections
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
1-64
FINE-
TO
CPARSE-GRAINED UND
WD
AND
GRAYEL
MDmY
GRAKL, CC8LES
BWUIERS
BEDRW-ULlmONE
g
WATER
LEVn
HD((RD!4TN
SCALE IN
0
mp
a PUMP
GRAPHIC SCALE
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
I
TRI-LEVEL
25TH STREET
MISSOURI
AVENUE
B'
D
NE!
C
SOUTH
C'
NORTH
FEET
MSL
420
-
FEET
MSL
B-211
41
6.80
-
420
FEET
W-5(75)
MSL
41
6.00
W-2(75)
W-4(75)
420-
W-1175'1
AIR
nn
41
5.00
FEET
MSL
420
-
FEET
MSL
-
420
FEET
MSL
-
420
320-
310
-
Mo-
m-
@
CROSS SECTION LOCATIONS MAP
FINE-
m
ams-c~a~rn
sum
SAND AND
CRAKL
)IIm
CRAWL
cc%LEs
BWLC€RS
BEORW-uumi
HWdZONW
SCU
IN
FEET
GRAPHIC SCALE
0
TW OF PUMP
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
IDOT Bowman Avenue Pump Station
C
Petition for Adjusted Standard
Andrews Engineering, Inc.
June 2007
Appendix C
Bowman Avenue Pump Station and Missouri Avenue Well Field
Historical Water Quality Data
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Appendix C
[DOT District 8 Bowman Avenue Pump Station
Historical Water Quality Data (Monthly DMR Grab Sample)
Parameter:
Total Sulfate
Total Dissolved Solids
Units:
mglL
mglL
Number of samples:
57
57
Number of
ND's:
0
0
Minimum:
233
988
Maximum:
580
1280
Mean:
380.771 9
1097.3333
STD:
66.4421
48.2439
% Relative Standard Deviation:
17.9746
4.3965
Prediction Limits
Proposed
95%
Prediction Limit:
496.2426
1178.7271
Existing Standard:
500
1000
TPD Proposed Standard:
750
1500
#of Standard Deviations from the Mean
Proposed
95%
Prediction Limit:
1.69
1.69
Existing Standard:
1.74
2.02
TPD Proposed Standard:
5.39
8.35
Mean within
2 - 3 Standard Deviations
2 STD
517.66
1193.82
3 STD
586.1 0
1242.07
Data Values
Note:
c
indicates a non detect
Bowman Yard
intelwell 95% all data (2006)
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Appendix C
IDOT DistrMissouri Avenue
Historical Water Quality Data
mglL
mglL
Parameter:
Total Sulfate
Total Dissolved Solids
Units:
mglL
mglL
Number of samples:
27
27
Number of
ND's:
0
0
Minimum:
179
746
Maximum:
642
1390
Mean:
290.7857
911.8214
STD:
88.9370
120.5332
% Relative Standard Deviation:
30.5851
13.2189
Prediction Limits
Proposed
95% Prediction Limit:
445.2619
1121.1775
Existing Standard:
500
1000
# of Standard Deviations from the Mean
Proposed
95% Prediction Limit:
1.74
1.74
Existing Standard:
2.35
0.73
Mean within
2 - 3 Standard Deviations
2 STD
468.66
1 152.89
3 STD
557.60
1273.42
Note:
c
indicates anon detect
Andrews Engineering, lnc.
J:\IDOT2006\1D0T2OO6-OO3\Analytical\Backgrounds\lDOT CALCS for Adjusted std Missouri
Data Values
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
IDOT Bowman Avenue Pump Station
D
Petition for Adjusted Standard
Andrews Engineering, Inc.
June 2007
Appendix D
Bowman Avenue Pump Station and Missouri Avenue Well Field
Graphs of Parameters versus Time
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Bowman Avenue Pump Station
Grab Sample
Total Sulfate
(mg/L)
2003 to Present
+Grab
-
Limit
Andrews Engineering, Inc.
Grab Graphs (2006)
SO4
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Bowman Avenue Pump Station
Grab Sample
Total Dissolved Solids
(mg/L)
2003 to Present
I
+Grab
I
Limit
I
Andrews Engineering, Inc.
Grab Graphs
(2006)
TDS
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Missouri Avenue Well Field
Individual Deep Well Samples
Total Dissolved Solids
(mg/L)
~Missouri
- 1
--$r Missouri - 2
-+
Missouri - 3
+Missouri
- 4
IIllIlIIIIIIlIIIllIl11111111l111111111IIlIIIIJIIIIIIIIlIIIIl
Andrews Engineering, Inc.
Graphs Individual (2003
- 2006)
TDS (Mo)
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Missouri Avenue Well Field
Individual Deep Well Samples
Total Dissolved Solids
(mg/L)
-+-Missouri - 1
-A- Missouri - 2
+Missouri
- 3
-+
Missouri - 4
Andrews Engineering, Inc.
Graphs Individual (2003
- 2006)
TDS (Mo) (2)
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Missouri Avenue Well Field
Individual Deep Well Samples
Total Sulfate
(mg/L)
clclc-
Missouri - I
-iP Missouri - 2
+ Missouri - 3
+ Missouri - 4
Andrews Engineering,
Inc.
Graphs Individual (2003 - 2006)
SO4 (Mo)
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Missouri Avenue Well Field
Individual Deep Well Samples
Total Sulfate
(mg/L)
--h- Missouri - 2
+Missouri
- 3
+ Missouri - 4
Andrews Engineering, Inc.
Graphs Individual (2003
- 2006)
SO4 (Mo) (2)
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
IDOT Bowman Avenue Pump Station
E
Petition for Adjusted Standard
Andrews Engineering, Inc.
June 2007
Appendix E
Individual Deep Pumping Wells Historical Water Quality Data
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Appendix E - Individual Deep Pumping Wells
(25th St./I-55 TRI-Level/I-64/Missouri Ave.) - Historical Water Quality Data
Min
Max
Mean
Min
Max
Mean
Min
Max
Mean
Well
Analyte
Units
Limits
Oct-03
Dec-03
Feb-04
Mar-04
May-04
Aug-04
Nov-04
Feb-05
33.5
336
91.03304
25th St.-2
Chloride, total
mg/L
41.4
35.4
46.7
43.1
45.5
80.4
47.5
35.4
80.4
48.57143
25th St.-4
Chloride, total
mg/L
38.4
37.3
38.7
40.1
41.3
85.4
55.3
37.3
85.4
48.07143
25th St.-7
Chloride, total
mg/L
38.4
33.5
34.7
35.2
41.4
51.9
33.5
51.9
39.18333
25th St.-8
Chloride, total
mg/L
37.4
33.5
40.7
37.2
41.7
51.4
33.5
51.4
40.31667
33.5
85.4
44.36538
I55 - 04
Chloride, total
mg/L
68
85.2
94.3
87.1
93.4
111
75.3
68
111
87.75714
I55 - 05
Chloride, total
mg/L
112
106
69.5
97.8
134
69.5
134
103.86
I55 - 06A
Chloride, total
mg/L
89.7
101
96.3
92
82.9
100
93.9
82.9
101
93.68571
I55 - 09A
Chloride, total
mg/L
67
67
67
67
I55 - 10
Chloride, total
mg/L
85.7
74.7
71.5
88.6
71.5
88.6
80.125
I55 - 11A
Chloride, total
mg/L
72.9
77.5
89.3
82.2
79.8
68.5
85.1
68.5
89.3
79.32857
I55 - 12A
Chloride, total
mg/L
55.2
85.2
98.3
86.1
86.3
93.3
94.4
55.2
98.3
85.54286
I55 - 13
Chloride, total
mg/L
79.4
94.3
82.2
85.8
79.4
81.2
79.4
94.3
83.71667
I55 - 15
Chloride, total
mg/L
113
105
108
103
132
103
132
112.2
55.2
134
89.67959
I64-19
Chloride, total
mg/L
168
166
175
173
85.2
191
158
85.2
191
159.4571
I64-20
Chloride, total
mg/L
315
297
275
111
290
336
333
111
336
279.5714
85.2
336
219.5143
Missouri - 1
Chloride, total
mg/L
71
87.1
68.5
71.4
71.4
68.5
87.1
73.88
Missouri - 2
Chloride, total
mg/L
80.8
76.6
76.4
69.5
64.2
39.7
82.2
39.7
82.2
69.91429
Missouri - 3
Chloride, total
mg/L
64.1
69.9
72.5
63.6
61.6
69
70.4
61.6
72.5
67.3
Missouri - 4
Chloride, total
mg/L
77.9
80.4
83.9
78.3
80.4
39.7
77.3
39.7
83.9
73.98571
39.7
87.1
71.06923
Well
Analyte
Units
Limits
Oct-03
Dec-03
Feb-04
Mar-04
May-04
Aug-04
Nov-04
Feb-05
0.1
2.69
0.525621
25th St.-2
Fluoride, total
mg/L
0.26
0.801
0.8
0.757
0.669
0.73
0.386
1.16
0.26
1.16
0.695375
25th St.-4
Fluoride, total
mg/L
0.82
0.259
0.22
0.27
0.1
0.162
0.285
0.226
0.1
0.82
0.29275
25th St.-7
Fluoride, total
mg/L
0.26
0.271
0.22
0.259
0.1
0.196
0.223
0.1
0.271
0.218429
25th St.-8
Fluoride, total
mg/L
0.32
0.305
0.23
0.276
0.1
0.188
0.408
0.1
0.408
0.261
0.1
1.16
0.375367
I55 - 01A
Fluoride, total
mg/L
2.27
2.27
2.27
2.27
I55 - 04
Fluoride, total
mg/L
1.41
0.312
0.26
0.263
0.13
0.199
0.266
0.273
0.13
1.41
0.389125
I55 - 05
Fluoride, total
mg/L
0.325
0.299
0.245
0.403
0.288
0.245
0.403
0.312
I55 - 06A
Fluoride, total
mg/L
0.43
0.413
0.36
0.365
0.258
0.335
0.442
0.389
0.258
0.442
0.374
I55 - 09A
Fluoride, total
mg/L
0.26
0.236
0.236
0.26
0.248
I55 - 10
Fluoride, total
mg/L
0.47
0.463
0.29
0.226
0.212
0.212
0.47
0.3322
I55 - 11A
Fluoride, total
mg/L
0.38
0.319
0.39
0.395
0.275
0.385
0.978
0.544
0.275
0.978
0.45825
I55 - 12A
Fluoride, total
mg/L
0.29
0.271
0.26
0.276
0.1
0.26
0.328
0.278
0.1
0.328
0.257875
I55 - 13
Fluoride, total
mg/L
0.59
0.282
0.115
0.171
0.386
0.882
0.115
0.882
0.404333
I55 - 15
Fluoride, total
mg/L
0.28
0.167
0.261
0.39
0.312
0.167
0.39
0.282
0.1
2.27
0.386732
I64-19
Fluoride, total
mg/L
0.34
2.12
2
1.95
1.56
2.32
2.36
2.02
0.34
2.36
1.83375
I64-20
Fluoride, total
mg/L
0.34
1.44
1.5
1.61
1.38
1.8
1.82
2.69
0.34
2.69
1.5725
0.34
2.69
1.703125
Missouri - 1
Fluoride, total
mg/L
0.36
0.315
0.32
0.323
0.167
0.286
0.167
0.36
0.295167
Missouri - 2
Fluoride, total
mg/L
0.33
0.343
0.38
0.281
0.1
0.335
0.806
0.341
0.1
0.806
0.3645
Missouri - 3
Fluoride, total
mg/L
0.32
0.338
0.34
0.333
0.183
0.32
0.329
0.283
0.183
0.34
0.30575
Missouri - 4
Fluoride, total
mg/L
0.32
0.286
0.29
0.276
0.124
0.269
0.243
0.273
0.124
0.32
0.260125
0.1
0.806
0.307133
by Parameter
by site
within each well
* System - Well # (ex. I55 - 01A) = Individual Well System followed by the specific well from the system.
Andrews Engineering, Inc.
6/7/2007 10:02 AM
1 of 2
J:\IDOT2006\IDOT2006-003\Analytical\Bowman Yard Data May 1994 to Present
Parameter (rev2)
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *
Appendix E - Individual Deep Pumping Wells
(25th St./I-55 TRI-Level/I-64/Missouri Ave.) - Historical Water Quality Data
Min
Max
Mean
Min
Max
Mean
Min
Max
Mean
by Parameter
by site
within each well
Well
Analyte
Units
Limits
Oct-03
Dec-03
Feb-04
Mar-04
May-04
Aug-04
Nov-04
Feb-05
586
2350
1081.364
25th St.-2
Solids, Total Dissolved (TDS)
mg/L
1000
1350
1370
1400
1320
1240
1300
939
1560
939
1560
1309.875
25th St.-4
Solids, Total Dissolved (TDS)
mg/L
1000
724
712
719
738
756
697
1040
810
697
1040
774.5
25th St.-7
Solids, Total Dissolved (TDS)
mg/L
1000
639
648
655
661
639
675
706
639
706
660.4286
25th St.-8
Solids, Total Dissolved (TDS)
mg/L
1000
641
586
644
691
686
677
886
586
886
687.2857
586
1560
870.3
I55 - 01A
Solids, Total Dissolved (TDS)
mg/L
1000
1170
1170
1170
1170
I55 - 04
Solids, Total Dissolved (TDS)
mg/L
1000
775
812
932
972
883
924
1130
818
775
1130
905.75
I55 - 05
Solids, Total Dissolved (TDS)
mg/L
1000
993
997
688
1020
972
688
1020
934
I55 - 06A
Solids, Total Dissolved (TDS)
mg/L
1000
806
784
782
792
772
676
736
772
676
806
765
I55 - 09A
Solids, Total Dissolved (TDS)
mg/L
1000
1040
1040
1040
1040
1040
I55 - 10
Solids, Total Dissolved (TDS)
mg/L
1000
1120
1180
1120
1130
1070
1070
1180
1124
I55 - 11A
Solids, Total Dissolved (TDS)
mg/L
1000
1210
1150
1190
1190
1280
1140
999
1210
999
1280
1171.125
I55 - 12A
Solids, Total Dissolved (TDS)
mg/L
1000
717
973
1220
1330
1160
1200
1300
1280
717
1330
1147.5
I55 - 13
Solids, Total Dissolved (TDS)
mg/L
1000
1040
1100
1100
1070
983
1050
983
1100
1057.167
I55 - 15
Solids, Total Dissolved (TDS)
mg/L
1000
980
1020
828
924
864
828
1020
923.2
676
1330
1007.393
I64-19
Solids, Total Dissolved (TDS)
mg/L
1000
1780
1800
1840
1860
1810
1770
1840
1630
1630
1860
1791.25
I64-20
Solids, Total Dissolved (TDS)
mg/L
1000
2210
2290
2350
2280
2210
1830
2070
2260
1830
2350
2187.5
1630
2350
1989.375
Missouri - 1
Solids, Total Dissolved (TDS)
mg/L
1000
831
836
942
813
879
866
813
942
861.1667
Missouri - 2
Solids, Total Dissolved (TDS)
mg/L
1000
963
933
856
957
808
883
1390
938
808
1390
966
Missouri - 3
Solids, Total Dissolved (TDS)
mg/L
1000
963
943
935
970
916
948
954
970
916
970
949.875
Missouri - 4
Solids, Total Dissolved (TDS)
mg/L
1000
990
1060
1050
1070
1050
979
746
948
746
1070
986.625
746
1390
946.2333
Well
Analyte
Units
Limits
Oct-03
Dec-03
Feb-04
Mar-04
May-04
Aug-04
Nov-04
Feb-05
108
1420
392.1515
25th St.-2
Sulfate, total
mg/L
500
377
876
1420
711
569
685
227
716
227
1420
697.625
25th St.-4
Sulfate, total
mg/L
500
256
315
249
202
141
205
250
205
141
315
227.875
25th St.-7
Sulfate, total
mg/L
500
198
273
236
172
141
240
201
141
273
208.7143
25th St.-8
Sulfate, total
mg/L
500
259
349
231
226
139
188
302
139
349
242
139
1420
351.9667
I55 - 01A
Sulfate, total
mg/L
500
368
368
368
368
I55 - 04
Sulfate, total
mg/L
500
219
256
381
287
220
341
247
224
219
381
271.875
I55 - 05
Sulfate, total
mg/L
500
388
250
139
275
245
139
388
259.4
I55 - 06A
Sulfate, total
mg/L
500
202
237
225
159
146
184
108
232
108
237
186.625
I55 - 09A
Sulfate, total
mg/L
500
368
438
368
438
403
I55 - 10
Sulfate, total
mg/L
500
388
466
272
329
457
272
466
382.4
I55 - 11A
Sulfate, total
mg/L
500
589
500
482
426
401
491
289
431
289
589
451.125
I55 - 12A
Sulfate, total
mg/L
500
307
419
461
487
522
670
342
516
307
670
465.5
I55 - 13
Sulfate, total
mg/L
500
368
308
289
593
248
295
248
593
350.1667
I55 - 15
Sulfate, total
mg/L
500
368
251
248
183
181
181
368
246.2
108
670
334.2143
I64-19
Sulfate, total
mg/L
500
1190
938
798
603
486
833
478
708
478
1190
754.25
I64-20
Sulfate, total
mg/L
500
1340
1010
871
683
748
945
762
951
683
1340
913.75
478
1340
834
Missouri - 1
Sulfate, total
mg/L
500
301
257
280
188
241
257
188
301
254
Missouri - 2
Sulfate, total
mg/L
500
340
288
267
281
179
301
642
447
179
642
343.125
Missouri - 3
Sulfate, total
mg/L
500
365
326
295
260
248
335
247
289
247
365
295.625
Missouri - 4
Sulfate, total
mg/L
500
405
360
316
344
265
373
181
267
181
405
313.875
179
642
304.8333
* System - Well # (ex. I55 - 01A) = Individual Well System followed by the specific well from the system.
Andrews Engineering, Inc.
6/7/2007 10:02 AM
2 of 2
J:\IDOT2006\IDOT2006-003\Analytical\Bowman Yard Data May 1994 to Present
Parameter (rev2)
Electronic Filing, Received, Clerk's Office, June 8, 2007
* * * * * * AS 2007-007 * * * * * *