1. Appendix B
  2. Chemical Probability PlotsLower Des Plaines RiverUse Attainability Analysis
  3. Appendix C
  4. Attachment A
  5. Appendix D: Water Quality Modeling for the Lower
  6. Des Plaines River
  7. EmreAlp
  8. Charles Melching
      1. 1-2-3 4-5-6
      2. 1-2-3 4-5-6
  9. Appendix E
      1. 0:: 10
      2. Sample Stations
      3. Assessment Area
    1. Assessment Area
    2. IIlHD2000i
      1. Sample Stations
      2. Sample Stations
      3. IIIHD 2000]
      4. Sample Stations
    3. .s::: 30
    4. o 20
      1. Sample Stations
    5. Sample Stations
      1. Sample Stations
      2. Sample Stations
      3. Sample Stations
      4. 20 f-
      5. Sample Stations
      6. Sample Stations
      7. Sample Stations
      8. Sample Stations
      9. Sample Stations
    6. Assessment Area
      1. Sample Stations
      2. o 0.3
      3. Sample Stations
      4. Sample Stations
      5. Sample Stations
  10. International, Ltd
      1. PAGElS
      2. PAGEl6
  11. Response to Comments, Chapter 5
      1. Review of the Lower Des Plaines River Use Attainability Analysis
      2. (UAA) Draft Report
      3. APPENDIX 1
      4. Review of the Lower Des Plaines River Use Attainability Analysis
      5. (UAA) Draft Report
      6. APPENDIXl

Attachment A
Appendix A: IEPA Documents

ILLI~OIS
POLLUTION CONTROL BOARD
November
8
t
1973
IN THE
~~TTER
OF UATER QUALITY
STANDARDS REVISIO':JS
OPINW:i OF THE BOARD (by
~ir.
Dumelle):
)
)
)
)
R72- 4
This Opinion of the Board is in support of
a~endments
to Cha?ter
3 of the Pollution Control BoardTs Water Pollution Regulations
adopted on June 28) 1973.
These ainendmentS; i,-ere consolidated
frCI:T)
revisions proposed by the
Board~
the Environmental Protection
Agency (Agency), Granite City Steel, The Metropolitan
Sani~ary
District of Greater Chicago (MSDGC) , and Commonwealth
Edi~Jn Corr~anv.
After reviewing the recorl produced in ten hearings, the Board
a~cpied
the aIi1endr.le-r.-::s as publishe:' in the Nel'lsletter #65,
May
17,
1973~
with tHO revisions
that Here published in Ne\'lslette-r #69,
J~ly
16,
197.3.
The A;:endncnts
were
first published in
~el\'51ette:::
#50) Jull' 14,
1972. He<;rings
i'[&N
held in six cities throughout Illinois.
1.
The first group of amendrr:ents Viere proposed
by
the Board_
An ar.tendment to Sec.
406
Nitros:er.
\<:a5
proposecl and ado";?ted to
control ind.ustrial dischargers ot
l'lOre
thsil 100 Ibs. of ammonia
as N, whose waste10ad cannot be computed on a population equivalent
(PE) basis. Such industrial discha.rgers 'Ivho' discharge into the
Illinois River, Chicago River Systera or Calumet River System. loli11 be
subj eet to an ammonia effluent standard of 3.0 mg/l as
~~
after
December
3l~
19i4.
The Board found that present technology is
cap:;ble of meeting this limit and should result in the rer.wval of
much
an~onia
nitrification oxygen demand (NOD) from these stressed
waterl';ays. Ammonia removal fro;!! such industrial wastes, \'lhe:l
COI:1-
pared with removal frcm domestic wastes is rather easily applied
CR. 25, Septenber 13) .1972).
The definition of tti.:atcr
rt
in Section 104 Defini ticns was
amended
by
the Board to add a clause that allows the use of in-stream
aeration under Agency permit.
Another Board uroDosal would have allowed the Agency to require
bends as a condi
t.io~
to ooto.in an Agency permit.
After considcriJ1.g
their
Tevision~
the Board declined to adopt the proposed new Section
926.

----_.
--~
--
....... :2-
2.
Another group 0: 2ncndmcnts
w~ich
were pLoposec by the Agency,
were received on Apri: 7, 1972. The first. of. the Agency proposals
was to amend Section 103 Renea1s to repeal SWB-2 and SWB-17, and
to replace SWB-2 Kith a new Part XII: Treatment Plant Operation
Certification.
S~B-2
and SWB-17
~ere
adopted
by
the Illinois Sanitary
Water Board and ccr,,;:m:ed in effect by Section. 4S}(c) of the
Environnental Protection Act " un'til repealed, :a.rnended, or superseded .
by regulations :Jild.8r this Act." SII'B-2 set rigid regulations that goveTned
the certification of treatment plant operators by the Agency. The
Agency
desired this amendment to permit then a greater flexibility
to change certi:i:icu.tion requiremeats with technological developments.
As a result of discussion concerning this amendment the Agency proposed
an addition to Part XII to insure that an applicant could appeal
his certification denial to the Board. The Board adopted the repeal
of
S~~-2
and tte addition of Part XII in order to allow the Agency
to cope l'ith various problems such as hol' to certify the 400
~·ISDGC
plant operators. The Agency sought the repeal of SWB-17 because
of language that sight be construed to conflict with the act which
gives the Agency
excl~sive
control of
~he
administration of Federal
grant monies, The Beard agreed and amended Section 103 to repeal
SWB-17 which had set out Lules for establishing priorities for
awarding Federal nanies in order to avoid any conflict with the Act.
The next portion of the Agency proposal dealt with a relatively
minor group of amendr.:(mts to correct or supply missing STORET :-;Ubl3ERS
in the follcwing
Sec~ions:
203(£), 204(b), Z06(c), and 408(a).
The Agency
PTopo~cd
a correccion of a typographical error in the
placemeIlt of the phrase "for excess energy" ',ithin Section 104
Definitions "I ..custrial I':astes". A correction of misspelled words
in Section 501, 502 and 912 was also proposed.
The Board adopted
these changes as published in Ke'isletter #65, May 17, 1973.
The Agency proposed to amend Section 302 Restricted Use Waters
by adding a clause to require that the Board
h~ld
aearings in 1973
and every 5 years
thereaf~er
to determine whether any Restricted
Use Water should be reclassified as a General Dse Water. This
amendment is in response to the Federal Environmental Protection
Agency
(U.S. EPA) policy not to approve restricted use
status as a permanent status for any water CR. 11, September 13,
1972 and Ex. #4).
In addition to the Federal objection, the
revision would give notice to those who are currently discharging
into !<.estricted Use Waters that they are not p.ernanently guaranteed
such use CR. 12,
Septe~ber
14, 1972).
The Board agreed with the
Agency's reasoning and "dDpted its amendrr:en1: to reflect a limitation
on the Restricted Use designation.
The Agency proposed a
chan~e
in Section 404(fj(ii)B to substitute
"the levels set
by
the applicable Hater quality standard" for the
previously specified numerical DO level. The Board approved this
clarification and adopted the amendment.

- 3-
The Agency proposed amending Section 405 Bacteria by addition
of "governed. by this part" to clarify the "'ordIngwhich requires
disinfection of
co~bined
overflows by July 31, 197Z. The deletion
of the language referring to S\'iB,7 through Sl\'B-lS ,.as also proposed.
The Agency also proposed establishing a later deadline of
Dece~her
31,
1973 for discharges into the Ohio and MississipPi Rivers. Regulations
passed by the Board in 1971 (R,
70-3
and 71-3) required disinfection
of combined overflows discharging into the Ohio and Mississippi
Rivers by Deceuber 31, 1973.
w11en the Board amended this regulacion
in R70-7, 71-14 and 71-20 it unintentionally accelerated the deadline
fA~
Ohio and Mississippi River discharges. The Board ad.opted this
amendment to correct a previous error.
The Agency proposed that Section 406 Nitrogen be amended to
include the Des Plaines
do~~stTe&~
of its confluence with the
Chicago River System in those waters which have an effluent li",ita-
tion on
.&~monia.
The Board approved this amendment because it
conforms to the Boa::d's original in-tent when it placed ammonia
effluents on the other waterways listed in this Section.
The Agency proposed a specific standard of 0.025 mg/l as a
limit for discharges- of;
cYa~ide
into a public sewer system.
Section 702(a) Cyanide prev:Lously had read. "detectable levels of
cyanide". The Board adopted this as a parallel to the llfater Quality
Standard of 0.02S mg/l found in Section 203.
The Agency proposed the deletion of "by the Agency" in Section
942 Permit Revocation to conform to the Board's desire that all
permit
revoc~tions
take place only as a result of a complaint and
action brought before the Board. The Board amended Section 942
to conform with this policy.
3.
Granite City Steel Company proposed an amendment to reclassify
Horseshoe Lake frem Public and Food Processing Water Supply to
General Use (Section 303). The Board received the proposal on
July 6, 1972. The basis for their request was that Horseshoe Lake
had never and would never be used
fOT
a public or food processing
water supply and thus should not be classified as such. Various
company officials 50 testified in support of their proposal CR. 32,
84, and Ill, September 22, 1972). Granite City Steel's Engineering
Consultant,
~r.
John Huston, testified that the Lake did not meet
the drinking 1vater standards required as a source of public waters.
The Agency testified that in their view an amendment of the rules
regarding Horseshoe Lake is not needed at the present time CR, 10,
Septesber 22, 1972), The Board finds that there is no need to
reclassify Horseshoe Lake as a general use
wat~r
(Section 301) and to
---"'-'---tili:e
it-out'of-Section 303 Public and Food Processing
\','ater Sup;;1y

~~.....-...--
.._- ..
._.-
.
- N4-
~ecause
of the extreme
unlikelihood that the Lcke will ever be
used as
~
Dublic water supply and thus such standards may never
become operative.
4.
The NSDGC proposed an amendment to Section 404(e) Deoxygenating
Wastes to change tha effluent limits to 10 mgll BODS and 12 mgll
suspended solids (55) frem 4 rng/l
BODs
and 5 mg/l SS. The Board
received the proposal on April 2S, 1972. At the hearing, the
Agency stated that they did not oppose the amendment (R. 17, 9/13/72).
The original purpose of reqUiring the MSDGC to
mee~
a 4 mg/l BOD
p
and 5 mg/l S8 Has to remove deoxyger.ating wastes from their
effl~ent
and thus allow the DO in the aownstream waterways to reach the level
prescribed by the existing standard. During periods of low flow up
to 99% of the flow in the sanitary district's controlled waterways
is made of M5DGC effluent.
...,
Evidence presented
By
1'11';- Ralph Evans , Illino-i-s Water Quality
Survey, tends to Show that, even with the
~SDGC ~eeting
the 4-5
effluent standard, the Illinois River at Marseilles and Starved
Rock will not meet the DO standard of 6 and will be in fact less
than 4 reg!l DO CR. 114, 10/19/72). Even if the oxygen demand
exerted by nitrofication of a","lIonia (NOD) ..'ias zero, the lilodel
predicts that a DO level of 6 is not obtainable (R. 124, 10/19/72).
Mode1i:p.g conducted by th.e ,,1SDGC also predicts that both 4 mg!l
BOD~
and 5 mg/l 55 and 10 mg!l BOD, and 12 mg/1 55 will not achieve
a De level of 6 mg/l CR. 283, 10/l9!72),
.
The MSDGC proposed to amend the standard to require
the~
to
meet 10-12 instead of 4-5. They propose to carry out instrearn-
aeration to raise the DO level to 6.0 mg/l. MSDGC presented modeling
evidence that showed an effluent of
4~S
would result in an instream
BODs level of 2.4 mg!l with a DO level of 4.4 mg/l; while an effluent
of 10-12 would result in an instream BOD level of 2.6 mg/l with a
00 level of 4.2 mg/l (R. 17, 10/20/72). SEvidence sho\'Js the predicted
Cost of meeting the 4-5 standards is $236.7 million dollars with an
operational cost of $26 million dollars. The cost of 10-12 with
instream aeration is $138.8 million dollars with an operating cost
of $16 million dollars per year (R. 19, 10/20/72).
Two eminent professionals, Clair Sawyer and General Whipple,
both. testified that the most econotiic Way for the HSDGC to meet
the required DO levels is by 10-12' and iTIstream aeration (R .. 223,
235,
10/20/72). Dr. Sawyer testified the downstream DO problens
should be elininatcd once the MSDGC
begin~
to remove the
~OD
by
nitrification CR. 248, LO/20/72). Every pound of NOD is equal
to 4.57 pounds of BOD
CR. 2S4, lO/ZO/n}.
Dr.
Sa\~)'er
testified
that the
~OD
(nmmoniaSoxygen demand) could be easily reduced
below 2.5 mg/l (R. 257, 10/20/72).
~--
-'-
._-
---"-' - --
~_._-

-5-
- "'--'--'" ,
g-
The'Board
de~ided
to delete Section 404(b) instead of
amendi:lg it :lS proposed
by
the
~,ISDGC.
By
deleting the requirClf..0nt,
the intention of
~he
Board (reading both Section 404(c) and (f)
together) \.:as to require the }.[SDGC to meet 4 mg/l of BODS and
5 mg/l of 5S
by
Docenter 13, 1977 unless it can show through
Section 404(£) (ii) th:J.t such an effluent standard is not required.
In the event that MSDGC can meet 'the burden required in Section 404
(f)(ii) it is subject to an effluent standard of 10 mg!l of BODS
and 12
mg/l
of S5.
(See pages 14-16, of the Board's Opinion
accom?anying R7D-B, 71-14 and 71-20, for the reasoning supporting
the creation of a conditional exemption frorn the 4
~g/l
BODS
and S mgll S5 linit). The Board based its decision upon the
modeling evidence presented and by the testimony which showed
that DO standard would be met by 10 mgjl, BODs and 12
mg/l
of
55, in-stream aeration and nitrification.
S.
Commonwealth Edison proposed an amendment in the alternative
on
~farch
30, 1972, to loosen the
·.'~mperature
standard on the Des
Plaines River below the Interstate 55 bridge to its confluence with
th.e Kankakee River (hereinafter cited as "5 mile stretch
Tl
).
The
first alternative ";auld have amended Section 302(i) Restricti'.." Use
Waters to delete the phrase "to the Interstate 5S bridge" and replace
lt with the phrase "to its confluence \-lith the Kankakee
~iver."
Edison
t
s second alternative \-lould have amended Section 203(i) (4)
by
adding "Des Plaines River from the Interstate 55 bridge to its con-
fluence with the Kankakee River.
Temperature in this
segme~t
uf
the Des Plaines River shall not exceed ,.ZoF more than five nercent of
the time, by more than 5°F."
In response to a reques t frorr..
Hearing Officer Parker to
tigh:~n
up its proposal to reflect the
minin;,),J:: temperatures possible, Edison ,.lithdreH its original ar.!cnd;r.er:.ts
on :-.'oye::lber 29, and substituted an amendment to Section 203(i) (4) '"hie}:
proposed indiVidual
~onthly
temperature limits,
cQrrespondi~g
to
historical data, for the "5 mile stretch". This final amenciiJent also
contained a 5% excursion up to SOF maximum from the monthly limits.
CoJ:.J;l.on,...ealth Edison's Joliet Plant is located on the
Des Plaines River 7.3 miles upstream of the I-55 bridge. Heated
water 5rom both the old and new portions of the plant is discharged
to the river
th~cugh
once-through cooling systems. After the heated
water is discharged it nixes with the River water and gradually
cools as heat
dissi~ates
to the atRosuhere.
The river water
temperucure,
grad~aily
decreases with. distance
dOh~stTear.i
from
the power plant. Edison prcsented evidence that the wator does
not cool sufficient:!.)' by the time it reaches the I-55 bridge to raeet,
the geneysl usc tCl1pcrature limits during July and August. 'The
temperature at the I-55 bridgc would be the highest in the "5
~ile
stretch" (Ex. #3, Edison Ex. 25, page S).

-6-
The final pToposed ame:r.dr:lent
dro~ped
ta"e'-alternative to amend
Section 302(i) and proposed individual monthly temperature
li~its
for the five mile stretch from I-55 bridge to the confluence with
the Kankakee River.
The Board adOlHed the final Edis on amendment
as published with
so~e
exceptions.
It set 900F as the rnaxirnuc
temperature standard for the months of July and August and reduced
the excursion to four percent of the previous twelve month period.
"The Board also set an automatic termination date of July 1, 1978
at which tir.te the general use temperature standard will again apply.
Edison desired to amend the tem?erature limit to avoid the
necessity of prOViding cooling for its Joliet Power Plant which
consists of two parts located on either side of the Des Plaines
River some 7.3 miles
upstrew~
from the I-55 bridge. (R. 32, 9/8/72)
The Board in a previous decision adopting the revised Water
Quality Standards CR. 71-14, March 7, 1972) classified the Des
Plaines Riyer from the confluence with the Canal at Lockport to
the I-55 bridge as "restricted" use water (Sec tion 302 (i) . Its
temperature limits are 93°F (not to be exceeded mOre than 5% of
the time) or lOOgF at any time (Section 205(f). At the I-55
bridge, a discontinuity in temperature limit exists as the river
below the bridge is classified as a "General U;se" 'vater with the
more restrictive ,,.ater temperature limi ts
cont,aine~1
in Rule
203(i)
(4).
The basis for the Board's decision to use the I-55 ]lridge as a
boundary fer the ciivision of the Des ?laines Riyer into restrictive
and general use is that the location of the bridge corresponds to
changes in the physical
environ~ental
characteristics of the
area CR. 71-14 at page 11, ?clarch 3, 1972). Above the bridge, the
riyer has been greatly altered by man so that it is not as suited for
recreation, (Ex. #3, Edison
~x.
25, page 4) amd water quality is such
t~a
at the present time it is not capable of sUDporting a diverse
aquatic life (Ex. '3, Edison Ex. 25, page 4). Edison witnesses expressly
excluded the 5 mile stretch below the bridge, from possessing the
characteristic that led the Board to classify the upper river as
Restrictive Use.
The Board previously decided that the I-55 bridge should be
the dividing line between the upstream Restrill:ted Use designations
and the
downstrea~
General Use designation
i~
R71-l4.
The Board
considered over dOD pages of record and
numer~uS
exhibits before
reaching its
c~cision
on Edison's amendment.
Edison's amendment
is
based upon historical water data it collected dUring 1966 to 1971
by use of continuous reor:i tors located throughout the lower Des Plaines
waterway
syste~.
This data was submitted in Edison exhibits 47-62.
However, no tecperaturc data was recorded at the I-55 bridge. Edison
carried out
extrapol~tions
using the temperature data to arrive at
a probable water ter.1perature at the I-55 bridge. The two closest
recorded locations are 3.3 and 4.3 miles from the bridge.
The maximuc
~ater
temperatures extrapolated to the I-55 bridge
shc~
that 61 occurrences exdsteJ
~bO~B
gOOF during "the
moni~ored"periGd.
(Ex.
#3, Edison Ex. 47. Tablo 1)
This data supports the
statQ~ont
made during the hO<ll"inr;s that the "summer of 1966 S1101"5 some of
the
\~armcst
water temperature periods recorded in recent decades"

(Ex.
fi3)
Ellisor~
I:x
.
~
::g-2:).
Thu.s
c.ny
historical
da~a
S!l u J
!'
£l~c~ ~
longer
p~r
five
vea~ d~ta ~8T ~
GisQn's data clear
present Section' 20
,,' s v::'olu.te(l 19 days
tar.d~rd
ba~ed
UDOll
thi~,
od of tine than. the
y
de~ons~Tates
that the
during July. 1966,
Edison presented tesc:mony concerning in-plant cooling based
on the maxicuc
rce~~tiGn
ic heat discharge required to lower the
observed water
te~~cr~tures
to that required by Rule 203(i).
Edison
stated that
opeTu~ion
at partial load to
achiev~
the required
reduction ir.
ther~~l
dischQrge is not possible because the critical
period of 1,a-:::e1' tC:il?Crc,tures coincides with the system ,,,ide peaks
that require Eaxirrum power production from the Joliet Power Plant.
To meet the
ge~eral
use stan1ard, at the I-55 bridge, Edison estimated
it would have
~o
spend $21.9 million dollars to construct cooling
towers on the
neu
side if the critical load is less than 75% of
capacity (Ex. #3, Edison Ex. 66, page 2). ,
Dr. Lauer, an Ed.ison
~'litness,
testified that Edison's
discharge of hot water ",;o;.lld have a lil:\i ted effect on the
aquatic 'life use of the Lewer Des Plaines River (Ex. #3, Edison
Exs. 17, 37, and 38). He stated in his opinion, the maximum effect
of the
temper~tures
slle'.,'ed.
by
Edison's proposed <l.J;\endment ",'ould DE:
that. 785 pO'.mds of fish
~':ould
;;love out of the "5 mile stretch" and
into cooler 1'iater fer up to two 1,:eeks of the year (Edison Ex. 17 and.
38, 10). Edison pre:,c:nted a cost-benefit analyses "ihich concluded,
based upon a fish harvest of IOU pounds per acre per year, 'that
the fish "auld :,ave to
1:>3
'.-orth $27.91 per pound to \';arrant
cooling tONers (Ex.
1'3,
Ediso" Ex. 26. Page 4).
Dr. Upton
further test:ified that J,"sed upon a more conservat.ive fish harvest.
the fish ,;aUld "in reality" have to be 1,orth $1,395 per pound
'
(Ex. 13, Edison Ex. 26, Page 6).
Substantial opposition to Edison's proposal 1,'as voiced by the
Agency, U.S. EPA and by several citizen witnesses. The U.S. EPA
objected to any reclassification of a water into the Restricted Use
category becaus0 of its j?olicy to opposal to such a Classification.
The U.S. EPA, in conjunction with the Illinois Conservation
Depart~ent
collected fish on
~lay
lti, 1972 f,om fh'e lecations \'iithin the "£1\'13
mile stret::h" (Ex,
F,2,
~Iilburn).
The total catch consisted of 156 iis;,:
including gcldfisll, enerald
shi~ers.
northern redhorse, white crappie,
white Slickers, gizzaru shad, channel catfish and rock bass. Edison's
consultant also ::oniucted a fish survey, Ex. '3, Edison Ex. 44, a: one
location in the "5 !'iile stretch" and coLlected 19 fish; including
goldfish, carp and quillhack. Although these surveys disclosed that
fiSh species were DorB diversified in either the Kankakee or Illinois
Rivers than in the
Lo~':cr
Des ?lailles, the LOI\er Des Plaines is
capable of supportirg a desirable aquatic biota CR. 109. 9/14/72}.
The presence of benthic orgii.nishl:;; supports the conclusion that the:
fish
~lTe
not ju.st ;:ass::';-,g through becnuse bottom feeding fish have
a source of food CR. 109, 9/14/72).

---- ----
- s-
Evid:~nce
.:)f
tL.e
crf-;c~s
o.i
ter"~,?eT.at-:'tl"e
Or!. variou.3 fish
s-r;cci
cs is
dOCU~2nted
ill
Exilibi~ 31~
~n(i
Ex.
~3~
Edison Exhibits 38,
·~l ~~J 7~.
In Exhibi: 51
t!lC
~U:Ut]l ~~ti~:lal l~ate·l· Q~Rlitv ~ahorato~y recom~c~ds
maxirHl~1:
;,,'cB'kly-
<.:"~\·t::rZ\.s;c
ter;1?er~tl~res
for the IIJ.inois RiveTs.
Thes~
values a:-c 0o:;:-ri'.-ed iTon
d~t3..
of lethal teopC:Tatt:.tT'eS,
n~ax.i.!~u~
t.s:-::-r;era-
tures, rcprQd\..lc.t iCon and growth anc::.. should ::-esul t in
!f~tai n~cn2.nc(';
of reasonably gC0d. port:.lat.ions of most
spe(;i~s
to be pTotectcd" ..
When compared. to I'Topo,:;ed ;:e:npera t;;'1-e 1im:" ts fa r the "£ive :ni Ie
stretch", the
~econ~cndations
of the Water Quality Laboratory are
ccnsidc::-abl~"
lower.
Edison has presentcd. evidence that diversified
fish popUlations exist in
Dresde~
Lake
pDol~
which have water
temperatu:::-es ra:::1ging
£1'0;;1
96 .
.'l°r
tc S6of.
This presents evidence
that so".e f::'sh can acclin!ate to hi.gh .,.;ate:- temperatures
l~hen
confined
i~
an elevated temperature
~ody
of
~at~r
(EX. #3, Edison
Ex. 41).
B~t
fish in the Des Plaines River are not cunfined.
The BoaTc finds that the lOI,'er "five nile stretch" is capable
of providing a source of recreation badly needed in the area
(R. 107, 9/14/72). and is supporting a limited desirable
aqua~ic
biota.
The Board reduced Edison's prcposed
nop
temperature limh
during July ana August to gOOF in order t') give protection to this
aquatic life. Dr. Lauer testified that gOOF is recogni:ed as a
te~peTnture
which will begin to affect some individual species
CR. 277, 12/29/72).
A maximun
te~perature
limit of 90°F Is
recognized as
nec~ssBry
to protect fish (R. 219, 11/29/72. Ex. '3.
Edison Ex. 3:1, reference 5, p2.ge 57).
The Board. red.uced the a1lo\'!8101e excursion to 4% of the previous
year not to exceed 5CF after reviewing Ex.
i3,
Edison Ex. 47, Tuble 1,
Support Table E,
An excursion of 4% ",auld alloN up to 14.6 days
per year.
The Board fin<1.s that this excursion more closely reflects
the historical data. It should be noted that projected excurSion
temperatures are in f<'.ct "projected" va.lues not measured values.
Signi£icoT.t ?robleJ:1s arc present ,,-hen actually measuring tewper:Hures
due to differing te;;lperatures Hhich exist across the width and dc.?th
of a body of Kater. A projection based upon temperature necessarily
reflects such problems.
The Board decided to add Section 203(i)(9), which cancels
the special
teQpe~aturc
linits cn JUly I, 1978, as middle ground
betl-iccn Edison' s
pro~)csn.l
aId the need to protect aquatic life.
Evidence was presented that temperature is not
presently-th~
limitin;:; f:2ctor :,-hicil restricts "quatic life in the "5 mile stretch".
(Ex.
~3,
Eelis!)':! Ex. 7, pages 3-4)
11o'''';;'lor-,
additional evidcJ!co ,:25
presented during the 1lcaring that water quality in the Des Plaines
Ifill bc
ir.:pr~:n·c<l
as the ;-lSDGC, \,hich is the major pollution souTce.
-----_ --furt:W::x re_ducc_d. t_hg poJ}utClnts contr.ir,ed in its efflul;)nt.

.,
i
,
'J
The
~f5I~';C
is
Tt!q1.11...
'ed by
,~0c.:;iC:;l
.ta.~·(£)
to produce'
GIn
~ffl~c~1t
'.,~ich
shill excct>cl. 4 ,,:g/l BODe '-'1-
~' ::'~/]
SS on or Dcfc7C
Dccc:;;tJ{~:r
51
1977.
T~~e~
are required
by
S~c~i0n
406 to limit
~heir
ammonia
'
~ischarges
to 2.5
mg/l
during Aprjl
th~ough Octobe~, O~
4 mg/l
other
t:i.::~2'S,
3.ftcr DeceIT.ber 31, 1977.
Dr ..
S~-,~veT
testified~
t.h:tt
DO problCi1s
b·el·.)~·.f
LockpoTt wi:::'l be
Teso:~/Gd
by.
a:nmoni~
removal
CR. ZeiS, 10/18/72).
The
~·:SDc;ChCi';
sta.t.ed th:3.t they are goin.g
to conduct
in5tream-p.l~rJ.r:ion
tD
~·3.iS2
'-he DO level to 6.0 1.,g/1
(See p"ges 4 and 5 of this Opini.:):--. for discussion of i"stream
aeration plans of
~SDGC)"
ThEy
a~e req~ired
to treat or remove
combined sewer overflows by
Decern~er
31, 1977 (Section 602(d)),
and "ork on the proposed "deep
~u!;~,el"
is UndeD-lilY.
All of
these
?ro)~ct5 a~e
designated or
re~uirec
to be completed before
July 1978 with the
:resul~ing
reduction of the pollution load to
tile Des Plaines ;(iVCT. The Board finds that by July 1978, te::lpe:mturc
~'ill
bi:.: tile limiting factor to the att:::.inment of a desiruble
aquatic biota in the De-s Pla.i"r.es River celcJw "the ..I--55 bridge,
The July I, 1978, termin3.t:'on G<'.te for the specific te::lpe:-1,!:urc
standard is reasonable in light of the suecial
cir:::.u~stances ~re­
sented in this f3.ct
si~uation.
it
~s
a Board policy to pTctect
an~
enhance the qu"l:'ty of che aquatic envi rOI'Jnent ".I:ienever possible.
Large
di.sc~aTges
of heated
\'J:ii.>~T dist~rb
t!leaquat:'c enviroi':I:i::nt.
The
wa~eT
quality in the
Lo~~er
Des Plaines River is
pTesen~ly
depressed hy
d:="sc.r~~~~:;s
from u?strean
~Ct~rces
such as the
?\~SDGC
..
Snell
disch~=;ers aTi~ cU~Tently ~lnd.er
orders, or required
by
DcurJ
Tegulatic~s)
to
~educe
their
dis~ha~~es
by
1977 and are
pla~ni;l~
to implei7:ent
T~:r:e1ial
prograr.ls t.o
f ....
l~tl':.er
enhance
1.~ater
qua1. ity" ..
Water quaIl ty i71. tne "five-nile st:retch", should
C~
the 1i.mi tin,5
factor to obtain or supporc:
-l
d:;;;i lable aa.uatic life by 1978. The
teroina tio::l of thermal st:r.nd2.rd:s. ',-Ihien <,.J.loHad dis charge s that
limit the aquatic biota, is ttereiore necessary to protect
aq~ntic
life in the lO','er "five-raile
stl·et;:~".
Edison is
re~~ired
by
Sec. 203(i)(5) to conduct a
pTog~am
to
monitor
t~e
affects of their discharges of heated water
fra~ ~he
Joliet Plant and present the res;).} ts of that program to the Beard
at a ]-.eitring to be held bet\;een \<2.TCh, 1977 and
~lD.rch
1978.
If,
at that time,. the B0arc. is
cOn\"i~lced.
th3.t Edison's discharge ha3
not caused, or is nOe reasonably e.xpccted to cause significant
ecological da..'7t'lge to "':he Des
?la~J,"'S
!i.i...:er; t:he Beard
Kotila
r!")~
requi;:,
Edison to construct cooli&g
fucili~ies.
Edison could then either
ask the Board to
2.~r.cnu
i
ts
r~;;ulation
1:0
tJxtend to
th.3
temin8.t.ion
date to reflect "fater quality as ":GuLi then Q0
p,'~sent
in the "five-
mile stretch", or SeC'};. a vaTi2.itcc from the standard.
:Sut if the Board
is co:nrinced
t}~at
E.:lison has cnusecl or is
reason~bly
cxpcc.tcC
t~: C~·:..lS~::
significant ecological
dam~ge i~
the future, then the Board is require
by
Section 2U3(i)(5) to ardor
Edison to carry out
~?p;:opriate

measures to C07rect ecological
J~n~ge.
Edison,
b~ca~se
it had
Telied U?C;, exi sting
j)0;1.~·d
:c"gul,.tions, >'lould have the variance
procedure avail&ble to seek tiffi0 to correct tho problem.
The BOJrd notes
th~t
cost bcn0fit analyses,
~s
used by Edison,
wou.ld result i':l the «llo;.:ar;cc of large the:r;rral discharges C:l even
small trout strearns since it is likely that a lake or artificial
stream for
fishi~g
purposes could be built for less
~oney
than
cooling facilities.
I, Christan L. !-loffett, Clerk of the Illinois Pollution Cc,:tyo1
Board,
hen~by
certify the'above Optnion \'Ias adopted on the
l3 ;r.t\
-:lay
of :iove::>.bcr, 1973 by a vote of __
""-i~""e::--~O::::..
-------
chT~stan
L.
',[ol.tett/Cley;;
Illinois Pollution .:Dutycl Board

DATE:
TO:
FROM:
RE:
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 "O,TH G,"'''D,..
y,,,~£
EAS;, P.O. Box 19276, 'SP""GF:ELO,
Ill'~OIS
62794-9276 .
THOMAS V: SKI "MR. DIRECTOR
. July 2,2001
DIST~.~T~.O
T
COnni~sor
MidWest Generation file review/permit questions
Draft
P=it No. IL0064254
Procedural Background
On November 8, 2000, the illinois Environmental Protection
Agenl;:Y ("minois EPA")
sent draft permit No. IL0064254
to the USEPA for review.
On
November 30, 2000, the
USEPA contacted the illinois EPA
with several concerns. The concerns were: (1) a
concern that the effluent might be contributing to violations of the Dissolved Oxygen
standard
in the general use waters; (2) the applicant should submit a 3l6(b) of the Clean
Water Act study; and (3) monitoring must ensure compliance with the secondary contact
temperature standards. The permit should
contain.il condition showing the combined
effect
of Generation Unit 6 and the Joliet Station.
On
Apri130. 2001, the illinois EPA responded to the USEPA'sconcerns. USEPA had
withdrawn the concern with regard to Dissolved Oxygen. The permit bad been amended
. to request the Section 316(b) report when the federal guidance was finalized. The
reporting requirements
had been clarified.. The permit had been revised to require the
permittee utilize the Near-Field Compliance Assessment Model
to calculate fully mixed
receiving water temperatures on an hourly basis. The lllinois EPA noted that the mixing
zone was that portion
ofthe river allowed for mixing in PCB 87-93.
On May 31, 2001, the USEPA requested
90 days to review the permit, 40 CFR 123.44
(a)(I),
and additional information concerning whether the p=it insured that thennal
limits and monitoring conditions are appropriate for the secondary contact waters. The
USEPA requested a
copy ofthe thermal demonstration (pCB 87.93/PCB 89-93) and the
Near Field Compliance Model.
The following is a review of the various regulatory matters relevant to the Midwest
Generation Joliet 29 Station.
.Thennal Demonstration
PCB 87-93 (pCB 89-93) did not specify a mixing zone for the secondary contact water or
for the general use water at the I-55 Bridge.
GEORGE H.
RYAN,
GOVERNOR

Commonwealth Edison (now Midwest Generation) initially filed PCB 87-93, On June
19, 1987, Commonwealth Edison filed an amended petition for a Thermal Demonstration
under
35 Ill. Adm, Code 302,211(f). The amended petition replaced the previously
submitted petition and the Pollution Control Board renumbered in PCB 89-93. However,
the Board has subsequently referred to the determination as PCB 87-93.
In
In the Matter of: Proposed Determination ofno Significant Ecological Damagefor
the Joliet Generating Station,
(pCB87~93,
September 17,1983) Commonwealth Edison
sought a determination that the provisions
of35 TIL Adm. Code 302.211(f) did not apply
to it as it discharged into secondary contact water or
in
the alternative a detennination
that the discharges from the
J
oli et Station had not caused and could not reasonably
be
expected to cause significant ecological damage to the "Five-Mile Stretch"l within the
meaning ofSection 302.211(f). The Five-Mile Stretch is designated a general use water.
Section 302.211(f) provides that:
'Theowner or operator of a sourCe of heated effluent which discharges 150
megawatts (0.5 billions British thermal
units per hour) or more shall demonstrate
, in
a hea.rUig before this Pollution Control Board (Board) not less than 5 nor more
than 6 years after the effective date of these regulations, or
in
the case ofnew
sources,'after the commencement
ofoperation, that discharges from that source
have not caused and cannot be reasonably expected to cause significant ecological
.damage
to the receiving waters.
If
such proof is not made to the satisfaction of
.
the Board appropriate corrective measures shall be ordered to be taken \\1thin a
reasonable time as determined
by
the Board."
The
Joliet Station is located on both sides ofthe Des Plaines River, at a segment that is
designated as secondary contact water. The discharge is approximately 7.3 miles
upstream
of the I-55 Bridge, where for approximately five miles the river is designated as
general us'e water. The Board rejected Commonwealth Edison's argument and held that
it must perfollIl a thellIlal demonstration because
of the affect that the discharge could
have on the general use water.
On
November 15, 1989, the Board found that Commonwealth Edison had successfully
made the demonstration. The Board noted that Commonwealth Edison and the (Illinois
EPA) agreed that heat
was not a factor limiting the quality of the aquatic habitat of the
Five-Mile Stretch.
2
The Board further noted: "Edison's desire to proceed at this time
I
The "five Mile Stretch"
is
the segment ofthe I,ower Des Plames River between the Interstate 55 Bridge
and
the head ofthe Illinois River (the'confluenceof the Des Plames River and the Kankakee River);
2CoriJrnonwealth
Edison had received several variances from the requirements for a demonstration at 35
lIl..
Adm, Code 302.211(f), based on the argument that heat was not a limiting factor. See, PCB 78-79, PCB
81-24, and PCB 84-33. The last variance was due to expire
in
1989.

appears to be based in part on Edison'sbelief that it is in compliance with all pertinent
thermal water quality standards...
,,3
.
During the proceeding, the Illinois EPA supported Corrunonwealth Edison'spetition and
Corrunonwealth Edison's conclusion that the discharge complied with both the secondary
contact and General use Standards. The Board noted that Agency concluded
that as long
as the Joliet Station meets all the applicable standards at the point ofdischarge and in the.
downstreaniGeneral use waters, the Agency did not view the Joliet Station'sthermal
discharges
as limiting aquatic diversity in the receiving waters.
4
A mixing zone as it applied to the secondary contact water was never discussed, as all of
the infonnation was that the discharger was
in
compliance with the temperature limits for
the secondary contact water. Note: the record in this proceeding is no longer retrievable.
Therefore, I was not able
to review the exact testimony presented to the Board.
However
as to the General use water, one ofCommonwealth Edison'switnesses testified
that a complete mixing
of the effluent occurred at between two miles of transport (high
discharge) and five to six miles of transport (low discharge). No plume existed and
Corrunonwealth Edison was in compliance with the General use water quality standards.
The Board found this evidence persuasive.
Peter Howe
and the Sierra Club testified that the Commonwealth Edison discharge may.
be causing early spawning, decrease
in
viability of gametes, thermal related mortality,
cold shock, heat aversion and heat shock. The Board specifically noted that most
ofthe
Sierra Club and
Mr. Howe's concerns could be raised regarding any waterway that
received heated effluent. The concerns
are more
in
the nature ofchallenges to the
Board'swater quality standards for temperature. Therefore, the Board found that they'
were beyond the
scope of the proceeding.s
The Board noted that should revisions
of the water quality regulations with regard to the
Des Plaines River occur, Commonwealth Edison would have to comply with the
regulations..The Board also noted that its. fmding
6
did not relieve Commonwealth Edison
of its obligation to comply with the secondary contact or general use water quality
.standards as they then existed or as amended.
JpCB 87-93; PCB 89-93, at p. 3. Therefore, could not argue compliance would constitute arbitrary and .'
unreasonable hardship.
.~_"_.
'PCB 87-93; 89-93, at p. 9.
s:Mr. Howe in his letter concerning the instant permit is raising several ofthe same issues that were
raise~
•.
in
PCB 87-93; 89-93.
'.'..
6 Commonwealth Edison had
dero~nstrated
that the effluent from the Joliet Station had not caused and..
could not reasonably be expected to cause significant ecological damage to the General use Waters .of .", ''''-", .
~
!ii.<.:.
Five-Mile
Stretch.>.~:t;~f~~~r~::

As part
of~s
proceeding, Commonwealth Edison committed to implement an operating
plan which would limit the megawatt output for the Joliet Station which to ensure that the
monthly
ma.xUnmn temperature standard of Section 302.211(e) was not exceeded.
7
Variance
On November 21, 1991, the Board granted Commonwealth Edison a variance from the
requirements
of35 TIL Adm. Code 302.211(d) and (e) to conduct a study of the Upper
Illinois Water
Way and the impact ofheated effluent discharges to the receiving stream.
The
study then would become the basis ofan adjusted standard/alternate thennal
standard,
ifneeded.
Adjusted Standard
On May 16, 1996, Commonwealth Edison filed a petition for alternate thermal standards.
(In the Matter of Petition ofcommonwealth Edison Company for AdjustedStandard
from
35
Ill. Adm. Code 302.211(d) and (e),
AS 96-10, October 3,1996; "AS 96-10"). On
Octoher 3, 1996, the
Board granted the alternate thermal standards utilizing the adjusted
standard procedures.
The adjusted standard considered the combined discharges oftbe
Joliet, Crawford and Fisk generating stations,
Section 304.141(c) provides
the authority.forthe Board's action:
"The standards ofthis chapter shall apply to thermal discharges unless, after
public notice and opportunity for hearing, in accordance with Section 316
of the
CWA and applicable federal regulations, the Administrator and the Board have
determined that different standards shall apply to a particular thermal discharge."
(35 Ill. Adm. Code 304.l41(c»
Section
3l6(a) ofthe Clean Water Act states"
"With respect
to any point source otherwise subject to the provisions ofSec.tion
306
of this Act, whenever the owner or operator ofany such source, after
opportunity for public hearing, can demonstrate to the satisfaction
ofthe
Admin.iStrator (or, ifappropriate,
the
State) that any effluent limitation proposed
for the control
of the thermal component ofany discharge from any such source
will require effluent limitations
more stringent than necessary to assure the
protection and propagation of a balanced, indigenous population of shellfish., fish
and wildlife
in
and on the body of water into which the discharge is made, the
Administrator (or,
if appropriate, the State), may impose effluent limitation under
such section
on such plant,. with respect to the thermal component of such
discharge (taking into account the interaction
ofsuch thermal component with
other pollutants), that will assure the protection and propagation
of a balanced
indigenous population
ofshellfish, fish and wildlife in and on that body of water,"
7
PCB 87-93
at
21.

33 U.S.C.§1326, Section 316 oftbe CWA.
Section 125.73 (c)
ofthe Code ofFederal Regulations,. 40 C.F.R. §125.73(c), provides:
"Existing dischargers
may base their demonstration upon the absence ofprior
appreciable
harm...
Any
such demonstration shall show: (1) That no appreciable
harm has resulted from the
nonnaI component of the discharge
(taking into
account the interaction
ofsuch thermal component with oth.". pollutants and the
additional effect
ofother thermal sources)
[emphasis added] to a balanced,
indigenous
community of shellfish and \vildlife in and on the body ofwater into
which the discharge
has been made."
The Board in the alternate thennal standards considered the combined impact ofall of the
discharges on the Des Plaines and considered the. study of the waterway.
The Board concluded that Commonwealth Edison had made the requisite showing for an
alternate thermal standard under
Section 316(a) ofthe Clean Water Act and a showing for
an adjusted standard from 35
m.
Adm. Code 302.21 1(d) and (e) for the
Jolie~
Will
County, Crawford
and Pisk generating stations. The Board stated that the following
requirements applied at
the I-55 Bridge.
January
60'F
February
.60'F
March
65'F
Aprill-l5
73'F
April 16-30
gO'F
May 1-15
8S'P
May
l6~3l
90'F
June 1-15
90'F
June 16-30
91'P
July
9l'P
August
9l'P
September
90'P
October
8S'F
November
7S'F
December
6S'P
The Board further stated that the standards may be exceeded by no more that
3'F during
2% ofthe bours in the l2-month period ending December 31, except at no time shall
Commonwealth Edison's
plants
cause the water temperature at the I-55 Bridge to'exceed
93
'P.
"CornEd'splants continue to be subject to the Secondary Contact Standards at the
point ofdischarge.
.,8
.
The Board considered the combined effect ofthe discharges ofall of the Commonwealth
Edison plants in the alternate thermal standards proceeding.
It
noted operational
considerations
of each ofthe generating stations.
9
A review of the documentation in this
file
shows that the combined effect of all ofthe plants was considered in the study that
• AS
96-10, alp. 7.
'AS 96-10, at p. 3-4. The maxirrmm design temperature rise in the circulating cooling water is
approximately
11.1'F
for Will County,
1Z'F
for Crnv,.ford, and 12.2'Ffor Fisk. .

was presented to the Board. The stUdy specifically mentioned that at high operation the
Joliet Stations intake
ofthe river was from 75-100% of flow. 10
On December 18, 1996, the illinois EPA sent a copy of the Board'sorder, the petition,
the Exhibits, and the illinois
EPA'srecommendation to the USEPA (Joan Karnauskas),
pursuant to
40 CPR §131.21. The Illinois EPA has not, to date, received a response from
the USEPA.
On March 16, 2000, the Board granted a
transfer ofAS96-10 to Midwest Generation, as
the successor to Commonwealth Edison. The Board did
not change any provisions but
the name
oftbe OViner. I have located a March 23, 2000, letter from Richard Warrington
to USEPA pursuant
to 40 CFR §131.21. However, it is unsigned and I cannot verify that .
this documentation was transmitted.
Conclusion:
It
appears that the Board in granting the alternate thennallimits at the I-55 Bridge for tbe
general use waters did consider the combined effect
of the thermal discharges. It found
that the Joliet Station was subject
to secondary contact standards. Part of the information
before it was the effect
of the Crawford and Fisk stations, the cumulative impact ofthe .
thermal component
oftbe discharges from the Crawford and Fisk Stations. USEPA's
letter seems to suggest another study that
may in part be duplicative ofthe earlier study.
It seems as
ifthe question is whether there is a violation ofthe secondary contact
temperature standards at the Joliet Station.
10 Final Report Aquatic Ecological Smdy of the Upper illinois Waterway, Vol 2, pp. 10-4.5-10.4-7 (AS96-
10,
Exhibit 1).

Appendix B

Back to top


Chemical Probability Plots
Lower Des Plaines River
Use Attainability Analysis
Lower Des Plailles River Use Attaillability Allalysis
Draft: May 24,2001
A-I

Probability Plots for Barium
Reference Site
0.1
-
-.-.
99
s::
95
0
.-
......
!-<
80
0
50
0..
0
20
!-<
0..
5
99.9
,....
.
/ ..
./
,""
./
..
l·····d(~·······
r
~
.
.:.
"" :
-
:: ..
-
.
..................•..........
8
.
~
..
:.
: ..'
i...
,'.' '
'.. -' '
~
.. '.. .
.-.-.-.-.' -
.....
'.-..~
... " ..
.................
-............
. ..
-
... '"....
-
.. ,.- ......•
.
.
..........
_..
.
.
-
.
.
.
.
_
"
",
..
-1.4
-1.3
-1.2
-1.1
-1
-0.9
-0.8
99.9
99
s::
95
0
.-
.....
!-<
80
0
50
0..
0
20
!-<
0..
0.1
Total Barium (log Conceniration- mglL)
IEPA G-ll
:
,-/'/'
,
~OD
• l.o.r;:vD" u",
... 0.
",.y/!t)
eJt
~~-
,
r
)3'//~
n
/p---
,//
-1.7
-I.G
-1.5
-1.4
-1.3
-1.2
Total Barililll (log Concentration -
mglL)
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May 24,2001
A-2

99.9
99
~
95
......
0
80
t::
0
50
0..
0
20
;....,
0..
5
0.1
-2
-1.9
-1.8
IEPA G-02
-1.7
-1.6
-1.5
-1.4
99.9
99
~
95
......
0
80
t::
0
50
0..
0
20
;....,
0..
5
0.1
Total Barium (log Concentration - mg/L)
IEPA G-23
/
/n
O
u
~a:fP.
_6
0
"8
~
.~
I:V
~)'J
=
o
/9"
i
/
-1.9
-1.7
-1.5
-1.3
-1.1
Bariwn (log Concentration - mglL)
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May 24,2001
A-3

99.9
99
~
95
0
.-
.;..>
80
:-.
0
50
0-
0
20
:-.
0-
S
0.1
MWRD 91
///'
.///~
//f
;
n
/'
//
;
-2
-1.8
-1.6
-1.4
-1.2
Total Barium
Oog
Concentration -
mgIL)
MWRD 92
Data Insufficient for probability plot. Within acceptable range.
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-4

MWRD 93
99.9
99
C
95
0
--P
SO
;....
0
50
0..
0
20
;....
0..
0.1
f-~
..
>;,«
'-
f-
u
.-
r'
/../i'
-
c-
1///"'
E3
r'
//'
-
-
,-
,/,//
.
~"///
,2
-1.8
-1.6
-1.4
-1.2
-I
Total Barium (log Concentration - mglL)
MWRD 94
..
..:-
.... -:-
........................ ,
cr",,,--."'.-----------'
:j
QQ.9
-:.
........
'iQ
C
95
_.
.....
-l->
0
80
----------
.------
;....
0
50
0..
0
20
;....
0..
5
n
0,1 -, .. , .....
-1.7
-1.6
..........
-1.5
-1.4
............
;-
-1.3
Total Barium (log Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,2001
A-5

MWRD 95
99
::i
95
.8
80
""""'
o
l-<
50
I-Ei'<c"" """ "" '" """""""",J:l.",i""",
Cl.;
o
20
l-<
Cl.;
0,1 I::::i.:=====e::::=========:..:..i..=====.::::l
-1. 7
-1.6
-1.5
-1.4
-1.3
99,9
99
::i
95
......
0
80
1:
0
50
Cl.;
0
20
:-
Cl.;
5
0,1
Total Barium (log Concentration- mglL)
Riverside (USGS)
0
/'
'cBg;~/~~
/~/r;vu
g "
,/-;/
0
l/
,
/
'"
-1.8
-1.7
-1.6
-1.5
-IA
Data not available
Total Barium (log Concentration -mglL)
Romeoville (USGS)
Lower Des Plailles River Use Attaillability AlIalysis
Draft:
May 24,2001
A-6

Probability Plots for Boron
-0.5
Reference Site
99.9
99
C
95
0
.-
.......
80
I-<
0
50
0..
0
20
l-;
0..
5
0
0.1
-1.7
-1.5
-1.3
-1.1
-0.9
-0.7
Total Boron (log Concentration - mglL)
IEPA G-ll
99.9
99
C
95
.-
.......
l-;
0
SO
0
50
0..
0
20
l-;
0..
5
0.1
Q~/'
.
";'O~~/c:r
o
",,§,El9»"
.....
M
1;)9~a~§g
-
§
~//"
...
-
n
~
,/'-
/-~
,-
-1.2
-I
-o,S
-0,6
-OA
Boron (log Concentration - mgIL)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May
24,
2001
A-7

99.9
99
c:
95
0
......
80
t::
0
50
0..
0
20
;...,
0..
5
0.1
-0.8
-0.76
-0.72
IEPA 0-02
-0.68
o
-0.64
-0.6
Total Boron (log Concentmtion - mgIL)
IEPA 0-23
99.9
99
c:
95
......
0
80
t::
0
50
0..
0
20
;...,
0..
5
0.1
-1
-0.9
-0.8
-0.7
-0.6
-0.5
Boron (log Concentration - rnglL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-8

99.9
99
I=:
95
0
.-
t:
0
50
SO
0..
0
20
I-;
0..
5
0.1
-I
-0.8
MWRD 91
-0.6
-0.4
-0.2
99.9
99
c;
95
0
.-
.....
I-;
SO
0
50
0..
0
20
l-<
0..
0.1
Total Boron (log Concentration - mgIL)
MWRD 92
--/'
j--./
.
i..-_/
nO
~
~//
.~
~-Iff;
o~
1-;
~1f1"o!1P'
.
......
l-
f'G"'-
.,;r('
.
1-;
.__:Ji
1--
~':T
••
~
1-"
." ...
-0.7
-0.5
-0.3
-O.l
0.1
0.3
0.5
Total Boron (log Concentration- mgIL)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May 24,2001
A-9

MWRD 93
......
t::
o
c..
o
;....
c..
99 1-
,
.
95 H........................
,
.
so
50 1-,
i····B"'~'··'·
.
20
o
O. I
t:i::.;.;:.:::==':::±=::.:.==;.:.:i==:.;::;::d===:;:::;i====d
-0.86
-0.76
-0.66
-0.56
-0.46
-0.36
Total Boron (log Concentration - mg/L)
MWRD 94
99.9
99
c::
95
0
• .-..oj
80
.......
l-<
0
50
Q..
b
20
l-<
Q..
5
0.1
-0.93
-0.83
-0.73
-0.63
-0.53
-0.43
Total Boron (log Concentration - mg/L)
-0.33
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May 24,2001
A-lO

MWRD 95
-0.89
-0.79
-0.69
-0.59
-0.49
1:1...
20
99
95
80
50 .
0.1
l:::r:.===~L.::.=======::::i::c=======:.:.:.jd
99.9
~
.....
.......
o
1-<
o
0...
1-<
o
0...
Total Boron (log Concentration -mg!L)
Riverside (USGS)
99.9
99
0
95
......
0
80
1:::
0
50
0..
0
20
1-<
0
0..
0.1
-1.2
-1
-0.8
-0.6
-0.4
Total Boron (log Concentration -mg!L)
Romeoville (USGS)
Data not available
Lower Des Plaines River Use Attainability Analysis
Draft: May 24,2001
A-ll

999
_.'.
9<,)
-,
::::
95
-
0
.,....
80
-,
......
I-<
0
50
I-
0...
0
20
l-
I-<
0...
5
1-.
Probability Plots for Chloride
Reference Site
,. ,.,-
...)0,.,.,., , , ;_
o
1.1
1.3
1.5
1.7
1.9
2.1
99.4
99
::::
95
.,....
......
I-<
0
80
0
50
0...
0
20
I-<
0...
0.1
Chloride (log Concentration - mgfL)
IEPA G-ll
-"
1-'"
_.: ..
~d
p~D'cr'u
-:
_
..
:
.JJ{;
g..-O.d""
A-l3~gr6"
_.:
-~
.....
-:.
o"r("P-".....
.
-,
.
1.6
1.8
2
2.2
2.4
2.6
Chloride (log Concentration- mgIL)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May
24,
2001
A-12

IEPA G-02
99.9
. 99
s:::
95
0
.....
+-'
80
l-<
0
50
p.,
0
20
l-<
p.,
5
O.
j
1.7
1.9
:2.1
2.3
2.5
2.7
? .9
Chloride (log Concentration - mgIL)
IEPA G-23
99.9
99
s:::
95
........
0
80
t
0
50
p.,
0
20
l-<
p.,
5
.
.
.
.
.
.
0.1
b::====i:..:..===::.::.;j====:.:±====.±.'":.:;."":.:;.".:.:;.
....:.:;...
:.:;..,,:.:;.,,,,.:;:.,,,,:.:;.,,.::i
...i.:::l-
1.7
1.9
2.1
2.5
2.7
ChlOlide (log Concentration - mgIL)
Lower
Des
Plailles River
Use
Attaillability Allalysis
Draft: May
24,2001
A-13

MWRD 91
999
99
l:::
95
0
.,....
......;..;
80
0
50
0-;
0
20
;..;
0-;
0
0
0.1
i.~
2
2.2
2.4
2.6
2.8
Chloride
Oog
Concentration - mgIL)
MWRD 92
99.9
99
l::
95
0
.,....
80
1::
0
50
0-;
0
20
;..;
0-;
5
-' ..
-
'_.-H
.
............."
; .
.....................)
........ ,-
o
... , .....
+
.......1,,.........
.............
1-
..................... +
..................... +
o
;
I -0.
..,
,
,
+-
0.1 L--'-i
-'-
._..
...L
.•._...._..._...._..._..._...._...--'
.
.1__
.._
..__.__--'_..__.__._--'_.______--'
..
+L...J.-
2.2
2.4
2.6
2.8
ChlOlide (log Concentration-
mglL)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May 24,2001
A-14

MWRD 93
99.9
99
~
95
0
80
"-2
0
50
0...
0
20
;...
0...
....
@of
.
;~;)~~Eroa
b
"_-
•..........
,."'"
: _
'.>.~.~
:..
:~.ff!-.
........
.......•. "
...•,
.
....• '
JJ....
~,.-
""......................t",,
,'
..........,,........,,;.
...•....•....•........
~
.
.
.
.
.
..................: "
;
.0•
."0,,...
.
~
.. "
;
:
.
0.1
1.8
2
2.2
2.4
2.6
2.8
ChI01ide (log Concentration -
mglL)
MWRD 94
99.9
~:.
99 I-c
.
1- •.....
0
"
.
..-
......-
.:-
.... :.-
. '., .:-
.....
-
-
2.6
2.9
3.2
0.1
L~...l.':
---''---
'---
.J..-
-'-
. ._
. ...l..:-1-
l.7
Chloride (log Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,
2001
A-IS

99.9
99
Q
95
.....
......l-<
0
80
0
50
0..
0
20
l-<
0..
5
0.1
MWRD 95
....•.•.•.
•••••••••
.•.
"o<
.
••• : •• " •• ,,/.-.-::.::.
,/
~~f<~:·
g
P
:
:.
-
/,::(19
0
.
_
o
I~···~··········.·.·.·.·.·.··
.•..
..l.
_
.....................................
.
1iI
-
.
1.7
2.3
2.6
2.9
3.2
Chloride (log Concentration - rug/L)
Riverside (USGS)
.
:-
.............,...
.
-
~
,
:~tP~~rt:~·--·1~;~
~f~~l~?]!=
., , "..,....
.
,,~.,
,.,
~
"
-
+-
\l
.'
:.-
99.9
-,
......
99
-;...
..
Q
95
-; ..
.....
......
l-<
0
80
H
0
50
-c..
0..
0
20
-;
...
l-<
0..
5
t-r.<:"'''.
[p
0
1-'
.0
0.1
I-i..
...
j
.8
2.2
2.4
2.6
2.8
Chloride (log Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-16

Romeoville (USGS)
95
80
50
20
1--
.
1.4
1.7
2
2.3
2.6
2.9
Chloride (log Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-I?

Probability Plots for Copper
Reference Site
Data Insufficient for probability plot. Within acceptable range.
IEPA G-ll
Data Insufficient for probability plot. Within acceptable range.
IEPA G-02
Data Insufficient for probability plot. Within acceptable range.
IEPA G-23
Data Insufficient for probability plot. Within acceptable range.
MWRD 91
99.9
99
P
95
0
.-
.....
!-;
80
0
50
0...
0
20
!-;
0...
5
0.1
... ,
........
MO
~
[;;100c:.:
.......--;-----_.
--.~
;J....-(;.l-w..
-
,...ct...._-
_.,
8..
i
~
.......
-
.
-2.4
-2.2
-2
-1.8
-1.6
-1.4
Dissolved Copper (log Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft: May 24,2001
A-18

........ 0
:
......
~
l-<
o
0..
o
l-<
0..
99.9
99
95
80
50
20
0.1
MWRD 92
:
:
.
.:
el~,~:~c~~";>"I~!~~"~.,
..
..
-:
.
-2.4
-2.2
-1.8
-1.6
-1.4
-1.2
99.9
99
C
95
......
0
80
t:
0
50
0..
0
20
1-<
0..
0.1
Dissolved Copper (log Concentration - mg/L)
MWRD 93
~
u
:
-.
~
~o ~
__ .•. :
I
---~'::-.
.-
~
.
...---
-------
;,.
.-.-".
..~
:.
n
:
-2.4
-2.2
-2
-1.8
-1.6
Dissolved Copper (log Concentration - mg/L)
Lower Des Plaines River Use Attainability Analysis
Draft: May 24,2001
A-19

MWRD 94
~
~
99
....'._
L.
._
,_ ";.".
20
t.»'i".
5
,.§
.. 0.
80
95
50
.,...
'~e9;~j~~~-
0
......
~.~:>,~
..••.•..•.•........•.....• g
:.
...
:.
.........................
,
.... ;:
:
;
.
.
0.1
~
--'-
.
.L-
,I
__--i
t........
-'-
~.
-'--__
--.:..J..::::l
99.9
-2.4
-2.2
-2
-1.8
-1.6
-1.4
-1.2
Dissolved Copper (log Concentration - mglL)
MWRD 95
99.9
99
~
95
.
.....,
,....,
0
80
l-<
0
50
0..
0
20
l-<
0..
0.1
--
:til
.
0
_
..
rat_-
i-i---.....-...
..------
,-r
!L....
-·~····-·-
:
..-'
...
~
......
••
-
l-
..
-2.4
-2
-1.8
-1.6
-1.4
Dissolved Copper (log Concentration - mg!L)
Riverside (USGS)
Data Insufficient for probability plot. Within acceptable range.
Romeoville (USGS)
Data not available
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,
2001
A-20

Probability Plots for Dissolved Lead
Reference Site
Data Insufficient for probability plot. Within acceptable range.
IEPA G-ll
Data Insufficient for probability plot. Within acceptable range.
IEPA G-02
Data Insufficient for probability plot. Within acceptable range.
IEPA G-23
Data Insufficient for probability plot. Within acceptable range.
MWRD 91
Data Insufficient for probability plot. Within acceptable range.
MWRD 92
Data Insufficient for probability plot. Within acceptable range.
MWRD 93
Data Insufficient for probability plot. Within acceptable range.
MWRD 94
Data Insufficient for probability plot. Within acceptable range.
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May 24,2001
A-21

MWRD 95
Data Insufficient for probability plot. Within acceptable range.
Riverside (USGS)
99.9 FI-:i.,..:::"..:-:.
=~===~
..:-:
..::T+-:::
....
~
..
C::.
======y----/7~::::::====l
99
~
95
."",,,
.....
;...
0
80
0
50
0...
0
20
;...
0...
5
1-:
.
u
........
0.1
1-,
, .
-2
-1.7
-l.4
-1.1
.0.8
-0.5
-0.2
Dissolved Lead
Oog
Concen1mtion - mglL)
Romeoville (USGS)
Data not available
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-22

Probability Plots for Dissolved Oxygen
Reference Site
;i
~
.'
... ...i.....
.
, ,;,
i." O
,
~
~
..
o
1
J
~
1.21
. .....>
1.01
1.11
.';0_'
i....
i
.
0.81
0.91
99.9
99
~
...
-
l=:
95
.:
...
.-
""'"
0
'-<
80
0
50
>-"-'
A
.:
0
20
'-<
A
5
0.1
.......
0.71
Dissolved Oxygen (log Concentration - mglL)
IEPA G-ll
99.9
99
l=:
95
.-
t::
00
5080
A
0
20
'-<
A
5
0.1
.'.C..
0
"JJ--~
.--rrcr-
-rr--eJ'~U
f...
.".i4
D
..Ql-...C
••• • •
r-
iD
u
00.
0.76
0.86
0.96
1.06
U6
1.26
Dissolved Oxygen (log Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May
24,
2001
A-23

95 1--"
!EPA G-02
'-
o
;-
c-
.-
................ ,
;
;
.
0.58
0.68
0.78
0.88
0.98
1.08
1.18
99.9
99
l::::i
95
......
0
80
t::
0
50
0...
0
20
;...
0...
5
0.1
Dissolved Oxygen (log Concentration - mgfL)
!EPA G-23
0
,-'
:
0
0
--".-
:---.--
:
.......
;0. 5
1
_--...0.-'-
;---Q
.-rr
':'_~"[f-
;.-.;:;"
0
:
-:0
,-,-
:
0.6
0.7
0.8
0.9
1.1
Dissolved Oxygen (log Concentration -
mglL)
Lower Des Plailles River Use Attainability Allalysis
Draft: May
24,2001
A-24

... , .
MWRD 91
99.9
f-!..
.... ....
~
..
99 1-.
95
I-
/".-;:;0
80 r:....
.~._
~<gif
Q
~
!•.....................
H
50
~....
. .•.............
.",,,c.i[j!.U.><......................•.
2:
jC~:"'.~·J~IIl$"""····
.."
..
.§",,,.. .;
,
,
H
.:
Q
I
~o
-:
O.
J
tt=="':"':::'L.:::::==.::.t:::======J::.::::===t.===i=l
0.7
0.8
0.9
1.1
1.2
1.3
99.9
99
t:i
95
......
0
80
~
0
50
A
0
20
l-<
0..
5
Dissolved Oxygen (log Concentration - mg/L)
MWRD 92
.......................... ,.
,
.
.....•••...
o,./""
·~4~?~;
.
>/.......
~
.,."/
.
.
:
0.1 l....L.
-'-
.. _ _ _
_ _..
--'-__ _ _
_._ _ _ _ --'
••
--l
0.38
0.58
0.78
0.98
1.18
Dissolved Oxygen (log Concentration - mg/L)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May
24,
2001
A-25

99.9
99
~
95
......
r'
-
00
50
~O
0..
0
~O
;...
0..
0
0.1
0.57
0.67
0.77
MWRD 93
0.87
0.97
1.07
~
.-
t
o
o
0..
;...
o
0..
Dissolved Oxygen (log Concentration - mgIL)
MWRD 94
999
1-' .' ..
:-
:: ...,.. :
.......~.i:,,~·~?~O~~'=
80
I-
.
;
.,,~
;
-
0.1
:~
1-:
~l"·~~~
.'
.........: ••.••••• i
:~
;-
0.76
0.86
0.96
1.06
1.16
Dissolved Oxygen (log Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-26

MWRD 95
999
99
l:i
95
.......
4->
0
80
1-<
0
50
0..
0
20
1-<
0..
:.9""
0.1
0.76
0.8]
0.86
(J.OI
0.96
1.01
1.06
99.9
99
l:i
95
.......
0
80
t
0
50
0..
0
20
1-<
0..
5
0.1
Dissolved Oxygen (log Concentration - mgIL)
Riverside (USGS)
.,eo_r
_J5'--
R W
---
"'~
.oo.u""
__..v-
A""§---
_;:p:P--O
'"
cI
0.8]
0.9]
1.01
1.11
l.21
Dissolved Oxygen (log Concentrati.on - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-27

Romeoville (USGS)
5 I--'''u"......
50 1-
.
o
..•...
.:
....•
II:
; .....
:,::,'cFr""
:
~o'~
I.....' "''''''''''''''''''''''''''
~
:.-~_,>"".;
..
"'BLf'..... 0'3'
.-.
.
....
,.;,.;
20
99
95
80
q
.....
o
1::
o
0..
I-<
o
0..
0.5
0.6
0.7
0.8
0.9
Ll
Dissolved Oxygen (log Concentration - mg/L)
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May
24,
2001
A-28

Probability Plots for Fecal Coliforms
Reference Site
99.9
99
l=:
95
0
......
.......
l-<
80
0
50
0..
0
20
l-<
0..
5
O. ]
0
2
4
5
99.9
99
l=:
95
.-
1::
0
80
0
50
0..
0
20
l-<
0..
5
0.]
Fecal Colitorms (log Number
1100
mL)
IEPA G-ll
.
.....---if
.:. •.••• ".1::;--.-.".
:i:J
~.
1.o_q",~",""i::J
.~.
.--~r:r
:
;~D
a
0
~
.
-
1.6
2. ]
2.6
J.l
4.1
Fecal Coliform (log NLUllber
IIOO
mL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May
24,
2001
A-29

IEPA
G-D2
99.9
99
c:
95
0
.-<
SO
.......
~
0
50
0...
0
20
~
0...
5
0.1
1.3
1.7
2.1
2.5
2.9
3.3
3.7
Fecal Colifonn (log Number / 100 mL)
IEPA G-23
50 1-
,
..
80 H.
. .............. .;.
..
5
.......... ... .0.
20 H
.
... .... ...•.....
.. .
.
.
95
99. 9
P:::-'::-:-:-:':":-:-:':"-'-'-:'-:-.T.-'-'-:'~~:-:-:-:"-:-:-:C~~~:-:-:-:":-:-:-:1~=':":::'":'':":::'":''."':'':":"q
99 1-,
;
.
.-<
c:
o
1::
o
0...
o
~
0...
o
2
4
Fecal ColifOlm (log Number / 100mL)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May
24,2001
A-3D

99.9
99
l:::::
95
0
.,....
......
l-<
80
0
50
0...
0
20
l-<
0...
5
0.1
0
MWRD 91
2
Fecal Colifonn (log Number
I
mL)
MWRD 92
45
/J/
J.,v/F
~
.~
V
~~
~.
te~
//0
/~
.
.
••
//~
99.9
99
l:::::
95
0
.,....
80
1::
0
50
0...
0
20
l-<
0...
5
0.1
o
Fecal Colifoml (log Number
1100
mL)
"
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-31

99.9
99
~
95
0
.€
80
0
50
P..
0
20
:-.
P..
5
0.1
MWRD 93
J///
u
.
~
0
@~
(}'
~0f3d[jl6'
-,
__lP
rdci~f'
.-.../",8'""
.
••
:
1.6
2.1
2.6
3.1
3.6
4.1
4.6
99.9
99
0
95
0
''''';
.........
80
l-i
0
50
P..
0
20
l-i
P..
5
0.1
Fecal ColifOlms (log Number /1 00 mL)
MWRD 94
1.5
2
2.5
3.5
4
Fecal ColifOlms (log Number /100 mL)
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May
24,
2001
A-32

o
MWRD 95
0.1
1.9
2.3
2.7
3.1
3.5
3.9
99.9
99
P
95
.......
0
80
t::
0
50
P-.
0
20
;...
P-.
0.1
Fecal ColifoffilS (log Number / 100mL)
Riverside (USGS)
,
,-,-,-""'".'''''.-
---------
0
~,,,
..
~'-
_
.
----0
~
.<yp..
~.
>"'0
~I:f
,-
~
.-
>-
1...--
.-
.-
2.5
2.9
3.3
3.7
4.1
4.5
Data not available
Fecal
ColifOlms (log Number /100
rnL)
Romeoville (USGS)
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,2001
A-33

99.9
99
::::
95
0
"C
80
l-o
0
50
0..
0
20
l-o
0..
5
Probability Plots for Flouride
Reference Site
........,-
..............;
;
-
1--11
,
0.......
• .
...
O. I
t::.t:::.:;::::.===i.=.::;:::::==i.==::;;:::.:.:L::i===d====,d
-1
-0.9
-0.8
-O.?
-0.6
-0.5
Data not available
Data not available
Flomide
Oog
Concentration - mgIL)
IEPA G-ll
IEPA G-02
IEPA
G-23
99.9
99
::::
95
0
.....
.....
;.....
SO
0
50
A
0
20
;.....
0..
0.1
///:
.
.
/6/'°
.
¥
.¢if
r
.
,"'"
.......
..........
-
.~8fF
...
.-
0
M
//
.
.. '.
............:-
i::J
....-
/,//'
.
••
.,-
-0.56
-0.36
-0.16
0.1)4
0.24
Flouride (log Concentration - mgIL)
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May 24,2001
A-34

MWRD 91
..................................v
..
~~:~
, -t:l
..•.••
I .•.
.••• .
.••••.•.•.
·............;;§:··d'~···<5
..........
.....
..a.
:
@@ ..
tff~F~;~~~·
.••••••••• .
.• ...•••• .
.• .
.• .....
...••.•.•......•..•..•••..•••.
~.
..........,
.
......................
99.9
99
I::
95
0
.-
1::
80
0
50
0..,
0
20
h
j::!,..,"<
0..,
O(]
d'"
(]
c
0.1
-0.61
-OAI
-0.21
-0.01
0.19
Flouride (log Concentration - mgIL)
MWRD 92
0.21
.................................
~-
-0.39
-0.19
O.oJ
.....""
.,
"
.
....,......
-~C~?B~
"
,
;;f~~~i;:
-
.
:"-
r""--!
.
?;~;c~!
..............•••••••••••••••••••••
~..::
99.9
-~
99
_
..
I::
95
-
0
.-<
80
_.'
t::
0
50
-:
0..,
0
20
-:.
h
0..
5
f-.
I-P
,~,..
,..<
.'
O.!
I-
-0.59
Flouride (log Concentration- mgIL)
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May 24,2001
A-35

MWRD 93
Q
.......
o
t::
o
0..
....
o
0..
0.1
-0.38
-0.28
-0.18
-0.08
0.112
0.12
Flouride (log Concentration - mg/L)
MWRD 94
......'0
.
o'
.«"
.
i
.
0'
~'
..
:o~_nkd~~~<~f~>······
p
-.
j....
.
.
0.1
CJ..
•..:..,._.__--'
.._..
...J.
...._"_._,,_._"_"_"....J"._.
--'-
-'-__.:....:...=
99.9
99
q
95
0
.......
-
....
80
0
50
0..
....
0
20
0..
5
-0.46
.0.36
.0.26
-0.16
-O.O(i
0.04
O.l4
Flouride (log Concentration - mglL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May
24,
2001
A-36

MWRD95
99.9
99
95
80 1->
.
50
20
.•..........
;...-..-,,,Cf
~"J!~.JJ
P.
.
.
.
"""
~
0.1 C:±===="----__-'--:.:..L====i====::i:.::.===:.::.::i=i
-0.46
-0.36
-0.26
.0.16
-0.06
0.04
99.9
99
!=l
95
.......
0
80
i:
0
50
0..
0
20
;...
0..
5
0.1
Flouride (log Concentration -
mgIL)
Riverside (USGS)
0
~
8
~.
§ __
.}i.--
~
_"..."..El,....
.. ....,,'''''
--~,,--_.P'
-r'"
........
-0.7
-0.5
-0.3
-0. J
0.1
Flouride (log Concentration -
mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-37

Romeoville (USGS)
99.9
99
q
95
0
......
~
80
l-<
0
50
0...
0
20
l-<
0...
0.1
-0.31
-0.21
-0.11
-0.01
0.09
Flouride (log Concentration - mgIL)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May
24,
2001
A-38

Probability Plots for Manganese
Reference Site
99.9
99
l::
95
0
.-
t::
80
0
50
0..
0
20
1-<
0..
5
0
0.1
-1.2
-1
-0.8
-0.6
-0.4
-0.2
Manganese (log Concentration- mgIL)
IEPA 0-11
99.9
99
l::
95
.
t::
-
0
80
1-..
0
50
0..
--".-
0
20
1-<
0..
5
0
1 _.
0.1 -
-1.9
-1.8
-1.7
-1.6
-1.5
o 0
-1.4
-1.3
Manganese (log Concentraion- mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,2001
A-39

IEPA 6-02
-1.8
-1.7
-1.6
-1.5
-1.4
-L3
Manganese (log Concentration - mglL)
99.9
99
q
95
0
......
+->
80
l-<
0
50
0..
0
20
l-<
0..
0.1
-1.9
o
IEPA 6-23
Lower Des Plailles River Use Attaillability Allalysis
Draft: May 24,2001
A-40

99.9
99
l::
95
0
.-
.....
H
80
0
50
0..
0
20
H
0..
5
0.1
MWRD 91
//
!
J;;(/
"'iii
n
...... §/!
~c
1,//
••
.F!!
,
••
r;V~
~r
.
-
'"
..
.;
-1.7
-1.3
-0.9
-0.5
-0.1
0.3
0.7
Manganese (log Concentration - mgIL)
MWRD 92
l::
o
.
.....
-
H
o
0..
H
o
0..
.....,......,,..,.,1.... .....
n ....... ' ......., ...
1
~9...,-
.".
--,. -------.--,-
0.1 H--.-........... .-- "-..--.--- .. . .
. 'Ii:"
.
'
-:
.
-:
.....
..
-:
.
-
.•
.
~
~
..
.;
.. iii"
....•
.:.
i__ .
.---
..
.'
.:
~
..
o
~-
.
,,+-
..
'i-
i-
i-
-2
-1.6
-1.2
-0.8
-0.4
()
0.4
Manganese (log Concentration- mglL)
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May 24,2001
A-41

MWRD 93
99.9
99
~
95
0
...-;
80
1:
0
50
0..
0
20
;...
0..
5
0.1
-1.7
-1.5
-1.3
-I.J
-0.9
-0.7
-0.5
Manganese (log Concentration - mglL)
MWRD 94
-0.2
D
-1.1
-0.8
-0.5
..
.
·_",o~-
f-;,......................................................
~.~~>'
.~
-l
f-~
::-tV"'~;
....-:..
~
':..>
6
..
> ".,
~
:
!
:-j
I-;..."""
~t''''.....
:
"-1
99.9
99
~
95
0
.......
......
;...
80
0
50
__,,-;;Il
d
0..
0
20
;...
A
5
D
~~
~
0.1
-1.7
-1.4
Manganese (log Concentration - mglL)
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,2001
A-42

MWRD 95
99.9
99
t::
95
.....
.......
0
80
l-<
0
50
0...
0
20
l-<
0...
0.1
-1.7
-1.5
-1.3
-1.1
-0.9
-0.7
-0.5
Manganese (log Concentraion -
mglL)
Riverside (USGS)
99.9
99
t::
95
0
80
'-2
0
50
0...
.....
0
20
0...
5
0.1
rlJ~/
<lp.-'_.-'.JiP"
..rl9Q'#~
13•..
P
;J'"
~
>.;.r/~--'"
..,
R
n
.~/Q./
...,v
~
-2.6
-2.3
-2
-1. 7
-1.4
-l.l
Manganese (log Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-43

99.9
99
I::
95
0
.
,....
;...,
..-;
80
0
50
0...
0
10
;...,
0...
0.1
Romeoville (USGS)
-:
-~.-~
:
."--t'i
0
--
:--~
0
!tl~-'5§
..-
:::ci'/d'
;-0--
...
-1.9
-1.8
-1.7
-1.6
-1.5
-1.4
-1.3
Manganese
Oog
Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,
2001
A-44

Probability Plots for pH
Reference Site
99.9
99
~
95
0
......
.....,
80
l-<
0
50
0..
0
20
l-<
0..
5
0
0.1
6.5
6.9
7.3
7.7
8.1
8.5
8.9
pH
IEPA G-ll
,""
80 1-'
50 1--
.
99.9
I=I-r-:-:,---:::-----:::--c=.====r---:::--===::::r====:=::r.===/==J::=====:q
99
I-
/~
~
......
o
1::
o
0..
o
l-<
0..
6.9
7.3
7.7
8.1
8.5
8.9
9.3
pH
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,
2001
A-45

IEPA G-02
99.9
99
c::
95
.-<
0
80
+->
;....
0
50
0...
0
20
;...,
0...
5
0.1
6.9
7.1
7.3
7.5
7.7
7.9
8.1
pH
IEPA G-23
99.9
99
c::
95
0
.-
+->
;....
80
0
50
0...
;....
0
20
0..
5
0.1
7
7.1
7.2
7.3
7.4
7.5
7,6
pH
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May 24,2001
A-46

MWRD 91
99.9
99
~
95
0
.
.....
-
~
SO
0
50
0..
0
20
~
0..
5
0.1
5.3
6.3
7.3
8.3
.......;z
../7/.."........"0.'
//
.
.
//'0
§ .... :.
.,.,.,"<>" •.•
' ••.
..... ,......,.Iii......
...."""...
"
......,,'.,..
"'''''.'
. "".........•
9.3
pH
MWRD 92
6.3
7.3
8.3
.
".,.......................
"
.... :;-;7.
...
..1-
.................
.
;....
:/:/.
.
.
;-
...
....L..../u<Q~.·...D:
/or
~-
...............
~....
.
idid~
~
;
.••••••••••••
~..
/!
...................•..•.•.•.••.•.•.••••••
~.::
.•.
.••.•.•••••••
tr~
.....
················,t:~
5.3
9.3
5
f-;'
[]
~
.....
50 1-;.
20
1-+.
0.1
f-:"
99.9 t- ..
99 1-;
95
I-~'
SO 1-;
pH
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-47

MWRD 93
99.9
99
0
••
......
.,..,
;....
h0
80
95
..
•••
0
;....
0
P..
50
20
••
P..
5
0.1
•••
..
5.2
6.2
7.2
8.2
9.2
pH
MWRD 94
99.9
99
c:
95
0
.
.,..,
;....
......,
80
0
50
P..
;....
0
20
P..
5
O.J
.....,,.........;..;;F
0........ .........................•........
.
~'b
.
:
.
00//:
,. .
iii'
,.... .
:
p/ll
.
..
.
[J9-'~
Ii
······l;~~~lf~
....
.• ...•
~··
.•.•
··~~~7.·L··
.•.......................•.•.•• ..•••.•.•.•.•.•.• S
•.•
_
../~.............
..
67
pH
8
9
10
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,
2001
A-48

MWRD 95
99.9
99
l:i
95
.....
......
1-<
0
80
0
50
0...
0
20
1-<
0..
0.1
o
. ,
:
.
.'.' .- .' ,
,..
~.
iii'
,., ..
~.
..................:.•....
.........
:.
:-
:-
,..
~
......
...~:
~DEi
.....
.........)~~~;~<~,/
.............. ".,..(
)~
;
"
................................+
4.9
5.9
6.9
7.9
8.9
pH
Riverside (USGS)
.-
..
..
-....
.. ,-
,"
~
.
0:
oo.sJ
.....
:i
111
.. !(
.......
'"'
-1
-'
."iii
-'
.....•.
-'
-'
....II'
-'
............" ,.,
.
.......................,
..
/
,:,'"
.."
d... .
_/
//~
.~~~~~.
'
0.1
Z
99.9
99
l:i
95
.....
......
1-<
0
80
0
50
0..
0
20
1-<
0...
5
7
7.4
7.8
8.2
8.6
9
pH
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May 24,2001
A-49

Romeoville (USGS)
99.9
9<J
~
(.)5
0
.,...
......
l-<
80
0
50
0...
0
20
l-<
0...
5
O. J
7.2
7.4
7.6
7.8
pH
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,2001
A-50

Data not available
Data not
availabb
Data not available
Data not available
Probability Plots for Phenol
Reference Site
IEPA
G-ll
IEPA G-02
IEPA G-23
MWRD 91
99.9
99
!=:
95
0
.-
+-'
80
H
0
50
0-;
0
20
H
0-;
0.1
1-'
....
,
/
/~
~
c~
~'
1-.
h
A~
mi;fa
1
!
/~i1l'"
i-'
i-;
n
• /9/
-~
./«
-2.4
-2.2
-1.8
-1.6
-1.4
-1.2
Phenol (log Concentration -
mglL)
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,
2001
A-51

MWRD 92
99.9
99
l=:
95
0
.,....
.....
I-<
80
0
50
0...
0
]0
I-<
0...
0.1
.,.. ..•...
. ..... [J
...•"."
.......
,,>'
.,.~.
.....
••
" ....
....•.....
"
.
....
II!I...
.:
.
-2.3
-2
-L7
-1.4
-1.1
-0.8
99.9
99
l=:
95
0
80
"-2
0
50
0...
0
20
;...
0...
0.1
Phenol (log Concentration- mgIL)
MWRD 93
:
,/
-:
/
u
-
M0
#DU
H
c13#~
:
.i.il
jill'"
H
n 0
3
9
/
o
u //
y/
I-
///
1-:
-2.4
-2.2
-2
-1.8
-1.6
-1.4
-1.2
Phenol (log Concentration - mg/L)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May 24,2001
A-52

MWRD 94
c
o
--2
o
0..
l-.
o
0..
99.9
99
95
.............."
"",,;
.
••• - ••••• "." •.• "•••.• "••• >.- •••••..
() 1
L.l..__
~'
._--._--.._...._.....J..--._
..._...__
~
_
_'_
..._.._.--_
......J..--._.--_
.. --
__'__l
-2.1
-1.9
- 1. 7
-1.5
-1.3
99.9
99
C
95
0
.';:;
80
l-.
0
50
0..
0
20
l-.
0..
5
0.1
Phenol (log Concentration -
mgIL)
MWRD 95
/,,///'
.
,0/>/
LI
~.//jO~
,-
..!'Ygj,l
~-€l'!=I
/sr~'
,-
//c;'f~
'"
'~--;:;/'
CJ
-2,1
-1.9
-1.7
-1.5
-1.3
Phenol (log Concentraion -
mglL)
Riverside (USGS)
Data not available
Romeoville (USGS)
Data not available
Lower Des Plaines River Use Attainability Analysis
Draft:
May
24,
2001
A-53

99.9
99
l::
95
0
.....
+-'
80
l-<
0
50
0..
0
20
l-<
0..
0.1
Probability Plots for Dissolved Iron
Reference Site
.......
.....
....
.. ,
.,.~~<;Z
.,.,...
n
:P
................
l//>
co
~/
!
;//
//
//
...
-2
-J.
7
-1.4
-1.1
-0.8
-0.5
Dissolved Iron (log Concentration - mg!L)
IEPA G-ll
Data Insufficient for probability plot. Within acceptable range.
IEPA G-02
Data Insufficient for probability plot. Within acceptable range.
IEPA G-23
Data Insufficient for probability plot. Within acceptable range.
Lower Des Plailles River Use Attaillability Allalysis
Draft: May
24,
2001
A-54

99.9
99
~
95
.,....
.....
;...;
0
80
0
50
p.,
0
20
;...;
p.,
0.1
MWRD 91
: ..
,-
n
0
.,,,_
....•
i:P
8':'_-
,........
"'rf1iila~oa'
Bo..-"
~_'6"a'"
........
---
>,,_.
I
[
i
-2
-1.7
-1.4
.1.1
-0.8
-0.5
-0.2
99.9
99
0
95
0
.,....
......;...;
80
0
50
p.,
0
20
;...;
p.,
5
0.1
Dissolved Iron (log Concentration - mglL)
MWRD 92
......
,
n']
~
B
El
~
u
..---------
l!l_-B--~'-~----
..----{
1----;---
1----
0
,;,
-1.7
-1.4
-1.1
-0.8
-0.5
Dissolved Iron (log Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May
24,
2001
A-55

99.9
99
r::
95
0
of
80
0
50
P..
0
20
;...
P..
5
0.1
-2
-1.7
-IA
MWRD 93
-1.1
-0.8
-0.5
-0.2
99.9
99
~
95
0
.....
80
t::
0
50
P..
;...
0
20
P..
5
0.1
Dissolved Iron (log Concentration - mglL)
MWRD 94
~l:fI0o
e.-:"---
~
:J
.-----
t.
f1
_.'
?__
I;;I,5l.-.
,.__!il_--l
!}"...",
i------.
~
...
......
-2
-1.7
-1.4
-1.1
-0.8
.0.5
Dissolved Iron (log Concentration - mglL)
-0.2
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-56

99.9
99
c::
95
0
......
......
l-<
80
0
50
0...
0
20
l-<
0...
0.1
-2
-1.7
-1.4
MWRD 95
-1.1
-0.8
-0.5
-0.2
99.9
99
c::
95
• .-<
0
80
t:
0
50
0...
0
20
l-<
A
5
0.1
Dissolved Iron (log Concentraion - mgIL)
Riverside (USGS)
,//
.,,/0/
u
i)~"/'-'
~i;J
'.
............
.///•.
.... " ,".". 0< ..........
~".
-2
-1.7
-1.4
-1.1
-0.8
-0.5
-0.2
Dissolved Iron (log Concentration - mgIL)
Lower Des Plaines River
Use
Attainability Analysis
Draft: May
24,
2001
A-57

99.9
99
l=:
95
0
.......
....
1-<.
80
0
50
0...
0
20
H
0...
0.1
-2
-1.8
Romeoville (USGS)
-1.6
-1.4
-1.2
Dissolved Iron (log Concentration - mgfL)
Lower Des Plaines River
Use
Attainability Analysis.
Draft: May
24,2001
A-58

Probability Plots for Sulfate
Reference Site
99.9
99
95
•..
80
50
20
, 'g
.ir
.•.•.•.•.••
~
••••.•••..........
,
.
0.1 LJ..
'_'/_'
._
.._..J..
-'-
---'
-L....!
1.6
1.8
2
2.2
2.4
99.9
99
~
95
.....
~
0
....
0
50
80
0..
....
0
20
0..
5
0.1
Sulfate (log Concentration - mgIL)
IEPA G-ll
,.
.......,-
'0
1~~i9J/~
e&Pd'T
tF
J>~
,
~fi-
.........
CJ
,Ji
n
0
,/'/
////'
1.5
1.6
1.7
1.8
1.9
2.1
Sulfate (log Concentration - mglL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May
24,
2001
A-59

99.9
99
s:::
95
0
.-
+-'
;....
80
0
50
0..
0
20
;....
0..
5
0.1
IEPA G-02
.'
,
0
.-ri
t.i::J......>
~
•• _.• o
An-'
u
.=
~--
OW
......
i:J
1.8
l.85
1.9
1.95
2
2.05
~.I
Sulfate
(tog
Concen1ration - mglL)
IEPA G-23
99.9
99
s::;
95
0
.-
+-'
;....
80
0
50
0..
0
20
I-<
0..
0.1
1.7
1.8
1.9
2
Sulfate (log Concentration - mgIL)
~.I
Lower Des Plailles River Use
A ttaillability
Allalysis
Draft:
May 24,2001
A-60

MWRD 91
99.9
99
l=:
95
0
.-
+-'
80
I-<
0
50
0..
0
20
I-<
0..
5
0.1
1.6
1.7
1.8
1.9
2
2.1
Sulfate (log Concentration - mgIL)
MWRD92
99.9
99
~
95
'''-;
0
80
+-'
I-<
0
50
0..
0
20
I-<
0..
0.1
:P
cEl
Jl
~
..
"~"~
#~/"
....neil
1:I?"i;L.~iP
J$:f!.J!!..- ..-
~M.....--o~
~
1.7
1.8
1.9
2.1
2.2
Sulfate (log Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft: May 24,2001
A-61

99.9
99
$:I
95
0
......
80
t::
0
50
0..
0
20
.....
0..
5
0.1
1.7
1.8
1.9
MWRD 93
2
2.1
o
2.2
Sulfate (log Concentration - mglL)
MWRD 94
99.9
99
$:I
95
0
......
.....
.....
80
0
50
0..
.....
0
20
0..
5
0.1
1.6
.;....
1.7
1.8
1.9
2
2.1
2.2
Sulfate (log Concentration - mgIL)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May 24,2001
A-62

MWRD 95
999
99
c::
95
0
"Z
SO
l-.<
0
50
0..
0
20
l-.<
0..
OJ
1.6
1.7
1.8
1.9
Sulfate (log Concentraion - mgIL)
Riverside (USGS)
2.1
2.2
99.9
99
c::
95
0
SO
"f
0
50
0..
0
20
;...
0..
0.1
1-'
1--
u
1-..
R
I-~
~
.~.-"
1-'
~.g.
---
~g;J#--"I'-'
1-.
-
I-
i5I
l:l~~~'
:
....,..
.Q:~-
1-'
,
1-,
.
1.6
L7
1.8
1.9
2
2.1
Sulfate (log Concentration - mgIL)
Lower Des Plai1les River Use Attai1lability A1lalysis
Draft:
May 24,2001
A-63

Romeoville (USGS)
99.9
99
~
95
0
.....
80
~
0
50
0..
0
20
l-<
0..
5
a
0.1
I.7
1.8
1.9
2.1
Sulfate (log Concentration -
mglL)
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,2001
A-64

~
.-
t::
oo
0..
o
0..
....
Probability Plots for Temperature
Reference Site
o
5
10
15
20
25
30
99.9
99
~
95
.-
.....
00
....
8050
0..
0..
....
0
205
01
Temperatme (C)
!EPA G-ll
1-" ....
........
;=
J:/"/
A
,/~
dP'
-
0
/
.87
.
-
.0
/
/~//
-0.7
-0.3
0.1
0.5
0.9
1.3
1.7
Temperature (log C)
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-65

!EPA G-02
99.9
99
Cl
t::
95
.,....;
0
80
+-'
l-<
0
50
0...
0
20
l-<
0...
5
0.1
0.68
0.88
1.08
1.28
1.48
Temperature ( log
C)
!EPA G-23
99.9
99
t::
95
.
0
,....;
80
+-'
l-<
0
50
0...
0
20
l-<
0...
5
..• '
"
'._.
.
_
'.'._ .. '0._.
. ..
. 0:'or
••...••••.••
~..
....• •••••.•••
~..
.
.. ....-
.~::.~:.J.
......•.•...•...•.•.•.•..•...•...
J~~,.
~
.
................ ,
,
..
,,~[]
.-.-1:P:
"
:
'.
.
9-"~
o~-r
..........,
. .....:
.:
0.1
=..,:.:..;....._._
..
~
.._
.........:.:
.........:.:.'.:.:'..........
~._
..
~
.._
.._
.. _'-..
~~~~._
.. -'-
.._.
~~~---'-~_~~=
0.54
0.74
0.94
1.14
1.34
1.54
Temperature (log
C)
Lower Des Plaines River Use Attainability Analysis
Draft: May
24,
2001
A-66

MWRD 91
..... ,,-
.... <-
. ,-
.....
-
....
.....................................,
.
.
...
'_..
//
::.-
2031
7
;:
:
~
.
"
.................."...! ..".,.,
..
.....................:
~
.
.
0.1 f-L ..
99.9
99
.95
80
:
o
10
20
30
40
Temperature
(C)
MWRD 92
99.9 f-,....
99 H.nn,n
95 f-+ .n
n ' .
80 f-i.
,..
50 ,-+
. ........•.
...... !-
0.65
0.85
1.05
1.25
1.45
1.65
Temperature (log
C)
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May 24,2001
A-67

MWRD 93
99.9
99
I=:
95
0
......
.....,
80
:-.
0
50
P..
0
20
:-.
P..
5
0
0.1
0.59
0.79
0.99
1.I9
L39
1.59
Temperature (log C)
MWRD 94
q
......
o
1::
o
P..
o
a
99.9
-~.....
.
"..
.
~-
: =:PP.
..............-.............i.I
..
~2.;.I=
[J~
0.1
~
1-""
~;~~~TI..........::
..... _...
.
......i-
o
10
20
Temperature (C)
30
40
Lower Des Plaines River Use Attainability Analysis
Draft: May 24,2001
A-68

MWRD 95
99.9
99
Q
95
0
.......
......
1-<
SO
0
50
0..
0
20
1-<
0..
0.1
0
10
20
30
40
Temperature (C)
Riverside (USGS)
99.9
99
Q
95
......
0
80
t::
0
50
0..
0
20
1-<
0..
5
0.1
.
It
,-'
-'10
-~[:>-"-"
_nr;f19l~
...p--""~
~
n._rl
~-"~
;.g"_o~_"·J;J9:"'"-
~
o
5
10
15
20
25
30
Temperature (C)
Lower Des Plaines River Use Attainability Analysis
Draft: May 24,2001
A-69

Romeoville (USGS)
99.9
99
~
95
0
.,....
80
~
0
50
0..
0
20
$..;
0..
5
a
0.1
0.79
0.99
1.19
1.39
1.59
Temperature (log C)
Lower Des Plaines River Use Attainability Analysis
Draft: May 24,2001
A-70

99.9
99
q
95
0
.,..,
80
+->
I-<
0
50
0..
0
20
I-<
0..
5
0.1
-2
Probability Plots for Total Ammonium as Nitrogen
Reference Site
-1.7
-1.4
-1.1
-0.8
-0.5
Total Ammonium as N (log Concentration - mgIL)
IEPA G-ll
99.9
99
q
95
.-
1:::
0
80
0
SO
0..
0
20
I-<
0..
5
0.1
'//
.."pO
~g...
",1J
~[
~/
E:l g
~"
0
'~"/7'
,.;.
~~.
,-
...
................ ,-
-2
-1.5
-1
-0.5
o
0.5
Total Ammonium as N (log Concentration - mg/L)
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May
24,
2001
A-7!

IEPA G-02
99.9
99
s:::
95
0
.-<
80
+-'
H
0
50
0...
0
20
H
0...
5
0.1
-2
-1.6
-1.2
-0.8
-0.4
0
0.4
99.9
99
s:::
95
0
.-
+-'
80
H
0
50
0...
0
20
H
0...
5
0.1
Total Ammonium as N (log Concentration - mgIL)
IEPA G-23
.,.........
:.
,....
//
~/
...
L
0
,....
..aF
f5I
Jfl~u~
~!iV6
n
J.~r';f'
,0
///
[
/
-1.7
-1.2
-0.7
-0.2
0.3
0.8
[0£ lO(NH3 Tot)
Lower Des Plaines River Use Attainability Analysis
Draft: May 24,2001
A-72

MWRD 91
99.9
99
c:
95
......
0
80
--
l-<
0
50
0...
0
20
l-<
0...
5
0.1
-LA
-1.2
-I
-0.8
-0.6
-0.4
.......0:
[J
-0.2
Total
Ammonium as N (log Concentration - mglL)
MWRD
92
99.9
99
c:
95
......
0
80
--
l-<
0
50
0...
0
20
l-<
0...
5
0.1
-0.7
-0.5
-0.3
-0.1
0.1
0.3
0.5
Total
Ammonium as N (log Concentration - mglL)
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May
24,
2001
A-73

MWRD
93
99.9
99
0
95
0
".p
80
;....
0
50
0..
0
20
;....
0..
5
0.1
-1
-0.8
-0.6
-0.4
-0.2
0
0.2
Total Ammonium
as
N
(log
Concentration - mgtL)
MWRD 94
99.9
99
Q
95
0
.....
.....,
;....
80
0
50
0..
;....
0
20
0..
5
0.1
-0.86
-0.66
-0.46
-0.26
-0.06
0.14
Total Ammonium
as
N
(log
Concentratiol1-mgIL)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May
24,2001
A-74

99.9
99
Q
95
......
.....
1-<
0
80
0
50
0..
0
20
1-<
0..
0.1
-1
-(J.7
-0.4
MWRD 95
-0.1
0.2
0.5
99.9
99
!=i
95
......
0
80
t::
0
50
0..
0
20
1-<
0..
5
O.
j
Total Ammonium as N (log Concentration - mg/L)
Riverside (USGS)
_c..
:
:
:
//6'
-,
/<lXU
_c..
/~QJ
,~t(tI~
-~
/~
V
_:
_:.
v/
///~
-2
-1.7
-1.4
-1.1
-0.8
-0.5
-0.2
Total Ammonium as
N
(log Concentration - mg/L)
Romeoville (USGS)
Data not available
Lower Des Plaines River Use Attainability Analysis
Draft:
May
24,
2001
A-75

99.9
99
C
95
0
.,....
80
.;...>
l-<
0
50
0..
0
20
l-<
0..
5
0.1
-3
Data not available
Data
not available
Data
not available
Probability Plots for Unionized Ammonia
Reference Site
o
-2.8
-2.6
-2.4
-2.2
-2
-1.8
Unionized Ammonia (log Concentration - mglL)
IEPA G-ll
IEPA G-02
IEPA
G-23
Lower Des Plaines River Use Attainability Analysis
Draft: May 24,2001
A-76

Data rot available
Data not available
Data not available
Data not available
Data not available
MWRD 91
MWRD 92
MWRD
93
MWRD 94
MWRD
95
Riverside (USGS)
99.9
99
C
95
......
.....
....
00
8050
0...
....
0
20
0...
5
0.1
,__",-,--'0"
.8-.-
:-9'_:>=-"
~
----"
.......
..-
t-..--.---'
'-"e
-3
-2.8
-2.6
-2.4
-2.2
-2
-1.8
Data not available
Unionized Ammonia (log Concentration - mgIL)
Romeoville (USGS)
Lower Des Plailles River Use Attaillability Allalysis
Draft:
May
24,
2001
A-77

Probability Plots for
Cyanide(Weak
Acid Dissociable)
Reference Site
Data not available
IEPA G-Il
Data not available
IEPA G-02
Data not available
IEPA G-23
Data not available
MWRD 91
99.9
99
Q
95
0
.,....
80
1::
0
50
0..
0
20
I-<
0..
5
0.1
.,
//,./
"/u
,,~~,'c;'/.;
"d
P
s/!il/'
/0"
//i/''''
Y/'1:l
[
>/
;
~///
.
-4
-3.7
-3.4
-3. J
-2.8
-2.5
WADCN (log Concentration -
mglL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-78

99.9
99
c:
95
.......
0
80
1:
0
50
P-.
0
20
l-<
P-.
5
0.1
MWRD 92
-.-
'
'.. .
/:
-2.7
-2.5
-2.3
-2.1
-1.9
-1.7
99.9
99
~
95
0
.......
80
1:
0
50
P-.
0
20
l-<
P-.
5
0.1
WADCN (log Concentration -
mg/L)
MWRD 93
....
/~
.,);y/
.eAf"
~~i
p,,,,
~
y,/j}-{J
....
o~~>~
./,//
.,.
-3.7
-3.5
-3.3
-3.1
-2.9
-2.7
-2.5
WADCN (log Concentration -
mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft: May 24,2001
A-79

99.9
99
0
95
.~
0
80
t::
0
50
0..
0
20
;....
0..
0.1
-3.4
-3.2
-3
MWRD 94
-2.8
o
-2.6
-2.4
WADCN (log Concentration - mg/L)
MWRD 95
99.9
99
0
95
.~
0
80
.;..;>
;....
0
50
0..
0
20
;....
0-;
0.1
-3.4
-3.2
-3
-2.8
-2.6
-2.4
Data not available
Data
not available
WADCN (log
Omcentratioll - mg/L)
Riverside (USGS)
Romeoville (USGS)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May 24,2001
A-SO

Data not available
Data not available
Data not available
Data not available
Probability Plots for Dissolved Zinc
Reference Site
IEPA
G-ll
IEPA G-02
IEPA G-23
MWRD
91
99.9
99
=
95
0
.-
1::
80
0
50
0...
0
20
I-<
0...
5
0.1
-:
-:
~
/~
-: ....
nnS
~
-
~~
_c..
..,.l
EI
_~I'~
R
//-
...
~-
~/'~
-1.7
-1.5
-1.3
-Ll
-0.9
Dissolved Zinc (log Concentration - mgIL)
Lower Des Plaines River Use Attainability Analysis
Draft:
May 24,2001
A-81

99.9
99
P
95
0
......
.......
.....
SO
0
50
0..
0
20
.....
0..
0.1
-2
-1.8
-1.6
MWRD 92
-1.4
-1.2
-I
-0.8
99.9
99
P
95
0
......
SO
t::
0
50
0..
0
20
.....
0..
0.1
Dissolved Zinc (log Concentration - mgIL)
MWRD 93
-,
/'/
-
.~//
u
...
n
0
o/f
~/
~~y
PI
/-1
V
f-
,//Ir
t-
~<///
//i
-2
-1.7
-1.4
-l.l
-o.S
-0.5
Dissolved Zinc (log Concentration - mglL)
Lower Des Plailles River Use Attaillability Allalysis
Draft: May
24,
2001
A-82

99.9
99
~
95
0
.,...,
.....,;...
80
0
50
0..
;...
0
20
0..
5
o. ]
-2
-1.8
-1.6
MWRD 94
-1.4
-1.2
-I
-0.8
99.9
99
~
95
0
.
.....,
;...
.-;
80
0
50
0...
;...
0
20
0..
5
0.1
Dissolved Zinc (log Concentration - mg/L)
MWRD 95
--~
~rP1ft
u
__
~~/f
B
/"Q"~
~
"~~~
El
~/
0
-2
-1.8
-1.6
-1.4
-1.2
-I
-0.8
Data not available
Data not available
Dissolved Zinc (log Concentration
- mgIL)
Riverside (USGS)
Romeoville (USGS)
Lower Des Plail/es River Use Attail/ability AI/alysis
Draft:
May 24,2001
A-83

Back to top


Appendix C
Copper Analysis

One-Variable Analysis - 10g10 (Cli T AC) (site=91)
Summary Statistics for log10(CU_T_AC)
Count
~
50
Average
~
-0.670479
Median
~
-0.67904
Variance
~
0.0678061
Standard deviation
~
0.260396
Maximum
~
-0.0998848
Quantile Plot
~cP
cP 0
c
0.8
:;:;0
....
0.6
.J;
0
....
c..c..
0
0.4
(it
0.2
0
0
@I
-1.2
-1
-0.8
-0.6
-0.4
-0.2
0
log1 O(CU_T_AC)
Percentiles for log10(Cu_T_AC)
1.0%
~
-1.12718
5.0%
~
-1.0896
10.0%
-1.01673
25.0%
-0.863645
50.0%
-0.67904
75.0%
-0.508458
90.0%
-0.319945
95.0%
-0.20302
99.0%
-0.0998848
Normal Probability Plot
+
<D
0)
.....ro
c
<D
....
u
<D
0..
99.9
99
95
80
50
20
5
1
0
0.1
-1.2
-1
-0.8
-0.6
-0.4
log 1O(Cu_T _AC)
-0.2
o

One-Variable Analysis - 10910 (Cu T AC) (site=92)
Summary Statistics for log10(CU_T_AC)
Count
=
50
Average
=
-0.636359
Median
=
-0.633752
Variance
=
0.0719213
Standard deviation
0.268181
Maximum
=
-0.15168
Quantile Plot
c
0.8
o
~
0.6
0..
L-
o 0.4
0..
0.2
o
-1.1
-0.9
-0.7
-0.5
-0.3
-0.1
log10(Cu_T_AC)
Percentiles for log10(Cu_T_AC)
1.0%
=
-1.02097
5.0%
=
-0.993685
10.0%
-0.936255
25.0%
-0.898073
50.0%
-0.633752
75.0%
-0.392853
90.0%
-0.235687
95.0%
-0.191161
99.0%
-0.15168
Normal Probability Plot
Q)
0)
......
co
c
Q)
()
L-
Q)
0..
99.9
99
95
80
50
20
5
1
0.1
-1.1
-0.9
-0.7
-0.5
-0.3
log10(Cu_T_AC)
-0.1 0

One-Variable Analysis - loglO(Cu T AC) (site=93)
Summary Statistics for log10(Cu_T_AC)
Count = 48
Average
=
-0.644268
Median
=
-0.630148
Variance
=
0.0717919
Standard deviation
=
0.26794
Maximum
=
-0.179057
Quantile Plot
,0
c
0.8
,o@
0
0&1
:;:::;
0.6
'-
r
oF
0
0..
0
0.4
'-
0..
0.2
~I
0
-1.1
-0.9
-0.7
-0.5
-0.3
-0.1
log1 O(CU_T_AC)
Percentiles for log10(Cu_T_AC)
1.0% = -1.03208
5.0% = -1.02915
10.0%
-0.9823
25.0%
-0.910682
50.0%
-0.630148
75.0%
-0.412966
90.0%
-0.231084
95.0%
-0.215847
99.0%
-0.179057
Normal Probability Plot
a>
0)
......
co
c
a>
L-
o
a>
0..
99.9
99
95
80
50
20
5
1
0.1
-1.1
-0.9
-0.7
-0.5
-0.3
-0.1
log10(Cu_T_AC)
o

One-Variable Analysis - 10910 (Cli T AC) (site=94)
Summary Statistics for log10(Cu_T_AC)
Count
=
50
Average
=
-0.610251
Median
=
-0.599325
Variance = 0.0686361
Standard deviation = 0.261985
Maximum
=
0.0291739
Quantile Plot
riD
0
c:
0.8
/
od§l
0
:;:::;
....
0.6
0
Q.
....
Q.
0
0.4
0.2
~@
0
f5P
-1.1
-0.9
-0.7
-0.5
-0.3
-0.1
0.1
log1 O(CU_T_AC)
Percentiles for log10(Cu_T_AC)
1.0%
=
-1.05965
5.0%
=
-1.02846
10.0%
-0.98381
25.0%
-0.838133
50.0%
-0.599325
75.0%
-0.469388
90.0%
-0.249219
95.0%
-0.229886
99.0%
0.0291739
Normal Probability Plot
a.>
OJ
......
co
c:
a.>
....
()
a.>
Q.
99.9
99
95
80
50
20
5
1
0
0.1
-1.1
-0.9
-0.7
-0.5
-0.3
log10(Cu_T_AC)
-0.1
0.1

One-Variable Analysis - 10g10 (Cu T AC) (site=95)
Summary Statistics for log10(Cu_T_AC)
Count
~
40
Average
~
-0.621178
Median
~
-0.629625
Variance
~
0.0691333
Standard deviation
~
0.262932
Maximum
~
-0.162834
Quantile Plot
c
0.8
0
:;::;
....
0.6
0
0..
....
0
0.4
0..
0.2
0
0
-1.2
-1
-0.8
-0.6
-0.4
-0.2
log1 O(CU_T_AC)
o
Percentiles for log10(Cu_T_AC)
1.0%
~
-1.11483
5.0%
~
-0.976653
10.0%
-0.947736
25.0%
-0.850172
50.0%
-0.629625
75.0%
-0.370136
90.0%
-0.273706
95.0%
-0.196403
99.0%
-0.162834
Normal Probability Plot
Q)
0)
.....
c
CO
Q)
....
()
Q)
0..
99.9
99
95
80
50
20
5
1
0.1
-1.2
o
jl!JP
o
-1
-0.8
-0.6
-0.4 -0.2
log10(Cu_T_AC)
o

One-Variable Analysis - 10g10 (Cli T
ce)
(site=91)
Summary Statistics for log10(Cu_T_CC)
Count
=
50
Average
=
-0.453427
Median
=
-0.46314
Variance
=
0.0664622
Standard deviation
0.257803
Maximum
=
0.102259
Quantile Plot
#cP
cPO
c
0
0.8
rfl°@
:.e
0.6
0
II'
L..
c..
0
0.4
c..
0.2
~
0
~I
-0.9
-0.7
-0.5
-0.3
-0.1
0.1
0.3
1091 O(Cu_T_CC)
Percentiles for log10(Cu_T_CC)
1.0%
=
-0.897587
5.0%
=
-0.863502
10.0%
-0.79742
25.0%
-0.658581
50.0%
-0.46314
75.0%
-0.284675
90.0%
-0.104698
95.0%
0.00719819
99.0%
0.102259
Normal Probability Plot
Q.)
O'l
......
ro
c
Q.)
U
L..
Q.)
c..
99.9
99
95
80
50
20
5
1
0.1
-0.9
-0.7
-0.5
-0.3
-0.1
log10(Cu_T_CC)
0.1
0.3

One-Variable Analysis - 10g10 (CU T CC) (site=92)
Summary Statistics for log10(Cu_T_CC)
Count
=
50
Average
=
-0.428839
Median
=
-0.422067
Variance
=
0.0705013
Standard deviation
=
0.265521
Maximum
=
0.0552847
Quantile Plot
-0.81
-0.61
-0.41
-0.21
-0.01
0.19
Percentiles for log10(Cu_T_CC)
1.0%
=
-0.801262
5.0%
=
-0.776518
10.0%
-0.724433
25.0%
-0.689805
50.0%
-0.422067
75.0%
-0.177644
90.0%
-0.0311076
95.0%
0.00734718
99.0%
0.0552847
Normal Probability Plot
Q)
0)
2
c
Q)
~
Q)
Cl..
99.9
99
95
80
50
20
5
1
0.1
-0.81
o
o
-0.61
-0.41
-0.21
-0.01
log10(Cu_T_CC)
0.19

One-Variable Analysis - 10910 (Cu T CC) (site=93)
Summary Statistics for log10(Cu_T_CC)
Count
=
48
Average
=
-0.434513
Median
=
-0.418799
Variance
=
0.0704534
Standard deviation = 0.265431
Maximum
=
0.0239742
Quantile Plot
1.0%
=
-0.811343
5.0%
=
-0.808683
10.0%
-0.766193
25.0%
-0.70124
50.0%
-0.418799
75.0%
-0.203974
90.0%
-0.0288596
95.0%
-0.0112233
99.0%
0.0239742
Normal Probability Plot
Q.)
O'l
......
ctl
C
Q.)
....
Q.)
c..>
0..
99.9
99
95
80
50
20
5
1
0.1
-0.82
-0.62
-0.42
-0.22
-0.02
log10(Cu_T_CC)
0.18

One-Variable Analysis - 10g10 (Cu T CC) (site=94)
Summary Statistics for log10(Cu_T_CC)
Count
=
50
Average
=
-0.400037
Median
=
-0.390844
Variance
=
0.0670809
Standard deviation
0.259
Maximum
=
0.236192
Quantile Plot
1
0
0
c
0.8
/
DeE
0
~
....
0.6
0
0..
....
0..
0
0.40.2
,@
0
tP
-0.9
-0.7
-0.5
-0.3
-0.1
0.1
0.3
log10(Cu_T_CC)
Percentiles for log10(Cu_T_CC)
1.0% = -0.836343
5.0%
=
-0.808053
. 10.0%
-0.767562
25.0%
-0.635444
50.0%
-0.390844
75.0%
-0.265632
90.0%
-0.0443201
95.0%
-0.0226786
99.0%
0.236192
Normal Probability Plot
99.9
per
99
ce 95
nta
80
50
ge
20
5
1
0
0.1
-0.9
-0.7
-0.5
-0.3
-0.1
log10(Cu_T_CC)
o
0.1
0.3

One-Variable Analysis - 10910 (Cli T CC) (site=95)
Summary Statistics for log10(Cu_T_CC)
Count
=
40
Average
=
-0.411728
Median
=
-0.425915
Variance
=
0.0677506
Standard deviation
=
0.260289
Maximum
=
0.0436439
Quantile
Plot
c
0.8
0
:;:::;
.....
0.6
0
.....
c..c..
0
0.4
,gP
0.2
01:0
0
-0.89
-0.69
-0.49
-0.29
-0.09
0.11
Percentiles for log10(Cu_T_CC)
1.0%
=
-0.886389
5.0%
=
-0.76107
10.0%
-0.734846
25.0%
-0.646363
50.0%
-0.425915
75.0%
-0.158253
90.0%
-0.0655416
95.0%
0.00644575
99.0%
0.0436439
Normal Probability Plot
(1)
0)
.....
c
(1)
ro
~
(1)
n.
99.9
99
95
80
50
20
5
1
0
0.1
-0.89
-0.69
-0.49
-0.29
-0.09
log10(Cu_T_CC)
0.11

One-Variable Analysis - loglO(Cu D AC) (site-91)
Summary Statistics for log10(Cu_D_AC)
Count
=
50
Average
=
-0.882939
Median
=
-0.933974
Variance
=
0.0759142
Standard deviation
=
0.275525
Maximum
=
-0.358948
Quantile Plot
cD
DEi
c
0.8
rP°
0
oP
:e
0.6
/
DO
0
0..
0
0.4
'-
0..
0.2
@1!fI
0
Ql@
-1.4
-1.2
-1
-0.8
-0.6
-0.4
-0.2
Percentiles for log10(Cu_D_AC)
1.0% = -1.36948
5.0%
=
-1.3152
10.0%
-1.24662
25.0%
-1.06452
50.0%
-0.933974
75.0%
-0.643328
90.0%
-0.498526
95.0%
-0.41219
99.0%
-0.358948
Normal Probability Plot
Q)
0)
+-'co
c
Q)
()
'-
Q)
0..
99.9
99
95
80
50
20
5
1
0.1
-1.4
-1.2
-1
-0.8
-0.6
log10(Cu_D_AC)
-0.4
-0.2
o

One-Variable Analysis - 10g10 (Cll D AC) (site=92)
Summary Statistics for log10(Cu_D_AC)
Count
=
50
Average = -0.727801
Median
=
-0.744983
Variance
=
0.0707261
Standard deviation = 0.265944
Maximum
=
-0.223018
Quantile
Plot
c
:;::::;
o
....
o
0..
....
o
0..
0.8
0.6
/
0.4
§
or:FP
0.2
o
ol§!
I
-1.2
-1
-0.8
-0.6
-0.4
-0.2
Percentiles for log10(Cu_D_AC)
1.0%
=
-1.12993
5.0%
=
-1.08004
10.0%
-1.02626
25.0%
-0.958256
50.0%
-0.744983
75.0%
-0.499287
90.0%
-0.321383
95.~%
-0.268074
99.0%
-0.223018
Normal Probability Plot
Q)
0)
J]
C
Q)
e
Q)
n.
99.9
99
95
80
50
20
5.
1
0.1
-1.2
~§D
fJ
o
-1
-0.8
-0.6
-0.4
log10(Cu_D_AC)
-0.2
o

One-Variable Analysis - 10910 (Cli D AC) (site=93)
Summary Statistics for log10(Cu_D_AC)
Count
=
48
Average = -0.788253
Median
=
-0.80423
Variance
=
0.0659415
Standard deviation
=
0.256791
Maximum = -0.306943
Quantile Plot
rffJf5!
0.8
cP @
c
0
W'
t
0.6
0
fjjt?
CL
.....
0
0.4
/@
c..
0.2
0
0
-1.2
-1
-0.8
-0.6
-0.4
-0.2
Percentiles for log10(Cu_D_AC)
1. 0%
=
-1.18096
5.0%
=
-1.11008
10.0%
-1. 09204
25.0%
-1.01615
50.0%
-0.80423
75.0%
-0.589653
90.0%
-0.370461
95.0%
-0.357379
99.0%
-0.306943
Normal Probability Plot
per
99.999
~
0
ce 95
nta
80
50
/dP
oiUl!flJl
ge
20
5
1
0
0.1
-1.2
-1
-0.8
-0.6
-0.4
-0.2
0
log10(Cu_D_AC)

One-Variable Analysis - 10910 (Cu D AC) (site=94)
Summary Statistics for log10(Cu_D_AC)
Count
=
50
Average = -0.758788
Median = -0.75577
Variance
=
0.0716555
Standard deviation
=
0.267686
Maximum = -0.0744833
Quantile Plot
J
0
c
0.8
/~
0
:;:::;
....
0.6
0
0.
0.
....
0
0.4
0.2
I~
0
0
-1.3
-1
-0.7
-0.4
-0.1
0.2
Percentiles for log10(Cu_D_AC)
1.0%
=
-1.2102
5.0%- = -1.1531
10.0%
-1.11297
25.0%
-0.941408
50.0%
-0.75577
75.0%-
-0.572771
90.0%
-0.399729
95.0%
-0.378633
99.0%
-0.0744833
Normal Probability Plot
Q)
0)
.....
c
co
Q)
.....
()
Q)
Cl.
99.9
99
95
80
50
20
5
1
0.1
-1.3
o
-1
-0.7
-0.4
-0.1
log10(Cu_D_AC)
0.2

One-Variable Analysis - 10g10 (Cli D AC) (site=95)
Summary Statistics for log10(Cu_D_AC)
Count
~
40
Average
~
-0.771071
Median
~
-0.782482
Variance
~
0.0733137
Standard deviation
~
0.270765
Maximum
~
-0.284285
Quantile Plot
c
0.8
0
:;::;
.....
0.6
0
Cl..
.....
0
0.4
Cl..
0.2
0
OJ
-1.3
-1.1
-0.9
-0.7
-0.5
-0.3
-0.1
log10(Cu_D_AC)
Percentiles for log10(Cu_D_ACl
1.0%
~
-1.24477
5.0%
~
-1.19028
10.0%
-1.11146
25.0%
-0.991605
50.0%
-0.782482
75.0%
-0.548878
90.0%
-0.380191
95.0%
-0.32197
99.0%
-0.284285
Normal Probability Plot
-1.1
-0.9
-0.3
-0.1 0
-0.7
-0.5
log10(Cu_D_AC)
cJIl~
oQJ
o
99.9
99
95
80
50
20
5
1
0.1
-1.3
Q)
0>
CO
+-'
C
Q)
....
Q)
o
Cl..

One-Variable Analysis - 10g10 (Cu D CC) (site=91)
Summary Statistics for log10(Cu_D_CC)
Count
=
50
Average
=
-0.665887
Median
=
-0.72043
Variance
=
0.0751555
Standard deviation
=
0.274145
Maximum
=
-0.142382
Quantile Plot
-0.6
o
-0.4
-0.2
c
0.8
0
:;:::;
L-
0.6
0
L-
a..
0
0.4
a..
0.2
o
cP@@
@/
-1.2
-1
-0.8
Percentiles for log10(Cu_D_CC)
1.0%
=
-1.15176
5.0% = -1.0884
10.0%
-1. 02795
25.0%
-0.844153
50.0%
-0.72043
75.D%
-0.415668
90.0%
-0.282158
95.0%
-0.210046
99.0%
-0.142382
Normal Probability Plot
o
a>
OJ
......
ctl
c
()
a>
L-
a>
Cl.
99.9
99
95
80
50
20
5
1
0.1
-1.2
-1
-0.8
-0.6
-0.4
log10(Cu_D_CC)
-0.2
o

0.8
One-Variable Analysis - 10910 (Cu D CC) (site=92)
Summary Statistics for log10(Cu_D_CC}
Count ; 50
Average; -0.520281
Median; -0.534281
Variance; 0.069343
Standard deviation; 0.263331
Maximum; -0.0160527
Quantile Plot
c
.::.....
0.6
r
j}!
~
0.4
130
o~
Ci. 0.2
0:.0
13
I
-0.92
-0.72
-0.52
-0.32
-0.12
0.08
Percentiles for log10(Cu_D_CCl
1.0% ; -0.919475
5.0% ; -0.862092
10.0%
-0.812814
25.0%
-0.752894
50.0%
-0.534281
75.0%
-0.308589
90.0%
-0.121534
95.0%
-0.0639253
99.0%
-0.0160527
Normal Probability Plot
<D
0)
......
co
c
<D
()
.....
<D
0..
99.9
99
95
80
50
20
5
1
0.1
-0.92
-0.72
-0.52
-0.32
-0.12
log10(Cu_D_CC)
0.08

One-Variable Analysis- 10910 (Cu D
CC)
(site=93)
Summary Statistics for log10(Cu_D_CC)
Count ; 48
Average; -0.578498
Median; -0.593301
Variance; 0.0646338
Standard deviation; 0.254232
Maximum; -0.103912
Quantile Plot
-0.97
-0.77
-0.57
-0.37
-0.17
0.03
Percentiles for log10(Cu_D_CC)
1.0% ; -0.960403
5.0% ; -0.88934
10.0%
-0.880184
25.0%
-0.805754
50.0%
-0.593301
75.0%
-0.383417
90.0%
-0.169093
95.0%
-0.150735
99.0%
-0.103912
Normal Probability Plot
(J.)
Ol
......
co
c
(J.)
....
()
(J.)
0.
99.9
99
95
80
50
20
5
1
0.1
-0.97
-0.77
-0.57
-0.37
-0.17
log10(Cu_D_CC)
0.03

One-Variable Analysis - 10910 (Cu D CC) (site=94)
Summary Statistics for log10(Cu_D_CC)
Count
~
SO
Average
~
-0.548574
Median
~
-0.542936
Variance
~
0.0702682
Standard deviation
0.265082
Maximum
~
0.132534
Quantile Plot
J
0
c
0.8
0
/@
:;::;
....
0.6
0
Q.
....
c..
0
0.4
@I
0.2
0
~Drlfjj
-1
-0.8
-0.6
-0.4
-0.2
0
0.2
log10(Cu_D_CC)
Percentiles for log10(Cu_D_CC)
1.0%
~
-0.987946
5.0%
~
-0.94
10.0%
-0.896546
25.0%
-0.728322
50.0%
-0.542936
75.0%
-0.353134
90.0%
-0.188402
95.0%
-0.177115
99.0%
0.132534
Normal Probability Plot
Q)
0)
.....
ro
c
Q)
~
Q)
c..
99.9
99
95
80
50
20
5
1
0.1
o
-1
-0.8
-0.6
-0.4
-0.2
0
log10(Cu_D_CC)
0.2

One-Variable Analysis - loglO(Cu D CC) (site=95)
Summary Statistics for log10(Cu_D_CC)
Count
=
40
Average
=
-0.56162
Median
=
-0.571391
Variance
=
0.0721667
Standard deviation
=
0.268639
Maximum
=
-0.081728
Quantile Plot
c
0.8
0
:;::::;
'-
0.6
0
c..
0
0.4
'-
c..
0.2
0
-1.1
-0.9
-0.7
-0.5
-0.3
-0.1
0.1
1.0%
=
-1.03574
5.0% = -0.967457
10.0%
-0.898041
25.0%
-0.783064
50.0%
-0.571391
75.0%
-0.339853
90.0%
-0.172027
95.0%
-0.117161
99.0%
-0.081728
Normal Probability Plot
Q)
OJ
......
co
c
Q)
'-
o
Q)
0..
99.9
99
95
80
50
20
5
1
0.1
-1.1
~
0
o
c§J;
o
-0.9
-0.7
-0.5
-0.3
log10(Cu_D_CC)
-0.1
0.1

Institute for Urban Environmental Risk Management
Marquette University, Milwaukee WI 53201-1881

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Attachment A

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Appendix
D: Water Quality Modeling for the Lower

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Des Plaines River

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EmreAlp

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Charles Melching

TABLE OF CONTENTS
TABLE OF CONTENTS
i
List
Of Figures
ii
List
of Tables
iii
CHAPTER 1 -
WTRODUCTION
1
CHAPTER 2 - Model development
3
2.1 Overview of the QUAL2E Model...
3
2.1.1 Application
3
2.1.2 Review
of the previous Models and studies
4
2.1.3 Process Simulated
4
2.1.3.1 Nitrification
5
2.1.3.2 Carbonaceous Biochemical Oxygen Demand
5
2.1.3.3 Sediment Oxygen Demand
5
2.1.3.4 Algal Respiration and Photosynthesis
5
2.1.3.5 Atmospheric and
Dam Reaeration
6
2.1.4 Water Quality Data Obtained for Model Calibration and Verification
6
2.2. Hydraulic Model
7
2.2.1 Model Reaches
7
2.2.2 Time
of Travel and dispersion
9
2.2.3 Flow Measurement and Flow Modeling
9
2.3 Headwaters, Point Sources and Initial Conditions
12
2.4 Atmospheric and Dam Rearation
13
2.5 Algal Growth
13
CHAPTER 3 - CALIBRATION
15
3.1 Introduction
15
3.2 Model Requirement
15
3.3 Overview of the Calibration Process
15
3.4 Calibration variables
16
3.5 September /October-1990
16
CHAPTER 4 -VERIFICATION
20
4.1 Introduction
20
4.2 Overview
of the Verification Process
20
APPENDIX A
29

List Of Figures
Figure
1.
Lower Des Plaines River Study Area
2
Figure 2.
Schematic diagram of the Lower Des Plaines River QUAL2E modeL
8
Figure 3.
September 1990 Calibration
18
Figure 4.
October 1990 - Calibration
19
Figure 5.
MAY 1991 (October-1990 Calibration values)
22
Figure 6.
MAY 1991 (modified)
,
23
Figure 7.
JUNE 1991 (October-1990 Calibration values)
24
Figure 8.
JUNE 1991 (modified)
25
Figure 9.
JULY 1991 (September-1990 Calibration values)
26
Figure 10.
JULY 1991 (modified)
27
Figure 1.
JULY 27,2000 (May_modified 1991 values)
28
11

List of Tables
Table
1.
Sampling Periods
6
Table 2.
Model Reaches and Elements
7
Table 3.
Summary of the cross section data
9
Table 4.
September Flow Balance
10
Table 5.
October Flow Balance
10
Table 6.
May Flow Balance
10
Table 7.
June Flow Balance
11
Table 8.
July Flow Balance
11
Table 9.
July/August Flow Balance
11
Table 10.
Point Sources
12
Table 11.
September Reaeration rate
13
Table 12.
September - Dam Parameters
13
Table 13.
September-and October - Global
Nutrient-Nitrification
Parameters
14
Table 14.
September (calib.)-July - Reach
-Algal-
Parameters
14
Table 15.
October(Calib.)/May/June
-Algal-
Parameters
14
Table 16.
CBOD Decay, and Settling,
Phosphorus,
Nitrification
-Algal-
Parameters
(September/October
-1990)
17
Table 17.
September 1990(calibrated)-July 1991 ( modified) - Reach CBOD Decay, and
Settling,
Phosphorus,
Nitrification
-Algal-
Parameters
21
Table 18.
October(Calibrated) 1990, - May/June (modified) 1991 -Reach CBOD Decay, and
Settling,
Phosphorus,
Nitrification
-Algal-
Parameters
21
111

CHAPTER 1 - INTRODUCTION
The enhanced water quality model, QUAL2E, permits simulation 0 any branching one-
dimensional stream system. The aim
of this study is to develop a QUAL2E model for the
Lower Des Plaines River. The model is calibrated for the flow and water-quality data
measured in 1990. Verification
of the model is done for the flow and water quality data
measured in 1991.
The study area is the Lower Des Plaines River from its confluence with the Chicago Sanitary
and Ship Canal to the
155 Bridge (Figure 2.). The total length of the modeled river system is
13.25 mile. Locations along the waterways are referred by the U.S. Army Corps
of Engineers
(COE) river mile point system. The model begins at River Mile
291 at the downstream of
Lock Port and Dam and ends at River Mile 277.75 at the 155 Bridge. Mile point references in
this report are rounded to the nearest 0.25-mile.
1

l
I
-N-
I
SAG JUNonoN
gl8
LOCKPORT POOL
I
I
Figure 2.
Lower Des Plaines River Study Area
2

CHAPTER 2 - MODEL DEVELOPMENT
2.1 Overview
of the QUAL2E Model
QUAL2E is a widely used water quality model that can predict the physical, chemical and
biological processes that affect the dissolved oxygen in a river system.
For this study,
QUAL2E simulates the major water quality interactions in the river system, including
nitrogen cycle, phosphorus cycle, algal production, sediment oxygen demand, carbonaceous
biochemical oxygen demand, and dam aeration.
2.1.1 Application
The stream water quality model QUAL2E is used for waster load allocation, discharge permit
determinations, and other conventional pollutants evaluation. QUAL2E can simulate up to
15
water quality constituents in any combination desired by the user. Constituents which can be
simulated include the fallowing: dissolved oxygen, biochemical oxygen demand,
temperature, algae as chlorophyll-a, nitrogen, phosphorus, and coliform.
The model assumes that the major transport mechanisms for chemical constituents are
advection, and dispersion, and that these mechanisms are significant only along the main
direction
of flow.
It
allows for multiple waste discharges, withdrawals, tributaries flows, and
incremental inflow and outflow.
Hydraulically, QUAL2E limited to the simulation
of the time periods during which both the
stream flow in riverbasins and input waster loads are essentially constant. QUAL2E can
operate either as a steady state or as a dynamic model. When simulated as a steady state
model, it can be used to study the impact
of waste loads on stream water quality and also can
be used in conjunction with a field sampling program to identify the magnitude and quality
3

characteristics of non point source waste loads. By operating the model dynamically, the user
can study the effects
of diurnal variations of algal photosynthesis on water quality.
The application
of the QUAL2E model to the study area requires several assumptions to be
made. Hydrologically, QUAL2E
is limited to the simulation of the periods during which both
the river flow and plant flows (water reclamation plants, and tributaries) are constant. Rivers
must also be well mixed horizontally and vertically, and the major transportation
mechanisms, advection and dispersion, are significant only along the main direction
of flow.
The data presented in this report will indicate that these assumptions are upheld for the
application
of the model.
2.1.2 Review of the previous Models and studies
There have been several studies on the Chicago Waterway and the Upper Illinois River in the
past years. Major studies have included studies by the Illinois State Water Survey in 1974
and 1975, the 208 study by Hydrocomp, Inc in 1979, followed by a study by Northeastern
Illinois Planning Commission in 198i. Camp Dresser
&
McKee used QUAL2EU to simulate
dissolved oxygen on the Chicago Waterway and Upper Illinois River in 1992.
As a part
of the model development, water quality data and some parameter values presented
in the
Camp Dresser
&
McKee (CDM) report were used in this report.
2.1.3 Process Simulated
The focus of this study is the dissolved oxygen (DO) concentration in the study area.
QUAL2E simulates the processes that affect the dissolved oxygen in the water column.
4

2.1.3.1 Nitrification
Nitrification is a two-stage process. The first stage is the oxidation of ammonia to nitrate by
Nitrosomonas bacteria. During the second stage
of nitrification, Nitrobacter bacteria oxidize
nitrite to nitrate.
2.1.3.2 Carbonaceous Biochemical Oxygen Demand
Biochemical oxygen demand is utilization of dissolved oxygen by aquatic microbes to
metabolize organic matter. Carbonaceous biochemical oxygen demand (CBOD) represents
the amount
of oxygen required by the microorganisms to stabilize organic matter under
aerobic conditions. CBOD or DO usage is simulated as a first order exponential reaction in
QUAL2E. The rate
of biological oxidation of organic matter is directly proportional to the
remaining concentration
of unoxidized material. All referenced CBOD values in this report
are 20-day values (CBOD
20
).
2.1.3.3 Sediment Oxygen Demand
Oxygen demand by benthic sediments and organisms has historically represented a large
fraction
of oxygen consumption on the Chicago Waterway and the Upper Illinois River
(CDM, 1992). Benthal deposits at any given location in a system are result
of the
transportation and deposition
of organic material. QUAL2E does not simulate the transport,
deposit and decay
of the benthal deposits, but instead represents the demand with a constant
rate
of oxygen consumption.
2.1.3.4 Algal Respiration and Photosynthesis
The effects of algae on dissolved oxygen concentration are the most complex of the
processes simulated. Algae can bring about significant changes in dissolved can bring about
significant changes in the dissolved oxygen by several interactions. Algal dynamics and
5

nutrients uptake during algae growth in the main process that removes dissolved nutrients,
nitrogen and phosphorus, from the water. Algal respiration and decay are major components
of nutrient recycling. Algal processes can also cause diurnal variations in dissolved oxygen
due to algal respiration during the night. Dead algae that settles on the river bottom is often a
major source
of organic matter for the benthic demand. QUAL2E simulates the algal
dynamics including photosynthesis and respiration, nitrogen and phosphorus uptake and
return.
2.1.3.5 Atmospheric and Dam Reaeration
Reaeration is the process of oxygen exchange between the atmosphere and a water body.
Typically, the net transfer
of oxygen is from the atmosphere and into the water, unless the
dissolved oxygen levels in the river system are above the saturation and then the reverse is
true. Dams can influence rearation
by changing the dissolved oxygen deficit in a short reach
of the river. The water passing over the dam is very turbulent and has a large volume of
oxygen transferred. The water passing over the dam is very turbulent and has a large volume
of oxygen transferred.
2.1.4 Water Quality Data Obtained for Model Calibration and Verification
Water quality data for the model calibration and verification presented in this report were
taken from the previously done study (CDM, 1992). The ISWS developed a mobile sampling
program to collect water quality data along the study area being modeled. Sampling was
performed in three periods during six months
as follows:
Table 1.
Sampling Periods
Period I
Period II
Period III
September 1990
May
1991
July 1991
October 1990
June
1991
August 1991
6

Each sampling event consisted of six passes. Each pass was 8 hours long for a total of 48
hours
of sampling for each event. Two types of sample stations were established: one was for
full range
of water quality samples and make water quality measurements, while a second
was for
DO and temperature only. Also, samples were taken at mouths of significant
tributaries. Water quality data are given
in Appendix
A.
2.2. Hydraulic Model
The first step in the development of input data for the QUAL2E water quality model is the
delineation
of model reaches and the development of hydraulic data. The required hydraulic
parameters for this application are: i) channel cross-section ii) dispersion constant iii)
Manning's n.
2.2.1 Model Reaches
This model has 6 reaches with a computational element length of 0.25 mile. It lays from
downstream
of Lock Port and Dam to I 55 bridge, a distance of 13.25 miles. The reaches and
the elements
of the model is given in Table 2. Schematic diagram of the reaches, and location
of the point sources are given in Figure 3.
Table 2.
Model Reaches and Elements
Reach #
Starting Point
Ending Point
Number of
Location
(River Mile)
(River Mile)
Elements
1
291
290
4
Downstream
of LP
&
D -
CSSC*
2
290
287.25
11
Brandon Pool- D. P. R**
3
287.25
286
5
Brandon Pool- D.P.R
4
286
285.25
3
Dresden
Pool-D.P.R
5
285.25
280.25
20
Dresden
Pool-D.P.R
6
280.25
277.75
10
Dresden
Pool-D.P.R
*CSSC = Chicago Samtary Ship Canal; **D.P.R = Des Plames River
7

Reach
River Mil e
291
1
32
CD
4
290
1
2
~
Des
Plaines
2 9 0
3
River
4
5
67
<D
8
9
10
1 1
287 . 2 5
1
2
..----
Joliet E a s t WRP 286 . 6
34
<D
5
286
1
32
<D
285 .25
1
2
3
4
5
6
7
....
Joliet Army
2 8 3 . 7
8
Ammunition
PIa n t
9
11 10
<D
12
13
14
15
1 6
Mobile oil
281 . 4
1 7
PIa n t
18
19
20
1
2
3
4
56
0
7
8
9
~oliet
West WRP
2 7 8 . 2
1 0
277 . 7 5
Figure 3.
Schematic diagram ofthe Lower Des Plaines River QUAL2E model
8

Channel cross section data were obtained to detennine approximate channel dimension. A
total
of 40 cross sections were provided. Based on the cross section data, trapezoidal
approximation was done to obtain average bottom and top width, and water depth to use in
QUAL2E model. Reach slopes were calculated using bottom elevations at different points in
the reach. Table 3 shows a summary
of the cross section data developed for the model
reaches.
Table 3.
Summary ofthe cross section data
Bottom width
Top Width
Channel slope
Side slope 1
Side slope 2
Reach#
(WV)
(WV)
(ft)
(ft)
(ft/ft)
(ft/ft)
(ft/ft)
1
230
310
0.00090
1.50
1.50
2
275
350
0.00090
0.60
0.70
3
1100
1100
0.00180
0.001
0.001
4
1000
1000
0.00110
0.001
0.001
5
200
1000
0.00023
17.50
8.5
6
280
1000
0.00029
9.00
10
2.2.2 Time of Travel and dispersion
Data on dispersion, flow and time of travel was obtained from ISWS, the USGS, and
previously studies
of the Chicago and Illinois waterways. Dispersion is transport due to
mechanical mixing and/or diffusion. QUAL2E
is a one dimesional model only longitudinal
dispersion is considered. Velocity and depth were determined
as a part of the dispersion
studies.
In this model, Dispersion Constant (K) = 180 is used.
It
is stated that, this value
represents the best fit, based on the fmdings
of all dispersion studies (CDM, 1992)
2.2.3 Flow Measurement and Flow Modeling
The flow magnitude during water quality monitoring was determined by ISWS using flow
models. ISWS flow estimates for each
of the sampling period are presented in the flowing
tables.
9

Table 4.
September Flow Balance
Mile Point
Source
Flow (cfs)
Cum. Flow (cfs)
291.2
Lockport Land D
3305
290.0
Des Plaines river
217
3522
286.6
Joliet
27
3549
283.7
Joliet AA
5
3554
281.4
Mobil
7
3561
278.2
Joliet West
6
3567
Table 5.
October Flow Balance
Mile Point
Source
Flow (cfs)
Cum. Flow (cfs)
291.2
Lockport Land D
2491
290.0
Des Plaines river
392
2883
286.6
Joliet
27
2910
283.7
Joliet AA
5
2915
281.4
Mobil
6
2921
278.2
Joliet West
7
2928
Table 6.
May Flow Balance
Mile Point
Source
Flow (cfs)
Cum. Flow (cfs)
291.2
Lockport Land D
3332
290.0
Des Plaines river
522
3854
286.6
Joliet
35
3889
283.7
Joliet AA
1
3890
281.4
Mobil
4
3894
278.2
Joliet West
7
3901
10

Table 7.
June Flow Balance
Mile Point
Source
Flow (cfs)
Cum. Flow (cfs)
291.2
Lockport Land D
2788
290.0
Des Plaines river
688
3476
286.6
Joliet
25
3501
283.7
Joliet AA
1
3502
281.4
Mobil
5
3507
278.2
Joliet West
4
3511
Table 8.
July Flow Balance
Mile Point
Source
Flow (cfs)
Cum. Flow (cfs)
291.2
Lockport L and D
3781
290.0
Des Plaines river
181
3962
286.6
Joliet WRP
17
3979
283.7
Joliet AA
0
3979
281.4
Mobil
8
3987
278.2
Joliet West
3
3990
Table 9.
July/August Flow Balance
Mile Point
Source
Flow (cfs)
Cum. Flow (cfs)
291.2
Lockport Land D
3685
290.0
Des Plaines river
169
3854
286.6
Joliet
18
3872
283.7
Joliet AA
0
3872
281.4
Mobil
8
3880
278.2
Joliet West
3
3883
11

2.3 Headwaters, Point Sources and Initial Conditions
Headwaters and point source flows and constituent concentrations are diriving mechanisms
in a QUAL2E application. Headwater data is defined
as the most upstream conditions of the
river system. These data include flow and various water quality parameters.
In
this model
there is just one headwater, which is downstream
of Lockport
Point loads are flows or withdrawals from the system that influence the balance
of flow and
water quality in the system. Point loads are typically discharged in to the system from water
reclamation plants (WRP) and tributary rivers. For this study only point sources
of one
million gallons per day (mgd)
or greater considered. Flow and water quality data on point
sources was collected from information supplied by IEPA,
as well as the District. There are 5
point sources in this model. Names and locations are given in the following table.
Table 10.
Point Sources
Point Source
River mile
Des Plaines River
290.0
Joliet
286.6
JolietAA
283.7
Mobil
281.4
Joliet West
278.2
QUAL2E requires that initial flow and water quality conditions be assigned for each system
as a starting point for the system. Temperature is the only required variable for steady state
simulations.
12

2.4 Atmospheric and Dam Rearation
Reaeration is the process of oxygen exchange between atmosphere and a water body. Large
amounts
of oxygen transferred to the water is a function of dam height, the quality of the
water, and the type
of the dam. Atmospheric and Dam Rearation coefficients that were
obtained for the previous studies are used in this study.
Table 11. September Reaeration rate
Reach
Flow
Velocity
Depth
O'Connors and Dobbins,
Calibrated
#
(cfs)
(fps)
(ft)
Ka (llday)
K2
1-2-3
3434
0.755
17.5
0.15
0.15
4-5-6
3434
0.479
15.1
0.15
0.15
Table 12. September - Dam Parameters
Dam
a factor
b factor
%
flow over. Height of Waterfall,
the dam
(ft)
Brandon Road Dam
1.1
1.8
100%
34
2.5 Algal
Growth
Algal growth is an important consideration in modeling water quality.
It
is closely linked to
nutrient dynamics and can cause daily and seasonal variations in dissolved oxygen. The
major components
of algal growth simulated by QUAL2E are respiration rate, specific
growth rate, net algal oxygen production, the algal light relationship, and algal-nutrient
relationship. Global parameters, and reach variables parameter used in this report are given in
Table
13 and Table 14 and Table 15. The study area is divided in two regions: the Brandon
Pool, and the Dresden Pool. All
of the global parameters do not vary throughout the model
system. Reach variable parameters show differences among different reaches and time
periods.
13

Table 13.
September-and October - Global
Nutrient-Nitrification
Parameters
Parameter
Symbol
Unit
Value
Nitrogen Content
of algae
a1
mg-N/mg-A
0.08
Phosphorus Content
of algae
a2
mg-P/mg-A
0.012
Nitrogen
Half saturation coef.
KN
mg/L
0.02
Phosphorus
Half saturation coef.
KP
mg/L
0.002
Algal preference factor for NH3
F
-
0.9
02 uptake per NH3 oxidation
as
mg-O/mg-N
3.43
02 uptake per N02 oxidation
a6
mg-O/mg-N
1.14
Nitrification Inhibition Coefficient
KNITRF
-
0.7
Table 14.
September (calib.)-July - Reach
-Algal-
Parameters
Parameter
Reach
Reach
1-2-3
4-5-6
Chla: Algae RatioaO (Ilg-Chla/mg-A)
16
16
Algal settling Rate
J
al
(It/day)
1
1
Non-algal Light extinction,
/LO
(1ft)
0.69
0.90
Table 15.
October(Calib.)/May/June
-Algal-
Parameters
Parameter
Reach
Reach
1-2-3
4-5-6
Chla: Algae RatioaO (Ilg-Chla/mg-A)
16
16
Algal settling Rate
J
al
(ft/day)
0.5
0.5
Non-algal Light extinction,
/LO
(1ft)
0.85
1
14

CHAPTER 3 - CALIBRATION
3.1 Introduction
This section presents the calibration of the QUAL2E model to two data sets, September 25,
26,27, 1990, and October 23,24,25, 1990.
3.2 Model Requirement
Model calibration requires flow balance for the two ISWS sampling periods in September
and October 1990. All flows from point sources in excess
of 1 mgd were considered. Rivers,
WRP's, and industrial discharges are all considered to be point sources. The headwater flow
from downstream
of Lockport Lock and Dam is modeled as "headwater".
3.3 Overview of the Calibration Process
Calibration is the process where selected model variables are adjusted so concentrations
predicted
by the model agree with actual instream measurements. The major constituent of
interest for this study is dissolved oxygen. The method employed in this study is to fIrst
calibrate the individual constituents. Thus, variables in the model will be adjusted so the
predicted values
of flow, carbonaceous biochemical oxygen demand (CBOD20), organic
nitrogen, ammonia, nitrite, nitrate, ortophosphorus, and chlorophyll-a will match the instream
measured values. Then selected variables will be adjusted,
if needed, to reach agreement
between instream concentrations
of dissolved oxygen. The goal of the calibration is to have
the predicted values fall within one standard deviation
of the mean of the instream measured
constituent variance with the predicted.
15

3.4 Calibration variables
The fist step in the model calibration process is to accurately predict the flow values. The
flow balance
of the point sources versus river flow developed for September and October
bents was presented in the previous section. These values were taken from previously
conducted QUAL2E model (CDM, 1992). Calibration to water depth are done by adjusting
Manning'sn values.
CBOD20 is input into the model via headwater and point sources. The decay and settling
rates
(K1 and K2) are used to calibrate instream CBOD20 values. As CBOD20, phosphorus
is input into the model from headwater and point sources. Calibration
of phosphorus is done
by adjusting the organic decay rate,
~4,
the organic phosphorus source rate,
<>2-
Nitrogen is
simulated in four forms, organic, ammonia, nitrite, and nitrate. Calibration is done on each
form
of nitrogen by adjusting five rates, organic nitrogen settling rate,
~3,
ammonia oxidation
rate,
~l,
nitrite oxidation rate,
~2,
organic nitrogen settling rate, 0"4, and ammonia source rate,
0"3.
3.5 September /October-1990
In
the light of information given in the previous sections, the model was calibrated using
September and October flows and water quality data. Calibration values are presented in
Table
16. Figure 4 and Figure 5 present the model predicted values of the parameters against
measured instream measured values. Biologically, the system is divided into two regions:
Brandon Pool and Dresden Pool. Reaches 1-2-3 belong to the Dresden Pool and Reaches 4-5-
6 belong to the Dresden Pool.
In
Figure 4, and Figure 5, vertical arrows indicate The Des
Plaines River, which makes the largest flow contribution to the system. Lockport Lock and
Dam values are shown by horizontal arrows.
16

Table 16.
CBOD Decay, and Settling,
Phosphorus,
Nitrification
-Algal-
Parameters
(September/October
-1990)
Parameter
Reach
Reach
Reach
Reach
1-2-3
4-5-6
1-2-3
4-5-6
(Sept.)
(Sept.)
(Oct)
(Oct)
CBOD Decay Rate (Kl)
0.05
0.05
0.01
0.01
CBOD Settling Rate (K3)
0.20
0
-0.05
0
Rate Coeffor Org. P to P04
,{34
(l/day)
0.1
0.1
0.1
0.1
Rate Coeffor Org. P settling ,a5(I/day)
0
0
00
Source ratefor P04 settling ,a2(mg-Plft2-day)
300
0
-100
0
Rate Coef. for Org. N to NH3
,~3
(l/day)
0.05
0.05
0.05
0.08
Rate Coef. for Org. N settling ,a4(l/day)
0
0
00
Rate Coef. for Org. NH3 to N02
,~1
(l/day)
0.3
0.2
0.2
0
Source rate for NH3 ,a3(mg-N/ft2-day)
0
0
0
0
Rate Coef. for Org. N02 to N03
,~2
(l/day)
1
0.3
0.3
0
Chia: Algae Ratioa (/lg-Chla/mg-A)
16
16
16
16
Algal settling Rate, exl (It/day)
1
1
0.5
0.5
Non-algal Light extinction, A.-O (1ft)
0.69
0.90
0.85
1
17

Figure 4. September 1990 Calibration
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275
280
285
290
295
275
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280
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18

Figure 5. October 1990 - Calibration
--
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,
,
275
280
285
290
295
275
280
285
290
295
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1.2
0.35
1
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0.2
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0.6
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0
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---
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0.15
f--------- --
0.4
~
0.1
0.2
"'j.
...
'1
0.05
00
275
280
285
290
295
275
280
285
290
295
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2.5
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4.9
.<
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CI)
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275
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295
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280
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275
280
285
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295
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19

CHAPTER 4 -VERIFICATION
4.1 Introduction
In
this section, verification of the QUAL2E model with two data sets is presented. October
1990 values (falVspring non diversion) are used to verify May
1991 and June 1991 model.
September 1990 values (summer diversion) are used to calibrate July
1991 values.
4.2 Overview of the Verification Process
Data collected during May 21-23, 1991 and June 4-6 1991 was used to verify the calibrated
fall/spring non-diversion model. Data collected during July 16-18
1991 was used to verify
calibrated summer, diversion model.
Calibration is the process
of fme-tuning model parameters so that model accurately predicts
the. observed instream quality. Verification
is the process of using calibrated model with
different data, for which the water quality is known,
to examine the effectiveness of the in
predicting the instream concentrations
of water quality constituents under different
conditions (CDM, 1992). During calibration, model parameters are changed to match the
observed data. During verification, conditional parameters such
as flow and constituent
concentrations are changed to examine effectiveness
of the calibrated model. For each data
set, calibrated model is also modified
if the predicted values with the calibrated model did
not match the observed values.
In order to compare the calibrated model and modified model
parameters, both
of the model parameters are presented in Table 17 and Table 18. Figure 6,
Figure 7, Figure 8 and Figure 9, Figure 10, and Figure 11 present the calibrated/modified
model predicted values
of the constituents against measured instream measured values.
Vertical arrows indicate The Des Plaines River and horizontal arrows show Lockport Lock
and Dam values.
20

Table 17. September 1990(calibrated)-July 1991 ( modified) - Reach CBOD Decay, and
Settling,
Phosphorus,
Nitrification
-Algal-
Parameters
Parameter
Reach
Reach
Reach
Reach
1-2-3
4-5-6
1-2-3
3-4-6
(Sept.)
(Sept.)
(July.)
(July)
CBOD Decay Rate (K1)
0.05
0.05
0.05
0.05
CBOD Settling Rate (K3)
0.20
0
-0.5
-0.5
Rate Coe! for Orz. P to P04
,/34
(llday)
0.1
0.1
0.1
0.1
Rate Coer for Orz. P settlinz ,cr5(1Iday)
0
0
00
Source rate for P04 settling ,cr2(mg-Plft2-
300
0
300
0
day)
Rate Coef. for Org. N to NH3
,~3
(l/day)
0.05
0.05
0.05
0.05
Rate Coef. for Org. N settling ,cr4(l/day)
0
0
00
Rate
Coef. for Org. NH3 to N02
,~1
(l/day)
0.3
0.2
0.3
0.2
Source rate for NH3 ,cr3(mg-N/ft2-day)
0
0
0
0
Rate Coef. for Org.
N02 to N03 ,132 (l/day)
1
0.3
1
0.3
Chla: Algae Ratioa (ug-Chlalmg-A)
16
16
16
16
Alzal settlinz Rate, al (ftlday)
1
1
11
Non-alzal Lizht extinction, ;W (1ft)
0.69
0.90
0.69
0.90
Table 18. October(Calibrated) 1990, - MaylJune (modified) 1991-Reach CBOD Decay, and
Sett
r
mg,
Ph
OSlJ!
horus,
N"fi'
1tn 1catlOn-A
I
a
I
- Parameters
Parameter
Reach
Reach
Reach
Reach
Reach
Reach
1-2-3
4-5-6
1-2-3
4-5-6
1-2-3
4-5-6
(Oct)
(Oct)
(Mav)
(Mav)
(June)
(June)
CBOD Decay Rate (K1)
0.01
0.01
0.01
0.01
0.01
0.01
CBOD Settling Rate (K3)
-0.05
0
-0.05
-0.5
-0.05
0
Rate Coef for Orz. P to P04
,84
(llday)
0.1
0.1
0.1
0.1
0.1
0.1
Rate Coef for Orz. P settlin'i!
,
cr5
(1
Iday)
0
0
0
0
00
Source rate for P04 settling ,cr2(mg-
-100
0
-100
0
-100
0
Plft2-day)
Rate Coef. for Org. N to NH3 ,1)3 (l/day)
0.05
0.08
0.05
0.05
0.05
0.05
Rate Coef. for Org. N settling ,cr4(l/day)
0
0
0
0
00
Rate Coef. for Org. NH3 to N02
,~1
0.2
0
0.5
0.5
0.5
0.5
(l/day)
Source rate for NH3 ,cr3(mg-N/ft2-day)
0
0
0
0
00
Rate Coef. forOrg. N02 to N03
,~2
0.3
0
1
1
11
(l/day)
Chla: Algae RatioaO (Ilg-Chlalmg-A)
16
16
16
16
16
16
Alzal settlinz Rate, al (ftlday)
0.5
0.5
0.5
0.5
0.5
0.5
NO.50n-alzal Lizht extinction,
Ito
(1ft)
0.85
1
0.85
1
0.85
1
21

Figure 6.
MAY 1991 (October-1990 Calibration values)
,--------~
-~
280
285
290
295
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280
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280
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275
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22

Figure 7.
MAY 1991 (modified)
280
285
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295
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280
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275
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275
280
285
290
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280
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29
275
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275
280
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..
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,
,
275
280
285
290
295
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L.----_
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23

Figure 8. JUNE 1991 (October-1990 Calibration values)
280
285
290
295
10
------
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-------,----
T
-------------~--l
-
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-----.---------.,
275
280
285
290
295
275
o
c
RM
RM
1.2 -,----------------
1 -f--
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0.2 +----------------
280
285
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295
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275
c: 0.15 +--__----__
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_
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280
285
290
295
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A
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0.4
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...----.'t
1"----
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O-f-------.----.--------,--------,
275
RM
RM
280
285
290
295
2
+-------------....,........?--
2.5 -,---------------
D. 1.5 +-----------a----.--.---
C
~
1
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~
1
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o
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---."-------"
280
285
290
295
275
3.25 -,---------------
3.2 +-_....
A
-
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3.1 +----------------
3.05 +--------------
3+----==~=-_tl
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~-
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I
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275
z
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o
RM
RM
280
285
290
295
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2
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-_
; ,:1
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0.5
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i
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275
RM
24

Figure 9. JUNE 1991 (modified)
I
_.-.
--~-
I
10
t-
9
i
8-
I
8
.-.--l
-_.~--
A
A
7
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6
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4
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4
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2
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2
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1
275
280
285
290
295
0
,
,
,
275
280
285
290
295
RM
_._~
RM
1.2
0.3
1
----
'-'.......
A~
0.25
I.
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0.8
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0.6
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0.15
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0
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-
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t
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0
275
280
285
290
295
275
280
285
290
295
RM
RM
3.35
2.5
3.3
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3.25
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275
280
285
290
295
275
280
285
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1.52
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1
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275
280
285
290
295
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25

Figure 10. JULY
1991
(September-l 990 Calibration values)
--------~
~-_.-
_.-
r
14
~.
I,
16
i
I
14
12
...
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,
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1
10
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12
8
10
10
0
0
6
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8
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4
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I
I
64
...
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2
------
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~
r
2
0
I
0
275
280
285
290
295
I
275
280
285
290
295
RM
I
RM
0.5
0.2
0.45
..
/
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0.18
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0.4
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0.16
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r
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0.06
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0.05
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0
0
I
275
280
285
290
295
275
280
285
290
295
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RM
3.5
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3
3
II;
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c.
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2
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275
280
285
290
295
275
280
285
290
295
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RM
45
40
35
30
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25
-----
(.)~
20
15
10
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5
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0
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---,
275
280
285
290
295
RM
26

Figure 11. JULY 1991
(modified)
I
-
I
14
--i
16
.---------_.
I
.
-
I
14
'!l
~.
12
-
-
----- --.
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10
12
10
8
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C
0
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8
c
6
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-
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lO
6
-
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4
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4
22
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0
II
0
--
275
280
285
290
295
275
280
285
290
295
--
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RM
0.5
0.2
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0.45
.410
0.18
0.350.4
----
0.16
r
=1
0.14
0.3
0.12
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;;;:
N
:I:
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0.25
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z
0
0.1
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0.2
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t.
0.05
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I
0
0
I
275
280
285
290
295
275
280
285
290
295
RM
RM
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3
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3
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2
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~~
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0
ci. 1.5
z
1.5
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C
1
1
0.5
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0
275
280
285
290
295
275
280
285
290
295
RM
RM
45
40
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35
30
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25
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20
-
t.>
15
10
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5
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~"=O:4
0
,
,
275
280
285
290
295
RM
27

Figure 12. JULY
27, 2QOO (May_modified
1991
values)
290
280
285
295
4
+-~~~~~-,------~-
2
+--~~~~~-.--
~
6
+-------~-
CD
o
+--~~,---~--------,--
--~,
-------,
280
285
290
295
275
1-~
.-==:=-,
-~..-r-\
---I ::
l:=·~===·
== ••••.
~-~-.~-=
g :1-
~.
o
+---~--.-~~--.-~~--.-~~---;
i
275
RM
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0.7
0.6
0.5
:z 0.4
M
~
0.3
0.2
0.1
o
275
280
285
RM
290
295
0.25
0.2
0.15
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0
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0.1
00:
~
275
280
285
290
295
RM
.........
~
~
!
!
.....
i
I
a
A
.,....
/
I
5.1
5
4.9
4.8
C"'>
4.7
~
4.6
4.5
4.4
4.3
4.2
275
280
285
290
1
0.9
0.8
0.7
0.6
c...
0.
0.5
i5 0.4
0.3
0.2
0.1
o
295 '
275
280
285
290
295
RM
RM
28

APPENDIX A
WATER QUALITY DATA
(SEPTEMBER-OCTOBER 1990, MAY-JUNE-JULY-1991)
29

Table al. September 1990 (mean and standard deviation)
River
TKN
(mg/L)
N02
N03 (mg/L)
Ortho.P
S.D (in.)
Chl.a (ug/L)
Mile
(m /L)
(ml/L)
278
1.14
0.14
0.18
0.02
2.79
0.10
1.29
0.07
31.25
5
1.78
0.35
285.3
1.29
0.28
0.14
0.02
3.04
0.14
1.43
0.07
21.25
6.67
1.42
0.71
287.9
1.21
0.21
0.12
0.03
2.79
0.10
1.21
0.07
27.92
5
0.71
0.01
290
1.29
0.29
0.05
0.01
4.43
0.21
2.14
0.42
15.42
7.5
3.57
0.71
291
1.31
0.29
0.12
0.02
2.5
0.14
I
0.28
33.75
2.5
0.71
0.01
291.2
I.21
0.29
0.08
0.02
1.5
0.43
0.85
0.20
37.5
8.33
0.5
0.01
River Mile
DO mglL)
NH3-Nfmg/L)
CBOD20(mg/L)
278
8
0.22
0.44
0.12
5.15
0.52
285.3
0.28
0.16
4.32
0.42
287.9
5.77
0.33
0.28
0.12
4.21
0.53
289.9
5.66
0.22
290
8.44
1.33
0.28
0.08
4.94
0.63
290.1
5.44
0.44
291
5.11
0.22
0.36
0.16
4.32
1.05
291.2
6
0.44
0.48
0.12
3.58
0.21
Table a2.0ctober 1990 (mean and standard deviation)
River
N02
Ortho.P
TKN
(mg/L)
(mg/L)
N03 (mg/L)
(mg/L)
S.D (in.)
ChI.a (ugiL)
Mile
278
2
0.35
0.25
0.04
4.6
0.01
1.75
0.01
18
2
2.14
0.57
285.3
2
0.12
0.24
0.04
4.6
0.2
1.9
0.05
23
0.5
1.5
0.49
287.9
2.1
0.12
0.19
0.06
4.9
0.4
2.15
0.8
12
0.01
1.29
0.29
290
1.47
0.17
0.07
0.06
4.3
0.6
1.7
0.15
3.71
1.43
291
2.47
0.30
0.2
0.09
4.5
0.2
1.9
0.7
0.64
0.14
291.2
2.30
0.12
0.3
0.06
4.9
0.4
2.2
0.1
0.94
0.21
River Mile
DO (mg/L)
NH3-N(mgiL)
CBOD20(mg/L)
278
8
0.24
0.78
0.09
5.95
0.6
280.9
8.24
0.24
283
8.47
0.35
285.3
8.94
0.01
0.7
0.08
6
0.6
287.9
5.05
0.47
0.48
0.17
8
1.2
289.9
4.94
0.58
290
9.18
0.82
0.30
0.17
5.8
0.01
290.1
4.59
0.35
291
3.85
0.01
1.09
0.09
5.95
0.2
291.2
4.59
0.94
0.43
0.17
5.95
0.4
30

Table a3. May 1991 (mean and standard deviation)
River
N02
Ortho.P
Mile
TKN (mg/L)
(mg/L)
N03 (mg/L)
(mg/L)
S.D (in.)
ChI.a (ugIL)
278
2.36
0.18
0.31
0.01
3.57
0.42
1.52
0.52
23
1.74
4
2.2
285.3
2.18
0.09
0.35
0.01
2.86
0.14
1.74
0.7
26.5
3.48
3.4
0.3
287.9
2.55
0.36
0.24
0.08
2.71
0.43
I.I3
0.17
32.6
3.48
2.7
0.6
290
1.81
0.27
0.1
0.04
2.93
0.29
1.21
0.17
10
1.74
6.5
1.2
291
2.90
0.55
0.31
0.11
2.90
0.42
0.91
0.35
44.4
6
1.8
0.2
291.2
2.55
0.55
0.26
0.09
3.43
0.71
1.26
0.17
38.3
5.2
1.4
0.5
River Mile
DO (mg/L)
NH3-N(mg/L)
CBOD20(mg/L)
278
7.2
0.6
0.5
0.01
8
0.01
280.9
7.4
0.3
283
7.6
0.4
285.3
8
0.6
0.72
0.01
7.86
0.29
287.9
4.5
0.8
0.5
0.16
8.14
0.28
289.9
4.3
I
290
6.6
0.8
0.56
0.1 1
5.71
0.29
290.1
3.7
0.4
291
3.4
0.4
0.89
0.28
6.14
0.01
291.2
3
0.2
I.II
0.17
6.43
0.01
Table a4. June 1991 (mean and standard deviation)
River
N02
Ortho.P
TKN (mg/L)
(mg/L)
N03 (mglL)
(mg/L)
S.D (in.)
ChI.a (ugIL)
Mile
278
1.27
0.45
0.23
0.01
3.21
0.01
1.09
0.09
15.6
5
2.77
0.66
285.3
1.63
0.01
0.24
0.02
3
0.14
1.22
0.04
16.25
3.75
2.55
I
287.9
1.73
0.18
0.16
0.01
3.14
0.57
1.45
0.27
22.5
1.25
3
0.66
290
1.36
0.46
0.11
0.04
2.92
0.43
1.4
0.13
10
0.6
4
0.88
291
2.09
0.36
0.25
0.07
3
0.42
1.4
0.27
45
5
2.22
0.44
291.2
2.09
0.01
0.25
0.02
3
0.28
1.95
0.18
30
5
2
0.61
River Mile
DO (mglL)
NH3-N(mglL)
CBOD20(mg/L)
278
6.7
0.3
0.22
0.01
7.95
0.28
280.9
7
0.4
283
7.1
0.4
285.3
7.5
0.2
0.39
0.01
7.95
0.57
287.9
3.8
0.2
0.5
0.22
8
0.28
289.9
4.5
0.8
290
6.9
0.6
0.56
0.22
8.14
0.57
290.1
2.9
0.8
291
2.6
0.4
0.72
0.22
8.14
0.14
291.2
2.6
0.4
I
0.01
6.71
1.42
31

Table as. July 1991 (mean and standard deviation)
River
TKN
(mg/L)
N02
Ortho.P
Mile
(mglL)
N03 (mglL)
(mglL)
S.D (in.)
ChI.a (ugIL)
278
1.47
0.17
0.19
0.01
2.95
0.1
1.32
0.14
24.34
3.4
8.5
3.5
285.3
1.47
0.17
0.\8
0.02
2.9
0.2
1.5
0.36
27.8
4.34
6.5
\
287.9
1.70
0.24
0.13
0.02
3.2
0.4
2.43
0.71
43.04
1
4.5
1
290
2.70
0.24
0.06
0.01
2.6
0.1
1.68
0.19
8.7
1.74
41.5
10
291
1.47
0.23
0.16
0.06
2.5
0.4
1.57
0.36
46
1.74
2
0.1
291.2
1.47
0.1
0.\6
0.01
2.75
0.2
1.78
0.42
46
4.34
\
0.1
River Mile
DO
mglL)
NH3-N mglL)
CBOD20(mglL)
278
8
0.52
0.18
0.01
5
1.38
280.9
7.95
\
283
7.30
0.7
285.3
7.47
0.34
0.25
0.03
4.95
0.83
287.9
4.34
1.04
0.14
0.03
5.27
2.22
289.9
4.52
1.39
290
11.47
5.9\
0.36
0.07
13.89
5.56
290.1
4
0.7
291
4
\
0.1
0.01
2.77
0.01
291.2
4
0.34
0.46
0.07
3
0.01
Table a6. August 1991 (mean and standard deviation)
River
N02
Ortho.P
TKN (mgIL)
(mglL)
N03 (mgIL)
(mglL)
S.D (in.)
Chl.a (uglL)
Mile
278
1.3
0.2
0.18
0.01
2.97
0.11
1.48
0.14
25
5
73
285.3
1.1
0.2
0.17
0.01
2.97
0.11
2
0.44
25
5
6.5
0.1
287.9
1.7
0.1
0.11
0.02
3.37
0.34
2.4
0.74
44
10
2.5
1
290
2
0.6
0.05
0.01
3.54
0.11
2.22
.44
8.5
2
5\
13
291
1.7
0.1
0.11
0.01
0.91
0.05
2.30
0.3
57.5
5
1
0.01
291.2
1.7
0.1
0.12
0.02
0.89
0.05
2.30
0.3
50
14
\
0.01
River Mile
DO (mglL)
NH3-N(mgIL)
CBOD20(mglL)
278
7.47
0.34
0.30
0.01
5.94
0.55
280.9
7.13
0.34
283
7.13
0.7
285.3
7.13
0.34
0.34
0.01
8.61
0.01
287.9
4
0.34
0.30
0.01
5.38
0.01
289.9
4.17
0.34
290
10.26
3.9
0.55
0.13
21.38
1.11
290.1
4
0.34
291
3.82
0.17
0.30
0.13
6.11
0.01
291.2
3.82
0.34
0.90
0.1
6.66
0.5
32

Back to top


Appendix E
Macroinvertebrate Plots

Figures 1 and 2
30
25
Q)~
20
s::
"5 15
ii:
CO
~
10
t-
5
~HD
20001
30
,----,..------r------,-------,r-------,
0
I
en
en
20
(1)
c
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t)
0:::
CO
X
CO
10
I-

Figures 3 and 4
20
18
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16
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(/)
(/)
14-
Q,)
.c:
t: 12
o
0::
10
~
8-
ca
I-
6-
4-
2
o
Sample Stations
20 ,----.--'--,-I----rl-------,I------.,
*
(!)
15
I-
-
0...
(J)
(J)
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c
..c
(.)
10
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--
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0:::
co
><
co
I-
5
-
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1111
PG
2000
I

Figures 5 and 6
10
9
ca
><
8
r:.
7
~
6
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o
5
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Q)
4
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E
3
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:::J
z
2
1
0
~~
~~
~c::P
~c::>Q
\:P
~
",Q
~
Assessment Area
I~HD
20001

Figures 7 and 8
I
i
3.5
I
3
C)
a. 2.5
In
In
Q)
c:
2
.t:
0
ii2
1.5
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a.
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1
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PG
2~gQJ
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3.5
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3.0
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><
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2.5
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(L
2.0
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ill
....
0
Q)
1.5
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E
1.0
::J
z
0.5
0.0
*

Figures 9 and 10
- ----
-~-------
100
90
Q)
80
g 70
llJ
-g
60
~
.0
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Attachment A
Appendix F: Fishery Data

Appendix F.4
River
Des Plaines Des Plaines Des Plaines Des Plaines Des Plaines Des Plaines Des Plaines
Station
G-07
G-11
G-18
G-28
G-33
G-34
G-35
Habitat Type
OH Boatable 181
36
20
30
32
32
24
28
#
Native Species
17
13
16
16
20
14
12
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1
4
6
4
3
4
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1
2
2
2
1
2
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NonIntolerantTolerantSpeciesCPE
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1
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56
4
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0.4
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5.5
1.4
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en
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5.7
21.1
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18.3
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49.7
16.5
26.7
47.2
31.3
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13.2
10.4
52.2
27.2
68.5
51.7
0
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0.4
7.8
6.8
1.7
10.8
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DELT Anomolies
nr
nr
nr
nr
nr
nr
nr
Total CPE
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172
230
90
235
358
120
#
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3
3
3
3
3
3
3
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#
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5
1
5
5
5
3
5
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1
1
1
1
1
1
1
~
0
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1
3
5
5
1
3
()
#
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1
3
1
3
3
1
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%
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3
1
3
1
1
1
1
en
%
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1
1
1
1
1
1
1
-
%
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5
3
5
5
1
5
0
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1
3
3
1
1
1
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5
1
1
3
3
5
3
0
%
Simple Lithophils
1
1
1
1
1
1
1
%
DELT Anomolies
3
3
3
3
3
3
3
Fox Key

River
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
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Fox
Fox
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Fox
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Fox
Fox
Fox
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Station
ALLO ALM1
ALM2
ALUP
CVLO CVUP
DALO DAM1
DAM2 DAUP
ELLO ELM1
ELM2
ELUP
GELO GEUP
HILO
HIUP
MHLO MHUP
MOLO MOUP
NALO NAUP
NBLO NBUP
Habitat Type
OS FF MO IMP MD IMP US IMP OS FF UP IMP OS FF MO FF MO FF US IMP os FF MO FF MO IMP US IMP OS FF US IMP OS FF US IMP OS FF US IMP DS FF US IMP OS FF US IMP OS FF US IMP
OH Boatable IBI
30
20
26
20
32
26
42
48
50
28
32
32
26
20
26
26
46
28
30
26
36
28
38
20
24
20
#
Native Species
18
6
8
6
17
13
21
13
16
9
15
21
10
8
16
7
13
11
13
11
16
8
13
9
10
7
#
Sunfish Species
3
2
2
3
3
4
3
0
5
12
4
3
23
21
24
21
3
1
32
2
(j)
#
Sucker Species
4
0
0
0
2
1
7
6
6
24
3
3
0
4
05
2
0
1
4
1
6
2
30
0
'C
#
Intolerant Species
4
120
4
2566
4
66
3
13
24
32
27
2
4
1
3
0
......
#
Non Tolerant CPE
128
34
29
26
102
37
206
90
100
46
86
81
26
<t.>
27
96
11
123
43
91
67
122
16
136
21
88
29
~
% Tolerant Species
28.9
47.7
39.6
41.9
26.3
41.3
8.5
13.5
9.1
41.8
25.9
32.5
38.1
43.8
29.1
54.2
9.6
20.4
26.6
23.0
20.5
28.6
16.0
41.7
32.0
31.7
CO
%
Round Bodied Suckers
15.0
0.0
0.0
0.0
0.7
0.0
15.2
58.7
50.0
20.3
11.2
2.5
4.8
0.0
9.0
0.0
51.5
11.1
0.0
2.3
35.1
4.8
22.8
8.3
7.8
0.0
%
Top Carnivores
26.1
13.8
12.5
18.6
26.3
19.0
14.3
18.3
29.1
25.3
28.4
33.3
31.0
33.3
41.0
20.8
27.9
42.6
23.4
31.0
9.3
23.8
40.1
27.8
28.9
34.1
0
%
Omnivores
41.7
47.7
41.7
37.2
24.1
41.3
12.9
14.4
'10.0
41.8
25.0
32.5
35.7
35.4
31.3
20.8
11.0
16.7
25.8
28.7
24.5
9.5
22.8
38.9
48.4
29.3
E
% Insectivores
32.2
38.6
46.8
44.2
50.4
39.7
37.1
67.3
60.0
32.9
46.6
34.2
33.3
31.3
28.4
58.3
61.0
38.9
50.8
40.2
84.9
67.1
37.0
33.3
24.2
41.5
0
%
Simple Lithophlls
15.0
0.0
2.1
0.0
4.4
0.0
17.4
59.6
60.0
20.3
12.9
9.2
4.8
0.0
10.4
0.0
51.5
11.1
0.0
2.3
37.7
4.8
24.1
8.3
78
0.0
%
DELT Anomolies
7.78
13.86
0.00
6.98 10.14
11.11
5.80
1.92
6.36
2.53
14.66
8.33
11.90
10.42
9.63
8.33
6.62
7.41
9.68
4.60
8.50
26.09
9.26
13.89
9.23
6.93
TotalCPE
180
65
48
43
138
63
224
104
110
79
116
120
42
48.
135
24
136
54
124
87
153
23
162
36
130
43
#
Native Species
3
1
1
13
35
33
1
3
5
3
13
13
3
3
33
1
3
1
31
(j)
#
Sunfish Species
3
3
3
33
5
3
1
5
1
3
5
33
3
31
3
5
3
1
31
3
3
3
<t.>
#
Sucker Species
3
111
1
1
55
3
1
3
3
3
13
1
3
11
1
3
1
5
131
'-
0
#
Intolerant Species
5
1
3
1
5
3
55
5
5
5
5
3
1
3
35
33
3
5
35
I3
1
0
#
Non Tolerant CPE
3
1
1
13
13
1
3
11
11
1
1
13
11
13
13
1
1
1
(J)
%
Tolerant Species
1
1
1
13
1
5
5
5
1
31
11
1
1
5
33
33
1
3
1
11
CO
% Round Bodied Suckers
1
1
1
111
1
5
5
311
1
1
11
5
11
13
1
3
111
%
Top Carnivores
5
5
5
5
5
5
555
5
5
5
5
5
5
5
5
5
5
5
3
55
5
5
5
0
%
Omnivores
1
1
1
1
3
15
5
5
1
3
11
11
3
5
3
3
13
53
111
..c
%
Insectivores
3
3
3
3
3
335
5
3
3
333
3
55
3
3
3
5
53
31
0
3
%
Simple Lithophlls
1
1
11
1
115
5
3
11
1
1
1
1
5
1
1
13
13
111
%
DELT Anomolies
1
1
5
1
1
1
1
3
1
311
1
1
1
1
1
1
1
1
1
11
1
11
RivH
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Fox
Green Green Green Green Green Rock Rock Rock Rock Rock Rock
Staticn
SBLO SBUP
SCLO SCM1 SCM2
SCUP
SELO SEUP
SILO
SIUP
YOLO YOM1
YOM2 YOUP
PB-02 PB-D4 PB-08 PB-10 PB-19 P-11 P-15 P-20 P-21 P-23 P-24
H~l>itlt
Typ..
OS FF US IMP DS FF MD FF MD IMP US IMP OS FF US IMP DS FF US IMP DS FF MO FF MO FF US IMP
Of-!
Boat;lb~
lSI
44
22
30
24
16
24
22
18
46
18
50
28
24
18
42
36
44
40
42
44
44
40
4S
44
44
#
r...tlv1! Species
16
8
12
13
6
6
13
6
10
5
16
11
7
6
18
17
18
15
19
32
20
18
26
27
21
#
Sunfish
SpIel'"
1
233
3
33
20
23
1
a
2
3
2
2
2
256
253
I
~
#
Suck;;'SP'ldes
6
123
1
02
0
4
1
6
3
2
16657785
478
9
E
#
IllIoler"n\ Speclas
4
3
3
3
0
a
3
14
17
3
3
0
5
345
712
5
6
7
9
8
<t.>
;I N"n
TO~'l.ni
CPS
150
15
123
29
18
17
46
17
107
8
139
51
53
7
235
128
155
218
255 437 313
313
266 235 232
2
%
TO~''l.nt
Speo,",s
8.0
76.6
21.4
61.8
65.4
53.6
46.5
48.5
5.3
75.0
10.9
43.3
44.8
78.6
17.9
21.4
11.0
27.8
16.4
3.5 14.0
7.1 11.0
4.9
2.5
CO
%
Round Sodiod Suckors
38.0
0.0
2.8
2.5
0.0
0.0
3.5
0.0
54.0
3.1
61.5
32.2
32.3
0.0
6.3
10.1
22.5
26.2
36.1 13.1
10.7
2.7 33.8
18.2
27.3
<~
Top
CarnIvores
35.0
12.5
40.7
22.4
9.6
14.3
28.7
39.4
34.5
18.8
10.3
23.3
24.0
10.7
14.7
25.8
28.3
11.9
5.2
8.8 11.6
9.5 10.0
9.3
5.5
0
%
Omnivo'''s
15.3
78.1
22.8
61.8
67.3
42.9
46.5
42.4
5.3
71.9
19.9
42.2
42.7
78.6
18.9
25.8
15.6
31.8
28.5
23.0
11.3
13.9 32.4 27.1 35.7
:E
%
los;;<>tivcru
49.7
9.4
44.1
15.8
25.0
75.0
26.7
18.2
60.2
9.4
69.9
34.4
33.3
25.0
66.7
48.6
53.2
55.3
65.8 42.7 32.8 29.1 53.8 52.2
58.0
0
%
S'mp,," Uihophils
38.7
0.0
3.4
3.9
0.0
0.0
4.7
0.0
54.9
3.1
62.8
35.6
32.3
%
DELT An"me>1l..s
11.04
1.56
12.82 18.42
9.43
2.70 15.12
18.18
9.73
6.25
2.56
5.56 19.79
TouIC?S
163
64
156
76
53
37
86
33
113
32
156
90
96
S
1
3
:>
1
1
3
1
3
1
3
3
1
I
:3
:;
3
;>
3,
~
3
3
'5
5
C
#
N3.t\<'e
SP~Ot~S
1
:s
3
3
3
:3
3
3
I
3
3
1
'<
3
3
:3
3
:>
3
5
1;
3
'5
.3
if)
#
Sunfis.h SpE'des
5
1
1
:3
1
I
1
1
3
1
5
3
1
5
5
3
1;
~<
~
3
3
5
5
~
#
Sudo:er Specl'?-s
5
.3
3
:.;
1
1
3
1
5
1
5
3
:.;
I
5
:.;
'5
1;
C'
5
1;
C'
'5
5
;
0
:#
Intolerant Spe<;ies
3
I
S
I
1
1
1
3
1
3
1
1
533
:.;
0
#
NcnTolerantCPS
"
'5
5
5
5
5
e
(J)
5
1
.3
1
1
1
1
~
1
5
1
I
S
:;
5
3
5
5
5
5
5
e.
as
% TO-4e:.ant Specie-s
5
1
1
'<
1
1
1
1
'5
1
5
3
3
I
1
1
3
:3
3
1
1
I
3
3
3,
%- ROLlno: So;:hed Suckers
5
55
5
3
55
5
5
5
5
5
5
5
5
5
5
53353
5
3
3
0
%.
Top Carnivores
5
1
3
1
1
1
1
1
5
1
3
1
1
I
3
:;
(\
'<
1
35
5
1
:3
I
:e:
%
%.
Inse-cth'ore:sOmnivores
3
1
:3
1
1
5
1
1
5
1
5
3
3
1
5
3
3
5
e
333335
0
%
Simple Lithophil.
S
1
1
1
1
11
1
5
1
5
:>
3
1
% DELT A""mClles
1
;)
1
1
1
;)
1
1
1
1
3
1
1
I
DS
DO'hm:~i!;sm
of Cam
us
Ups1re.l;m
of
Dolm
MOo
Midd(oe R>i3¢h
b-e1w~en
O.ams
FF
FtHFlowmo-
IMP
~ml)OundNi

Attachment A
Appendix G: Comments

Date: 10/30/2003
To: Toby Frevert
From: Howard Essig
Subject: Additional Comments on Draft Lower Des Plaines River Use Attainability Analysis
(3/10/2003).
Page 2-39, third paragraph. "However, most of the nutrient loads come from the upper reaches
of the Chicago Area Waterway System ... " Comment: A substantial portion of the nutrient
loading to the lower Des Plaines River
is also coming from the upper Des Plaines River. Are
there any plans to deal with this source?
Page 2-40, first complete paragraph, second sentence. ''The acute criterion is a function of
pH ..." Comment: Insert "Federal" in the beginning of the sentence - The Federal acute criterion
Page 2-40, first complete paragraph, third sentence. "The chronic standard is a function ..."
Comment: Insert "Illinois" - The Illinois chronic standard...
Page 2-41 ,last paragraph, second sentence. ''The margin of safety would be large for all
stations
of the lower Des Plaines River except MWRDGC 95 (I-55)..." Comment: The margin of
safety would also be low for the upper Des Plaines station IEPA G-11. What about the IEPA
station on the CSSC (GI-02)?
Page 2-45, Copper, first paragraph, second sentence "The difference in the analyses was a
partial problem."
Comment: IEPA analyzed both total and dissolved copper while MWRDGC
analyzed only for total. What were the differences in total copper concentrations between IEPA
station G-23 and MWRDGC station 93? The compliance issue may
be more of a
QAlQC
problem. According to page 2-35, IEPA and MWRDGC stations that were located in similar
locations (i.e., G-23 and MWRDGC 93, GI-02 and MWRDGC 92, and
G-11 and MWRDGC 91)
exhibited different probabilities
of compliance. Collection methods differ between the two
agencies. IEPA employs a depth integrated equal width transect method while MWRDGC uses a
bucket grab center
of flow.
Page 2-45, Seasonal variation, last sentence. "However, this pattern is specific only for the
MWRDGC data ..." Comment: Were other IEPA stations besides G-23 (i.e., G-39 Riverside, G-
11, GI-02, F-02) checked to see if they exhibited this same pattern?
Page 2-46, Sources of Copper, second paragraph, last sentence. The IEPA detection limit
for total and dissolved copper is 10 ug/L.
Page 2-47, second paragraph, fourth sentence. "Chloride concentrations found in urban runoff
and streams after application
of deicing salts ...n Comment: According to figure 2.17, elevated
concentrations of total copper were found from September through January, with most of them
apparently found
in October and November when salt application rarely occurs in northeastern
Illinois.
Page 2-48, Relation to Flow. Where did the flow data that is shown in figure 2.19 come from?
Did other stations show this same trend in copper concentrations with flow (i.e., G-39 Riverside,
G-11, G-23, GI-02)?
Page 2-49, last paragraph, third sentence and Page 2-50, Figure 2.21. "A high concentration
spike is a result of a barge tow..." Comment: Could these TSS spikes be due to storm /high flow
events? Did MWRDGC field notes indicate barge traffic
on these dates? According to USGS
flow data from the CSSC at Romeoville; it appears some of these TSS peaks were
associ~J~d~._.~.
-----
with increased flows. For example, IEPA station G-45 near Empress Casino was sampied on
1

July 10 and had a TSS concentration of 92 mg/L. The flow at Romeoville on this date was 6636
cfs, about 2.5 times the annual mean flow.
Did TSS results from other MWRDGC stations on these dates indicate a similar pattern (i.e., 91,
92, 93, 95)? Hickory Creek enters the lower Des Plaines River just below the Brandon Lock and
Dam. IEPA and USGS have water quality monitoring and flow gaging stations on Hickory Creek
in Joliet. The Joliet MWWTP discharges into Hickory Creek near the mouth. Were any of these
data sources checked to see if they contributed to the results found at MWRDGC station 94?
Page 2-50, Sediment as a source of copper, first paragraph, first sentence. "Table 2.8
contains the sediment copper concentration data...and the reference Kankakee River at I-55 near
Wilmington"
Comment: In Table 2.4 on page 2-24 the Kankakee River at Momence (F-02) is
indicated as the reference site.
Page 2-50, Sediment as a source of copper, first paragraph, second sentence. "The data
were provided
by the MWRDGC." Comment: The data from the Kankakee River was provided by
IEPA. Why were IEPA data from 2000 at stations G-45 near Empress Casino (RM 282.8), G-01
at I-55 (RM 277.3) and G-24 (RM 273.2) not included in the analysis?
Page 2-50, Sediment as a source of copper, first paragraph, third sentence. "Only the data
between 1994
and 2000 were considered." Comment: The summarized sediment data
presented
in Table 2.8 on page 2-51 includes data from the Kankakee River from 1982 through
1994, but does not include 2000 data.
Page 2-50, Sediment as a source of copper, first paragraph, fourth sentence. "All
measurements were made
in the month of October." Comment: The sediment data from the
Kankakee River
in 1994 was collected in July.
Page 2.50, Sediment as a source of copper, first paragraph, sixth sentence. "The sediment
concentration of copper between these two locations doubles."
Comment: According to the mean
values given in Table 2.8 the copper concentration nearly triples. IEPA sediment data from 2000
at stations G-45 (RM 282.8),
G-01 (RM 277.3) and G-24 (RM 273.2) indicate similar
concentrations between these three stations
(61 mg/kg, 60mg/kg and 57 mg/kg, respectively).
Page 2-50, Sediment as a source of copper, second paragraph, first sentence. "IEPA
classified the sediments
in the state waters .. ." Comment: It should be indicated that these
classifications were based on field sieved
(62u)
samples and may not be applicable to whole
sediment samples collected by MWRDGC.
Page 2-50, Sediment as a source of copper, second paragraph, second sentence. "Based
on this comparative classification the copper content
of the sediments..." Comment: The
Dresden Pool at
RM 185 should be RM 285. The lower copper concentration at RM 285 may be
because of a higher content of coarser particles beiow the Brandon Lock & Dam. Percent volatile
solids at this location was much lower than at
RM 290.5 and RM 278 indicating that this may be
part
of the reason (see Table 2.8). Contaminants tend to concentrate on finer grain sediments
and these particles are more likely to be re-suspended than coarser sediments. Field sieving to a
more uniform small particle size (Le. <62
u)
limits the variability of constituent concentrations.
IEPA sieved sediment copper concentrations from 2000 were similar at stations G-45
(RM 282.8),
G-01 (277.3) and G-24 (RM 273.2). The concentrations at these three stations (57 ug/kg -61
ug/kg) would be classified as elevated. Copper concentrations from 2000 were also available for
the upper Des Plaines River at Lockport (G-11),
Du Page River at Channahon (GB-01) and the
Kankakee River near
1-55 (F-01). Sediment results from these locations indicated non-elevated
concentrations of 27 mg/kg, 20 mg/kg and 10 mg/kg, respectively. These results indicate that the
source
of copper is probably from above the Brandon Lock and Dam.
2

Page 2-51, Table 2.8. Indicate number of samples for each station. The Kankakee Data is from
IEPA and is from 1982 - 1994. Percent volatile solids data is available for the Kankakee and was
included
in the data sent to the contractor. Why was 2000 data from the Kankakee (F-01), lower
Des Plaines (G-11, G-45 and G-24) not included in this table? The minimum TVS value for RM
278 is obviously too high (44).
Page 2-54,
Third
paragraph. "An increase in copper concentrations occurs between sites 93
and 94 ..." Comment: IEPA collected water samples three times in 2000 at five stations between
the Brandon Lock
&
Dam and the Dresden Lock and Dam. Total copper concentrations were
below the detection limit
«10 ug/L) in all three samples from stations G-45 (Near Empress
Casino,
RM 282.8) and 1:40 (Illinois River
u/s
Dresden L
&
0, RM 272.0). Copper was detected
once at station G-12 (Brandon Road,
RM 285.3) and G-01 (I-55, RM 277.0) and twice at G-24
(RM 273.6). These stations were sampled from the middle
of the channel, as was MWRDGC
station 93, and may not be comparable to MWRDGC stations 94 and 95, which were collected
from the Empress Casino Dock and Mobil Oil Co. Dock, respectively.
3

PRELIMINARY WATER BODY ASSESSMENT: CHEMICAL INTEGRITY OF THE
LOWER DES PLAINES RIVER
RESPONSE TO THE COMMENTS AND SUGGESTIONS OF THE
METROPOLITAN WATER RECLAMATION DISTRICT OF GREATER CHICAGO
by
AquaNova International/Hey
&
Associates
January 2002
We greatly appreciate the comments and suggestions of the MWRDGC. We have carefully
reviewed the comments, found them very helpful and will consider incorporating them into the
fmal report.
We would like to point out, as it was correctly recognized by the MWRDGC
reviewers, that this is a draft report that has been reviewed by several agencies and has become a
joint effort.
Comment
#1
Inclusion ofa Table ofContents and List ofFigure and Tables.
These were included after the executive summary on pages numbered by small Roman numerals
vi to ix . This is the standard format for reports.
Page i
Paragraph
1. Analysis ofthe current water quality conditions as compared to Secondary Contact
and Indigenous Aquatic Life water quality standards.
The following paragraph was added to the report:
The report evaluates the water quality data obtained from the agencies for compliance
with the Illinois General
Use Standards. If a parameter complies with the General Use it
can be implicitly assumed that it also complies with the Indigenous Aquatic Life and
Secondary Contact use for which the standards are less stringent. Some parameters (e.g.,
bacteria) have only a General
Use standard.
Additional wording will be added to the
DO evaluation where at some locations (e.g., Dresden
Island Pool) the
DO concentration may meet the Indigenous Aquatic Life/Secondary Contact use
but not the General Use.
It
appears that there a misunderstanding about the role this UAA. The need for the UAA is
derived from the wording
of the Clean Water Act that, in Section lOl(a):
1

$
wherever attainable, achieve a level of water quality that provides for the protection and
propagation
of fish, shellfish, and wildlife, and recreation in and on the water, and take
into consideration the use and value
of public water supplies, and agricultural, industrial,
and other purposes, including navigation (Sections 10l(a)(2) and 303(c)
of the Act); and
$
restore and maintain the chemical, physical, and biological integrity of the mtion's
waters (Section 101(a)).
Under Section 303(c), EPA is to review and to approve or disapprove State - adopted water
quality standards. This review involves, among others, to determine whether the State Standards
include the uses specified in section 101(a)(2).
If the designated use and ensuing standards are
not in accordance with the above rules
of the State, the State must submit an UAA. EPA
disapproves the standards
if the state standards are not in accordance with the uses specified in
Section 101(a) and
"the State has notfollowed its legal procedures for revising and adopting
standards"
and/or
"the State standards are not based upon appropriate technical and scientific
data and analyses".
The State developed its Secondary Contact and Indigenous Aquatic Life use in 1970's and has
not received an approval from the US EPA
.. This use is not in accordance with the CWA Section
101(a). The Illinois General Use is. Therefore, this
UAA is not defending or making justification
for the Secondary Contact and Indigenous Aquatic Life Use. Based on the law we must begin
with the General Use and its standards and find out whether the use and its standards are
attainable. The UAA regulations included in 40 CFR 131 specify six reasons by which the
General lEe standards can be relaxed and the use modified.
We have already identified
19 parameters that fully meet the general use standards. Weare now
looking into remaining 6 parameters and trying to
identifY whether they are attainable. Weare
considering several alternative scenarios such as considering Water Effect Ratios, water quality
in reference water bodies (the Kankakee River is a reference only for chemical constituents),
definition
of a new use based on irreversible physical restrictions caused by navigation, and
habitat restriction. In the final outcome, all six reasons may be investigated.
We already know
that some
may not be applicable (e.g., lack of flow).
If this UAA fails, e.g., by excluding reference streams from consideration that prevents then
invoking Reason 1,
or if the State fails to submit a technical and scientific documentation for
altering the
General Use
standards then, by default, the General Use with its standards will
become the only use allowed.
We have also noted that the Secondary Contact WQSs have standards for cyanide and total iron
that is not included in the General use WQSs. Also present Secondary Contact WQSs for
Unionized Ammonia (as
N) and dissolved iron are more restrictive than the General use
standards or federal criteria. We will address the compliance with the more stringent general Use
standards
in the final report and suggest a reconciliation.
"Dresden Island" identification was corrected.
2

Page ii
Paragraph 1
The data from Commonwealth Edison and the Midwest Generation have been
collected only for I-55 and in this preliminary evaluation only DO and temperature would have
been pertinent. These data only confirm what was found using the MWRDGC and IEPA data,
i.e., that at the end
of the investigated reach both parameters comply with the General Use
standards. The data only covered the period from 1997 to 2000 and the continuously obtained
measurements are not statistically the same as the randomly collected data. They could not be
used for trem analysis.
These data are now being used in the detailed analysis
of the DO and temperature situation of the
Dresden Island Pool.
The table was corrected and editorials (e.g., MWRDGC.) were also corrected. We have
eliminated numbering of the tables in the Summary because the sequence of the tables is not the
same as in the text which would lead to confusion.
Probabilistic analysis. The 99.8 % probabilistic compliance
of the acute standards is derived
from the wording
of the Federal EPA incorporated in the frequency and duration dimension of
the water quality standards for priority pollutants (40 CFR 131). The regulations specify that the
criteria are applied to a concentration that is exceeded once in three years which means that one
out
of3 x 365 = 1,095 daily measurement (0.1 %) can exceed or 2 out 1,095 daily measurements
(0.2%) can equal or exceed the standard. Therefore, 1,093 daily concentrations or 99.8 % must
be less. Because very rarely one has daily grab measurements fitting the incomplete series
of
measured data to a probability distribution and deriving the 99.8 % value in this way is the only
logic and scientific way.
Since the IEPA has accepted the federal criteria as state standards it is implicitly assumed that
the duration and
freql.lmcy component is applied too. Otherwise the impossible "never to be
exceeded" rule would apply and the whole analysis would collapse to a discussion
of what is
meant
by "never to be exceeded".
The
lo~normal
probabilistic fitting has been, to our knowledge, applied and accepted by the US
EPA. For example, in 1983 EPA scientists used
lo~normal
probability analysis for the
nationwide assessment
of the stormwater pollution in the Nationwide Urban Runoff Project and
reported the results to Congress. The US
EPA'sTMDL study of the New York Harbor uses
almost exactly the same methodology as we proposed and conducted.
For waste allocations,
USEPA has developed and promotes a model called DYNTOX that performs normal and
lo~
normal probability distributions in almost exactly the same way as we do on this project and
provides probabilistic estimates
of the exceedance or compliance with the criteria. The
Sacramento Regional Sanitation County District consultants used DYNTOX to develop
probability plots for the Sacramento River and presented them to the State
of California that
accepted and recommended the methodology. This is an established, scientific methodology.
3

Page iii
CCC
was defined in the body of the text as Criteria Continuous Concentration, which means
chronic toxicity criterion.
CCC
and CMC (acute) definitions were incorporated into the
Summary. The reference to an "ideal standard" is being taken out from the report.
It
has low
relevance.
It
was used in the original manuscript of the report by the NRC Committee to
Evaluate the Scientific Basis
of the TMDL to define a fonnat of a standard.
Page iv
The scientific judgement was explained in the main report. We made a judgement that a
component
of a common salt (chloride) is not acutely toxic at the concertrations found in the
river; therefore, the probability
of exceedances greater than 0.2 but far less than 10 percent
(allowable exceedance used
by the US EPA and some states for non toxic pollutants in the
305(b) reports) was acceptable for non priority pollutants such as salt (chloride) or pH.
For example, tests on fish showed that after 13 months of exposure to pH of 4.5 the test fish were
affected but not dead (1986 US EPA criteria document - the yellow book).
The paragraph that includes antidegradion and 303(d) listing has been replaced by the following
sentence:
Water column concentrations oftoxic metals (with exception ofmercury) listed in the above
table
do not provide ajustificationfor including metals into the 303(d) listing.
Page
v
We have included probabilities in the main report. Also in the table listing noncompliance
stations we have included a column an indication
of compliance or non-compliance with the
Illinois Indigenous Aquatic Life and Secondary Contact use and also included this evaluation in
the main report.
'Threatenedat all" means that the parameter is threatened at all stations. Page v is part
of the
summary. Detailed explanations are included or will be included in the report.
Pagel
Suggested corrections were made throughout the report.
The entire paragraph 3 was reworked to include better-referenced materials.
"Fair" classification
of water quality of the river upstream from Lockport was found in the
Illinois 305(b) report from which also Figure 1 was taken. The green color indicates "fair" water
quality based on the most recent definition of the 305(b) report by the US EPA to Congress.
Page
2
A better identification of the study reach was made on the figure.
4

Page
3
Paragraphs 1 and 2 were modified to reflect the comments. The term "river" was replaced by a
term "water body"; however, the name still remains the Des Plaines River, therefore, the
reference to a river is appropriate. Modified
or channelized rivers historically still remain rivers.
A term "canal" typically refers to a completely man-made channel in a place that was
not a river.
We feel, indeed, that we were asked to advise the Illinois EPA ofpossible modifications of the
303(d)
list.
Paragraph 6
We do not have a problem with tre substitution of this paragraph proposed by the MWRDGC..
The sponsoring agency ( Illinois EPA) has also no objections against this substitution.
Box 1
Numbering the reasons appears in our report. Apparently it was lost in transmission and
downloading.
We believe that a study technically but not legally similar to a TMDL should be
performed in order to use Reason 6. In some complicated cases, it is needed to find the loading
capacity, margin
of safety, perform load and waste load allocation and provide cost of abatement
before one can make a socio-economic analysis
of benefits and cost or financial impact.
For consistency,
we have removed the last sentence from Reason 6 and put the following
sentence below the
Box: "Reason 6: The UAA may require estimating load capacity of the
water body and perform load and waste load allocation processes in order to perform a socio-
economic impact analysis based on benefit/cost or financial impact analyses (Novotny et al.
l
)".
This is consistent with the earlier EPA \\ater quality standards documents such as EPA 44405 88
- 089 "Introduction to Water Quality Standards" or the 1986 Water Quality Standards Handbook.
Page
5
When a State states designates uses that are not in conformance with Section 101(a) statutory
uses, an UAA
must
be performed. If none of the six reasons is found to apply the use must be
upgraded.
In this sense the UAA is used to upgrade the previous non-conforming use. If the
agency chooses to accept for the body the General Use standards without a modification, an
UAA is not needed.
UAA is, however, needed if the upgrade of the use is less than the full
general use. Thus,
an UAA is needed for an upgrade to an optimal use that is less than the
general use.
Paragraph 3- wording was modified.
Page
6
The abbreviations were replaced by full wording (e.g., BMP = best management practice)
Page
9
Paragraph
1.
The typo was corrected. See discussion of probabilistic analysis on Page 3.
5

Paragraph
2. The reference is Delos, C. (1990) " Metals criteria excursions in unspoiled
watersheds," Unpublished draft, Criteria and Standards Div., U.S. Environmental Protection
Agency, Washington, DC. He suggested a range of compliance based on randomly taken data for
CCC criterion from 99.2 to 99.8 %. His calculation using analysis of autocorrelation was
credible. However, based on our judgement, the high limit of99.8
%
does not make sense
because that would
make the limiting probability of the CCC excursion equal to one daily grab
sample in three years (allowing one to
be equal) which corresponds to the CMC frequency. The
low limit of 99.2
%
compliance is more or less for randomly fluctuating sample series. Knowing
the fact that daily water quality series are mildly autocorrelated but still random (based on our
own research analyzing daily concentrations in WWTP influents and effluents) we opted for a
middle range
of 99.4 % compliance.
In
the subsequent document on the detailed analysis of
copper, we pointed out the deficiency of the USEPA CCC criterion.
Page 10
Table
1
Typically, both DO federal criteria, i.e., 7 day average of 6 mg/L and daily minimum
of 5 mg/L have to be satisfied. The concept of 7 day average obviously required continuous
sampling.
Page
14
Selection ofthe ammonium criterion.
The following sentences will substitute the statement in the report:
Salmonidfish species are not
indigenous to the Des Plaines River/Upper Illinois River System. Therefore, the criterion
for
salmonidfish absent will be used in this UAA.
The issue of early life forms present or absent will be discussed in great detail in the document
outlining the proposed Modified Warm Water Use.
In
this report we substituted the following
sentence:
The conditions whether early life forms can develop in the river system will be a
subject
ofthis UAA study.
A detailed analysis of the fish and other life forms present or potentially present will be included
in the subsequent documents.
Page 15
The name for Brandon Road Lock and Dam was corrected.
WER values in the USEPA document are very conservative. We prefer a site-specific
determination that is included
in the subsequent detailed documents. Note that this preliminary
analysis document was used only for screening and elimination from the further analysis
of
components that clearly have complied with the general use standards.
Although sulfides are
known ligands they do not exist in oxygenated water. Data were not
available for the sulfide content
of sediments.
.
Page 16
Paragraph
1.
Compliance with secondary standards was included in the Table as a comment.
See note
on Page 1.
6

Page
17
Reference station
The Biologic Subcommittee has been trying to find a reference point for biotic assessment. The
Kankakee River is used for illustration and reference
of chemical parameters. We cannot use the
downstream pools
of the Illinois River for chemical reference as suggested but not agreed on by
the subcommittee. The Illinois River flow at these points contains pollutants from a population
of over 9 million. Reference water bodies are unimpacted or least impacted bodies by humans.
So far, the Kankakee River is the best
we could identify so far. Reference bodies do not have to
be pristine but they should not contain wastewater from 9 million inhabitants. Without a
reference we would not be able to fully develop site specific criteria. We believe that the
Kankakee River is a credible reference since its character resembles what the Des Plaines River
would have been without urbanization.
Page 18
Same answer on the applicability of tre reference as that for page 17.
Page 23
We substituted "visual fitting" for "eyeball estimate".
For the acceptability of the probabilistic methods see the reply note on p.2 of this reply.
Page
24
and 25
If a parameter meets the General Use it also meets the current Secondary Contact and Indigenous
Aquatic Life Use (Table 5).
We added a sentence in this regard. Table 6 was modified to include
comments
on the compliance with the Secondary Contact and Indigenous Aquatic Life use. We
have noted that
tre secondary use standard for unionized ammonia (as N*) in the Secondary Use
is more stringent than that in the General use.
We will address it in the final report, i.e., if there is
a conflict between the attainment
of the US EPA ammonium criterion and IEP A standards we
will suggest a reconciliation
.. Our report has addressed attainment of the General use standards
and
US.EPA criteria.
Page 27
As stated before it is our interpretation of the contract and RFP that were asked by the IEPA to
identify those parameters that should
be removed from the 303(d) list. All parameters identified
as fully meeting the General use standards that are
on the list should be removed. If we do not
state this fact will
be understood by the agency by default. We have added a sentence stating that
all parameters in Table 5 meeting the Illinois General use standards also meet the Secondary
Contact and Indigenous Aquatic Life use which has far less stringent standards.
We remove the antidegradation statement from the report However, in submitting the standard
modification document the State is required to consider and include the antidegradation
statement.
Page
28
This report focus on screening parameters and locations for compliance or noncompliance. Some
possible analyses for Tier II were described in our previous document "Methodology ..." that
7

was already reviewed and commented on. Detailed Tier II methodology will be included in the
subsequent documents (copper, dissolved oxygen, other pollutants).
Table 6
We have rot commented on compliance or noncompliance of stations outside of the Lower Des
Plaines River. Table 6 is a summary
of noncompliance, we have reported in detail percent
noncompliance for each occurrence in the pertinent section dealing with the parameter. Table 6
would become unmanageable and information redundant if the same comprehensive information
was included.
Station 92 is right at the boundary
of the investigated reach of the Lower Des Plaines River and it
reflects the condition at the beginning.
If there is a consensus that this station should be deleted
we will delete it.
Page 29
We were provided standards by the IEPA that are either standing or proposed, including the
federal criteria, and were asked to evaluate all three categories.
Using nearby unimpacted or least impacted streams as reference water bodies is a perfectly
legitimate and needed component
of any UAA. Not using a reference would deprive the UAA
and the State
of the use of the reference data to arrive at a site specific standard. For example, if
reference data indicate that a nationwide standard is not attainable, the standard can be adjusted
to reflect this fact (see Reason
1).
It
is contradictory to the UAA process to ask that reference
data be removed and then demand that all 6 reasons be used in the UAA. Reason 1 cannot be
invoked
if reference data is not available.
Page 30
The editorial corrections were made.
Last paragraph
We do not suggest a downgrade of the Kankakee River. The Kankakee River is the reference
stream but it is not subject to this UAA.
If the river is found as not meeting the standing General
Use standards, the IEPA can conduct an UAA invoking Reason 1 at a later time.
Page
31
Paragraph
2 - See the preceding reply.
Paragraph 5, subparagraph 1
As
in
the Summary we have removed the note on antidegradation and substituted the following
sentence:
The fllinois EPA should reevaluate inclusion
ofthe metals listed in Table
5
and
ammonium in the 303(d) list.
Only temperature was identified in Table 6 as a threatened parameter and referred for further
analysis. The reason is the fact that the General Use temperature limit is being approached, the
8

trend is increasing and a judgement was made by the AquaNovalHey Associates team, discussed
also with the Illinois EPA, that temperature should be evaluated in greater detail inside the pools
between the sampling points.
Page
32
Paragraph 5
The trend analysis is a simple statistical fitting
of data to time or
C
= a
+
b x (time)
where a and b are statistically derived coefficients. lfb is statistically significant and positive
then we have an increasing trend. A visual observation
of the plot is also done to confirm the
reality
of the plot (e.g., for some constituents a change in the detection limit may indicate a false
decreasing trend). This type
of analysis (regression analysis) is apart of any statistical package
or a statistical text.
If a judgement was made that the trend is towards a possible exceedance of the standard within
the next five years the parameter would
be judged as threatened and referred for additional
analysis.
Page 33
The following text was added to explain the trend analysis:
The plots were evaluated visually.
If
the line ofthe bestfit indicated more than 20percent
increase or decrease over a
period offive years the trend was ranked as significant. A weak
trend is when the change is evident but less than
20 percent over a period of
5
years or
if
the
data shows a trend but may be distorted by laboratory detection limits. Compounds that
had data
distorted by detection limits
to a point that a trend could not be detected were not included.
Page 34
As stated before we were under the impression that we were asked by the Illinois EPA to
identifY
the parameters that should be deleted from the 303(d) list. After consulting this issue with the
IEPA it was fount that all
of the metals (Rg, Cr,
Cu,
Pb, Zn) and PCB listed in the 1998 303(d)
for the G-23, G12, and G-Ol were based
on sediment data and not on water quality standards
violations. Also, PCBs were listed as a cause because there is a fish consumption advisory for
the Lower des Plaines River. Our wording will indicate that the water quality in the water
column need not to be listed in the 303(d) report; however, these parameters (see our detailed
report on copper) may need to be listed based
on the sediment data.
Page 35
The DO link to temperature will be established
by the QUAL 2E model.
Figure 9 explains the methodology for the next step.
In
the next step, the UAA must develop
necessary reductions
of the concentrations and loads. This figure was already presented,
discussed and explained earlier when the committee discussed the methodology. The figure
could be deleted from this particular report since it is not a part
of the screening.
9

Page
36 -
Summary ofDO excursions
In the text describing the DO excursions we have reported percent compliance with the General
Use standard as
Reference site
IEPA GI -02
MWRDGCn
IEPAG 23
MWRDGC93
MWRDGC94
MWRDGC95
99%
60 % Upstream site
50 % Upstream site
75 % Brandon Dam Pool
80 % Brandon
Dam Pool
99
%
Dresden Island Pool
>99.8 % Dresden Island Pool
It
is evident that the term "great margin" can be used only for the Brandon Road Dam Pool (sites
IEPA G23 and
MWRDGC 93) and not for the Dresden Island Dam Pool (sites MWRDGC 94
and MWRDCGC 95). The site MWRDC 95 indicates compliance. We can state again that this
preliminary report is used for screening and a detailed
DO analysis is forthcoming.
We delete the statement
on aeration from the screening report but may address the attainability
of the (proposed) DO standards in the upcoming detailed report on DO..
Page
37
Recreation standard.
This response
on the same issue was provided to the Midwest Generation:
Most
of the wording was taken from the USEPA documents on this issue, namely the 1994
Water Quality Standards Handbook. The text detailing the three options and the statement
"Failure to support the swimmable goals for a stream is a major
deficiency..." are verbatim
quotations from the Standards Handbook (p2-3) and we included them to point out the problems
with defining the recreational use.
We included them to document the USEPA positions
expressed
in this particular guideline report. We have provided the citation in the report by a
superscript reference pointing to the 1994 Water Quality Standards Handbook (possibly this
superscript was lost in downloading the document). The AquaNova- Hey Associates team has
not completed the detailed analysis
of regulatims and options available to derive a proper
recreational use.
We are now collecting and analyzing data from reference streams and trying to
identify the source
of bacterial contamination that, as correctly pointed out by Ms. Wozniak in
her comments, might be of an uncontrollable nonpoint origin.
As pointed out
in our last paragraph, the USEPA has modified its position and now allows more
flexibility and other recreation classifications. The January 2000
Draft Implementation Guidance
for Ambient Water Quality Criteriafor Bacteria-1986
list the other options. This document does
emphasize that all six reasons should
be considered. One option was quoted as
"designating a
secondary contact recreation may be appropriate where primary use is not an existing use and
high levels
ofnatural and uncontrollablefecal pollution exist
(p.30)". Physical restriction of the
Brandon Pool and intensive navigation that may not be correctable as well as the fact that the
reference streams also have high bacterial counts, will
be considered along with Reason 6 of the
10

UAA regulations.
Finding an optimum use designation for recreation will not be simple and at this point we do not
have any preconceived positions or fixed solutions.
We thank MWRDGC for your excellent comment and we will consider all of them. We hope
that this response is satisfactory and we are looking forward to cooperation on the next, more
difficult steps of the UAA.
Vladimir Novotny
Neal O'Reilly
11

Back to top


International, Ltd
Environmental, Ecological
and Water Resources'
Engineers
I
November 12,2003
Mr. Toby Frevert
Manager, Water Pollution Control
Illinois Environmental Protection Agency
Springfield,IL
Re:
Tlrree Rivers Manufacturer'sAssociation
bear Toby:
First, let
me on behalf ofAquaNova, Hey Associates and the entire Des Plaines River UAA team
congratulate you
on the promotion to the position'ofManagerofthe Division ofWater Pollution
Control
ofthe Illinois EPA. We are delighted to have had this opportunity ofworking with you on the
Des Plaines River and hope that, after this project
is over, we will be able to work with on other
, important water quality issues
ofthe State ofIllinois. We also appreciate your tactfulness, deep
knowledge
of the issued involved and guidance in this difficult project. '
You have asked us top reflect on the three letters containing comments ofthe
'Three
River
Manufacturer'sAssociation.
_1 have received these letter oilly about ten days ago. 1understand that,
even though these letters were addr.essed to you, you expect our reaction.
We greatly appreciate the inputs of all stakeholders we met during this almost three years project and
understand their concerns. We have made an extra effort to make this
UAA objective and unbiased.
We also understand that there may be some socio-economic issues involved that are beyond our
analysis.
As you are aware we have tried very hard to accommodate all comments and suggestions into
our report and recommendations to the Agency and spent numerous
40urs with you and your staffand
with stakeholders
in and out the regular hearitigs of the two advisory committees and put in an effort
that far exceed,ed the contractual expectation,s. In'ourreplies we will focus on the last TRMA letter of
June 8,2003, hoping that these replies will also
a~dress
their concerns in the previous two letters
because there is some repetition.
BefoI:C we go into the discussion we have to emphasize that the outcome ofthis UAA will have little or
no impact on those dischargers that have already implemented CWA Section 30I and 306 pollution
abatement and comply with their NPDES permits.
For most pollutants the Lower Des Plaines River is
780 centre Street Unit C. Newton MA 02458. pHI FAX (617) 916 -2117. Email v,novolny@comcast.net

I
not water quality limited and additional expenses over those required to comply with the pennit will not
be needed.
Chapter 1
We in principle agree with a comment that
any ofthe reasons may justify. However, we stated
on numerous occasions that our interpretation
ofthe UAA rules is that the General Use is the
starting point
ofour analysis, i.e., we arte not defending existing use, or status quo, which does
not comply
with the goals ofthe Clean Water Act but we ask and analyze whether the General
Use is attained or attainable. The
six reasons provide a list based on which the entire general
use can be modified and corresponding standards relaxed
or for modifying an individual
General Use standard. However, the entire process must
be realistic, defensible, and according
to relatively strict water quality regulations.
On the other hand we could not propose a change
in a situation where most ofthe standing General Use standards have already been attained or
could be attained, which is the case ofthe Lower Des Plaines River. There are several
important examples where we hope we were successful in modifying the use
or standards, e.g.:
~
We have prosed the
Modified Impounded Use
for the Brandon Road Pool that, if
implemented, enables to relax the key standard for the dissolved oxygen and
ammonium We have extensively documented that the reduced DO standard is not lethal
nor chronically toxic to the resident and potentially indigenous aquatic population
and is
in accordance with the standing USEPA (1986) criteria document. For the same pool
we have documented that the primary contact recreation is not the proper use and'
advised to the Agency
to adopt secondary use Eo Coli standard at a level that is clearly
already attained. We have also found that most other chemical parameters, including
temperature,
alr~ady
meet the General Use standards, therefore, there is no reason for
trying some relaxed standards.
~
We have proposed an
Impounded (General) Use
for the Dresden Island Pool that
recognizes the fact that impounded
water bodies can not attain the ecological status of
wadeable small stream based on Which the current Illinois biotic integrity guidelines
were fonnulated.
It
should be noted that there are no current biotic standards. We have
also prosed a relaxation
ofthe dissolved oxygen standard of 5 mg/L to be based on 24
hour mean rather than
an, absolute minimum. Again, this standard has been attained and
would
be attainable if our proposed frequency of allowable excursions, was adopted.
We have also proposed to adopt a
high risk "restricted" primary recreation that is again
clearly attainable. It would require disinfection but there were no objections from the
City
ofJoliet to consider.this step ofimproving quality of their effluent, especially under
the circumstances that this
large urban area has a great need for waterborne recreation.
We will add "flow" alteration as one ofthe reasons for 303(d) listing.
The question is now whether
we could go any further and further downgrade the status of the
river as implied
in the letter. What would be the reasons? Navigation? There are many
navigation streams in the State
ofIllinois that have been classified as general use, so all ofthem
would have to be downgraded. Impoundment? Same reasons. Contaminated sediments?
Evidence shows that this is not a reason to downgrade
the use because excessive legacy
pollution should be remedied. Examples
of the Fox and Sheboygan Rivers in Wisconsin, the
Hudson River in New York State and other water bodies
wlth contaminated sediments clearly
document that sediment contamination is a
reason for TMDL and a follow up clean up but not a
reason for a downgrade
of the use.
Almost all
our pictures were taken during our visit ofthe sites organized by the Metropolitan
Water Reclamation District
of Greater Chicago during summer of2001. During this daylong

I
visit we saw one barge tow passing the Lockport lock and included the picture in our report.
The rest
of the river was as it looked on the picture. So, we had no reason to deceive anyone
and resent this connotation. We have reported that the average number
oftows during summer
is about 7 - 8 per day which is hardly a reason to downgrade the use
of the water body in the
Dresden Island pool.
Chapter 2 comments
These comments object the use
of statistics and temperature.
Use
of statistics is a mandatory tool ofall water quality. We have discussed it extensively when
we presented out methodologyJor approval to the stakeholder'scommittee and responded to
the comments more than two years ago.
It
is the only way how to arrive, as close as possible,
to an unbiased water quality evaluation.
We have done it in accordance with the fundamental
laws
of statistical analysis of water quality data and water quality regulations that express the
water quality standards
in
statistical terms ofmagnitude and probability of allowed excursions.
The federal water quality criteria specifically require that the statistical notion
of frequency
(related to probability) must be considered.
The
statistics does not obscure, just the opposite,
not using
it would lead to arbitrary judgements and indefensible conclusions. Statistics is not for
hiding a bias,
it
prevents a bias and subjectivity.
We could not write an UAA without considering temperature.
Not only that temperature is a
pollutant,
it also affect many other water qUality parameters, reaction rates and health ofbiota.
We have not tried nor attempted to define any
new standards but have noticed that the current
standard is clearly
in the lethal range and reported so
in
the UAA. We have also noted and
reported that the General Use thermal standard does not have this problem and should
be used
as a basis for any proposals for alteration
ofthe thermal standard. We have acknowledged that
the Midwest Generation is submitting their
own document and are certain that this document
will receive proper attention.
We can again ask what would be the reasons that would allow the thermal standard to be near
or in the lethal zone even for most thermally adaptable fish and almost all macroinvertebrates
(that can not
move to colder, waters miles downstream)? Navigation, impoundment, or sediment
contamination or composition are clearly not the reasons.
We cannot blankly state that we think
that Reason 3
or any other reason applies. We have to scientifically document that
it
does and
then why temperature standard
coUld be relaxed. We could not do that and have not seen that
anybody else could with the exception
of the Reason 6. Most other water quality parameters
meet the general use standards. Temperature
is
a~ost
the only one that does not.
Chapter 3
The 2001 USEPA sediment data are in public domain and we have made a request to the
USEPA for the data. We do not have
funds nor are privileged to distribute the USEPA data to
other parties. A simple request to the USEPA would suffice. The
same is true for any other
data we obtained from agencies.
Chapter 4
"Lack ofriffle/run habitat, limited hard substrates, channelization", although they appear to be
consistent with Reasons 3,4, and 5, are also common for any other navigable water body. At
one time we have proposed to the stakeholders committee to develop aspecial impounded use
but met a great resistance because it would have lead
to reclassification ofmany other water
bodies. Instead, we have
in
om: UAAproposed a .'modifiedimpounded" use for the Brandon
--------'

Poll and "impounded (general)"
us~
for the Dresden Island Pool. These modifications reflect the
fact that the optimal ecologic status
ofthese bodies is different from wadeable free flowing
water bodies and the reasons are irreversible. However, this reclassification cannot downgrade
chemical (including temperature) standards
if they are attainable. There seems to be a
misunderstanding
on the part of some that such reclassification will lead to a blank relaxation of
standards for pollutants.
We do not imply that the barge traffic will be reduced
in
the long run.
Chapter 5 and 6
. Chapter 7
No comments
I
Again, we do not imply that navigation will be reduced in the future. On the contrary, we have
emphasized that navigation is a protected use; however, navigation cannot reduce standards for
. aquatic life. We have used the argument ofthe conflict ofprimary recreation with .navigation in
our proposal for secondary recreation use in the Brandon pool. We could not have done it for
the Dresden Island pool because the key
limitationS (physical configuration, narrow chani:J.el, not
access) were not present
in
the Dresden pool. The reasons the TRMA state for eliminating
recreation are based on a perception that it would
be inconvenient to the manufacturers, a
reason that the authors
ofthe UAA nor the Agency cannot advocate.
Chapter 8
.We have used the argumentation stated in the first paragraph in an attempt to justify the "high
risk" infrequent or highly reduced recreation
in
the upper Dresden Island pool. We believe that
this was the only course
of action that would allow the Agencies to apply a side specific
standard
that.would not require subsequent
p~riodic
UAA evaluations needed for a secondary
use classification. Furthermore, the standard for such use is attainable so we have lost the
argument to go
further with
downgrading~
7- 8 barge tows in a summer day is not an argument
td
eliminate recreation
in
the entire Lower des Plaiiies River, just a cautionary limitation that
must
be conveyed to those infrequent users. In our survey, although not specifically asked, boat
accidents were not mentioned
by those contacted and asked about the limitations on the
recreation use.
In the news item attached to the TRMA letter the cause ofthe death
in
the
boating accident was given
as" windy weather, choppy water and an overloaded boat". These
causes cannot downgrade the use designation.
We proposed environmentally sensitive disinfection and discussed this alternative with
MWRDGC and City
of Joliet and there were no complaints, just an agreement.
Chapter 9
.
We appreciate the support for the Modified Impounded Use.designation.
We hope that this analysis ofthe,TRMA comments
is
helpful when you prepare you response. Let me
know it this suffice.
Lets hope that the next week meeting will be productive.
..
---
----------'

L
Sincerely,
Vladimir Novotny,
PhD, P.E. .
The overall impression
-,

Date: 10/15/03
To: Toby Frevert
From: Howard Essig
Subject: Comments
on Draft Lower Des Plaines River Use Attainability Analysis (3/10/2003)
Page 1-5, Des Plaines River Watershed, sixth sentence. "The overall resource quality shown
in Figure 1.1 assessed in the 1998 Illinois Section 305(b) report .. ." Comment: Why was the
1998 305(b) report used instead
of the 2000 or 2002 305(b) reports? It should be noted that the
1998 303(d) list was based on the 1996 305(b) report, which used data up through 1994.
Page 1-5, Des Plaines River Watershed, seventh sentence. "The potential causes of water
quality problems ...
in the Illinois Section 305(a) ..... Comment: This should be Illinois Section
305(b) not 305(a). "Phosphorus attached to sediment particles" is a source for lake assessments
only and not
for rivers and streams.
Page 1-5, Des Plaines River Watershed, eighth sentence. "A total of 76 lakes .. ." Comment:
Why mention lakes? This is a UAA for the lower Des Plaines River.
Page 1-5, The Des Plaines River, first paragraph, last sentence. " Since other treatment
plants ... discharge into the CSSC ... the lower segment of the Des Plaines River
is effluent
dominated ..
." Comment: What other Chicago metropolitan treatment plants discharge into the
CSSC? The upper Des Plaines River (IL/WIS state line to
eSSC) is also dominated by MWWTP
discharges including NSSD Waukegan and Gurnee, MWRDGC Kirie and Egan plus many others
see Table
1.1 on page 1-10.
Page 1-5, The Des Plaines River, second paragraph, first sentence. "All of the Des Plaines
River mainstem (156 miles) ..... Comment: According to Healy (1979) there are only 109.9 miles
of the Des Plaines River in Illinois. The upper Des Plaines River, from the IL/WIS state line to the
confluence
of the CSSC, is 93 miles. The lower Des Plaines River from the CSSC confluence to
the Kankakee confluence is 16.9 miles. Not all of the Des Plaines River miles were rated as fair
in the 1998 305(b) report. Segments G11, G39, G22, G07, G08 (or about 18.6 miles) were rated
as good. Miles for many of the Des Plaines River segments were corrected for the 2000 305(b)
report resulting
in a total of 110.7 miles, which is in better agreement with the 109.9 miles from
Healy (1979). The 2000 305(b) report also indicated additional segments rated as good including
G08, G07, G22, G26, G35 and G36 (or about 33.4 miles).
Page 1-5, The Des Plaines River, second paragraph, second sentence. "Degraded water
quality conditions were attributed to nutrients and siltation
.. ." Comment: Other causes of
degradation were also listed including priority organics, metals, ammonia, TDS/conductivity,
suspended solids, flow alterations and habitat alterations. "Phosphorus attached to sediment
particles" is a source for lake assessments only and not for rivers and streams. Other sources
besides municipal and industrial point sources, urban runoff and contaminated sediments were
listed including agriculture, CSOs, land development, flow regulation, channelization and
streambank modification.
Page 1-5, The Des Plaines River, second paragraph, third sentence. " All of the 48 stream
miles assessed on Salt Creek ..." Comment: Why mention Salt Creek? No other Des Plaines
River tributaries are discussed.
Page 1-6, Figure 1-1. This figure does not present the entire Des Plaines River Watershed.
Lake County is missing. Since the text on the previous page discusses the entire Des Plaines
River this map should include the whole basin.
Page 1-7, The Study Reach, first paragraph, second sentence. "Almost the entire reach is
impounded .. ." Comment: The word impounded implies "lake like" or reservoir conditions with
1

minimal velocities (e.g. <0.3 fUsec). According to Irwin Polls average velocities in the Brandon
and Dresden Pools are 0.75
and 0.65 fUsec, respectively.
Page 1-7, The Study Reach, second paragraph, fifth sentence. "The water quality status of
the Des Plaines River, upstream from the confluence ..."
Comment: The entire Des Plaines
River upstream from the CSSC
is not rated as only fair. About 19 miles in the 1998 305(b) and
33 miles in the 2000 305(b) are rated as good.
Page 1-7, The Study Reach, second paragraph, sixth sentence. "It receives urban runoff from
many suburban communities." Comment: There are also numerous MWWTPs and CSOs that
discharge into the upper Des Plaines River and its tributaries.
Page 1-8, Water Quality, fifth paragraph. Indicate year of 303(d) list. It should be noted that the
1998 303(d) list was based on the 1996 305(b) report. Parameters of concern in the study area
should include the following: low dissolved oxygen/organic enrichment and flow alteration.
Page 1-10, Table 1.1. Are the average effluent flows given in this table design average flows or
are they average flows for a period of record? Include dates for period
of record. Two
Bensenville plants are listed
in the Table. Bensenville (South) discharges into Addison Creek,
tributary to Salt Creek. Hinsdale discharges into Flag Creek, tributary to the Des Plaines River.
Wood Dale North and South are not included on this Table. They both discharge into Salt Creek
and have OAFs
of 3.05 and 1.75 cfs, respectively. Mokena and New Lenox discharge into
Hickory Creek and should probably be included in this table.
Page 2-5, fourth paragraph, first sentence. "For chronic toxicity, composite samples (over a
24-hour period) are more appropriate."
Comment: Why are federal chronic standards being
used instead if Illinois chronic standards? Illinois standards require only that a minimum
of four
samples be collected over a period of at least four days. Samples collected monthly (or longer)
are acceptable (Le. four month average). The dataset
is sufficient to apply the Illinois chronic
standards because the stafldards do not require a maximum of four days.
Page 2-8, Table 2.1 continued (Zinc). The acute and chronic standards for zinc are incorrect.
The acute
"An value should be 0.9035 and the Chronic "A" value should be -0.8165.
Page 2-9, Table 2.1 continued (total ammonia nitrogen). The total ammonia nitrogen general
use standard is 15 mg/L.
Page 2-9, Table 2.1 continued (un-ionized ammonia). The new standards effective 11/8/2002
should be used
in this Table and include acute, chronic and sub-chronic standards.
Page 2-16, First complete paragraph, first sentence. "Ten-fifteen years after the Palmer's
survey's had been conducted the water quality
of the Lower Des Plaines River was dramatically
altered by the Chicago Sanitary and Ship Canal."
Comment: According to Com Ed (1996) the
CSSC opened
in 1900, only 1 - 3 years after the Palmer survey. According to page 1-14, thirteen
miles of the Des Plaines River were re-routed into a diversion channel
in the late 1800s. The
CSSC was finished at the beginning
of the 20
th
century. According to Table 2.3 on page 2-15,
Palmer's survey was completed from 1897 through 1899.
Page 2-21, First complete paragraph. This description of the Green River should include
305(b) assessments, Le. fifty-seven miles of the Green River were rated as full support (good)
and 26 miles as partial support (fair).
Page 2-21,
First complete paragraph, last sentence. "The nutrient pollution has caused
extensive phytoplankton blooms."
Comment: Document this statement - provide citation.
2

Page 2-12, second paragraph. There are two AWQMN stations on the Green River, which
station was used as a reference site for bacteria?
Page 2-23, Rock River, third paragraph, first sentence. "The Illinois part of the basin is divided
into the upper and lower Rock River Basins."
Comment: The Rock is not divided into upper and
lower basins - the Fox Basin
is divided into an upper and lower basin.
Page 2-23, Rock River, third paragraph, third sentence. "Of the total miles, 69 miles have
"good" quality ..."
Comment: When discussing quality of the river indicate where this assessment
is from e.g. 2000 305(b) report. According to the 2000 305(b) report, 154 miles of the Rock River
was rated full support (good) and
13 miles as partial support (fair). Nutrients, and suspended
solids were not listed as causes of less than full support.
Page 2-23, Rock River, third paragraph, last sentence. "The river is impounded ..." Comment:
The entire river is not impounded. There are six dams on the Illinois portion (167 miles) of the
Rock River located at Rockton, Rockford, Oregon, Dixon, Sterling/Rock Falls.
Page 2-23, Fox River, second paragraph, first sentence. "The lower Fox covers about 1,100
sq miles ..." Comment: Why is this discussion limited to the lower Fox River? There are 15
dams on the Fox River with four dams
in the upper river and 11 dams in the lower river.
Page 2-23, Fox River, second paragraph, third sentence. "Overall resource quality was "good"
on 495 miles and "fair"
in 53 miles." Comment: The length of the entire Fox River in Illinois
(including the chain
of lakes) is only 115 miles. The 495 miles includes ratings for tributaries,
which should not be included because the purpose of this exercise is to compare large rivers with
dams. The most current assessment
of the Fox River is in the 2002 305(b) report. Data from
USEPA and the Max McGraw Wildlife Federation were used to help complete these
assessments. This data included biological and chemical data collected upstream and
downstream of every dam on the Fox River. According to the 2002 305(b) report,
33 miles of the
Fox River were rated as full use (good) and 67 miles as partial support (fair). The primary causes
of less than full use included priority organics, PCBs, nitrates, siltation, low dissolved oxygen, flow
alteration, habitat alteration, suspended solids, fecal coliform and pH. Sources of these problems
included urban runoff, CSOs, MWWTPs, flow regulation/modification, upstream impoundment,
streambank stabilization/modification and contaminated sediments.
Page 2-26, third paragraph, last sentence. "In the case of the reference sites, all existing data
was used in the statistical analysis." Comment: Why was all data from the reference sites used?
This would amount
to over 20 years of data for the reference sites compared to only five years for
the study sites. It seems that it would be more accurate to limit both datasets to the same time
period.
Page 2-26, Percentiles for Comparison with Standards, fourth sentence. "If one exceedance
is allowed by the criteria regulations, this ..." Comment: This sentence appears to be incomplete.
Page 2-27. Total Ammonium. Why are federal criteria being used instead of Illinois standards
(revised 11/8/2002)?
Page 2-28, Table 2.4. Acute and Chronic Toxicity Standards Derived from Average
Hardness for total Metal Concentrations. This should be Table 2-5 not 2-4. The reference
(Kankakee) should be labeled as IEPA - F-02. The site labeled as USGS Riverside should be
labeled as IEPA - G-39. Acute and chronic zinc values are incorrect. Wrong "Au values were
used
in the zinc equations and should be 0.9035 for acute and -0.8165 for chronic (see
comments for page 2-8, Table 2.1).
Page 2-29, Table 2.5. Acute and Chronic Toxicity Standards Derived from Average
Hardness for Dissolved Metal Concentrations. This should be Table 2.6 not 2.5. The
3

reference (Kankakee) should be labeled as IEPA - F-02. The site labeled as USGS Riverside
should
be labeled as IEPA - G-39. Acute and chronic zinc values are incorrect. Wrong "A" values
were used in the zinc equations and should be 0.9035 for acute and
-0.8165
for chronic (see
comments for page 2-8, Table 2.1).
Page 2-31, Probabilistic Analysis, sixth paragraph. IEPA collected total and dissolved metals
data at all stations used
in this study including F-02, G-39, 8-11, GI-02 and G-23.
Page 2-31, Probabilistic Analysis, sixth paragraph, last sentence. "In this case the WER for
these two metals .. ."
Comment: What two metals? - Only copper is discussed in this paragraph.
Page 2-32, Parameters in Compliance, second paragraph, second sentence. "The Illinois
EPA should reevaluate inclusion of the metals listed in Table 2.6 and ammonia in the 303(d) list".
Comment: Ammonia was not listed as a cause
in the 2000 and 2002 305(b) reports. It should be
noted that the 1998 303(d) list was based on the 1996 305(b) report and therefore is out of date.
The metals (chromium, lead and zinc) were listed
as potential causes ofdegradation in the
305(b)/303(d) because
of highly elevated concentrations in sediments.
Page 2-32, Parameters in Compliance, pH. Why are sites MWRDGC 91, G-11, G-39
(Riverside) not listed
in the compliance probabilities for pH?
Page 2-33, Table 2.6, Parameters meeting Illinois General Use Standards and Federal
Criteria. Why is a 97% probability
of compliance acceptable for chloride?
Page 2-35, Table 2.7. Parameters Not Meeting Illinois General Use Standards or
Threatened. All violations except for fecal coliform and dissolved oxygen occurred only at
MWRDGC sites. This may be a
QAlQC
issue.
Pages 2-35
to 2-37. Why are stations 8-11, 8-39 (Riverside) and MWRDGC 91 not included in
the compliance tables for copper, mercury, fecal coliform and dissolved oxygen?
Page 2-26, first paragraph, second sentence. "It is not possible to estimate loading ... if a
majority of the measurements have a detection limit that is above the standard." Comment: The
detection limit for mercury
(0.1 ug/L) is not above the mercury standards (acute 2.6 ug/L, chronic
1.3 ug/L).
Page 2-37, Parameters Not Addressed by this Report, Priority organics, first sentence.
"Data on priority organics were not provided." Comment: Data was provided for phenols, which is
a priority organic and has General Use (100 ug/L) and Secondary Contact and Indigenous
Aquatic Life (300 ug/L) standards.
In addition, sediment data was provided for PCBs, DDT,
chlordane, Dieldrin, etc.
4

August 26, 2003
Ms. Linda Holst
Chief, Water Quality Branch
United States Environmental Protection Agency
Region 5
77 West Jackson Boulevard
Chicago, Illinois 60604-3590
Subject:
Summary
ofDiscussions Regarding Midwest Generation's
Use Attainability Analysis (UAA) Thermal Report
We appreciate the opportunity to have met with you and your staff on August 6, 2003 to
discuss the various issues highlighted in your June
3, 2003 letter to Illinois EPA. Based
on the meeting discussion, Midwest Generation (MWGen) will revise certain portions
of
our report entitled "Appropriate Thermal Water Quality Standards for the Lower Des
Plaines River," dated January 24, 2003 (the "Thermal Report") to provide greater
clarification and additional data and information, where necessary, to address the issues
raised by the U.S. EPA Region
5. We believe the revisions will lend further support to
the Thermal Report'sfinding that the entire UAA reach (i.e., from Lockport to I-55)
meets Factors 3 and 4 ofthe six UAA factors outlined in 40 CFR 131.10(g), allowing for
the application
of a use designation other than General Use.
We also appreciated hearing Region
5'sconcurrence with the Biological Subcommittee's
conclusion that the biological potential ofthe Brandon Pool is limited due to habitat
alterations resulting from a combination
ofFactor 3 (Human-caused conditions), Factor 4
(Dams, diversions and other hydrologic modifications), and/or Factor 5 (Physical
conditions) influences. This confirmed our understanding that the scope
of the UAA
process includes consideration
of physical and biological integrity, not simply chemical
water quality,
in order to determine the attainable use for the waterway. (We recognize
that this understanding also was put forth in the results ofthe National Symposium on
"Designating Attainable Uses for the Nation'sWaters" held on June 3-4, 2002 in
Washington, D.C. but it was still beneficial to have this clarified
in our meeting
discussion.)
MWGen believes that the information that is provided
in our Thermal Report, as
supplemented by the information that we discussed during our August meeting, will
allow for similar concurrence by Region
5, as well as Illinois EPA and the UAA
Biological Subcommittee, that the Upper Dresden Pool does not meet the physical and
biological criteria necessary to support a General Use designation.

However, we also believe that any site-specific use designation for the Upper Dresden
Pool must accurately reflect both the improvements made in chemical water quality over
the past 30 years and the inherent physical and biological limitations which continue to
exist in the waterway. MWGen supports the need to protect the existing water quality
of
the Upper Dresden Pool.
In an effort to summarize the information presented during the August 6th meeting, we
have put together this synopsis, which is organized to respond to the items outlined in
your comment letter in the order presented.
u.s. EPA Comment, Page
1,
bottom:
The Agency refers to the finding in the Hey and Associates report that "thermal
discharges from the power generation facilities owned and operated by
MG are a
contributing factor in preventing the lower Des Plaines River from reaching its full
biological potential."
MWGEN Response: The information relied upon by Hey and Associates/AquaNova
International (henceforth referred to as the "IEPA Consultants") to determine that
MWGen'sthermal discharges are having detrimental impacts was predicated on false
assumptions and/or conclusions based on inaccurate, misrepresented or misused data.
This matter was discussed in detail at the June 6th meeting of IEPA, MWGen and IEPA
consultant representatives. As such,
U.s. EPA should not rely on the IEPA Consultant's
erroneous assumptions and conclusions to determine whether or not MWGen's
discharges are having a detrimental impact on the existing aquatic community in the
lower Des Plaines River.
It
is our understanding that the thermal portion ofthe draft
UAA report has been revised by Hey and Associates, based on MWGen's submitted
comments and corrections, will be issued for the UAA Workgroup'sreview shortly.
MWGen has provided a significant amount
of actual stream monitoring data which
supports the position that our thermal discharges are not having a detrimental impact on
the aquatic population which is or would be reasonably expected to be present in the
waterway, especially given the other permanent limitations
ofthe system (e.g. those
characteristics that are considered under Factors 3 and 4
ofthe UAA regulations) .
u.s. EPA Comment, Page 2, Factor 2 Section:
Naturalflow conditions prevent the attainment ofuse.
The Agency states that the Thermal Report did not describe how water levels prevent the
attainment
of use, and only stated that they are controlled by diversions, POTW flow and
manipulated for barge traffic. The Agency commented that even with the flow
variations experienced in the system, the base flow is sufficient to support a General Use
classification.
2

MWGEN Comment: Some clarification ofthe text ofthe Thermal Report is needed to
address this misunderstanding
ofthe relevant issue here. Our intent was to describe the
adverse impacts caused by the fluctuations
in water levels within the UAA reach, not to
focus on flow fluctuations. We intended to point out that there are certain areas within
the UAA waterway that are continually disturbed by frequent and often dramatic level
fluctuations. The Brandon tailwater area, which has been found to contain the best
physical habitat in the Upper Dresden Pool,
is the most heavily impacted by these level
changes. This could result in stranding
of eggs, larvae, or even adults and certainly could
affect the reproductive success
of various species, especially nest builders, and also could
increase predation, especially during low water periods.
Water levels in the system as a whole are maintained by the Corps
ofEngineers
controlling works at Brandon Road Lock and Dam and the MWRD-controlled Lockport
Lock. Water levels in the main body
ofthe river rarely fluctuate, being maintained at a
relatively constant navigational depth, but water flow rates change hourly, and by several
thousand cubic feet per second. While we agree that there is always sufficient water in
the system (i.e. it is not,
by any means, an ephemeral stream), the rate or velocity at
which the water passes through the system can greatly affect the aquatic life which
resides there, especially at critical times ofthe year.
In a completely natural system, spring thaws result in a "flushing effect", which is then
followed by relatively constant flows through the course
ofthe summer. In the lower Des
Plaines, there is no seasonality to these flushing events, which occur any time there is
significant rainfall in the Metropolitan Chicago area. The artificial conveyance designed
to take treated sewage away from Lake Michigan (i.e. the Chicago Sanitary and Ship
Canal) cannot accommodate the large volumes of runoffwater which result from a heavy
rainfall. The
MWRD's TARP system also isn'tpresently large enough to accommodate
the large influx
of flow from both runoffand the combined sewer overflows (CSO's)
which occur during heavy rains.
As a result, all of this water must be quickly shunted
down to the lower Des Plaines River to effect flow control, resulting in short-term river
flows that surpass 20,000 cfs at times. During dry weather, the flows continue to
fluctuate on an hourly basis. There is no "steady-state" flow in the river which would be
beneficial for the colonization
ofhigher quality benthic organisms, or accommodating to
those fish species which need such conditions to successfully carry out their life histories.
In
addition, the question ofwhether the flow conditions described above can be
considered "natural" in the context
ofthe UAA factor, is a difficult one. The entire
waterway is not a natural stream, and has a man-made flow regime, as the result
of
human-induced conditions. As such, MWGen believes that the effects ofthis altered
flow regime could be equally applicable under both UAA Factors 3 and 4.
U.S.
EPA Comment, Page 3, Top; Factor 3 Section:
Human caused conditions or sources ofpollution prevent attainment ofuse and cannot
be remedied.
3

The Agency comments that MWGen does not demonstrate that, absent the thermal
impacts
of our generating facilities, that sediment contamination and flow alterations
would be sufficient to preclude a more diverse aquatic community than already exists.
MWGen Response: Our report, "Appropriate Thermal Water Quality Standards for the
Lower Des Plaines River" does address this issue on pages 26-32. Lack of clean,
suitable substrate, along with an erratic flow regime, frequently traversed by barge traffic,
will serve to limit the number
of fish species which can be expected to inhabit the system,
even in the absence
ofthermal discharges. While it may not be possible to separate the
various stressors to the system to determine which ones are most responsible for the
limitations on the biological potential
ofthe waterway, thermal discharges alone are not
sufficient
to account for the lack of a balanced indigenous fish community in the lower
Des Plaines River. As discussed during our meeting, additional supporting information
on this finding will be included in a revision ofMWGen's report.
Clarification on Sediment Issues:
The potential for sediment remediation was not addressed by MWGen in our report since
it has not been established what entity would be responsible for such an undertaking, or
if
and when, realistically, it could potentially be done. Our report describes contaminated
sediments as "limiting." We will
clarifY this description to explain that the physical
characteristics
of the sediment in the system (fine, silty, organic) are not amenable to
many higher quality fish species which need a hard, clean substrate for spawning. Even
ifthe stream was remediated and the existing sediment (contaminated or not) removed,
the nature
ofthe waterway itself (e.g. impounded) would ensure that additional fine, silty
sediment (whether clean or contaminated) would continue to be deposited, thereby
preventing an improved habitat for better quality aquatic life.
It
is the physical quality of
the sediments in the system that are limiting further biological improvements, with
existing, depositional area sediment contamination exacerbating the siltation problem.
In a recently completed (May, 2003) habitat evaluation on the Dresden Pool, it was found
that sedimentation was moderate to severe in many (23 out
of34 or approx. 70%) ofthe
areas where QHEI scores were calculated. Sedimentation appears
to have gotten worse
over the past 5-10 years.
(e.g.,
DuPage Delta). Our report will be revised to include this
information.
With respect to the
u.S. EPA sediment sampling results (Table I on Page 3 of June 3,
2003 letter),
we do not believe that it is appropriate to average sets of samples from
varying locations in the waterway for use in any meaningful analysis. (See also the data
contained in Figure I in the same
letter). Sediment distribution (and any associated
contamination) is extremely heterogeneous in nature. Depositional areas, such as those
found
just above or below lock and dams or backwaters/side channels, have large
accumulations
of sediment, while locations near the main channel may have sparse or no
sediment accumulation, due to the scouring effects
of barges and sporadic high river
flows.
The depositional areas are also the primary sources of available habitat for the
fish community
ofthe lower Des Plaines. As such, the fish are likely exposed to
4

whatever contamination currently exists within these specific areas. When multiple sites
are averaged together,
it becomes impossible to determine where any specific
contamination "hot spots" may be located. In addition, lumping all data together to
determine an "average" concentration
of chemicals/metals/toxics does not provide a true
picture
ofwhere the specific areas of contamination are, as well as the associated levels.
Averaging dampens out the heterogeneity
of sediment quality and distribution, which is
an extremely important factor
in determining exposures to biological organisms.
The data presented do not state where each
ofthe respective sampling locations was, nor
do they differentiate which locations had cores, versus ponar grabs, etc. This
information is vital in order to assess the overall sediment quality
of any particular
location within the waterway. While the results do indicate the presence
of sediment
contamination, in varying degrees related to depth, for the reasons indicated above,
we do
not believe that compositing the results for the entire lower Des Plaines River is
appropriate.
Clarifications/Cautions Regarding Burton Sediment Toxicity Studies:
Regarding the Burton 1999 studies, there are several reasons why MWGen feels that this
data should
be viewed with caution. First, we firmly believe that actual river temperature
and biological data is more reliable and probative than any laboratory or artificially
controlled in-situ study. Fisheries data collected on the lower Des Plaines River during
the summer period for more than 20 years show the indigenous fish populations to be
largely unaffected by water temperatures which are often above what Burton has stated to
be the critical threshold temperature for indigenous species in the Upper Illinois
Waterway.
Within the body
ofthe Burton report itself, questions are raised regarding the reliability
of some ofthe study conclusions.
The results
ofthis particular series oftests had a considerable amount of scientific error
and/or uncertainty associated with them. The greater mortality rates
ofthe fathead
minnows used in the study was attributed to handling/shipping induced stress resulting in
overall poor organism health. In addition, some
ofthe mortality observed during the
laboratory tests has been, in part, attributed to increased ammonia levels associated with
the feeding
of the test organisms. The acclimation period for the organisms (24-36
hours) also
may not have been sufficient. Also, since the testing was done by holding
the test organisms in a chamber for a 7-day period with a constant exposure to
contaminants and/or high temperatures, it should not
be assumed that this is how
organisms would react
in a real-world situation in which there are refuge areas for them
to move to
if conditions become unfavorable.
As stated in the report, the level of stress
imparted on any test organism is dependent on: species sensitivity, exposure period,
acclimation temperature and presence
of other stressors, such as ammonia or water and
sediment with associated contaminants. In sum, the testing done has inherent
inaccuracies and variabilities common in biological testing protocols and should be
considered as an effort to model the hypothetical ''worstcase" condition; a condition
5

which has not been found in the actual river monitoring data and biological studies
conducted to date.
U.S.
EPA Comment, Page
4,
Bottom:
One example ofthe far-reaching statements made in the report that are not entirely
supported by the existing data is
on page 27 ofthe 1999 Burton report referenced by
Region 5 which states that
"Most of the river upstream ofl-55 does not contain
depositional sediments, such as
those found in the Brandon Lock
&
Dam pool."
MWGen Response: This statement is largely unsupported by the actual river data that
was obtained and submitted as part ofthe UIW studies, as well as the recent studies done
on the Dresden Pool.
As evidenced by the recent QHEI score attributes, there is a
significant amount
of depositional sediment within the Upper Dresden Pool ).
Depositional sediments occur throughout the waterway, primarily in main channel
border, side channel, backwater
and tributary areas. Accurately stated, depositional
sediments are found throughout
the Upper Dresden Pool, to varying degrees, but are
primarily found in main channel border, side channel and backwater areas and are not
generally present in the main channel.
u.s. EPA Comment, Page
4,
Surface Water Toxicity:
The Agency points out that in the 1995 Burton report, the studies demonstrated that heat
from the Joliet
Power plant was increasing surface water toxicity in the lower Des
Plaines.
MWGEN Response: The Burton 1995 Report, submitted as part ofthe UIW Study
effort, states that "(t)hese results suggest that the upper warm waters
ofthe thermal plume
may be exerting a slight effect on some species (with regard to toxicity); however the Des
Plaines River exerts a greater effect". (emphasis added). [Page. 8
ofDecember 18,1995
report]. This was especially apparent after large storm events resulted in greater test
organism toxicity, due to increased turbidity and CSO influences. In addition, the report
goes on to say that "(t)he effects observed at
35°C (referring to the greater study
mortalities at higher continual temperature exposures) likely do not occur in the
UIW
because organisms are not exposed to 35°C (95 OF) water for 7 day periods and no
effects were observed in 7 day exposures at
30°C (86 OF)." Our recent (2002) thermal
plume study data confirm that the higher temperatures, in fact, located closer to the
surface
ofthe river and cooler temperatures are found at greater depths in the waterway.
In
another section ofthe report, not cited by U.S. EPA, poorer survival oftest organisms
C.
dubia
and
H.
azteca
was observed in the sediment and site water treatments at cold
temperatures, as compared to controls. This suggests that colder temperatures increased
the adverse effects
of continual exposures when in the presence of other metal or organic
stressors occurring in the sample sites (Page 9
of December 18, 1995 report).
6

U.S. EPA appears to be focusing only on those portions ofthe Burton 1995 Report that
indicate potential thermal concerns. The Report as a whole ultimately suggests that there
are likely inherent toxicity issues
in the waterway which are not either directly linked to
or significantly influenced by
MWGen'sthermal discharges.
MWGen's power stations comply with all applicable thermal water quality standards,
which are, by regulatory definition, designed to be protective
ofthe indigenous fish
community.
As such, our contribution of heat to the waterway is not, in and of itself,
having a toxic effect. If, as the UIW studies have indicated, there is inherent toxicity in
both the sediments and/or overlying water column at certain locations at certain times,
depending on exposure time and concurrent temperature conditions at the sediment/water
interface, then it should not be
MWGen'scharge to further limit our discharges when
they are not directly or indirectly impacting toxicity. Since our thermal discharges are
surficial
in nature, higher temperature water does not come into direct contact with the
bottom sediments, and thus does not have an exacerbating effect on any toxic fractions in
the sediments.
U.S.
EPA Comment, Page 5, Habitat Modifications to Support Navigation:
The Agency states that MWGen does not demonstrate the extent to which barge traffic
impacts the aquatic community or the ways in which these impacts can be mitigated.
MWGen Response:
As we understand it, U.S. EPA does not disagree that barge traffic
is frequent and heavy on the lower Des Plaines River. Instead, Region 5 is asking for
more information on the effects
ofthat frequent and heavy traffic on the aquatic
community. Observation
ofthe response ofthe river to a passing barge tow shows a
dramatic change in the shoreline water level before and after passing a given point along
the channel. Tow boat props stir up sediments, which are then deposited either upstream
or downstream
oftheir point of origin--this can be seen in aerial photos, as well as by
general observation. The entire river channel is effected, to some extent, when a barge
tow passes. While temporary in nature, this disturbance is nonetheless a negative
influence on the biota which reside
in the waterway. Unfortunately, much ofthe
scientific study of barge traffic effects has focused on the potential impacts on overall
water quality by the passage
oftows, and not on the impacts to the aquatic community
which resides in the waterway. The physical forces
in play during a barge tow likely
have a significant impact on any organism who is trying to establish a "home" within
these zones
of frequent disturbance ofthe bottom sediments. MWGen has not studied
these effects, but common sense suggests that they do occur.
Furthermore, a recent study by USGS and the INHS has documented direct mortality
caused by towboats. Gutreuter et al (2003) found that various medium to large fish were
killed as a result
of propeller strikes in Pool 26 ofthe Mississippi River, as well as the
lower portion
ofthe Illinois River. They estimated that 790,000 gizzard shad were killed
in just this area as a result ofpropeller strikes. The number of fish killed was a function
ofthe number offish killed per kilometer times the amount of barge traffic (kilometers
traveled). On a large river such as the Mississippi, at least some fish will move away in
7

response to oncoming barge traffic. (Lowery 1987, Todd et aI1989). In a smaller,
narrower river like the Des Plaines, propeller avoidance would likely be more difficult, so
it is reasonable to assume that the mortality rate estimated for the Mississippi River will
at least be as high and may be higher
in the Des Plaines River. So, in addition to
detrimental effects due to re-suspension of sediment (contaminated and otherwise) and
localized changes in water levels, direct mortality to the aquatic community due to barge
traffic has now been established. This information will be incorporated into
MWGen's
revised thermal report.
In addition, the fact that the flow regime of the entire waterway is artificially controlled
also negatively impacts the aquatic community in various ways, as discussed in our report
on Page 13.
It
is our understanding that commercial navigation is a protected use under
Section 303(c)(2)(A) ofthe Clean Water Act 40 CFR 131.10(a) and therefore will remain
a factor limiting the overall potential ofthe aquatic community ofthe lower Des Plaines
River in the future. Since the waterway is controlled to accommodate commercial
navigation, the operation ofthe locks and dams, including flow/level control, as well as
impoundment, the protected, navigational impacts appear to satisfy both Factor 3 (Human
caused conditions), as well as Factor 4 (Dams, diversions and other types ofhydrologic
modifications)
ofthe UAA criteria to support an alternate use designation.
Based on our discussion, we understand that Illinois EPA will take the lead on
establishing a dialog with the U.S. Army Corps. of Engineers to determine whether
beneficial changes can be made to existing water control operations to enhance the
biological integrity
ofthe entire UAA study reach, with particular emphasis on the Upper
Dresden Pool. MWGen would also be benefited by the establishment of a more
predictable flow regime for the lower Des Plaines River, if this could realistically be
accomplished. We look forward to hearing the response
ofthe U.S. Army Corps at a
future UAA workgroup meeting.
U.S. EPA Comment, Page 5, mid-page: The Agency stated: "(R)egarding the habitat
limitations in the
UAA segment resulting from extensive modifications to the natural
waterway, U.S.
EPA states that the QHEI score cited in the MG report cannot be
considered definitive when it falls between two categories
ofuse such as the modified
warmwater and warmwater use classifications. The Brandon Pool is more characteristic
of a modifiedwarmwater stream while the Dresden Pool shares characteristic of both use
classes. When habitat scores fall between use designations a further analysis ofthe
system is required along with an investigation into the possibilities for remediation. No
information was provided that indicates that habitat alteration or other modifications
could not improve thehabitat."
MWGen Response: While using the Ohio use classification as a reference is useful, as
agreed to by the Biological Subcommittee, until Illinois develops its own sub-
classification system for its waterways, we are left with only General Use or Secondary
Contact classifications to which to compare QHEI scores. The QHEI scores for the
UAA waterway are all clearly well below what would be expected for a General Use
stream under the Illinois use classification system.
8

Modifications to the QHEI factors which could improve overall habitat should be
considered by Illinois
EPA and their consultants as part ofthe UAA analysis, but this is
not the charge of MWGen. On the whole, the individual QHEI metrics which are the
major contributors to degraded habitat quality are those that cannot be easily or
successfully mitigated, including flow alteration, sediment quality (not necessarily
contamination, but the consistency
ofthe sediments),. lack of riffle areas, little or no
sinuosity and poor riparian development.
As discussed at length during the meeting, EA Engineering, Science and Technology has
reviewed
the QHEI scores collected at 34 locations at 0.5 mile increments throughout
Dresden Pool in May, 2003 and determined that
poor habitat is pervasive throughout the
Pool. Provided below are
the 10 major components ofthe QHEI that contributed to the
low scores:
Factor
No. of Locations Affected (out of 34)
Poor Development (of riffles)
ALL
No Riffles
32
Current Speed None or Slow
32
Recent Channelization or Lack or
30
Recovery
No Sinuosity
23
Moderate to Heavy Silt
23
Extensive or Moderate/Extensive
19
Embeddness
Only Substrate Silt or Detritus
10
Poor
(~
6) Instream cover
8
Urban or Industrial Riparian Zone
6
Practically speaking, these factors either cannot be remediated (e.g. lack of sinuosity,
substrate only silt)
or the effort to remediate them, (e.g., the amount of instream cover)
would be unprecedented for a stream ofthis size.
In addition, EA has reviewed the observed habitat characteristics ofthe Brandon and
Upper Dresden Pools and has compared them to the published criteria for the Ohio use
designations
of Warm Water Habitat (WWH) and Modified Warm Water Habitat
(MWH) to provide the additional analysis that U.S. EPA had requested. The results of
this exercise are presented in the following table. As can be seen from this data, both the
Brandon and Upstream Dresden Pool areas share many ofthe characteristics of modified
warm water habitat streams, and except for depth, possess none ofthe characteristics
associated with warm
water habitat streams.
9

Comparison of warm water habitat (WWH) and modified warm water habitat
(MWH) characteristics
of the Des Plaines River.
Brandon Pool
Upper Dresden Pool
WWH Characteristics
No Channelization or
Recovered
Boulder, Cobble, Gravel
Substrates
Silt Free
Good-Excellent
Development
Moderate-HiQh Sinuosity
Cover Moderate to
Extensive
Fast currents & Eddies
Low/Normal Substrate
Embeddness
Max Depth> 40cm
X
X
Low/No Riffle embeddness
TotalWWH
1
1
Characteristics
MWH Characteristics with
High Influence
Recent Channelization
Silt/Muck Substrates
X
X
No Sinuosity
X
X
Sparse/No Cover
X
X
Total MWH (HiQh)
3
3
MMH Characteristics With
Moderate Influence
Recovering Channelization
X
X
High or Moderate Silt Over
Other Substrates
Sand Substance (Boat)
Fair/Poor Development
X
X
Low Sinuosity
Onlv 1-2 Cover Types
Intermittent or Interstitial
Max Depth < 40cm
High Embeddness of Riffle
X
X
Substrates
Lack of Fast Current
X
X
Total MWH (Moderate
4
4
Total MWH (All)
7
7
10

As U.S. EPA has already agreed that the Brandon Pool cannot meet General Use due to
unalterable physical/habitat alterations, MWGen believes that the above information
meets the test for UAA Factors 3 and 4 to qualify the Upper Dresden Pool for a use
designation other than General Use.
U.S.
EPA Comment, Page 5, Bottom: The Agency states that: "MG fails to
demonstrate that habitat, rather than temperature, is the primary factor limiting the
aquatic community.
MG presents data that show similarities between the fish community
above the I-55 Bridge (secondary contact), and below the I-55 Bridge (general use) to
illustrate that, since both segments have similar habitat, habitat rather than thermal
regime must be limiting the aquatic community. What MG fails to disclose is that the
segment below the bridge is subject to a thermal variance, allowing higher ambient
temperatures than permitted under Illinois' general use standards. Temperatures at this
location consistently remain at the upper levels of the temperature range. The most
probable explanation for the similarities in the fish community is the similarities in the
thermal regime." (emphasis added)
MWGen Comments: MWGen did not "fail to disclose" anything. There is no thermal
variance which covers the waterway downstream ofthe I-55 Bridge--that area is subject
to the General Use thermal limits. MWGen retains an alternate thermal standard (AS96-
10) which is only applicable at the I-55 Bridge location,
not any area downstream. This
alternate thermal standard is a set
of monthly/semi-monthly temperature limits which
vary on a seasonal basis, but are identical to the General Use numeric limits during both
the summer months (mid-May through September) and the winter months (January and
February). Moreover, during the remainder ofthe months (April through early May and
October- November), the monthly limits at I-55 are actually more stringent than General
Use numeric limits would allow.
As an example, in April, the General Use limits would
allow a maximum temperature of90 OF (with an allowable excursion up to 93 OP); the
alternate I-55 standard for April only goes up to 80 OF (with an allowable excursion up to
83 OF).
AS96-10 ALTERNATE THERMAL LIMITATIONS FOR THE I-55 BRIDGE:
Jan Feb Mar Apr 1-15 Apr 16-30 May 1-15 May 16-30 Ji.m 1-15 Jun 16-30 Jul
~
fum
Oct Nov Dec
of
60 60 65
73
80
85
90
90
91
91
91
90
85
75
65
These standards may be exceeded by no more than 3°F during 2% of the hours in the I2-month period ending
December 31, except that at no time shall Midwest Generation'splants cause the water temperature at the I-55 Bridge
to exceed 93°F.
11

March and December are the only months in which the Alternate I-55 Thermal Standards
allow a temperature
of 65 of when the corresponding General Use Thermal Standard for
the same time period is 60
of (with an allowable excursion ofup to 63 OF).
Winter Temperatures in the Lower Des Plaines River:
So far, no one involved in the UAA has addressed the winter temperature limit, which is
.of equal concern to MWGen as the summer temperature limit. There are periods during
the Winter and Spring when ambient river temperatures currently exceed the
corresponding General Use thermal water quality limit, largely due to the influences of
the MWRDGC'sStickney Treatment plant, which provides up to 100 % ofthe flow to
the waterway during the winter months. The temperature
ofthe Stickney outfall is
elevated from what would be found in a natural waterway during this time
ofyear, and as
a result, the entire system follows an altered thermal regime, regardless
of the input of
heat from MWGen'splants.
u.s. EPA Comment, Page 6, second para!!raph: The Agency questioned the validity
ofMWGen's selection ofRepresentative Important Species (RIS) for the lower Des
Plaines River and the analysis which showed that the biological community
is not
impacted by the thermal discharges. U.S. EPA believes that the species used in the RIS
should include species representing the potential biological community and should not be
dominated by those species that already exist in the system. The Agency believes that
there are a number
of cool water species that should be represented, including walleye,
other percids and esocids, since they are present in the Kankakee River and could
potentially migrate into the lower Des Plaines.
MWGen Response: U.S. EPA is correct that "potential" fish communities should be
considered. This
is why redhorse were included in MWGen'sRIS. However, the species
suggested by U.S. EPA are not appropriate representatives
ofthe potential fish
community. Not only is the Upper Dresden Pool near the edge
oftheir natural ranges,
but there is little or no habitat in the Brandon and Upper Dresden Pools to support them.
We do not disagree that northern pike and yellow perch (we assume that U.S. EPA is
referring to this species when they say "other percids") are cool water species. However,
both require clear, well-vegetated lakes, pools, or backwaters to thrive and particularly to
reproduce. Such areas are rare to nonexistent
in
these pools. Therefore, these species
will be limited naturally.
U.S. EPA implies that
if Upper Dresden Pool were assigned the General Use thermal
standard, then good northern pike and yellow perch populations would become
established based on recruits from the Kankakee River. Since, as shown during
EA's
recent habitat survey of the entire Dresden Pool, habitats upstream and downstream ofI-
55 are similar, it follows that these species should have been able to establish viable
populations
in lower Dresden Pool, which is already subject to the General Use thermal
standard. However, data collected over the past
nine years (See Table I, attached), show
that only one yellow perch and one northern pike have been collected from the General
Use portion of the pool. Since populations ofthese two species in lower Dresden Pool
12

are already protected by the General Use thermal standard, the only logical reason for
their extreme rarity in lower Dresden Pool
is lack ofproper habitat or other non-thermal
causes. Given that they are habitat limited, it follows that they should not be designated
as RIS. Both species are also rare in upper Marseilles Pool (See Table 2, attached). U.S.
EPA (1977) guidance supports
MWGen'sapproach that species at the edge oftheir range
should normally not be designated RIS. The U.S. EPA report stated (p. 36) that "[w]ide-
Ranging species at the extremes oftheir ranges would generally not be considered
acceptable as 'particularly vulnerable'or 'sensitive'representative species" though they
still could be considered important." Here, based not only on their peripheral nature but
also the obvious habitat limitations, the U.S. EPA guidance does not support their
inclusion in the RIS designation.
Walleye are more thermally
tolera~t
than yellow perch or northern pike and, as a result,
are more widely distributed in Illinois (Smith 1979). Thus, they were not excluded from
the MWGen RIS list based on being peripheral. However, like the two species just
discussed, they clearly are habitat limited. Most walleye populations spawn over clear
cobble or rubble areas, but some populations can spawn in flooded, well-vegetated
backwaters. However, except for a small portion
ofthe Brandon tailwaters, both habitat
types are rare in Dresden Pool. Examination
of data from Lower Dresden Pool and
Upper Marseilles Pool supports our contention that walleye are habitat limited. Nine
years of collecting fish has yielded only one walleye from the Lower Dresden Pool and
only one from the Upper Marseilles Pool (See Tables 1 and 2) despite the fact that
General Use thermal standards prevail in both areas. Thus, there is no reason to believe
that walleye would be any more successful
in the Upper Dresden Pool than the Lower
Dresden Pool.
If we compare catches ofwalleye with those of smallmouth bass, a species considered to
have similar thermal tolerance, or to redhorse, which are likely more thermally sensitive
(Reash et al 2000), it is equally clear that walleye numbers in these areas are constrained
by something other than temperature. For example, Lower Dresden Pool, which yielded
only one walleye, produced 477 smallmouth bass and
571 redhorse (all redhorse species
combined) during the same period (See Table 1), and upper Marseilles Pool, which also
yielded only one walleye, yielded 172 smallmouth bass and 348 redhorse. The only
possible interpretation
ofthis data is that walleye are habitat limited while the other two
species, which have roughly similar thermal requirements, are not. Given that it is
habitat limited, walleye is clearly not an appropriate RIS.
u.s. EPA Comment, last sentence of the 3rd paragraph:
"In addition, there are a
number
ofother critical temperatures related to gamete maturation, spawning, early lift
history survival, preference, avoidance, and optimum growth. "
MWGen Response: We interpret U.S. EPA'scomment to mean that there are other life
cycle endpoints to consider. We agree. However, we believe these have been addressed.
Not by comparison with laboratory - derived endpoints but rather by examining the large
biological data set that has been collected form this area, a more reliable, holistic and
ecologically meaningful exercise. Good populations will be maintained only
ifthere is
13

adequate early life history survival, successful spawning, etc. Our examination ofthe
long term data sets has indicated that those species tolerant ofthe broad set oflimiting
conditions that exist in the study area
(e.g.,
gizzard shad, most centrarchids , various
minnows, etc.) are doing quite well, whereas those that are more sensitive to these
limitations (e.g., redhorse and darters) are not. Thus, it
is factors other than temperature
(e.g.,
sedimentation, poor habitat, silty and/or contaminated sediments, etc.) that
determine and limit the Upper Dresden and Brandon fish communities. Temperature
plays a small and largely secondary role. In other words, there would be no significant
change
in these fish populations even if General Use thermal standards were applied to
the Upper Dresden and Brandon Pools.
U.S.
EPA Comment, Page 6, Fourth paragraph: The Agency states that temperature
affects dissolved oxygen levels in this system by depressing the saturation levels, which
has the effect
of exacerbating diurnal DO sags due to increased algal growth and
photosynthesis. The Agency also states that it is aware of other factors that may be
responsible for
some ofthe low DO's observed at the I-55 continuous monitoring station.
Region 5 is recommending that the QUAL2E model developed and calibrated by
MWRDGC be reevaluated and re-run with current conditions in the waterway;
MWGen Comments: If algal growth and photosynthesis is increased, then this would
also result
in super-saturation during the daylight
hours~
The DO measurements taken at
I-55 over the past 6 years show this to occur. DO sags are also common occurrences, but
do not normally drop down and remain at a level which would be biologically limiting.
Overall, the average DO in the waterway
is well above that needed to sustain the
indigenous biological community, as evidenced by both our continuous I-55 monitoring,
as well as measurements taken as part
of our long-term fisheries monitoring program.
These data continue to show more than adequate levels
ofDO at all ofthe sampling
locations in the lower Des Plaines River, including the immediate generating station
discharge canals, where water temperatures are the highest.
Use and/or manipulation
ofQUAL2E is not the responsibility of Midwest Generation.
MWRDGC
is already in the process ofhaving QUAL2E recalibrated by Marquette
University in order to make it a more dynamic, versus steady-state, model
ofthe
waterway. Since MWGen has several years
of continuous, in-stream temperature/DO
measurements near the I-55 Bridge, as well as frequent DO grabs throughout the lower
Des Plaines River, this real data should take precedence in making a determination on the
overall impact (or lack thereof)
ofwater temperature on the dissolved oxygen levels in
the waterway_ Our analysis ofthis data, as well as the fisheries monitoring results,
shows that there have been no adverse impacts on the indigenous aquatic community
of
the lower Des Plaines River from any hypothesized temperature-related effects on DO
levels.
u.s. EPA Comment, Page 6, Factor 4, last paragraph:
Dams, diversions or other types ofhydrologic modifications preclude attainment.
14

U.S. EPA does not agree that hydrologic modifications are sufficient to preclude
improvements
to the aquatic community. U.S. EPA believes that MWGen should
provide more information to support its claim that the hydrologic modifications
ofthe
lower Des Plaines River are limiting the aquatic community. "Consistent with Federal
regulations at 40
CFR 131.1 O(g), such a demonstration should also show that the
hydrologic modifications cannot be operated in such a manner as to mitigate the impacts
on the aquatic community.".
MWGen Response: The QHEI data provided to U.S. EPA and the UAA workgroup
clearly demonstrate the impact
of a hydrologically altered system on habitat
availability/quality. In addition, the nature
of the sediments in the system (fme, silty)
regardless
ofthe presence ofcontamination or not, is not conducive to those fish species
which require gravel/cobble substrates for successful spawning to occur.
The flow
regime is not that
of a natural waterway, and has large, localized fluctuations in level
below the Brandon
Lock and Dam that would be adverse to any nest-building species.
The velocity at which water is released from the lock and dam may also have negative
effects on the biota in the immediate vicinity
ofthe release.
As acknowledged
by U.S. EPA and well-established in the literature, dams reduce the
abundance and diversity
of riverine species. This is a result of interrupting or eliminating
migration, the pooling effect upstream
of each dam, the sediment that build up behind
dams, etc. The studies that U.S.
EPA conducted and/or sponsored on the Fox River
clearly demonstrate these impacts as shown by declines in IBI scores upstream
of each
dam. These adverse impacts are recognized by other Region 5 States. For example,
Wisconsin and Michigan are actively promoting dam removal. Ohio has a separate use
classification based on effects from dams. Species most effected are so-called fluvial
specialists (e.g., most darters, many suckers, etc.), whereas habitat generalists (e.g.,
common carp, gizzard shad, channel catfish), and pelagic species (e.g. emerald shiner,
freshwater drum) do quite well under impounded conditions. Similarly, simple
lithophiles (e.g., redhorse and most darters), which require clean, hard substrates, do
poorly in impounded situations because
of increased siltation while those that are nest
builders (e.g., centrarchids), or have modified spawning strategies (e.g., bluntnose
minnow) do quite well under the same set
of circumstances.
To ignore the impacts associated with hydraulic modifications is to disregard the
considerable body
ofresearch that has been collected during the past 20 years and the
precedents that have been established by other states, such as Ohio. Even the IEPA
Consultant'sDraft
UAA report acknowledged (pg 8-16) that expectations for Upper
Dresden Pool were lower because
ofhydraulic impacts and thus created the category
"General Use Impounded". Clearly, the biological expectations for such areas are
indeed lower than for "full" General Use. These conditions support either retention
of
the existing Secondary Contact use (or creating a new use that includes modified thermal
and other standards). There is nothing in the regulations which would require Secondary
Contact to retain the identical thermal limitations that it has now. These may be modified
in order to protect the current and expected assemblage
of aquatic life that would reside
15

in the Upper Dresden Pool, given the permanent constraints on the system under UAA
Factors 3, 4 and/or 5.
The system'shydraulic modifications are solely under the control ofMWRDGC and the
U.S. Army Corps
of Engineers, and are in place exclusively to accommodate flood
control and commercial navigation. As stated earlier, Illinois EPA has assumed the
responsibility to address this issue with the Corps.
u.s. EPA Comment, Page 7, First paragraph, Factor 5:
Physical conditions related to the naturalfeatures ofthe water body, such as lack of
proper substrate, cover, flow depth, preclude attainment ofuse.
U.S. EPA states that, "given the extensive modifications ofthis system, it is difficult to
attribute the habitat limitations to "natural features"
ofthe waterbody. Therefore, this
factor does not seem
to be relevant to the UAA for the lower Des Plaines River. In fact,
where the river does exhibit more "natural" features, the habitat resembles closely that
of
other waters that are classified as General Use."
MWGen Response: IfU.S. EPA agrees that the waterway's habitat limitations are the
result
ofthe fact that it is not a natural system, then such "permanent" alternations
(natural or manmade) should be considered equally in assessing whether the waterway
can support a higher use. Habitat
is defined by the existing and future anticipated
physical conditions
ofthe waterway, whether the result ofnatural or man-made
influences.
QHEI scores for the entire UAA reach are much lower than would be
expected for a General Use waterway. In fact, even the General Use waterway directly
downstream
ofI-55 has QHEI scores lower than what would be considered as General
Use. IBI scores in the entire Dresden Pool are also similar, and much below that
expected for a General Use Stream (see
MWGen's Thermal Report, pages 39-41, also
included in attachments). As stated earlier, this is not due to the input
of heat, since the
General Use thermal standards apply to this segment. The only logical explanation is that
the habitat
ofthe entire system (although it may appear, from the surface, to be more
"natural") still has inherent limitations which prevent it from sustaining more
sensitive/higher quality aquatic species.
Indeed, the results
ofthe recent pool-wide habitat assessment and the poor IBI scores
throughout Dresden pool suggest that,
if anything, it is lower Dresden pool that is
misclassified. Because
of poor habit conditions due to impounding and the other factors
discussed previously, the biological data supports a lowering
ofthe use classification of
lower Dresden Pool and does not support upgrading the use designation ofthe upper
Dresden Pool.
16

u.s. EPA Comment, Page 7, Second paragraph. Factor 6:
Controls more stringent than those required by Section 301(b)(1)(A) and (B) ofthe
Clean Water
Act would result in substantial and widespread economic and social
impact.
U.S. EPA states that no "extraordinary controls" would be required on point source
dischargers in the lower Des Plaines to improve chemical water quality in the lower Des
Plaines River. Therefore, "it seems unlikely that point source discharge(r)s would incur
any extraordinary costs to achieve the chemical water quality needed to support an
improved aquatic community."
MWGen Response: While this may be true ofmany ofthe more conventional chemical
pollutants, U.S.
EPA'sposition does not adequately consider the bacterial contamination
ofthe waterway Secondary Contact water quality limits currently have no fecal
coliform (or
e. coli) limit on dischargers. Imposition of General Use water quality
standards would require a bacterial limit, as well as a Total Residual Chlorine limit which
is very stringent. Effecting such control for a municipal or industrial discharger will
result
in considerable costs. In order to implement the disinfection process needed to
control the bacterial content
ofthe discharge, the amount of chlorine required would
certainly require dechlorination. These combined processes
(chlorination/dechlorination) would introduce additional contaminants into the waterway
(chloramines--bioaccumulative, bisulfite--a known oxygen scavenger, etc) which could
pose additional risks to the aquatic community. And
in the end, the result would be an
effluent which is likely
of higher quality than the receiving stream itself, due to the
continued presence of bacterial contamination from wildlife, runoff and CSO events.
The economic burden on the regulated community would
be significant, but the
environmental benefit would be negligible. The Upper Dresden Pool is unlikely to
become a sought-after primary contact recreational area, and bacterial contamination has
little impact on the indigenous aquatic community.
U.S.
EPA Comment, Page 7, Paragraph 3: The U.S. EPA identified the statement in
MWGen'sThermal Report that heat from the Will County generating plant is lost to the
atmosphere prior to it reaching the Brandon Pool portion ofthe UAA. U.S. EPA
contends that
ifthat were the case, this portion ofthe system would be meeting the
General Use standard.
MWGen Response: The wording in the MWGen report will be revised to clarify the
meaning. The heat from Will County Station'sthermal discharge
is gradually dissipated
to the atmosphere along the approximate five mile reach from the station to the Lockport
Lock, and receives further cooling as it mixes with the discharge from the Upper Des
Plaines River below Lockport. We did not intend to imply that the added heat was
completely lost before reaching the Brandon Lock and Dam. The revised report will
reflect this clarification.
17

The intake temperatures at Will County Station often meet or exceed the General Use
thermal limits, especially during the winter months, so even
ifthe heat discharged by the
station were to fully dissipate by the time it reaches Brandon Road Lock and Dam
(which, in most cases, it does not), the ambient temperature in the waterway is already
close to
or over the applicable General Use thermal limit before it reaches Joliet Station.
The temperature regime ofthe entire waterway is strongly influenced by the discharge
from the MWRDGC Stickney plant, which contributes up to 100% ofthe entire flow in
the waterway during the winter months (per conversation with Dick Lanyon,
MWRDGC). This factor must be taken into consideration regarding future seasonal
temperature limits for the waterway, especially for winter conditions.
u.s. EPA Comment, Page 7, Paragraph 4, Factor 6:
Controls more stringent than those required by Section 301(b)(1)(A) and (B) ofthe
Clean Water
Act would result in substantial and widespread economic and social
impact.
U.S. EPA states that MWGen does not provide the economic data necessary to
demonstrate that providing additional cooling at its facilities will result in substantial and
widespread social and economic impacts. In addition, the cost that has been expended
by society to improve the water quality ofthis system must be factored into this analysis.
MWGen Response: MWGen did not provide economic data for the installation of
additional cooling capacity for our facilities because the information in our report
demonstrated that other
UAA factors were applicable to the waterway, such that a full
socio-economic impact study was not necessary. We have agreed to provide Illinois EPA
with the cost information that will be necessary for them to fully consider the cost/benefit
ofthe imposition ofmore stringent standards, and will provide additional
biological/habitat data that will allow Illinois EPA to make an informed decision
regarding the overall environmental benefit to be attained by the imposition
ofmore
stringent thermal limits on the lower Des Plaines River.
It is unclear what costs the U.S. EPA is including by its reference to the cost borne by
"society" to improve water quality. Accordingly, we are unable to respond to this
comment. However, it is also questionable whether this comment is relevant to or
supported by the language ofthe UAA regulation concerning the review of social and
economic impacts caused by the proposed use upgrade.
u.s.
EPA Comment, Page 7, Paragraph 5: The Agency has reviewed MWGen's
current operation ofthe Joliet #29 cooling towers and assumes that it would be possible
to operate them when discharge temperatures are less than low-to mid 90
0
F to
accommodate seasonal temperature needs. In terms
of space, it was noted that there
appears to be space adjacent to Joliet 9 and there may be space that can be purchased.
u.S. EPA references the effectiveness ofthe cooling towers at Joliet 29 and assumes that
temperatures consistent with more protective thermal criteria could be achieved.
18

MWGen Response: Current operation ofthe cooling towers is geared towards
remaining in compliance with both the near-field (Secondary Contact) and far-field (I-55)
temperature standards. The towers are normally turned on when the circulating water
discharge temperature exceeds
93 of for an extended period oftime. The towers do not
operate as efficiently when the inlet to the towers (e.g. the circulating water discharge
temperature) is less than 90
°
F, so it cannot be assumed that simply by turning them on
sooner, or running them for a longer period oftime, that this would allow a lower near-
field temperature limit to be met. (i.e. tower efficiency
is not a constant). Seasonality
also has a significant impact on tower operation, since the towers are not currently
designed to operate during the cooler times
ofthe year. They do not have plume
abatement controls, which means that significant fogging/icing could be expected during
winter operation to meet a more stringent near-field limit, should
it even be technically
feasible to do so. Such fogging is a major concern, due to the proximity
of both a major
interstate highway,
as well as a small municipal airport. Installation of plume abatement
technology can also easily double the overall cost
of any supplemental cooling system.
U.S.
EPA's solution to MWGen'scurrent space constraints for additional cooling towers
is very simplistic. We agree that there is some space available on the Joliet 9 side ofthe
river for some towers, however, Joliet 9 does not have the same thermal effect on the
waterway as the larger Joliet 29 does. Even
iftowers were installed at Joliet 9, they
would only serve to control Joliet
9's discharge, and would do nothing for Joliet 29's
near-field compliance.
Space constraints at Joliet 29 were the primary focus ofthe
statements made in MWGen'sreport. Purchasing additional property on which to build
towers, even
if it were available (which is doubtful) would place them at a significant
distance from the site, which would involve additional piping, pumping and electrical
hook-ups to route the cooling water through them and back to the river. Installation
of
supplemental cooling when there is evidence of a significant detrimental effect ofthe
thermal discharge on the indigenous aquatic community, or
if a facility cannot comply
with currently applicable thermal limits, may be warranted, but without such evidence or
supporting data, the need for, and any environmental benefit to be derived from, such
measures is questionable.
u.s. EPA Comment, Page 7, Bottom: U.S. EPA'sposition is that MWGen has not
demonstrated that any ofthe six factors listed in the Federal regulations at 40 CFR
101.10(g) prevent improvements to the aquatic community in the lower Des Plaines
River regardless
ofthe thermal impacts resulting from MWGen's generating facilities.
(emphasis added).
MWGen Response: U.S. EPA admits, on page
7 ,
first paragraph oftheir comment
letter, that there have been "extensive modifications
ofthis system", yet it disregards
these modifications and assumes that thermal effects are a primary cause ofthe limited
aquatic community in the waterway. However, even in the draft UAA report, several
chapters come to the conclusion that one or more
ofthe
6
factors are met in the
waterway, thus allowing for consideration
ofa less than full General Use designation.
The fact that these individual chapter conclusions are not incorporated into the final UAA
summary
is problematic.
19

We hope that
this~summary
has provided you with detailed information and clarifications
regarding the issues raised in your June 3, 2003 letter and subsequently discussed on
August
6, 2003. We will revise our draft report to be consistent with the changes
indicated herein and forward it for review by Illinois EPA and the UAA Biological
Subcommittee:
MWGen maintains that UAA Factors 3, 4 and 5 are applicable to the Upper Dresden
Pool, which prevent it from being able to meet full General Use criteria. As such,
we
would be glad to work with Illinois EPA to develop appropriate temperature limitations
for this river reach, under either the existing use designation (Secondary Contact) or
under a new use designation which will reflect both the improvements and the inherent
limitations
ofthe lower Des Plaines River which prevent it from being able to support a
balanced, indigenous aquatic community.
Please contact Julia Wozniak or myself
ifyou have any questions or comments regarding
this matter.
Sincerely,
Basil G. Constantelos
Director, Environmental Health and Safety
cc:
Ed Hammer--U.S. EPA Region 5
Toby Frevert--IIIinois EPA
Attachments: Tables 1 and 2
MWGen Thermal Report Figures 4, 5 and 6
20

APPROPRIATE THERMAL WATER QUALITY STANDARDS
FOR THE LOWER DES PLAINES RIVER
Summary Report
Prepared by Midwest Generation and EA Engineering, Science and Technology, Inc.
October 13,2003 Revision
Table of Contents
Section
Page No.
I.
INTRODUCTION................................................................................
f
A. UAA Regulatory Overview
.
B. Application ofthe UAA Factors to Assess Chemical,
Biological and Physical Characteristics
ofthe Lower
Des Plaines River............................................................................ 2
II.
BACKGROUND................................................................................... 4
III.
HISTORY OF THE WATERWAy
4
A.
Power Plants
in
the UAA Reach...........................
5
IV.
CURRENT UAA REACH USE DESIGNATION AND
THERMAL WATER QUALITY STANDARDS
10
A. Thermal Water Quality Standards
10
1. Secondary Contact.....
10
2. General Use.......................................................................... 11"
3. Alternate Thermal Standard for I-55
11
V.
THE RELATIONSHIP BETWEEN THE ADJUSTED
THERMAL STANDARD AT I-55 AND THE UAA
FOR THE LOWER DES PLAINES RIVER.
12
VI.
CURRENT THERMAL COMPLIANCE STATUS
14
VII.
PHYSICALIHYDRAULIC/CHEMICAL NATURE
OF THE SySTEM
14
A.
BriefDescription ofthe Pools Comprising the
Upper Illinois Waterway
14

APPROPRIATE THERMAL WATER QUALITY STANDARDS
FOR THE LOWER DES PLAINES RIVER
Summary Report
Prepared
by Midwest Generation and EA Engineering, Science and Technology, Inc.
October 13, 2003 Revision
Table of Contents
Section
B.
C.
D.
E.
F.
Page No.
Effects
of Artificial Flow Control and Barge Traffic
15
Pollutant Loadings to the UAA Reach
17
Extent and Physical Characteristics of Sediments
in the
UIW
17
Effect
of Temperature on Contaminated Sediments
21
Physical Habitats
21
1. Types and Availability ofPhysical Habitats
21
2. Physical Habitat Quality
22
G.
Limitations
ofthe Illinois Use Classification System
26
VIII.
POWER PLANT EFFECTS ON THE WATERWA
Y.
30
A. Effects
of Power Plants on Physical Habitat..
30
B. Water Temperature Regime
30
C. Longitudinal Temperature Distributions
31
D. Non.,.Summer Water Temperatures in the
Lower Des Plaines River.
31
E. Lack of Thermal Effects on Phytoplankton and
Zooplankton
32
F.
No Adverse Effects on Macrophytes
33
G.
No Adverse Effects on Benthic Macroinvertebrates
33
ii

APPROPRIATE THERMAL WATER QUALITY STANDARDS
FOR THE LOWER DES PLAINES RIVER
Summary Report
Prepared
by Midwest Generation and EA Engineering, Science and Technology, Inc.
October 13,2003 Revision
Table of Contents
Section
Page No.
H. Effect on Fisheries
34
I.
Temperature Effects on Dissolved Oxygen Levels
36
IX.
UNIQUENESS OF THE WATERWAY.
37
X.
CURRENT MONITORING STUDIES OF THE UAA REACH
38
XI.
ESTABLISHING PROTECTIVE THERMAL LIMITS FOR THE
BRANDON POOL AND THE UPPER DRESDEN POOL.
39
A.
Temperature is a Unique Constituent...
39
B.
Brandon Pool Current Conditions
40
C.
DresdenPool.
40
D.
Justification for Selection
ofRepresentative Important
Species (RIS)
41
E.
Temperature Tolerance ofRIS
43
F.
Is a Balanced, Indigenous Aquatic Community Present?
44
G.
Are the Secondary Thermal Limits the Cause ofthe
Lack
of Balance?
44
H..
Would the Dresden Pool Aquatic Biota Improve
Significantly
if General Use WQS Were Applied and
Would a BIC be Achieved?
46
iii

APPROPRIATE THERMAL WATER QUALITY STANDARDS
FOR THE LOWER DES PLAINES RIVER
Summary Report
Prepared
by Midwest Generation and EA Engineering, Science and Technology, Inc.
October 13,2003 Revision
Table
of Contents
Section
Page No.
XII.
COST/BENEFIT ISSUES
60
A.
Compliance with General Use Thermal
Water Quality Limits
60
B.
Costs Associated with Technological Controls and/or
Operating Restrictions to Meet More Stringent
Thermal Water Quality Standards
60
XIII. CURRENT AND FUTURE OPERATIONAL
CONSIDERATIONS
61
A.
SEASONALITY OF PEAK POWER PRODUCTION
61
B.
USE OF EXISTING COOLING TOWERS
61
C.
CURRENT PLANT DERATINGS
62
D.
FUTURE COMPLIANCE ALTERNATIVES
62
XIV. TEMPERATURE LIMIT PROPOSAL FOR
THE BRANDON POOL
64
XV.
TEMPERATURE LIMIT PROPOSAL FOR THE
UPPER DRESDEN POOL
64
Modified Thermal Limits for the Upper Dresden PooL
65
XVI. SUMMARY AND CONCLUSIONS
68
IV

APPROPRIATE THERMAL WATER QUALITY STANDARDS
FOR THE
LOWER DES PLAINES RIVER
Summary Report
Prepared
by Midwest Generation and EA Engineering, Science and Technology, Inc.
October 13, 2003 Revision
Table
of Contents
Figures
Figure
1:
Figure 2:
Figure 3:
Figure 4:
Figure 5:
Figure 6:
Page No.
Map
of Upper Illinois Waterway, Including UAA Reach
6
Upper Illinois Waterway Mean IBI Scores, 2001..
55
Upper Illinois Waterway Mean IBI Scores, 2000
56
Mean IBI Scores Within the Upstream and Downstream
I-55 Segments, 1999
57
Mean IBI Scores Within the Upstream and Downstream
I-55 Segments, 2000
58
Mean IBI Scores Within the Upstream and Downstream
I-55 Segments, 2001
59
v

APPROPRIATE THERMAL WATER QUALITY STANDARDS
FOR THE LOWER DES PLAINES RIVER
Summary Report
Prepared
by Midwest Generation and EA Engineering, Science and Technology, Inc.
October 13, 2003 Revision
Table of Contents
Tables
Table
1:
Table lA
Table IB
Table lC
Table ID
Table IE
Table IF
Table 2:
Table 3:
Table 4:
Table
5:
Page No.
Listing
of Current Water Quality Limitations In Effect for
the Lower Des Plaines River
7
Des Plaines River QHEI Scores,
21 May 2003
23
QHEI Scores at Off-Channel Locations
23
Dresden Pool Individual QHEI Factors--May 2003
24
Comparison
of warm water habitat (WWH) and
modified warm water habitat (MWH) characteristics
ofthe Des Plaines River
25
Number, CPE (No./km), and Relative Abundance
of all Fish
Taxa Collected Electrofishing From
Lower Dresden Pool for
the Period
of 1994-2002
47
Number, CPE (No./km), and Relative Abundance
of all Fish
Taxa Collected Electrofishing Downstream
ofDresden
Lock and Dam for the Period
of 1994, 1995, and 1999-2002..... 49
Upper Thermal Temperatures
ofVarious Des Plaines River
Representative Important Species (RIS)
51
Comparison ofRIS Catch Rates (No/km) Upstream and
Downstream
of I-55
53
Kankakee, Illinois and Des Plaines River Catch Rates
of
Redhorse (all species combined) Collected by Electrofishing.... 54
Proposed Modified Thermal Limits for the
Upper Dresden Pool.
67
.vi

APPROPRIATE THERMAL WATER QUALITY STANDARDS
FOR THE LOWER DES PLAINES RIVER
Summary Report
Prepared by Midwest Generation and EA Engineering, Science and Technology, Inc.
October 13,2003 Revision
Table of Contents
Appendices
Page No.
Appendix I: Use Attainability Analysis (UAA) Factors
73
Appendix 2: Executive Summary ofUIW Study, Results
and Conclusions
76
Appendix 3: List of Individual Biological, Chemical and Physical
Study Reports Associated with the Upper Illinois
Waterway, 1990 to present..
79
Appendix 4: Joliet Station Near-Field Compliance
ModeL
82
Citations and References
85
vii

(Letter from MWRDGC)
November 7,2001
Mr. Neal O'Reilly
Hey and Associates, Incorporated
240 Regency Court, Suite
301
Brookfield, WI 53045
Dear
Mr. O'Reilly:
Subject: Draft Report -
Preliminary Water Body Assessment: Chemical Integrity of
the Lower
Des
Plaines River
The
draft report prepared for the illinois Environmental Protection Agency (IEPA) by
Aq-
uaNova International and Hey and Associates has been reviewed by the Metropolitan Water Reclama-
tion District
of Greater Chicago (MWRDGC). We are providing the following comments and questions
concerning the subject report. The numbering that
follows corresponds directly to the pages referenced
in the subject report.
The subject report should include a Table
of Contents and List ofFigures and Tables.
PAGEi
Paragraph 1. The subject report should also include an analysis ofthe current \Vater
quality conditions as compared
to
Secondary Contact water quality standards. This
analysis will be needed
in a petition to the illinois Pollution Control Board (!PCB) if
IEPA intends to change the designated use of Secondary Contact and Indigenous
Aquatic Life Waters. Therefore, we believe that the report should
include an analysis to
determine
if
water quality is meeting the current water quality standards for Secondary
Contact waters.
Paragraph
2. Insert the word "Island" following the word "Dresden."
PAGE
ii
Paragraph 1. Insert a semicolon following the word "agencies." Insert period fonowing
"USGS." Delete the letter "s" in the word "Generations." Explain why was water quality
data provided by Commonwealth Edison and Midwest Generation not used in the pre-
liminary
.
analy
SIS.
.
?

Table. The subject table should be numbered Table 1. The following information con-
cerning a description of the waterbody and the location should be added to the subject
table.
91
Des Plaines River, upstream of
Material Service Access Road near
Brandon Road Pool
Lockport Power House
92
Chicago Sanitary and Ship Ca-
Lockport Power House Forebay
nal, Lockport Pool
93
Des Plaines River, Brandon
Jefferson Street Bridge, Joliet
Road Pool
94
Des Plaines River, Dresden Is-
Empress Casino Dock
land Pool
95
Des Plaines River, Dresden Is-
Interstate 55 Bridges
land Pool
G-11
Des Plaines River, upstream of
Division Street Bridge, near Lockport
Brandon Road Pool
PowerHouse
GI-02
Chicago Sanitary and Ship Ca-
Lockport Power House Forebay
nal, Lockport Pool
G-23
Des Plaines River, Brandon
Ruby Street Bridge, Route 53, Joliet
Road Pool
G-39
Des Plaines River, upstream of
Barry Point Road, Riverside
Brandon Road Pool
F-02
Kankakee River
Route 17 Bridge, Momence
Probabilistic analysis of the water quality data. This section should
first
discuss the ra-
tionale for using probabilistic analysis for setting water quality standards. Supply a ref-
erence for the defined "ideal" standard shown in italics.
On one hand the report advocates the use ofprobability.ofnon-exceedance for toxic
pollutants, or 99.8 percent, and on the other hand advocates "scientific judgement" for
compliance of nontoxic pollutants with a probability ofnon-exceedance in the range of
90 to 99.8 percent. It should be explained ifthis approach is approved and/or en-
dorsed by the IEPA, if this approach has been acceptable to the IPCB in past rulemak-
ings and if this approach approved or used by other state regulatory agencies.
PAGE
iii
Paragraph 1. Define CCc.
Table 1. MWRDGC station 83 should be 93. Define CMC and CCC for ammonia.
The table should also include the results ofan analysis for compliance with Secondary
Contact water quality standards.

PAGEiv
Paragraph 1. Explain the application of scientific judgement and supply references as
appropriate.
Paragraph 2. Delete the words "For these parameters" and replace with "For the pa-
rameters in Table 1." The antidegradation statement was not correctly applied unless a
comparison with the Secondary Contact standards,
not General Use standards, was in-
tended. Perhaps the antidegradation statement should be deleted from the subject re-
port,
.as it is irrelevant. The statement suggesting that most metals should be deleted
from the current 303(d) list for Illinois should not
be included in the subject report be-
cause this is not a report on use impairment We recognize that a reassessment of the
IEPA 303(d)
list
for this study reach was included in the scope of work, but you have
not included a complete reassessment to support the statement regarding removal.
IEPA staffmakes 303(d) listing determinations based on an independent analysis fol-
lowing defined agency procedures. A similar approach must be used for this reassess-
ment.
Paragraph
3. The sentence is incomplete.
Paragraph
5.
Nutrients.
The Nitrate-N drinking water limit is 10
mgIL.
The Nitrate
standard is 45
mgIL.
Paragraph 6.
Siltation and habitat alteration.
Explain what is meant by "...and po-
tential for the Des Plaines River."
PAGE v
Table 2. Capitalize the
first
letter of the
first
word in the table (parameters). IdentifY the
monitoring stations that are included
in the subject report. MWRD Stations #91 and
#92 should not be included in the analysis because these stations are not in the study .
reach of the lower Des Plaines River. The number and percent ofvalues exceeding the
standard should be included
in the subject table. Define "Threatened at all" for water
temperature. The discussion concerning water temperature observations in footnote 2
should be deleted because it is not relevant to the issue. Explain what is a "possible
trend to exceedance. Define Tier I and Tier II analyses. A second table should
be
prepared showing the water quality parameters that meet the Secondary Contact stan-
dards as this will
be needed in the IPCB petition.
PAGEl
Paragraph 1. Regarding the purpose ofthe subject report, see comment above for
page
i. The criteria and process for determining when a water quality parameter is not

in compliance for a designated use, or its potential to meet a standard for a higher use
designation should be fully explained here or elsewhere
in the report. Explain what
conditions are assumed in determining
if
there is a threat to meeting water quality in the
future.
MWRD should be MWRDGC throughout the report. Delete "s" in the word
Generation.
Paragraph 2. "Chicago Ship and Sanitary Canal" should read Chicago Sanitary and
Ship Canal.
Paragraph
3. The contribution of "approximately 80 percent of flow" was determined
by comparing USGS flow data for the Riverside and Romeoville USGS gauges. The
reference "(Polls, personal communication)" is not correct. The 80 percent was in a
MWRDGC work product prepared for this UAA.
It
is recommended that the flow
comparison
be checked and the USGS be referenced.
It
is stated, "The river upstream
from the Chicago Sanitary and Ship Canal has been classified as fair." Provide a refer-
ence for this statement.
How was the term "fair" determined? Is this relevant? Fair is
not a classification established
by the IPCB. The Des Plaines River also receives
treated effluent from several POTWs, combined sewer overflows and agricultural drain-
age.
PAGE 2
Figure I does not clearly identify the Lower Des Plaines River reach. Highlight it
clearly. Also, it does not define the Lower Des Plaines River watershed or all
of the
Chicago Sanitary and Ship Canal as the title implies.
PAGE 3
Paragraph 1. The reach is not natural and the shorelines are not natural. The reach
has
been modified for navigation, meanders have been cut-offand the shoreline
is
eroded
by wave action caused by navigation. Water depths are artificially controlled. Any
perceived resemblance to a natural river is a misinterpretation
ofreality.
Paragraph 2. Delete the words "the Tunnel and Reservoir Project (TARP)" and replace
with the words "combined sewers." The sentence "Consequently, the environmental
potential
ofthe river..." is very subjective and should be deleted from the subject report.
Despite the name "Des Plaines River," the study reach is a drainage and navigation canal
identified
by the federal government as the illinois Waterway. See 33 CFR 207.300
and 207.425.
Paragraph 3.
It
is stated, "The Des Plaines River contnbutes about 41 percent of the
nutrients to the illinois River." Specify, which nutrients are included and provide a refer-
ence for this statement.

Paragraph 4. Regarding the reference to the current 303(d) list, see comment above for
page iv, paragraph 2.
Paragraph 5.
ill
the first sentence, delete "water" and replace with "effluent" and add
''NorthSide" following "Stickney."
DIy weather flows do not flow into TARP. The
words "lesser use" should
be deleted. Secondary Contact is the current water use
promulgated
by the IPCB. Water supply is not included in Secondary Contact uses.
The last sentence should be changed to read "Wastewater discharges and drainage are
other
de facto uses."
Paragraph 6 continuing
on to page 4. We believe that this paragraph needs to be re-
written to properly characterize the statutory and regulatory framework. The following
is suggested. "The IEPA is attempting to determine the potential to achieve and main-
tain higher valued uses, such as, a diverse
and balanced self-supporting aquatic commu-
nity and primary contact recreation, consistent with the goals and objectives
of the
Clean
Water Act (CWA) and the intent ofthe lllinois General Use Water classification.
The
CWA at 33 USC Sec. 1251(a)(2) sets forth the "...national goal that wherever at-
tainable
...water quality...provides for the protection and propagation offish...and
wildlife and provides for recreation in and on the water be achieved by July I, 1983."
Designated
as a Secondary Contact Water since the I 970s, the lower Des Plaines
River does
not meet this goal. However, the purpose of water quality standards, as de-
fined
at 40 CFR Part 131.2, is to achieve the aforementioned goal. Consequently, the
USEPA Region 5 his requested the IEPA to re-examine the SCW use classification. A
UAA, as defined at 40 CFR Part 131.3(g) ".. .is a structured scientific assessment of
the factors affecting the attainment of the use... " Further, in compliance with 40 CFR
Part 131.1 OG)(l), the IEPA is performing this UAA because the Secondary Contact
and
fudigenous Aquatic Life Waters classification does not include the uses set forth in
the national goal cited above. U
AAs are also to be used per 40 CFR Part 131.10(g),
when a state wishes to remove a designated use, which is not an existing use,
or to es-
tablish sub-categories
of a use if it can be demonstrated that attaining the designated use
is not feasible for six specific factors. The
UAA will identify the conditions necessary
for the higher valued uses and test the feasibility
ofthese conditions against the six spe-
cific factors identified
in Box 1."
Box I. Number each of the six reasons and make the language identical to the regula-
tion. All
six
reasons are required for this UAA per 40 CFR 131.1
OU).
Change the
parenthetical reference
to 40 CFR Part 131.1 o(g). The last line ofthe last reason in the
box includes a statement indicating that a TMDL
is
required. We disagree. A TMDL
is not required because of a use designation, but when uses are found to be impaired.

PAGES
Paragraph 1. 1bis language is not consistent with the regulation. A UAA is not re-
quired to upgrade a use designation. Please revise. Further, it should be qualified that
the document in footnote 1 is not a USEPA publication and the USEPA has not ap-
proved this definition ofa UAA.
Paragraph 3. Delete the words ''harmfulsubstance must have," and replace with the
"pollutant has."
PAGE 6
Define BMPs, WAC,
PIP
and PINP in the figure.
PAGE 9
Paragraph 1. 1/(355
x
3) should read as 1/(365 x 3). A frequency of once in three
years ofallowable excursions is used to calculate the probability of compliance. Explain
the accepted practice, the practices used in other states and what is acceptable to
USEPA, ifknown. Explain why this approach was chosen.
Paragraph 2.
It
is stated in the subject report, "For a first cut assessment, the 99.4 per-
centile will be used..." Why was a 99.4 percentile selected? The percentile should be
99.3, according to the USEPA interim guidance document mentioned. Give the
co~
plete citation for
this
document
PAGE 10
Table 1. Do early fish life stages require both a seven-day mean dissolved oxygen
(DO) concentration of 6.0 mgIL and a one-day nllnimum value of 5.0
mgIL?
PAGE 14
Near the top of the page, it is stated in bold italics, "In this UAA study it is assumed that
the criteria for salmonid fish absent is appliCable." Please state this in a less awkward
fashion to indicate what fish are present and the criteria is applicable.
At the middle ofthe page it
is
stated in bold, "In this UAA Study it
will
be assumed that
early life forms are present" Provide justification for this assumption for each segment
ofthe reach above and below the Brandon Road Lock and Dam given the physical set-
ting and current use ofeach segment. Also include the aquatic species and ifthey are
indigenous to Secondary Contact waters or are aquatic life typical of General Use wa-
ters.

PAGElS
Use the correct the name ofthe Brandon Road Lock and Dam.
Explain why WER values compiled by USEPA may not be applicable
to
the Des
Plaines River segments. Recommend the development ofWERs for the Des Plaines
River segments before water quality standards are established or a use designation is
recommended.
. Last
Paragraph. The ligands that immobilize metals also include sulfides.
PAGEl6
Paragraph 1. As mentioned and explained above, an analysis to determine compliance
with Secondary Contact water quality standards should be included in the subject re-
port.
Table 3. Subscript I should read "sampled weekly" not monthly.
PAGE 17
Paragraph 1. No reference station for the lower Des Plaines River
has
been agreed to
by the UAA workgroup. The report should provide a comparison of the Kankakee
River and watershed with the lower Des Plaines River and watershed
to
document the
differences or similarities. A reference location is not necessary when existing chemical
water quality standards and criteria are available.
PAGElS
As explained above delete the use ofa reference site and use the evaluation oflower
Des Plaines River water quality based on existing criteria and standards.
PAGE 23
Paragraph 2. The UAA is a scientific assessment and use of the tenn "eyeball estimate"
is not good science. As stated previously, please supply documentation that the prob-
abilistic approach has been endorsed for regulatory proceedings.
PAGE 24
Paragraph 2. Toxic chemical concentrations should also be compared to Secondary
Contact water quality standards.

PAGE 25
Paragraph 2. Tables should beprepared that show the chemical parameters that meet
and do not meet the Secondary Contact water quality standards.
PAGE 27
Paragraph 1. As explained above, the statement suggesting that toxic metals and
am-
monia should be removed from the current 303(d) list for Illinois should not be included
in the subject report. The antidegradation statement was not correctly applied and
should be deleted from the subject report. The comparison should also be for the Sec-
ondary Contact standards, as well as General
Use standards.
PAGE 28
Paragraph 1. Describe which analyses are included in Tier II.
Table 6. Delete the words "or Threatened" from the title
ofthe table.
Do
measured
copper concentrations above the General
Use standard occur at all five MWRDGC
monitoring stations or just at the stations
in the lower Des Plaines River? Is fecal coli-
form and water temperature above the General Use standard at all monitoring stations?
Which monitoring stations are included in the analysis? The number and percent
ofval-
ues exceeding the General Use water quality standards should be included in the subject
table. A table should be prepared showing the parameters that do not meet the Secon-
dary Contact water quality standards.
Paragraph 2.
Why is MWRDGC monitoring station 92 included in the analysis? The
station is not on the Des Plaines River or in the study reach. Were any measured con-
centrations above the chronic copper standard?
PAGE 29
Paragraph 1. The mercury standard in the subject report is not the current General Use
standard,
but a proposed standard. The reference site location should be deleted from
the subject report as explained above.
Last paragraph. Is it being suggested that the Kankakee River
be downgraded to a
Secondary Contact water?
PAGE 30
Paragraph 1.
It
is stated that 00 in the lower Des Plaines River falls frequently below
the General
Use standard. The adverb should precede the verb. Cite the results for
Brandon Road and Dresden Island navigational pools separately.

Paragraph 2. The reference site, IEPA GI-02 and MWRDGC 92 should be deleted
from the subject report because they are outside the study reach. The analysis should
only include stations on
the lower Des Plaines River.
PAGE 31
Paragraph 2. As explained above, the reference site, IEPA GI-02 and MWRDGC 92
should be deleted from the subject report.
Paragraph
5, subparagraph 1. The antidegradation statement was not correctly applied
and should
be deleted from the subject report. The comparison should be for the Sec-
ondary Contact standards, not General Use. Identify the threatened parameters and
explain why they are threatened.
PAGE 32
Paragraph 5. Why was a trend analysis performed? Provide the methodology used to
perform the trend analysis and a reference for the statistical trend analysis. Did the team
review sampling and analytical methods and trends
in river discharge since 1978 to de-
termine the impact
of these factors on the water quality trend(s).
PAGE 33
Table 7. Define the +, -, x, weak trend, significant decrease, and significant decrease in
the table.
PAGE 34
Paragraph 1. Identify the water quality parameters that currently meet the Secondary
Contact standards. The statement regarding removing water quality parameters
from the
current 303(d) list should be deleted from the report as explained above.
PAGE 35
Paragraph 1.
It
is stated, "However, there is a potential link to the oxygen depletion... "
How will
the water temperature effects be estimated concurrently with DO? Figure 9
relates
to the discussion ofTMDLs on page 34, therefore Figure 9 should also be de-
leted
as explained above.

PAGE 36
Paragraph 1.
It
is stated, "The lllinois General Use standard has been exceeded by a
great margin." Please explain this in scientific
term;. Are the DO exceedances through-
out the lower Des Plaines River? What
is the range of exceedances? The comparison
against the reference stream
is not appropriate and should be deleted from the subject
report as explained above. Why consider potential improvement in DO in the lower
Des Plaines River only by supplemental aeration? Other
teclmologies should also be in-
vestigated and alternatives should be compared on a benefit-cost ratio basis.
PAGE 37
Option 3, Paragraph 2. The information on Option 3 referenced from the 1994 Water
Quality Standards Handbook
is not current. New information concerning physical habi-
tat factors to be considered in determining whether a waterbody should be used for
primary contact is described in the 1998 USEPA'sANPRM proposed regulation.
Option
3, Paragraph 4. All six factors described on page 4 of the subject report should
be considered in the UAA
for determining ifprimary contact is an attainable water use
for the lower Des Plaines River.
By copy
of this letter, Mr. Frevert is requested to advise the MWRDGC ifwe have misinter-
preted
the IEPA's intent in conducting the UAA and/or the scope of work.
If
you should have any questions concerning the MWRDGC's comments, please contact Mr.
Irwin Polls at (708) 588-4219.
Very truly yours,
Richard Lanyon
Director
Research
and Development
RL:js
cc: Frevert (IEPA)/KolliasffataiSawyerlPolls

MEMORANDUM

Back to top


Response to Comments, Chapter 5
TO:
FROM:
DATE:
Neal O'Reilly
Mike Mischuk
November 16, 2003
Page 5-7: It is stated that the taxa richness for artificial samplers increased between the
Lockport
and Brandon Road navigational pools. Include in
l
the report numeric data
showing the change in taxa richness.
I believe
the graphic representation of the data allows the reader to view the data in a form
that shows the trends better.
Page 5-7: It
must be explained how the taxa richness for benthic invertebrates relates to the
ecological integrity or stream impairment in the Brandon Road and Dresden Island
navigational pools.
I believe
that Table 5Apresentsa definition of the metrics and what happens to the metric
with increase or decrease in perturbation. The suggestion is made that as perturbation
increases ecological integrity decreases.
Page 5-8: It
is stated that the number of EFT taxa was low. Include in the report numeric
data showing the low values and indicate how many EFT taxa should be present in a
healthy, deep-water river.
On~~ould
presentatableofthe data although we have already graphed it,which I think is
adequate considering the limited data we had to work with. Comparison to a reference
condition was suggested to the committee, but no consensus was agreed upon by the
committee as to what river system to use.
Page 5-11: It is stated
that aquatic worms were high in number in the Lockport and Brandon
Road pools. Include
in the report numeric data showing the abundance of aquatic worms.
Again,
we presenteda graphic of this data which one could obtain numeric values from.
The presentation
of the data in graphic form allows for better comparison between sample
location
and areas.
Page 5-14: The lower Des Plaines River below the
I-55 Bridge was used as a biological
reference/comparison condition for the Lockport, Brandon Road, and Dresden Island pools.
The Chicago Sanitary
and Ship Canal in the Lockport pool and the Des Plaines River in the
Brandon Road pool are channelized waterways. The Des Plaines River in the lower Dresden
Island pool is a natural river. Because
of the difference in physical habitats, it is not
appropriate to use the Lower Des Plaines River as a reference/comparison condition.
Again, consensus
was never reached as to an appropriate reference condition. Since the
lower Dresden Island
pool was a part of the same river system, and was meeting it'suse
MEMO RESPONSE TO COMMENTS.DOC

RESPONSE TO COMMENTS, CHAPTER 5
classification, and since the committee could not come to consensus on an appropriate
reference stream/river, the Lower Dresden pool was used.
Pa~e
5-14: It is stated that some metrics indicate a restricted benthic community in the,
Lockport
and Brandon Road pools. Define "restricted" and identify the metrics that show a
restricted fauna.
I believe
one can obtain this from the graphics of the stated individual metrics.
Page 5-15: The Illinois Macroinvertebrate Biotic Index (MBI) does not include the effects of
metals
or habitat. Additionally, the MBI was developed for wadeable streams, not
man-made impoundments or large river systems. The MBI may not be the appropriate
index to use for this waterway.
The statement above may be right, but it is an index currently in use in Illinois. It was
suggested by some members of the committee that we adopt the Ohio macroinvertebrate
index
even though Ohio does not use it in impounded waters for regulatory purposes.
Again,
the committee could not come to consensus on this.
Pa~e
5-17: Describe the benthic community that would be indicative of a General Use
classification.
A
community that would indicate a Fully Supporting use classification.
If
one accepted the
use of the Illinois MBI, it would be and MBI equal to or greater than5.9. (Loaded question)
Pa~e
5-18: It is stated that "The results of the macroinvertebrate sampling were heavily
influenced
by lack of habitat and barge traffic." it is recommended that the previous
sentence
be revised to read, "The lack of instream and riparian habitaf'andbarge traffic limit
the biological integrity in the lower Des Plaines River."
I think it'sbetter to
use the first statement since we have not researched quantitatively the
relationsrupsbetween the macroinvertebrate community and the otherfactors.
MEMO RESPONSE TO COMMENTS.DOC

Institute for Environmental Quality
064 Brehm Lab
3640 Colonel Glenn Hwy.
Dayton, OH 45435-0001
(937) 775-2201
(FAX (937) 775-4997
email: ieqstaff@wrightedu
October 14, 2003
Julia P. Wozniak, Senior Biologist,
Midwest Generation EME, LLC
One Financial Place
440 South LaSalle Street
Suite 3500
Chicago, IL 60605
Re: Position Paper for the Upper Illinois Waterway UAA Draft Report
Dear Julia:
Attached is the position paper you requested. I will be in the office all week, but out Oct 18-23 if
you have any questions or comments.
Sincerely,
G. Allen Burton, Jr., Professor and Director

2
Review of the Lower Des Plaines River Use Attainability Analysis
(UAA) Draft Report
by
G. Allen Burton, Jr.
October 14, 2003
Introduction
I have been asked by Midwest Generation to review and comment on the UAA Draft Report
(AquaNova & Hey 2003). Relatively late in the process of the 1990'sUpper Illinois Waterway
(UIW) Task Force process, I was asked to evaluate the role of sediment quality on the UIW. So,
in the mid-1990's I led some evaluations of water and sediment quality on the Des Plaines River
for Commonwealth Edison (Burton, 1995, 1998; Burton and Brown 1995). These studies
involved evaluations of sediment contamination and toxicity on the upper
~55
miles of the UIW,
reviews of the literature on temperature, turbidity and barge traffic effects,
in situ
toxicity
evaluations around the Joliet power stations, and laboratory evaluations oftemperature effects.
Some of these studies have been heavily cited in the draft UAA, but there was not a balanced
presentation of the data and, in many cases, misinterpretations of the conclusions.
My area of expertise is in the evaluation of freshwater ecosystem stressor effects, particularly
focusing on the role of sediment and stormwater quality (Appendix 1). Therefore, my review of
the UAA report deals with the stressors in the UIW and their role in biological impairment,
focusing on sediments and stormwaters and inter-relationships of other key waterway factors.
Any evaluation of aquatic ecosystem quality is complex with numerous assumptions and
uncertainties that confound the decision-making process. The evaluation requires an
interdisciplinary approach and understanding of how dominant physical, chemical and biological
factors interact. This dictates that state-of-the-science approaches be used that generate an
adequate level of quality data and that the associated uncertainties and assumptions be clearly
understood and stated. The current consensus is that reliable "weight-of-evidence" based
approaches are necessary in environmental quality assessments, providing for sound decision-
making
(e.g.,
Burton
et al.
2002ab). These approaches should characterize the key "exposure"
and "effects" components of the ecosystem using reliable and quantitative approaches where
reference conditions, dominant stressors, and their risk is clearly defined for the users.
Unfortunately, this important process was not followed in the draft UAA.
The Des Plaines Watershed
A wealth of data exists on the Des Plaines River and its watershed.
It
covers nearly 855,000 acres
in Lake, Cook, DuPage and Will counties. The majority of Chicago'smetropolitan area drains
into the Des Plaines River and its tributaries. Much ofthe current data has been summarized by
the Illinois Environmental Protection Agency (IEPA) in their recent 305(b) Water Quality Report
(IEPA 2002). This human-dominated watershed is characterized primarily by urban and
agricultural land uses (AquaNova
&
Hey 2003). The river is effluent dominated, receiving
municipal wastewaters from many cities, including the 3
rd
largest in the nation. The municipal
wastewater constitutes more than 90% of the low flow during the winter. The IEPA 305(b) and
303(d) reports identify priority organics, nutrients, metals, pathogens, ammonia, siltation and
habitat alteration as the potential causes of water quality problems. The quality of the Des
Plaines River ranks among the worst, with the 2
nd
highest number of impaired reaches (66;
USEPA 303d Fact Sheet). In the 18 reaches assessed in the IEPA 2002 305b report, all had
impaired uses, averaging 8 causes of impairment per reach (145 total). Ofthe 58 beneficial uses
on the 18 assessed reaches, 52 were impaired and 66% had fish consumption advisories. Greater
than 50% of the Des Plaines River reaches average over 12 different causes of impairment. The

3
only causes of use impairment that were not identified in the Des Plaines were thermal
modification, pathogens, algal/plant/exotic species, new age pesticides and dioxin (likely not
analyzed for), pH and a few inorganic chemicals (IEPA 2002 305(b)). The dominant stressors
and the percentage of reaches where they were identified as a problem are: metals (100%),
nutrients (56-61%), PCBs (44%), flow alteration (44%), suspended solids (39%), organic
enrichment (33%), low dissolved oxygen (33%), and IDS (33%). Though not identified as
impairment causes, pathogens and new age pesticides are also likely problems in the Des Plaines
River, since these have been identified as always being elevated in all human dominated
waterways (USGS 1999; USEPA 2000). The high degree of impairment and the multiple causes
are to be expected, based on the dominance of human activities and the limited nonpoint source
runoff controls in the watershed. In fact, these dominant stressors and the resulting biological
impairments are similar to other waterways that are human dominated (e.g., Burton
et al. 2000;
Burton and Pitt 2001).
The unique nature ofthis watershed makes the critically important issue of reference waterway
selection difficult. The reality is that the Des Plaines watershed is one of the most heavily
human-dominated waterways in the nation. This will not change. Less than 5% ofthe UIW has
been identified as riverine habitat, with average habitat scores ranked as poor. Habitat is poorest
in the Lockport, Brandon and Dresden Pools and the dominating main channel habitat area. Most
of the habitat factors causing the poor ranking are irreversible (ComEd 1996). Comparing this
waterway to one that is dominated to lesser degrees by better habitats or urban inputs
(e.g.,
Kankakee River) implies that the Des Plaines can be improved to a similar state; which would
require massive urban NPS controls and habitat restoration, at a minimum. While there is little
doubt the quality ofthe Des Plaines can be improved,
it
will always be a heavily modified
waterway and never be of high quality. Until the stressors that dominate the beneficial use
impairments (identified above) are reduced significantly, human and ecological risks will persist.
Sediment Quality
It
is well known that chemicals (nutrients, synthetic organics and metals) and pathogens tend to
associate with solids due to polar and nonpolar binding affmities (Burton 1992). Therefore, those
sediments that have greater surface areas (clays, silts, colloids) will accumulate the greatest
concentrations, and thus serve as both a sink and a source of contamination. Indeed,
contaminated sediments are the cause of use impairment of 42 Great Lakes Areas ofConcem and
the dominant cause for Superfund site designation in our waterways. Depositional sediments are
not stationary and continue to contaminate resident organisms and downstream waters
via
common fate processes, such as resuspension, advection, bioturbation and diffusion. These issues
have been at the heart of the Fox and Hudson River cleanups. All of these fate processes exist on
the Des Plaines River and vary spatially and temporally. While overlying water quality can be
relatively good
(i.e.,
meet water quality standards), contaminant concentrations will steadily
increase in depositional sediments and provide an environment for bioaccumulation in benthic
organisms. The U.S. Environmental Protection Agency (USEPA) has shown dramatic
correlations between fish tissue consumption advisories and sediment contamination. On the Des
Plaines, 66% of the reaches assessed in the 305(b) report have fish consumption advisories and
the levels of PCBs found in sediments suggest a substantial risk exists to those consuming fish
from the Des Plaines River.
Contamination ofthe Des Plaines River sediments is not strictly historical and is on-going.
Nutrients, metals, pathogens and synthetic organics (primarily polycyclic aromatic hydrocarbons
(PAHs) and new age pesticides) are common constituents of both point and nonpoint source
loadings in waterways such as the Des Plaines (Burton and Pitt 2002; USGS 1999). Therefore,
removal of significantly contaminated and acutely toxic sediments from depositional areas

4
identified throughout the UIW (Burton 1995), would provide but a temporary improvement. The
hydrologic conditions and source loadings would eventually result in contaminated sedimel"its re-
accumulating since the myriad of sources will not be removed.
There are no reliable data establishing a trend of improving sediment quality, contrary to
statements made in the UAA report.
It
was established by previous studies that extreme spatial
heterogeneity exists in the UIW and is related primarily to sediment particle size and navigation
channel
vs.
depositional areas. Spatial heterogeneity is a major issue in the assessment of
sediment quality (USEPA 2001; Burton 1992) and can vary by orders of magnitude over
horizontal and vertical distances of centimeters. There is no indication that this site-specific
variation was characterized in the data being evaluated for trends. Indeed, the concentrations of
organic contaminants in the depositional sediments ofthe UIW exceed reliable sediment quality
guidelines (SQGs) for probable adverse biological effects (Table 1). TheUAA report discussion
of sediment criteria is based on an antiquated ranking approach and fails to use accepted sediment
quality guidelines that have been applied in numerous regulatory situations throughout the U.S.
(Wenning and Ingersoll 2002).
It
is naIve and clearly not appropriate from a scientific
perspective to attempt to predict metal availability in the manner being proposed by Ambrose.
Ambrose (1999) is cited heavily suggesting a partitioning approach for metals concentrations in
pore waters, but is a draft document that is 4 years old and has not been supported by the peer
reviewed literature. The use of a 75
th
percentile to convert marine to freshwater values also has
no scientific basis.
The peer-reviewed literature and approved USEPA approaches should be used for the UAA
decision making process (Wenning and Ingersoll 2002). The 4
th
paragraph on p. 3-23 is full of
inaccurate statements regarding use ofWQC for sediment assessments, regarding prediction of
sediment toxicity and benthic
vs.
water column organism sensitivity. More importantly, widely
used SQGs are exceeded, suggesting these sediments are highly contaminated and are likely to
cause adverse biological effects.
There are no sediment toxicity data to refute the idea that these sediments are acutely toxic.
Contrary to what is stated in the UAA report, the USEPA data of200l suggests the depositional
sediments are still highly contaminated and acutely toxic (Table 1). These sediments exceed the
respected SQGs known as Probable Effects Levels (PEL) for a multitude of organic chemicals
which have been shown to be accurate
~70%
ofthe time
(e.g.,
Buchman 1999; McDonald
et al.
2000ab). Since the USEPA'smore recent survey found highly contaminated depositional
sediments similar to what we found in the mid-90's(Burton 1995), it is likely that depositional
sediments are not being cleaned out. As discussed above, these sediments are being routinely
contaminated from urban, residential, transportation and agricultural runoff and a wide variety of
small to large point sources (Burton and Pitt 2001; Burton
et al.
2000). These sources will
continue to contaminate the depositional sediments and, as these sediments are resuspended they
will continue to contaminate the more biologically sensitive and productive lower reaches of the
Illinois River system. The authors of the draft report do not establish that the highly
heterogeneous sediments are improving. They do not establish that sediments over a multi-year
period were sampled from the exact same locations (as required for trend evaluations) and imply
that data originating from navigational sediments (poor fish habitat) that are clean can be
compared to depositional areas that are contaminated. There are no data adequate for trends
analyses of sediment contamination. Despite their contention that sediments are cleaner, they still
exceed that of many Superfund sites and are highly likely to produce toxic effects. Figures 3.6-
3.8 do not show the many problem stressors and do not indicate sediment spatial heterogeneity.

5
The draft UAA report (p. 3-8) states that main channel sediments are non-toxic, which would be
expected
of sand, gravel, cobble sediments. However most depositional sediments showed acute
toxicity and lie in the limited habitat areas for fish. The main channel is not primary habitat and
not suitable for spawning. Indeed the prime habitat for spawning, below Brandon Lock
& Dam
tailwaters is contaminated. These shallow areas allow for photoinduced-toxicity of low ug/L
(ppb) levels of PAHs, contrary to the incorrect statements in the report (p. 3-8). The
photoinduced PAHs will be toxic to zooplankton, benthic macroinvertebrates, fish and
amphibians in surficial layers
of waters throughout the UIW. This phenomenon is well cited in
the peer-reviewed literature
(e.g.,
Hatch and Burton 1998, 1999; Ireland
et al.
1996). The limited
citations (p. 3-35-36) for
PAR toxicity fail to recognize the wealth ofliterature that documents
PAH contamination in urban waterways that is toxic in the low ppb level in waters and in the ppm
level in sediments. The
UIW has significant areas of biological productivity that are shallow
«1m depth) and thus subject to photoinduced PAH toxicity. In addition, the levels found in the
sediments are high enough to cause acute toxicity without UV stimulation, with or without carbon
loadings, based on accepted SQGs.
SQGs are but one
ofthe lines-of-evidence that are used in an assessment ofecosystem quality.
Other important LOE include indigenous biota, toxicity and bioaccumulation, and habitat
conditions. Only when each
LOE is comprised of high quality data from an adequate design to
characterize spatial and temporal conditions, can it be used with confidence in a weight-of-
evidence evaluation (Burton
et al.
2002b). In addition, the dynamic nature of aquatic systems for
both contaminants and organisms dictates that data be collected concurrently in order to link
stressor exposures with biological responses. Unfortunately, the data used for much
ofthe UAA
does not allow for quantitative analyses
ofthe separate lines-of-evidence, or their quantitative
integration into a weight-of-evidence based decision.
The ammonium text (p. 3-13 - 15) and resulting conclusions are misleading. Ammonium is
typically considered to be the ionic form, while the term ammonia is inclusive of both the ionic
(dominant species) and unionized
<NHtOH) forms. The unionized form is more toxic to some
species, such as rainbow trout, but not others
(e.g., Hyalella azteca).
All ammonia is not oxidized
in the'upper aerobic layer as stated (p. 3-14); otherwise there would be no sediment related
ammonia toxicity. Ammonia originating in sediments can affect benthic organisms and pass into
overlying waters via porewater movement (advection), bioturbation, loss
of gas bubbles, sediment
disturbance and diffusion (Wetzel 1983).
To imply that the aerobic layer provides a virtual cap
for ammonia and to suggest that benthic organisms are not affected by ammonia in sediments is
scientifically unjustified, overly simplistic and refutes site-specific data. Nitrifying bacteria have
a wide temperature tolerance range
(1 to 37° C). Nitrification continues down to dissolved
oxygen levels
of 0.3 mg/L and is dominated by heterotrophic nitrifying bacteria found in both
aerobic and anaerobic waters. However, nitrification is greatly reduced in undisturbed sediments
because oxygen is typically low
or absent (Wetzel 1983). So, as long as there continues to be high
loadings
of natural organic compounds and suspended solids, there will be ideal environments in
the UIW for ammonia production. Ironically, the closing paragraph
of the section (p. 3-15) states
"This discussion of the ammonium toxicity in sediment by no means tries to downgrade the
concerns about the toxicity
ofthe sediments and ammonium in particular. However, stressors or
a combination of stressors other than ammonium may be responsible for the low biotic integrity
of the Brandon Road and Dresden Island pool. .."; which is absolutely correct!
The UAA report fails to show the high levels
of contaminants found in previous ComEd studies
from virtually all depositional sediments along the UIW.
It
also fails to point out that ammonia
was found to be one
of the primary toxicants (as suggested in the Lawler
et al.
report) and its
statistically significant correlation with sediment toxicity, particle size and organic contaminants

6
(Burton 1995). The discussion fails to point out the toxicity noted in waters and sediments not
impacted by thermal plumes. In addition, the majority of the data from the Wright State
University studies pointed to ammonia toxicity as a primary stressor.
Hyalella azteca
showed
greater effects, as would be predicted, since it is epibenthic and in closer proximity to higher
ammonia concentrations (and other contaminants co-existing in the sediment). So the UAA
report's statements that ammonium did not affect the survival or that no proof are provided are
both incorrect and puzzling. There are at least 3 lines of evidence showing ammonia is a major
stressor throughout the UIW.
Ceriodaphnia dubia
survival was affected by turbidity as would be expected (Burton 1998).
Filter feeding zooplankton are known to be sensitive to suspended solids at levels of 50-1 00 mg/L
(e.g.,
IEQ 1995). This dominant stressor of the UIW likely impacts zooplankton populations
throughout the waterway and is aggravated by barge traffic.
Another sediment contamination concern is that of pathogen risk. Nutrient rich, depositional
sediments allow for extended survival of pathogens (Burton
et al.
1987). Survival can extend for
months and as sediments are resuspended, serve as a potential source of human risk. Fecal
coliform is the most commonly violated NPDES permit"limit (USEPA 2002). The large amount
of municipal wastewater effluent and untreated stormwater runoff from urban, residential and
agricultural areas will always comprise a high loading potential for pathogens in waters and
sediments of the UIW.
The Toxicity Identification Evaluation (TIE) results also suggested ammonia and PAHs as
primary toxicants (Burton 1998). The authors ofthe UAA report imply that pore water toxicity is
greatly reduced by various complexing agents. This is true sometimes and not others, depending
on the sediment's physical and chemical characteristics, species type and life history, feeding
characteristics, the residence time ofthe pore water, and the microbial communities and their
indigenous activities (Burton 1991, 1992). Obviously pore water concentrations are predictive of
effects to overlying biological communities, because the USEPA has based their sediment quality
guidelines of equilibrium partitioning on this assumption.
It
is curious as to why the UAA focuses on copper.
It
is but one of the potential stressors, and an
unlikely one at that.
Tubiftx
is not the most sensitive benthic species to Cu as stated, rather the
epibenthic amphipod
Gammarus
is (Brix
et
al.
2001). Cu is likely unavailable, as pointed out in
our studies and due to the existing hardness, solids, and organic ligands available.
Tubifex
is
quite resistant to the organic chemical pollutants and ammonia that exist in the UIW. The UAA
report recommends Tubifex for toxicity evaluations ofthe UIW; however, it is not an organism of
choice for testing and has not been recommended by the USEPA (USEPA 2000).
A substantial concern exists for the data gaps that will likely show even greater contamination
and biological impact. The concentrations of compounds that highly bioaccumulate (chlorinated
pesticides and PCBs) are excessive (higher than many Superfund sites) and have undoubtedly
contaminated the indigenous biota. Fishing is common on the lower UIW, yet likely poses a
health risk. In addition, no data are provided for the "new age" pesticides that are currently being
used in this large watershed. We know that the new age pesticides and nutrient contamination
have occurred in every studied urban and agricultural watershed ofthe US with elevated sediment
and fish tissue levels (USGS 1999). In addition, pharmaceutical and personal care products
(PPCP) are also common from urban waterways and have been shown to impact fish reproduction
via
hormonal disruption; however, no data are available on these likely contaminants.

7
TABLE 1. Sediment Threshold and Probable Effect Levels (ug/Kg) vs. USEPA UIW
Sediment Survey Data*
Compound
Dieldrin
Endrin
DDT
Heptachlor epoxide
PCB (total for TEL/PEL)
Chlordane
Anthracene
Fluoranthene
Fluorene
Benzo(a)anthracene
Napthalene
Phenanthrene
Benzo(a)pyrene
TEL**
2.8
2.7
6.9
0.6
34.1
4.5
5.9
III
21
32
35
42
32
PEL**
6.7
62.4
4,450
2.7
277
8.9
128
2,355
144
385
391
515
782
UlW Sediment
7.5
7.0
20
10
600-16,000 for an individual congener
5
2,000
10,000
2,000
5,000
900
4,000
5,000
*
Des Plaines River sediment data taken from Tables 3.8, 3.9, 3.14 and 3.15.
**
Based on 1
%
TOe. Carbon data not available for UIW normalization. Other relevant SQGs could
be used (e.g., AETs, ERLs/ERMs, C-TEC/C-EEC) showing similar exceedances.
Stormwater Quality
It
is implied that because of watershed and MWRDGC improvements (including TARP) that
there are no significant inputs of contaminants and contaminated solids. However, most urban
waterways do not have CSOs and still have these same stressors and degraded biological .
communities, as discussed above. The sheer magnitude of urbanization and agriculture in the
watershed and lack of effective NPS controls dictates that NPS-related degradation will be a
dominant source of impairment for decades. This is not surprising since it is the leading cause of
water quality problems in the
u.s.
(USEPA2002). While the recent and near-future
improvements from TARP are noteworthy, this still is a highly impacted waterway, being effluent
dominated and receiving massive amounts of untreated NPS runoff containing a wide range of
nutrients, pathogens, metals, petroleum products, "new-age" pesticides and PPCP many of which
are known to be toxic at the part-per-trillion level and/or hormone disruptors (Burton and Pitt
2001; Burton
et at.
2000). Stormwaters in streams are often acutely toxic (Burton
et al.
2000;
Burton and Pitt 2001; Hatch and Burton 1999; Tucker and Burton 1999). In addition to the
chemicals, massive loadings of solids erode from urban, construction and agricultural lands and
constitute the number one pollutant of river systems (USEPA 2002; Burton and Pitt 2001). Most
ofthe stressors have been already identified by the IEPA as the causes of impairment on the Des
Plaines. Other stormwater issues are discussed in the preceding and following text.
Temperature
It
is noteworthy that thermal modifications have not been identified as one ofthe 23 impairment
causes on the Des Plaines River (IEPA 2002). While temperature can certainly be a stressor, a
literature review found that warm temperatures can be both advantageous and detrimental to
aquatic biota (IEQ 1995). Another concern not discussed in the UAA Report is that there are
winter maximum temperatures which are impacted by municipal wastewater effluents and may
impede some fish reproductive processes. The "Selection of the Temperature Standard" and
"Critique ofthe Current Secondary Contact and Indigenous Aquatic Life Standard" sections have
inaccurate statements regarding temperature effects on riverine species and ecosystem processes.
High and low temperatures mayor may not be detrimental to aquatic life that resides in the UlW.
There is not a simple relationship, as noted from many past studies
(e.g.,
Cairns
et at.
1973;

8
Cairns
et al.
1978; review by Burton and Brown 1995). Both low and high temperatures can
increase and decrease toxicity due to exposures from other chemical stressors, such as found in
the UIW, and is both species and toxicant type and concentration dependent. The UAA report's
over-simplification that high temperatures increase toxicity is simply incorrect. Nitrification is
also inhibited by cold temperatures and ammonia is not always consumed in the upper sediment
layers. Nitrification is very sensitive to toxicants, which abound in the UIW'sdepositional
sediments. The authors incorrectly imply that high temperatures are always detrimental by
focusing on negative impacts and over generalizing.
Blue green algae are not a concern on the UIW due to its flow conditions. Toxic cyanobacterial
blooms are common to pond, lake and reservoir ecosystems. So, many of the "Negative"
examples used on p. 2-93 do not apply to the UIW, yet their presentation implies that they do.
On p. 2-97 the subsection title is "Experiments by Wright University to Establish Temperature
Limits". My study at Wright State University did not attempt to establish temperature limits for
the UIW. The discussion of my study is misleading, leaving out key portions ofthe conclusions
and misinterpreting others. Our findings substantiated previous studies by my laboratory and
others. The key findings documented that acute toxicity exists in short-term exposures to
multiple species in waters and sediments ofthe UIW without any temperature elevation. Toxic
sediments abound in most tributary mouth, tailwater, and pool depositional areas, which include
the better (but limited) habitats for fish. These same habitats are typically shallow waters which
are subject to rapid mortality as a result of photoinduced toxicity ofPAHs, as discussed above.
Both cold and hot temperatures accentuated toxicity originating from UIW waters and sediments.
Statistically significant correlations between sediment ammonia and fluorene concentrations and
toxicity were observed. Ammonia was also significantly correlated to depositional sediments and
the presence of high concentrations of organics. These
c~rrelations
were based on sediment data
collected from throughout the UIW.
In situ
toxicity was not observed due to temperature outside
the thermal discharge plume.
Thelaboratory toxicity test results produced by our studies further document the role of sediment
toxicity and how it is increased in the presence of temperature extremes. The Toxicity
Identification Evaluation Phase I experiments further substantiate \he findings of the Chemical
Screening Risk Assessment and the ammonia correlations with toxicity, suggesting that ammonia
is a primary system stressor to benthic and epibenthic species. However, these 7 day, static
renewal experiments do not adequately mimic dynamic,
in situ
conditions where light,
temperature, turbidity, water quality and food conditions change over minutes to hours. The most
reliable indicator of
in situ
conditions is the indigenous communities. Benthic and fish
community data show populations thriving despite the highly modified nature of the waterway.
These are the most reliable data for evaluations of thermal impacts.
UAAFactors
Contrary to the conclusions of the UAA report, the current and future status of this watershed and
the data clearly show that several UAA factors are met. The rationale supporting the statements
below are provided in the text above and literature citations; and through a weight-of-evidence
based, decision-making process involving the following 12 lines-of-evidence: magnitude ofSQG
exceedances, prevalence of sediment contamination, likelihood of continuing sediment
contamination, extreme degraded status of waterway compared to others in the nation, human
dominance of watershed, profuse NPS inputs, excessive habitat modification and degradation,
human risk from pathogens and fish consumption, toxicity lEwels in water and sediment,
correlations oftoxicity with chemical stressors, indigenous biotic indices, and excessive numbers
of use impairments throughout the watershed.

9
UAA Reasons Which Are Met:
Reason 1. Naturally occurring pollutant concentrations prevent the attainment of the use:
Sometimes ammonia is considered a "natural" pollutant
(e.g.,
see USEPA/USACOE dredging
guidance). The weight-of-evidence suggests ammonia is a stressor of concern throughout this
waterway, with multiple point and nonpoint sources. Erodable soils are another pervasive
stressor contributing to siltation, embeddedness, and turbidity-related stress.
Reason 3. Human caused conditions or sources ofpollution prevent the attainment of the use
and cannot be remedied or would cause more environmental damage to correct than to leave in
place:
This is the primary reason for not upgrading. The evidence of excessive impairments is clear
from the results of recent IEPA efforts (IEPA 305(b) and 303(d) reports). A multitude of
impairment causes and sources exist throughout the watershed as discussed and documented
above. These causes are unlikely to be significantly corrected.
Reason 4. Dams, diversions or other hydrologic modifications preclude the attainment of the use,
and it is not feasible to restore the water body to its original conditions or to operate such
modifications in a way that would result in the attainment of the use:
The waterway'shabitat is heavily and permanently modified. Barge traffic will continue to be a
major use and will continue to result in degraded habitat, resuspended contaminated sediments
and a physical hazard to recreational users.
Reason 5. Physical conditions associated with the natural features of the water body, such as the
lack of proper substrate, cover, flow, depth, pools, riffles and the like, unrelated to quality
preclude attainment of aquatic life protection uses:
See rationale for Reason 4 above. Habitat is ofpoor quality through most of the UIW and cannot
be significantly corrected.
Reason 6. More stringent controls than those required by Sections 301 (b) and 306 ofthe CWA
would result in substantial and widespread adverse social and economic impact:
It
is simply impossible to remove the many and widespread impairment sources or substantially
improve their quality (including NPS), which have been identified by the IEPA and USEPA,
without severe social and economic impact.
Conclusions
An extensive database exists on the UIW concerning its physical, chemical, biological and
toxicity characteristics. These multiple lines-of-evidence clearly establish this is a highly
modified waterway that has poor habitat, is effluent dominated and receives massive amounts of
untreated, nonpoint source runoff. Despite the many stressors that exist (and will continue to
exist) in this waterway, a thriving fish community exists which runs contrary to the UAA report
predictions oflethality. This line-of-evidence is a direct measure of indigenous biota and their
ability to exist under the current conditions of the UIW. The toxicity studies conducted by my
laboratory used worst-case exposure conditions for early life stages of two surrogate species.
These results documented acute toxicity in UIW water and sediment and that high and low
temperatures may accentuate the pervasive level of toxicity to these surrogate species. Other
laboratory-based research by Cairns
et aI.,
(1973, 1978) has shown the complexity oftemperature
and chemical interactions in organisms which refute the simplistic conclusions ofthe UAA
report. Laboratory-based results require extrapolation to field conditions and indigenous benthic
and fish communities, which have been thoroughly characterized in the UIW and are the most
important line-of-evidence. Depositional sediments throughout the UIW are contaminated with

10
levels of multiple contaminants that, in many locations, pose a hazard to aquatic biota, wildlife
and humans.
Major nonpoint source loadings of solids, nutrients, metals, and organics will
continue from small to major urban areas, sewers; construction, and agriculture in this human-
dominated watershed. Modified and limited habitats (channelization, barge traffic, lock and
dams), extreme turbidity and siltation, and stressor loadings will not improve in the foreseeable
future and will continue to
dominate water quality conditions and use impairments. Development
of new, modified standards will not address the key issue of excessive and pervasive pollution
sources, excessive use impairments
and limited habitats in this watershed.
The draft UAA report conclusions are quite misleading. The presentation of data, data
interpretation,
and supporting statements are often biased and fail to provide a scientifically-
balanced representation
of previous Upper Illinois Waterway (UIW) studies, peer-reviewed
literature and accepted approaches
that are the state-of-the-science. As such, this document fails
to provide a scientific basis for
an informed decision making framework for the UAA process.
References Cited
AquaNova International, Ltd. and Hey and Associates, Inc. 2003. Lower Des Plaines River Use
Attainability Analysis. Draft report prepared for the Illinois Environmental Protection Agency. Springfield,
IL. March.
Brix KV, DeForest DK, Adams WJ. 2001. Assessing acute and chronic copper risks to freshwater aquatic
life using species sensitivity distributions for different taxonomic groups. Environ Toxicol Chern 20:1846-
1856.
Buchman
MF 1999. NOAA Screening Quick Reference Tables, NOAA HAZMAT Report 99-1. Seattle
WA.
Burton, G.A., Jr., D. Gunnison and G.R. Lanza. 1987. Survival of enteric pathogens in freshwater
sediments. App!. Environ. Microbio!. 53: 633-638.
Burton, G.A., Jr. 1991. Assessing freshwater sediment toxicity. Environ. ToxicoL Chern.
10:
1585-1627.
Burton, G.A.,
Jr. 1992.
Sedimen~
Toxicity Assessment. Lewis Publishers. Boca Raton,
FL. 457 P
Burton, G.A.,
Jr. 1992. Sediment collection and processing: factors affecting realism. In, Sediment
Toxicity Assessment. Lewis Publishers. Boca Raton, FL. pp. 37-66.
Burton, G.A.,
Jr. 1992. Assessing contaminated aquatic sediments (a two part feature series - Special
Editor). Environ. Sci. Techno!.
Vo!. 26:1862-1863.
Burton, G.A.,
Jr. 1995. The Upper Illinois Waterway Study, 1994-1995 Sediment Contamination
Assessment Final Report. Commonwealth Edison, Co., Chicago, IL.
Burton, G.A.
Jr. 1998. The Upper Illinois Waterway Ecological Survey: Continuous
in Situ
Toxicity
Monitoring and Thermal Effect Characterization Tasks. Commonwealth Edison Corp. Chicago, IL.
Burton, G.A.,
Jr. 2002. Sediment quality criteria in use around the world. Limnology 3:65-76.
Burton, G.A., Jr. and
H. Brown. 1995. Reviews ofthe Literature Concerning: 1) Effects ofTemperature on
Freshwater Fish, 2) Effects on Freshwater Biota from Interactions
of Temperature and Chemicals, and 3)
Effects
ofTurbidity and Barge-Traffic on Aquatic Ecosystems. Commonwealth Edison, Co. Chicago, IL.

11
Burton, G.A., Jr., and R. Pitt. 2001. Stormwater Effects Handbook: A Tool Box for Watershed
Managers, Scientists and Engineers. CRC/Lewis Publishers, Boca Raton, FL, 924 pp.
Burton, G.A., Jr., R. Pitt, and
S. Clark. 2000. The role of whole effluent toxicity test methods in
assessing stormwater and sediment contamination. CRC Critical Reviews in Environmental
Science & Technology 30: 413-447.
Burton, G.A., Jr., P. Chapman, and E. Smith. 2002. Weight
of Evidence Approaches for Assessing
Ecosystem Impairment. Human and Ecological Risk Assessment 8:1657-1673.
Burton, G.A., Jr., G. E. Batley, P.M. Chapman, V.E. Forbes, E.P. Smith, T. Reynoldson,
e.E. Schlekat,
P.l den Besten, A.J. Bailer, A.S. Green and R.L. Dwyer. 2Q02. A Weight-of-Evidence Framework for
Assessing Sediment (Or Other) Contamination: Improving Certainty in the Decision-Making Process.
Human and Ecological Risk Assessment 8:1675-1696.
Burton GA, Jr., Rowland CD, Greenberg MS, Lavoie DR, Nordstrom JF, Eggert LM. 2003. A tiered,
weightcof-evidence approach for evaluating aquatic ecosystems, in, M. Munawar (ed.), Sediment Quality
Assessment and Management: Insight and Progress, 2003 Ecovision World Monograph Series, Aquatic
Ecosystem Health and Management Society Pub!., Hamilton, Ontario. pp. 3-21.
Cairns JJ Jr, Buikema AL Jr, Heath AG, Parker BC. 1978: Effects oftemperature on aquatic organism
sensitivity
to selected chemicals. Virginia Water Resources Research Center. Bulletin 106. Blacksburg, VA
Cairns JJ Jr, Heath AG, Parker Be. 1973. The effects oftemperature upon the toxicity of chemicals to
aquatic organisms. Report to Congress by the Environmental Protection Agency. Part 3. Serial No. 93-14.
Washington DC.
CornEd. 1996. Aquatic Ecological Study
ofthe Upper Illinois Waterway. Final Report. Chicago, IL.
Greenberg, M.S., G.A. Burton, Jr., P.B. Duncan. 2000. Considering Groundwater-Surface Water
Interactions in Sediment Toxicity Assessment. SETAC Globe. March, April, pp. 42-44.
Hatch, A.C. and G.A. Burton, Jr. 1998. Effects
of photoinduced toxicity offluoranthene on amphibian
embryos and larvae. Environ. Toxico!. Chern. 17:1777-1785.
Hatch, A.C. and G.A. Burton, Jr. 1999. Sediment toxicity and stormwater runoff in a contaminated
receiving system: Consideration of different bioassays in the laboratory and field. Chemosphere 39: 100 1-
1017.
Hatch,
A.e. and G.A. Burton, Jr. 1999. Photoinduced toxicity ofPAHs to
Hyalella azteca
and
Chironomus
tentans:
Effects ofmixtures and behavior. Environmental Pollution106: 157-167.
Illinois Environmental Protection Agency. 2002. Illinois Water Quality Report 2002. Bureau ofWater.
Springfield, IL.
Ireland, D.S., G.A. Burton, Jr., and G.G. Hess. 1996.
In Situ
toxicity evaluations of turbidity and
photoinduction of polycyclic aromatic hydrocarbons. Environ. Toxico!. Chern. 15:574-581.
MacDonald DD, CG Ingersoll and TA Berger. 2000a. Development and evaluation
of consensus based
sediment quality guidelines for freshwater ecosystems. Arch Environ Contam Toxico!. 39:20-3 I.
MacDonald DD, LM DiPinto, J Field, CG Ingersoll, ER Long and RC Swartz. 2000b. Development and
Evaluation
of consensus-based sediment effect concentrations for polychlorinated biphenyls. Environ.
Toxicol Chern. 19:1403-1413.
Tucker, K.A. and G.A. Burton, Jr. 1999. Assessment of nonpoint source runoff in a stream using
in situ
and laboratory approaches. Environ. Toxico!. Chern. 18:2797-2803.

12
U.S. Environmental Protection Agency. 2000. Methods for Measurin1 the Toxicity and Bioaccumulation of
Sediment-associated Contaminants with Freshwater Invertebrates. 2
n
Edition. EPA/600/R-99/064. Office
ofResearch and Development and Office of Water. Washington, DC.
U.S. Environmental Protection Agency. 2001. Methods for Collection, Storage and Manipulation
of
Sediments for Chemical and Toxicological Analyses: Technical Manual. Office of Water. EPA-823-B-01-
002. Washington, DC.
U.S. Environmental Protection Agency 2002. National Water Quality Inventory 2000 Report. Office
of
Water. Washington DC. EPA-841-R-02-001.
U.S. Geological Survey. 1999. The Quality of Our Nation's Waters. Nutrients and Pesticides. USGS
Circular 1225. Reston, VA.
Wenning RJ and Ingersoll CG. 2002. Use of sediment quality guidelines and related tools for the
assessment of contaminated sediments. Executive summary of a Pellston workshop. Society of
Environmental Toxicology and Chemistry. Pensacola, FL.
Wetzel RG. 1983. Limnology, 2
nd
ed. Saunders College Pub!., Philadelphia.

APPENDIX 1
Resume
13
Position Title
Professor and Director,
Institute for Environmental Quality
Name
G. Allen Burton, Jr., PhD.
Education
Ouachita Baptist University
Auburn University
University
of Texas @ Dallas
University
ofTexas @ Dallas
B.S.
M.S.
M.S.
PhD.
1976
1978
1981
1984
Biology
& Chemistry
Microbiology
Environmental Sciences
Env. Sci. (Aquatic Toxicology)
Professional Positions:
1980-1984. Life Scientist. U.S. Environmental Protection Agency, Dallas, Texas
1984-1985. Visiting Fellow. Cooperative Institute for Research in Environmental Sciences, University
of
Colorado @ Boulder
1985-1990. Assistant Professor, Dept.
ofBiological Sciences, Wright St. Univ.
1990-1996. Associate Professor, Dept.
of Biological Sciences, Wright St. Univ.
1985-present. Coordinator, Environmental Health Sciences Undergraduate Program, WSU.
1994-present, Director, Institute for Environmental Quality, WSU.
1996-present. Professor. Dept.
ofBiological Sciences, Wright St. Univ.
2000-2003. Brage Golding Distinguished Professor
ofResearch, WSU.
2002-2003. Director, Environmental Sciences Ph.D. Program, WSU.
2003-present. Associate Director, Environmental Sciences Ph.D. Program, WSU.
Awards and Other Professional Activities
(select):
1992-1999. U.S. EPA National Freshwater Sediment Toxicity Methods Committee
1994,2001. Visiting Senior Scientist, Italian Institute for Hydrobiology.
1994,1995,1998,1999. External Review Panel. Environmental Biology Research Program. Exploratory
Research. Office
of Research and Development, U.S. EPA.
1996. Visiting Senior Scientist,
New Zealand Inst. ofWater and Atmospheric Research.
1994-1997.
NATO Senior Research Fellow, University ofCoimbra, Portugal.
1993-1996. Board
ofDirectors, Soc. of Environmental Toxicology and Chemistry
2002. Meeting Chair. 5
th
International Symposium on Sediment Quality Assessment.
1999-2001. U.S.
EPA Scientific Advisory Panel, Office ofPesticide Programs
2001-2004, Editorial Board, Aquatic Ecosystem Health
&
Management and Chemosphere.
2000-2003. Brage Golding Distinguished Professor
of Research.
2003-2006. World Council, Society
of Environmental Toxicology & Chemistry
Recent Projects
(select):
U.S. Environmental Protection Agency, Office
of Exploratory Research. Sediment
contamination assessment methods: validation
of standardized and novel
approaches. 1997-2000.
U.S. Environmental Protection Agency. Office
ofExploratory Research. Intraspecies
genetic diversity measures
ofenvironmental impacts. 1998-2001. Co-PI.
U.S. Environmental Protection Agency. Enhancement
ofEnvironmental Communication
in
the Lower Great Miami Basin: A Pilot Demonstration. 1999-2000. Co-PI.
City
ofDayton. Stormwater Quality Assessment of Wolf Creek. 2003.
U.S. Environmental Protection Agency (via USlnfrastructure, Inc.). Handbook for Assessing
Stormwater Effects on Receiving Waters. 2000.
U.S. Environmental Protection Agency Region I (via Tetra Tech EM, Inc.) Ecological Risk
Assessment
ofDick's Creek, OH. 2000-2001.

14
u.s. Environmental Protection Agency (via Miami Valley Regional Planning Commission).
Enhancement
of Environmental Communication in the Lower Great Miami Basin.
Continuation
of Pilot Demonstration.2001.
U.S. EPA (via Roy
F. Weston). Sediment toxicity evaluation ofNyanza Superfund site. 2001.
U.S. Environmental Protection Agency Region I (via Tetra Tech EM, Inc.) Ecological Risk
Assessment
of Dick'sCreek, OH. 2000-2001.
American Chemical Council. A Diagnostic Approach for
IdentifYing Biological Impairment and
Dominant Stressors. 2001-2004.
International Lead Zinc Research Organization. Field Validation
of Sediment Zinc Toxicity for European
Union Zinc Risk Assessment. 2001-2003.
.
Nickel Producers Environmental Research Organization. Field Validation
of Sediment Nickel Toxicity for
the European Union Nickel Risk Assessment. 2003-2004.
Recent Publications
(select):
1. Chappie, DJ. and G.A. Burton, Jr. 2000. Applications of Aquatic and Sediment Toxicity Testing
In Situ.
J. Soil and Sediment Contamination 9:219-246.
2. Burton, G.A., Jr.,
R. Pitt, and S. Clark. 2000. The role ofwhole effluent toxicity test methods in
assessing stormwater and sediment contamination. CRC Critical Reviews in Environmental Science
&
Technology 30: 413-447.
3. Burton, G.A., Jr., and
R. Pitt. 2001. Stormwater Effects Handbook: A Tool Box for Watershed
Managers, Scientists and Engineers. CRC/Lewis Publishers, Boca Raton, FL, 924 pp.
4. Baird,
D. and G.A. Burton, Jr. (eds.) 2001. Ecosystem Variability: Separating Natural from
Anthropogenic Causes
of Ecosystem Impairment. Pellston Workshop Series. SETAC Press. Pensacola,
FL.
5. Greenberg, M., G.A. Burton, Jr., C.D. Rowland. 2002. Optimizing Interpretation
of
In Situ
Effects:
Impact
ofUpwelling and Downwelling. Environ. ToxicoI. Chem. 21:289-297.
6. Burton, G.A., Jr. 2002. Flux
of Sediment-Associated Contamination. Fact Sheet on Environmental Risk
Assessment. International Council on Mining and Metals. London, UK.
7. Landrum, P.F., M.L. Gideon, G.A. Burton, M.S. Greenberg, C.D. Rowland. 2002. Biological responses
of
Lumbriculus variegatus
exposed to fluoranthene-spiked sediment. Archives ofEnviron. Contam.
Toxicol. 42:292-302.
8. Burton, G.A., Jr. , D.L. Denton, K. Ho, and D.S. Ireland. 2002. Test methods for measuring sediment
toxicity, In, Hoffman, D., et al. (eds.), Handbook
of Ecotoxicology, 2
nd
ed. CRC/Lewis Publishers,
Boca Raton, FL. pp. 111-150.
9. Burton, G.A., Jr., P. Chapman, and E. Smith. 2002. Weight ofEvidence Approaches for Assessing
Ecosystem Impairment. Human and Ecological Risk Assessment 8:1657-1673.
10.Burton, G.A., Jr.,
G. E. Batley, P.M. Chapman, V.E. Forbes, E.P. Smith, T. Reynoldson, C.E. Schlekat,
PJ. den Besten, AJ. Bailer, A.S. Green and R.L. Dwyer. 2002. A Weight-of-Evidence Framework for
Assessing Sediment (Or Other) Contamination: Improving Certainty in the Decision-Making Process.
Human and Ecological Risk Assessment 8:1675-1696.
Expertise Summary
Dr. Burton is an Environmental Sciences Professor of Research and Director ofthe Institute for
Environmental Quality at Wright State University. He obtained a Ph.D. degree in Environmental Science
from the University
of Texas at Dallas in 1984. From 1980 until 1985 he was a Life Scientist with the U.S.
Environmental Protection Agency. He was a Postdoctoral Fellow at the National Oceanic and Atmospheric
Administration's Cooperative Institute for Research in Environmental Sciences at the University
of
Colorado. Since then he has had positions as a NATO Senior Research Fellow in Portugal and Visiting
Senior Scientist in Italy and New Zealand. Dr. Burton has served on numerous national and international
scientific committees and review panels, has had approx. $4.8 million in grants and contracts, and over
150
publications dealing with aquatic system responses to stressors.
See also: http://wvvw.wright.edul-allen.burtonlburton

Institute for Environmental Quality
064 Brehm Lab
3640 Colonel Glenn Hwy.
Dayton, OH 45435-0001
(937) 775-2201
(FAX (937) 775-4997
email: ieqstaff@wright.edu
October 14, 2003
Julia P. Wozniak, Senior Biologist,
Midwest Generation EME, LLC
One Financial Place
440 South LaSalle Street
Suite 3500
Chicago, IL 60605
Re: Position Paper for the Upper Illinois Waterway UAA Draft Report
Dear Julia:
Attached is the position paper you requested. I will be
in
the office all week, but out Oct 18-23 if
you have any questions or comments.
Sincerely,
G. Allen Burton, Jr., Professor and Director

2
Review of the Lower Des Plaines River Use Attainability Analysis
(UAA) Draft Report
by
G. Allen Burton, Jr.
October 14, 2003
Introduction
I have been asked by Midwest Generation to review and comment on the UAA Draft Report
(AquaNova
&
Hey 2003). Relatively late in the process of the 1990'sUpper Illinois Waterway
(UIW) Task Force process, I was asked to evaluate the role of sediment quality on the UIW. So,
in the mid-1990's I led some evaluations of water and sediment quality on the Des Plaines River
for Commonwealth Edison (Burton, 1995, 1998; Burton and Brown 1995). These studies
involved evaluations of sediment contamination and toxicity on the upper
~55
miles ofthe UIW,
reviews of the literature on temperature, turbidity and barge traffic effects,
in situ
toxicity
evaluations around the Joliet power stations, and laboratory evaluations oftemperature effects.
Some of these studies have been heavily cited in the draft UAA, but there was not a balanced
presentation ofthe data and, in many cases, misinterpretations of the conclusions.
My area of expertise is in the evaluation of freshwater ecosystem stressor effects, particularly
focusing on the role of sediment and stormwater quality (Appendix 1). Therefore, my review of
the UAA report deals with the stressors in the UIW and their role in biological impairment,
focusing on sediments and stormwaters and inter-relationships ofother key waterway factors.
Any evaluation of aquatic ecosystem quality is complex with numerous assumptions and
uncertainties that confound the decision-making process. The evaluation requires an
interdisciplinary approach and understanding of how dominant physical, chemical and biological
factors interact. This dictates that state-of-the-science approaches be used that generate an
adequate level of quality data and that the associated uncertainties and assumptions be clearly
understood and stated. The current consensus is that reliable "weight-of-evidence" based
approaches are necessary in environmental quality assessments, providing for sound decision-
making
(e.g.,
Burton
et aZ.
2002ab). These approaches should characterize the key "exposure"
and "effects" components of the ecosystem using reliable and quantitative approaches where
reference conditions, dominant stressors, and their risk is clearly defined for the users.
Unfortunately, this important process was not followed in the draft UAA.
The Des Plaines Watershed
A wealth of data exists on the Des Plaines River and its watershed.
It
covers nearly 855,000 acres
in Lake, Cook, DuPage and Will counties. The majority of Chicago'smetropolitan area drains
into the Des Plaines River and its tributaries. Much ofthe current data has been summarized by
the Illinois Environmental Protection Agency (IEPA)
in
their recent 305(b) Water Quality Report
(IEPA 2002). This human-dominated watershed is characterized primarily by urban and
agriCultural land uses (AquaNova
&
Hey 2003). The river is effluent dominated, receiving
municipal wastewaters from many cities, including the 3
rd
largest in the nation. The municipal
wastewater constitutes more than 90% of the low flow during the winter. The IEPA 305(b) and
303(d) reports identify priority organics, nutrients, metals, pathogens, ammonia, siltation and
habitat alteration as the potential causes of water quality problems. The quality of the Des
Plaines River ranks among the worst, with the 2
nd
highest number of impaired reaches (66;
USEPA 303d Fact Sheet). In the 18 reaches assessed in the IEPA 2002 305b report, all had
impaired uses, averaging 8 causes of impairment per reach (145 total). Of the 58 beneficial uses
on the 18 assessed reaches, 52 were impaired and 66% had fish consumption advisories. Greater
than 50% ofthe Des Plaines River reaches average over 12 different causes of impairment. The

3
only causes of use impairment that were not identified in the Des Plaines were thermal
modification, pathogens, algal/plant/exotic species, new age pesticides and dioxin (likely not
analyzed for), pH and a few inorganic chemicals (!EPA 2002 305(b)). The dominant stressors
and the percentage of reaches where they were identified as a problem are: metals (100%),
nutrients (56-61%), PCBs (44%), flow alteration (44%), suspended solids (39%), organic
enrichment (33%), low dissolved oxygen (33%), and TDS (33%). Though not identified as
impairment causes, pathogens and new age pesticides are also likely problems in the Des Plaines
River, since these have been identified as always being elevated in all human dominated
waterways (USGS 1999; USEPA 2000). The high degree of impairment and the multiple causes
are to be expected, based on the dominance of human activities and the limited nonpoint source
runoff controls in the watershed. In fact, these dominant stressors and the resulting biological
impairments are similar to other waterways that are human dominated (e.g., Burton
et al.
2000;
Burton and Pitt 2001).
The unique nature ofthis watershed makes the critically important issue of reference waterway
selection difficult. The reality is that the Des Plaines watershed is one of the most heavily
human-dominated waterways in the nation. This will not change. Less than 5% ofthe UIW has
been identified as riverine habitat, with average habitat scores ranked as poor. Habitat is poorest
in the Lockport, Brandon and Dresden Pools and the dominating main channel habitat area. Most
of the habitat factors causing the poor ranking are irreversible (ComEd 1996). Comparing this
waterway to one that is dominated to lesser degrees by better habitats or urban inputs
(e.g.,
Kankakee River) implies that the Des Plaines can be improved to a similar state; which would
require massive urban NPS controls and habitat restoration, at a minimum. While there is little
doubt the quality of the Des Plaines can be improved, it will always be a heavily modified
waterway and never be of high quality. Until the stressors that dominate the beneficial use
impairments (identified above) are reduced significantly, human and ecological risks will persist.
Sediment Quality
It
is well known that chemicals (nutrients, synthetic organics and metals) and pathogens tend to
associate with solids due to polar and nonpolar binding affinities (Burton 1992). Therefore, those
sediments that have greater surface areas (clays, silts, colloids) will accumulate the greatest
concentrations, and thus serve as both a sink and a source of contamination. Indeed,
contaminated sediments are the cause of use impairment of 42 Great Lakes Areas ofConcem and
the dominant cause for Superfund site designation in our waterways. Depositional sediments are
not stationary and continue to contaminate resident organisms and downstream waters
via
common fate processes, such as resuspension, advection, bioturbation and diffusion. These issues
have been at the heart oft1].e Fox and Hudson River cleanups. All of these fate processes exist on
the Des Plaines River and vary spatially and temporally. While overlying water quality can be
relatively good
(i.e.,
meet water quality standards), contaminant concentrations will steadily
increase in depositional sediments and provide an environment for bioaccumulation in benthic
organisms. The U.S. Environmental Protection Agency (USEPA) has shown dramatic
correlations between fish tissue consumption advisories and sediment contamination. On the Des
Plaines, 66% of the reaches assessed in the 305(b) report have fish consumption advisories and
the levels of PCBs found in sediments suggest a substantial risk exists to those consuming fish
from the Des Plaines River.
Contamination ofthe Des Plaines River sediments is not strictly historical and is on-going.
Nutrients, metals, pathogens and synthetic organics (primarily polycyclic aromatic hydrocarbons
(PAHs) and new age pesticides) are common constituents of both point and nonpoint source
loadings in waterways such as the Des Plaines (Burton and Pitt 2002; USGS 1999). Therefore,
removal of significantly contaminated and acutely toxic sediments from depositional areas

4
identified throughout the UIW (Burton 1995), would provide but a temporary improvement. The
hydrologic conditions and source loadings would eventually result in contaminated sediments re-
accumulating since the myriad of sources will not be removed.
There are no reliable data establishing a trend of improving sediment quality, contrary to
statements made in the UAA report.
It
was established by previous studies that extreme spatial
heterogeneity exists in the UIW and is related primarily to sediment particle size and navigation
channel
vs.
depositional areas. Spatial heterogeneity is a major issue in the assessment of
sediment quality (USEPA 2001; Burton 1992) and can vary by orders of magnitude over
horizontal and vertical distances of centimeters. There is no indication that this site-specific
variation was characterized in the data being evaluated for trends. Indeed, the concentrations of
organic contaminants in the depositional sediments of the UIW exceed reliable sediment quality
guidelines (SQGs) for probable adverse biological effects (Table 1). The UAA report discussion
of sediment criteria is based on an antiquated ranking approach and fails to use accepted sediment
quality guidelines that have been applied in numerous regulatory situations throughout the U.S.
(Wenning and Ingersoll 2002).
It
is naIve and clearly not appropriate from a scientific
perspective to attempt to predict metal availability in the manner being proposed by Ambrose.
Ambrose
(I
999) is cited heavily suggesting a partitioning approach for metals concentrations in
pore waters, but is a draft document that is 4 years old and has not been supported by the peer
reviewed literature. The use of a 75
th
percentile to convert marine to freshwater values also has
no scientific basis.
The peer-reviewed literature and approved USEPA approaches should be used for the UAA
decision making process (Wenning and Ingersoll 2002). The 4
th
paragraph on p. 3-23 is full of
inaccurate statements regarding use ofWQC for sediment assessments, regarding prediction of
sediment toxicity and benthic
vs.
water column organism sensitivity. More importantly, widely
used SQGs are exceeded, suggesting these sediments are highly contaminated and are likely to
cause adverse biological effects.
There are no sediment toxicity data to refute the idea that these sediments are acutely toxic.
Contrary to what is stated in the UAA report, the USEPA data of2001 suggests the depositional
sediments are still highly contaminated and acutely toxic (Table 1). These sediments exceed the
respected SQGs known as Probable Effects Levels (PEL) for a multitude of organic chemicals
which have been shown to be accurate
~70%
of the time
(e.g.,
Buchman 1999; McDonald
et al.
2000ab). Since the USEPA'smore recent survey found highly contaminated depositional
sediments similar to what we found in the mid-90's (Burton 1995), it is likely that depositional
sediments are not being cleaned out. As discussed above, these sediments are being routinely
contaminated from urban, residential, transportation and agricultural runoff and a wide variety of
small to large point sources (Burton and Pitt 2001; Burton
et al.
2000). These sources will
continue to contaminate the depositional sediments and, as these sediments are resuspended they
will continue to contaminate the more biologically sensitive and productive lower reaches of the
Illinois River system. The authors of the draft report do not establish that the highly
heterogeneous sediments are improving. They do not establish that sediments over a multi-year
period were sampled from the exact same locations (as required for trend evaluations) and imply
that data originating from navigational sediments (poor fish habitat) that are clean can be
compared to depositional areas that are contaminated. There are no data adequate for trends
analyses of sediment contamination. Despite their contention that sediments are cleaner, they still
exceed that of many Superfund sites and are highly likely to produce toxic effects. Figures 3.6-
3.8 do not show the many problem stressors and do not indicate sediment spatial
heterogeneity~

5
The draft UAA report (p. 3-8) states that main channel sediments are non-toxic, which would be
expected
of sand, gravel, cobble sediments. However most depositional sediments showed acute
toxicity and lie in the limited habitat areas for fish. The main channel is
not primary habitat and
not suitable for spawning. Indeed the prime habitat for spawning, below Brandon Lock
&
Dam
tailwaters is contaminated. These shallow areas allow for photoinduced-toxicity of low ugIL
(ppb) levels
ofPAHs, contrary to the incorrect statements in the report (p. 3-8). The
photoinduced
PAHs will be toxic to zooplankton, benthic macroinvertebrates, fish and
amphibians in surficial layers
of waters throughout the UIW. This phenomenon is well cited in
the peer-reviewed literature
(e.g.,
Hatch and Burton 1998, 1999; Ireland
et al.
1996). The limited
citations (p. 3-35-36) for PAH toxicity fail to recognize the wealth
ofliterature that documents
P
AH contamination in urban waterways that is toxic in the low ppb level in waters and in the ppm
level in sediments. The UIW has significant areas
of biological productivity that are shallow
«1m depth) and thus subject to photoinduced PAH toxicity.
In
addition, the levels found in the
sediments are high enough to cause acute toxicity without
UV stimulation, with or without carbon
loadings, based on accepted SQGs.
SQGs are
but one of the lines-of-evidence that are used in an assessment of ecosystem quality.
Other important
LOE include indigenous biota, toxicity and bioaccumulation, and habitat
conditions.
Only when each LOE is comprised of high quality data from an adequate design to
characterize spatial and temporal conditions, can it be used with confidence in a weight-of-
evidence evaluation (Burton
et al.
2002b). In addition, the dynamic nature of aquatic systems for
both contaminants and organisms dictates that data be collected concurrently in order to link
stressor exposures with biological responses. Unfortunately, the
data used for much ofthe UAA
does not allow for quantitative analyses
ofthe separate lines-of-evidence, or their quantitative
integration into a weight-of-evidence based decision.
The
ammonium text (p. 3-13 - 15) and resulting conclusions are misleading. Ammonium is
typically considered to be the ionic form, while the term ammonia is inclusive
of both the ionic
(dominant species) and unionized (NH
4
0H) forms. The unionized form is more toxic to some
species, such as rainbow trout, but not others
(e.g., Hyalella azteca).
All ammonia is not oxidized
in the upper aerobic layer as stated (p. 3-14); otherwise there would
be no sediment related
ammonia toxicity. Ammonia originating in sediments can affect benthic organisms and pass into
overlying waters via porewater movement (advection), bioturbation, loss
ofgas bubbles, sediment
disturbance and diffusion (Wetzel 1983).
To imply that the aerobic layer provides a virtual cap
for
ammonia and to suggest that benthic organisms are not affected by ammonia in sediments is
scientifically unjustified, overly simplistic and refutes site-specific data.
NitrifYing bacteria have
a wide temperature tolerance range
(1 to 37° C). Nitrification continues down to dissolved
oxygen levels
of 0.3 mgIL and is dominated by heterotrophic nitrifYing bacteria found in both
aerobic and anaerobic waters. However, nitrification is greatly reduced
in undisturbed sediments
because oxygen is typically low
or absent (Wetzel 1983). So, as long as there continues to be high
loadings
of natural organic compounds and suspended solids, there will be ideal environments in
the
UIW for ammonia production. Ironically, the closing paragraph of the section (p. 3-15) states
"This discussion ofthe ammonium toxicity in sediment by no means tries to downgrade the
concerns about
the toxicity of the sediments and ammonium in particular. However, stressors or
a combination of stressors other than ammonium may be responsible for the low biotic integrity
ofthe Brandon Road and Dresden Island pool..."; which is absolutely correct!
The
UAA report fails to show the high levels of contaminants found in previous ComEd studies
from virtually all depositional sediments along the UIW. It also fails to point out that ammonia
was found to
be one of the primary toxicants (as suggested in the Lawler
et al.
report) and its
statistically significant correlation with sediment toxicity, particle size and organic contaminants

6
(Burton 1995). The discussion fails to point out the toxicity noted in waters and sediments not
impacted by thermal plumes. In addition, the majority of the data from the Wright State
University studies pointed to ammonia toxicity as a primary stressor.
Hyalella azteca
showed
greater effects, as would be predicted, since it is epibenthic and in closer proximity to higher
ammonia concentrations (and other contaminants co-existing in the sediment). So the UAA
report's statements that ammonium did not affect the survival or that no proof are provided are
both incorrect and puzzling. There are at least 3 lines of evidence showing ammonia is a major
stressor throughout the UIW.
Ceriodaphnia dubia
survival was affected by turbidity as would be expected (Burton 1998).
Filter feeding zooplankton are known to be sensitive to suspended solids at levels of 50-1 00 mgIL
(e.g.,
IEQ 1995). This dominant stressor ofthe UIW likely impacts zooplankton populations
throughout the waterway and is aggravated by barge traffic.
Another sediment contamination concern is that of pathogen risk. Nutrient rich, depositional
sediments allow for extended survival of pathogens (Burton
et al.
1987). Survival can extend for
months and as sediments are resuspended, serve as a potential source of human risk. Fecal
coliform is the most commonly violated NPDES permit limit (USEPA 2002). The large amount
of muniCipal wastewater effluent and untreated stormwater runoff from urban, residential and
agricultural areas will always comprise a high loading potential for pathogens in waters and
sediments of the UIW.
The Toxicity Identification Evaluation (TIE) results also suggested ammonia and PAHs as
primary toxicants (Burton 1998). The authors ofthe UAA report imply that pore water toxicity is
greatly reduced by various complexing agents. This is true sometimes and not others, depending
on the sediment's physical and chemical characteristics, species type and life history, feeding
characteristics, the residence time ofthe pore water, and the microbial communities and their
indigenous activities (Burton 1991, 1992). Obviously pore water concentrations are predictive of
effects to overlying biological communities, because the USEPA has based their sediment quality
guidelines of equilibrium partitioning on this assumption.
It
is curious as to why the UAA focuses on copper.
It
is but one of the potential stressors, and an
unlikely one at that.
Tubifex
is not the most sensitive benthic species to Cu as stated, rather the
epibenthic amphipod
Gammarus
is (Brix
et al.
2001). Cu is likely unavailable, as pointed out in
our studies and due to the existing hardness, solids, and organic ligands available.
Tubifex
is
quite resistant to the organic chemical pollutants and ammonia that exist in the UIW. The UAA
report recommends Tubifex for toxicity evaluations of the UIW; however, it is not an organism of
choice for testing and has not been recommended by the USEPA (USEPA 2000).
A substantial concern exists for the data gaps that will likely show even greater contamination
and biological impact. The concentrations of compounds that highly bioaccumulate (chlorinated
pesticides and PCBs) are excessive (higher than many Superfund sites) and have undoubtedly
contaminated the indigenous biota. Fishing is common on the lower UIW, yet likely poses a
health risk. In addition, no data are provided for the "new age" pesticides that are currently being
used in this large watershed. We know that the new age pesticides and nutrient contamination
have occurred in every studied urban and agricultural watershed of the US with elevated sediment
and fish tissue levels (USGS 1999). In addition, pharmaceutical and personal care products
(PPCP) are also common from urban waterways and have been shown to impact fish reproduction
via
hormonal disruption; however, no data are available on these likely contaminants.

7
TABLE 1. Sediment Threshold and Probable Effect Levels (ug/Kg) vs. USEPA UIW
Sediment Survey Data*
Compound
Dieldrin
Endrin
DDT
Heptachlor epoxide
PCB (total for TELIPEL)
Chlordane
Anthracene
Fluoranthene
Fluorene
Benzo(a)anthracene
Napthalene
Phenanthrene
Benzo(a)pyrene
TEL**
2.8
2.7
6.9
0.6
34.1
4.5
5.9
III
21
32
35
42
32
PEL**
6.7
62.4
4,450
2.7
277
8.9
128
2,355
144
385
391
515
782
UIW Sediment
7.5
7.0
20
10
600-16,000 for an individual congener
5
2,000
10,000
2,000
5,000
900
4,000
5,000
*
Des Plaines River sediment data taken from Tables 3.8, 3.9, 3.14 and 3.15.
**
Based on 1%
TOC.
Carbon data not available for UIW normalization. Other relevant SQGs could
be used (e.g., AETs, ERLs/ERMs, C-TEC/C-EEC) showing similar exceedances.
Stormwater Quality
It
is implied that because ofwatershed and MWRDGC improvements (including TARP) that
there are no significant inputs
of contaminants and contaminated solids. However, most urban
waterways do not have CSOs and still have these same stressors and degraded biological
communities, as discussed above.
The sheer magnitude of urbanization and agriculture in the
watershed and lack
of effective NPS controls dictates that NPS-related degradation will be a
dominant source
of impairment for decades. This is not surprising since it is the leading cause of
water quality problems in the U.S. (USEPA 2002). While the recent and near-future
improvements from TARP are noteworthy, this still is a highly impacted waterway, being effluent
dominated and receiving massive amounts
of untreated NPS runoff containing a wide range of
nutri~nts,
pathogens, metals, petroleum products, "new-age" pesticides and PPCP many of which
are known to be toxic at the part-per-trillion level and/or hormone disruptors (Burton and Pitt
2001; Burton
et al.
2000). Stormwaters in streams are often acutely toxic (Burton
et at.
2000;
Burton and Pitt 2001; Hatch and Burton 1999; Tucker and Burton 1999). In addition to the
chemicals, massive loadings
of solids erode from urban, construction and agricultural lands and
constitute the number one pollutant of river systems (USEPA 2002; Burton and Pitt 2001). Most
ofthe stressors have been already identified by the IEPA as the causes of impairment on the Des
Plaines. Other stormwater issues are discussed in the preceding and following text.
Temperature
It
is noteworthy that thermal modifications have not been identified as one of the 23 impairment
causes on the Des Plaines River (IEPA 2002). While temperature can certainly be a stressor, a
literature review found that warm temperatures can be both advantageous and detrimental to
aquatic biota (IEQ 1995). Another concern not discussed in the UAA Report
is that there are
winter maximum temperatures which are impacted by municipal wastewater effluents and may
impede some fish reproductive processes. The "Selection
of the Temperature Standard" and
"Critique of the Current Secondary Contact and Indigenous Aquatic Life Standard" sections have
inaccurate statements regarding temperature effects on riverine species and ecosystem processes.
High and low temperatures
mayor may not be detrimental to aquatic life that resides in the UIW.
There
is not a simple relationship, as noted from many past studies
(e.g.,
Cairns
et at. 1973;

8
Cairns
et
at.
1978; review by Burton and Brown 1995). Both low and high temperatures can
increase and decrease toxicity due to exposures from other chemical stressors, such as found in
the UIW, and is both species and toxicant type and concentration dependent. The UAA report's
over-simplification that high temperatures increase toxicity is simply incorrect. Nitrification is
also inhibited by cold temperatures and ammonia is not always consumed in the upper sediment
layers. Nitrification is very sensitive to toxicants, which abound in the UIW's depositional
sediments. The authors incorrectly imply that high temperatures are always detrimental by
focusing on negative impacts and over generalizing.
Blue green algae are not a concern on the UIW due to its flow conditions. Toxic cyanobacterial
blooms are common to pond, lake and reservoir ecosystems. So, many of the "Negative"
examples used on p. 2-93 do not apply to the UIW, yet their presentation implies that they do.
On p. 2-97 the subsection title is "Experiments by Wright University to Establish Temperature
Limits". My study at Wright State University did not attempt to establish temperature limits for
the UIW. The discussion of my study is misleading, leaving out key portions of the conclusions
and misinterpreting others. Our findings substantiated previous studies by my laboratory and
others. The key findings documented that acute toxicity exists in short-term exposures to
multiple species in waters and sediments of the UIW without any temperature elevation. Toxic
sediments abound in most tributary mouth, tailwater, and pool depositional areas, which include
the better (but limited) habitats for fish. These same habitats are typically shallow waters which
are subject to rapid mortality as a result of photoinduced toxicity ofPAHs, as discussed above.
Both cold and hot temperatures accentuated toxicity originating from UIW waters and sediments.
Statistically significant correlations between sediment ammonia and fluorene concentrations and
toxicity were observed. Ammonia was also significantly correlated to depositional sediments and
the presence of high concentrations of organics. These correlations were based on sediment data
collected from throughout the UIW.
In situ
toxicity was not observed due to temperature outside
the thermal discharge plume.
The laboratory toxicity test results produced by our studies further document the role of sediment
toxicity and how it is increased in the presence oftempeniture extremes. The Toxicity
Identification Evaluation Phase I experiments further substantiate the findings ofthe Chemical
Screening Risk Assessment and the ammonia correlations with toxicity, suggesting that ammonia
is a primary system stressor to benthic and epibenthic species. However, these 7 day, static
renewal experiments do not adequately mimic dynamic,
in situ
conditions where light,
temperature, turbidity, water quality and food conditions change over minutes to hours. The most
reliable indicator of
in situ
conditions is the indigenous communities. Benthic and fish
community data show populations thriving despite the highly modified nature of the waterway.
These are the most reliable data for evaluations of thermal impacts.
UAAFactors
Contrary to the conclusions of the UAA report, the current and future status of this watershed and
the data clearly show that several UAA factors are met. The rationale supporting the statements
below are provided in the text above and literature citations; and through a weight-of-evidence
based, decision-making process involving the following 12 lines-of-evidence: magnitude ofSQG
exceedances, prevalence of sediment contamination, likelihood of continuing sediment
contamination, extreme degraded status of waterway compared to others in the nation, human
dominance of watershed, profuse NPS inputs, excessive habitat modification and degradation,
human risk from pathogens and fish consumption, toxicity levels in water and sediment,
correlations oftoxicity with chemical stressors, indigenous biotic indices, and excessive numbers
of use impairments throughout the watershed.

9
UAA Reasons Which Are Met:
Reason
1.
Naturally occurring pollutant concentrations prevent the attainment ofthe use:
Sometimes ammonia is considered a "natural" pollutant
(e.g.,
see USEPA/USACOE dredging
guidance). The weight-of-evidence suggests ammonia is a stressor of concern throughout this
waterway, with multiple point and nonpoint sources. Erodable soils are another pervasive
stressor contributing to siltation, embeddedness, and turbidity-related stress.
Reason 3. Human caused conditions or sources of pollution prevent the attainment of the use
and cannot be remedied or would cause more environmental damage to correct than to leave in
place:
This is the primary reason for not upgrading. The evidence of excessive impairments is clear
from the results of recent IEPA efforts (IEPA 305(b) and 303(d) reports). A multitude of
impairment causes and sources exist throughout the watershed as discussed and documented
above. These causes are unlikely to be significantly corrected.
Reason 4. Dams, diversions or other hydrologic modifications preclude the attainment of the use,
and it is not feasible to restore the water body to its original conditions or to operate such
modifications in a way that would result in the attainment of the use:
The waterway's habitat is heavily and permanently modified. Barge traffic will continue to be a
major use and will continue to result in degraded habitat, resuspended contaminated sediments
and a physical hazard to recreational users.
Reason 5. Physical conditions associated with the natural features of the water body, such as the
lack of proper substrate, cover, flow, depth, pools, riffles and the like, unrelated to quality
preclude attainment of aquatic life protection uses:
See rationale for Reason 4 above. Habitat is of poor quality through most ofthe UIW and cannot
be significantly corrected.
Reason 6. More stringent controls than those required by Sections 301(b) and 306 ofthe CWA
would result in substantial and widespread adverse social and economic impact:
It
is simply impossible to remove the many and widespread impairment sources or substantially
improve their quality (including NPS), which have been identified by the IEPA and USEPA,
without severe social and economic impact.
Conclusions
An extensive database exists on the UIW concerning its physical, chemical, biological and
toxicity characteristics. These multiple lines-of-evidence clearly establish this is a highly
modified waterway that has poor habitat, is effluent dominated and receives massive amounts of
untreated, nonpoint source runoff. Despite the many stressors that exist (and will continue to
exist) in this waterway, a thriving fish community exists which runs contrary to the UAA report
predictions of lethality. This line-of-evidence is a direct measure of indigenous biota and their
ability to exist under the current conditions ofthe UIW. The toxicity studies conducted by my
laboratory used worst-case exposure conditions for early life stages oftwo surrogate species.
These results documented acute toxicity in UIW water and sediment and that high and low
temperatures may accentuate the pervasive level of toxicity to these surrogate species. Other
laboratory-based research by Cairns
et aI.,
(1973, 1978) has shown the complexity of temperature
and chemical interactions in organisms which refute the simplistic conclusions ofthe UAA
report. Laboratory-based results require extrapolation to field conditions and indigenous benthic
and fish communities, which have been thoroughly characterized in the UIW and are the most
important line-of-evidence. Depositional sediments throughout the UIW are contaminated with

10
levels of multiple contaminants that, in many locations, pose a hazard to aquatic biota, wildlife
and humans. Major nonpoint source loadings of solids, nutrients, metals, and organics will
continue from small to major urban areas, sewers, construction, and agriculture in this human-
dominated watershed. Modified and limited habitats (channelization, barge traffic, lock and
dams), extreme turbidity and siltation, and stressor loadings will not improve in the foreseeable
future and will continue to dominate water quality conditions and use impairments. Development
of new, modified standards will not address the key issue of excessive and pervasive pollution
sources, excessive use impairments and limited habitats in this watershed.
The draft UAA report conclusions are quite misleading. The presentation of data, data
interpretation, and supporting statements are often biased and fail to provide a scientifically-
balanced representation of previous Upper Illinois Waterway (UIW) studies, peer-reviewed
literature and accepted approaches that are the state-of-the-science. As such, this document fails
to provide a scientific basis for an informed decision making framework for the UAA process.
References Cited
AquaNova International, Ltd. and Hey and Associates, Inc. 2003. Lower Des Plaines River Use
Attainability Analysis. Draft report prepared for the Illinois Environmental Protection Agency. Springfield,
IL. March.
Brix KV, DeForest DK, Adams WJ. 2001. Assessing acute and chronic copper risks to freshwater aquatic
life using species sensitivity distributions for different taxonomic groups. Environ Toxicol Chern 20:1846-
1856.
Buchman MF 1999. NOAA Screening Quick Reference Tables, NOAA HAZMAT Report 99-1. Seattle
WA.
Burton, G.A., Jr., D. Gunnison and G.R. Lanza. 1987. Survival
of enteric pathogens in freshwater
sediments. App!. Environ. Microbio!. 53: 633-638.
Burton, G.A., Jr. 1991. Assessing freshwater sediment toxicity. Environ. Toxico!. Chern. 10:
1585-1627.
Burton, G.A., Jr. 1992. Sediment Toxicity Assessment. Lewis Publishers. Boca Raton,
FL. 457 P
Burton, G.A., Jr. 1992. Sediment collection and processing: factors affecting realism. In, Sediment
Toxicity Assessment. Lewis Publishers. Boca Raton, FL. pp. 37-66.
Burton, G.A., Jr. 1992. Assessing contaminated aquatic sediments
(a two part feature series - Special
Editor). Environ. Sci. Techno!. Vo!. 26:1862-1863.
Burton, G.A., Jr. 1995. The Upper Illinois Waterway Study, 1994-1995 Sediment Contamination
Assessment Final Report. Commonwealth Edison, Co., Chicago, IL.
Burton, G.A. Jr. 1998. The Upper Illinois Waterway Ecological Survey: Continuous
In Situ
Toxicity
Monitoring and Thermal Effect Characterization Tasks. Commonwealth Edison Corp. Chicago, IL.
Burton, G.A., Jr. 2002. Sediment quality criteria
in use around the world. Limnology 3:65-76.
Burton, G.A., Jr. and H. Brown. 1995. Reviews
ofthe Literature Concerning: 1) Effects ofTemperature on
Freshwater Fish, 2) Effects on Freshwater Biota from Interactions
of Temperature and Chemicals, and 3)
Effects ofTurbidity and Barge-Traffic on Aquatic Ecosystems. Commonwealth Edison, Co. Chicago, IL.

11
Burton, G.A., Jr., and R. Pitt. 2001. Stormwater Effects Handbook: A Tool Box for Watershed
Managers, Scientists and Engineers. CRC/Lewis Publishers,
Boca Raton, FL, 924 pp.
Burton, G.A., Jr., R. Pitt, and S. Clark. 2000. The role ofwhole effluent toxicity test methods in
assessing stormwater and sediment contamination. CRC Critical Reviews in Environmental
Science
&
Technology 30: 413-447.
Burton, G.A., Jr., P. Chapman, and E. Smith. 2002. Weight
of Evidence Approaches for Assessing
Ecosystem Impairment. Human and Ecological Risk Assessment 8:1657-1673.
Burton, G.A., Jr.,
G. E. Batley, P.M. Chapman, V.E. Forbes, E.P. Smith, T. Reynoldson, C.E. Schlekat,
P.J. den Besten, A.J. Bailer, A.S. Green and R.L. Dwyer. 2002. A Weight-of-Evidence Framework for
Assessing Sediment (Or Other) Contamination: Improving Certainty in the Decision-Making Process.
Human and Ecological Risk Assessment 8:1675-1696.
Burton GA, Jr., Rowland CD, Greenberg MS, Lavoie DR, Nordstrom JF, Eggert LM. 2003. A tiered,
weight-of-evidence approach for evaluating aquatic ecosystems,
in, M. Munawar (ed.), Sediment Quality
Assessment and Management: Insight and Progress, 2003 Ecovision World Monograph Series, Aquatic
Ecosystem Health and Management Society Pub\., Hamilton, Ontario. pp. 3-21.
Cairns
11 Jr, Buikema AL Jr, Heath AG, Parker BC. 1978. Effects oftemperature on aquatic organism
sensitivity to selected chemicals. Virginia Water Resources Research Center. Bulletin 106. Blacksburg, VA
Cairns
11 Jr, Heath AG, Parker BC. 1973. The effects oftemperature upon the toxicity of chemicals to
aquatic organisms. Report to Congress by the Environmental Protection Agency. Part 3. Serial No. 93-14.
Washington DC.
ComEdo 1996. Aquatic Ecological Study ofthe Upper Illinois Waterway. Final Report. Chicago, IL.
Greenberg, M.S., G.A. Burton, Jr., P.B. Duncan. 2000. Considering Groundwater-Surface Water
Interactions in Sediment Toxicity Assessment. SETAC Globe. March, April, pp. 42-44.
Hatch, A.C. and G.A. Burton, Jr. 1998. Effects
ofphotoinduced toxicity offluoranthene on amphibian
embryos and larvae. Environ. Toxico\. Chern. 17:1777-1785.
Hatch, A.C. and G.A. Burton, Jr. 1999. Sediment toxicity and stormwater runoff
in a contaminated
receiving system: Consideration
ofdifferent bioassays in the laboratory and field. Chemosphere 39:1001-
1017.
Hatch, A.C. and G.A. Burton, Jr. 1999. Photoinduced toxicity
ofPAHs to
Hyalella azteca
and
Chironomus
tentans:
Effects
of mixtures and behavior. Environmental Pollution106: 157-167.
Illinois Environmental Protection Agency. 2002. Illinois Water Quality Report 2002. Bureau
of Water.
Springfield, IL.
Ireland, D.S., G.A. Burton, Jr., and G.G. Hess. 1996.
In Situ
toxicity evaluations
of turbidity and
photoinduction
of polycyclic aromatic hydrocarbons. Environ. Toxico\. Chern. 15:574-581.
MacDonald DD, CG Ingersoll and TA Berger. 2000a. Development and evaluation ofconsensus based
sediment quality guidelines for freshwater ecosystems. Arch Environ Contam Toxico!. 39:20-31.
MacDonald DD, LM DiPinto, J Field, CG Ingersoll,
ER Long and RC Swartz. 2000b. Development and
Evaluation
of consensus-based sediment effect concentrations for polychlorinated biphenyls. Environ.
Toxicol Chern. 19:1403-1413.
Tucker, K.A. and G.A. Burton, Jr. 1999. Assessment
ofnonpoint source runoff
in
a stream using
in situ
and laboratory approaches. Environ. Toxico\. Chern. 18:2797-2803.

12
U.S. Environmental Protection Agency. 2000. Methods for Measuring the Toxicity and Bioaccumulation of
Sediment-associated Contaminants with Freshwater Invertebrates. 2
nd
Edition. EPA/600/R-99/064. Office
of Research and Development and Office of Water. Washington, DC.
U.S. Environmental Protection Agency. 2001. Methods for Collection, Storage and Manipulation
of
Sediments for Chemical and Toxicological Analyses: Technical Manual. Office of Water. EPA-823-B-Ol-
002. Washington, DC.
U.S. Environmental Protection Agency 2002. National Water Quality Inventory 2000 Report. Office
of
Water. Washington DC. EPA-841-R-02-001.
U.S. Geological Survey. 1999. The Quality
of Our Nation's Waters. Nutrients and Pesticides. USGS
Circular 1225. Reston, VA.
Wenning RJ and Ingersoll CG. 2002. Use
of sediment quality guidelines and related tools for the
assessment
of contaminated sediments. Executive summary of a Pellston workshop. Society of
Environmental Toxicology and Chemistry. Pensacola, FL.
Wetzel RG. 1983. Limnology, 2
nd
ed. Saunders College Publ., Philadelphia.

APPENDIXl
Resume
13
Position Title
Professor and Director,
Institute for Environmental Quality
Name
G. Allen Burton, Jr., Ph.D.
Education
Ouachita Baptist University
Auburn University
University
of Texas @ Dallas
University
ofTexas @ Dallas
B.S.
M.S.
M.S.
Ph.D.
1976
1978
1981
1984
Biology
& Chemistry
Microbiology
Environmental Sciences
Env. Sci. (Aquatic Toxicology)
Professional Positions:
1980-1984. Life Scientist. U.S. Environmental Protection Agency, Dallas, Texas
1984-1985. Visiting Fellow. Cooperative Institute for Research
in Environmental Sciences, University of
Colorado @ Boulder
1985-1990. Assistant Professor, Dept.
ofBiological Sciences, Wright St. Univ.
1990-1996. Associate Professor, Dept.
ofBiological Sciences, Wright St. Univ.
1985-present. Coordinator, Environmental Health Sciences Undergraduate Program, WSU.
1994-present, Director, Institute for Environmental Quality, WSU.
1996-present. Professor. Dept.
ofBiological Sciences, Wright St. Univ.
2000-2003. Brage Golding Distinguished Professor
ofResearch, WSU.
2002-2003. Director, Environmental Sciences
PhD. Program, WSU.
2003-present. Associate Director, Environmental Sciences Ph.D. Program, WSU.
Awards and Other Professional Activities (select):
1992-1999. U.S. EPA National Freshwater Sediment Toxicity Methods Committee
1994,2001. Visiting Senior Scientist, Italian Institute for Hydrobiology.
1994,1995,1998,1999. External Review Panel. Environmental Biology Research Program. Exploratory
Research. Office
ofResearch and Development, U.S. EPA.
1996. Visiting Senior Scientist, New Zealand Inst.
of Water and Atmospheric Research.
1994-1997. NATO Senior Research Fellow, University ofCoimbra, Portugal.
1993-1996. Board
ofDirectors, Soc. of Environmental Toxicology and Chemistry
2002. Meeting Chair. 5
th
International Symposium on Sediment Quality Assessment.
1999-2001. U.S. EPA Scientific Advisory Panel, Office
of Pesticide Programs
2001-2004, Editorial Board, Aquatic Ecosystem Health
&
Management and Chemosphere.
2000-2003. Brage Golding Distinguished Professor
of Research.
2003-2006. World Council, Society
of Environmental Toxicology & Chemistry
Recent
Projects (select):
U.S. Environmental Protection Agency, Office
of Exploratory Research. Sediment
contamination assessment methods: validation
of standardized and novel
approaches. 1997-2000.
U.S. Environmental Protection Agency. Office
of Exploratory Research. Intraspecies
genetic diversity measures
of environmental impacts. 1998-2001. Co-PI.
U.S. Environmental Protection Agency. Enhancement
of Environmental Communication
in the Lower Great Miami Basin: A Pilot Demonstration. 1999-2000. Co-PI.
City
of Dayton. Stormwater Quality Assessment of Wolf Creek. 2003.
U.S. Environmental Protection Agency (via USlnfrastructure, Inc.). Handbook for Assessing
Stormwater Effects on Receiving Waters. 2000.
U.S. Environmental Protection Agency Region I (via Tetra Tech EM, Inc.) Ecological Risk
Assessment
of Dick'sCreek, OR. 2000-2001.

14
U.S. Environmental Protection Agency (via Miami Valley Regional Planning Commission).
Enhancement
ofEnvironmental Communication in the Lower Great Miami Basin.
Continuation
of Pilot Demonstration.2001.
U.S. EPA (via Roy F. Weston). Sediment toxicity evaluation ofNyanza Superfund site. 2001.
U.S. Environmental Protection Agency Region I (via Tetra Tech EM, Inc.) Ecological Risk
Assessment
of Dick'sCreek, OH. 2000-2001.
American Chemical Counci!. A Diagnostic Approach for
IdentifYing Biological Impairment and
Dominant Stressors. 2001-2004.
International Lead Zinc Research Organization. Field Validation
of Sediment Zinc Toxicity for European
Union Zinc Risk Assessment. 2001-2003.
Nickel Producers Environmental Research Organization. Field Validation
of Sediment Nickel Toxicity for
the European Union Nickel Risk Assessment. 2003-2004.
Recent
Publications (select):
I. Chappie, D.J. and G.A. Burton, Jr. 2000. Applications
of Aquatic and Sediment Toxicity Testing
In Situ.
J. Soil and Sediment Contamination 9:219-246.
2. Burton, G.A., Jr., R. Pitt, and S. Clark. 2000. The role
of whole effluent toxicity test methods in
assessing stormwater and sediment contamination. CRC Critical Reviews in Environmental Science &
Technology 30: 413-447.
3. Burton, G.A., Jr., and
R. Pitt. 2001. Stormwater Effects Handbook: A Tool Box for Watershed
Managers, Scientists and Engineers. CRC/Lewis Publishers, Boca Raton, FL, 924 pp.
4. Baird, D. and G.A. Burton, Jr. (eds.) 2001. Ecosystem Variability: Separating Natural from
Anthropogenic Causes
of Ecosystem Impairment. Pellston Workshop Series. SETAC Press. Pensacola,
FL.
5. Greenberg, M., G.A. Burton, Jr., C.D. Rowland. 2002. Optimizing Interpretation
of
In Situ
Effects:
Impact
ofUpwelling and Downwelling. Environ. Toxico!. Chern. 21 :289-297.
6. Burton, G.A., Jr. 2002. Flux of Sediment-Associated Contamination. Fact Sheet on Environmental Risk
Assessment. International Council on Mining and Metals. London, UK.
7. Landrum, P.F., M.L. Gideon, G.A. Burton, M.S. Greenberg, C.D. Rowland. 2002. Biological responses
of
Lumbriculus variegatus
exposed to fluoranthene-spiked sediment. Archives of Environ. Contam.
Toxico!. 42:292-302.
8. Burton, G.A., Jr. , D.L. Denton, K. Ho, and D.S. Ireland. 2002. Test methods for measuring sediment
toxicity, In, Hoffman, D., et a!. (eds.), Handbook ofEcotoxicology, 2
nd
ed. CRC/Lewis Publishers,
Boca Raton, FL. pp. 111-150.
9. Burton, G.A., Jr., P. Chapman, and E. Smith. 2002. Weight
ofEvidence Approaches for Assessing
Ecosystem Impairment. Human and Ecological Risk Assessment 8:1657-1673.
1O.Burton, G.A., Jr., G. E. Batley, P.M. Chapman, V.E. Forbes, E.P. Smith, T. Reynoldson, C.E. Schlekat,
PJ. den Besten, A.J. Bailer, A.S. Green and R.L. Dwyer. 2002. A Weight-of-Evidence Framework for
Assessing Sediment (Or Other) Contamination: Improving Certainty
in the Decision-Making Process.
Human and Ecological Risk Assessment 8:1675-1696.
Expertise Summary
Dr. Burton is an Environmental Sciences Professor of Research and Director ofthe Institute for
Environmental Quality at Wright State University. He obtained a Ph.D. degree in Environmental Science
from the University
ofTexas at Dallas in 1984. From 1980 until 1985 he was a Life Scientist with the U.S.
Environmental Protection Agency. He was a Postdoctoral Fellow at the National Oceanic and Atmospheric
Administration's Cooperative Institute for Research in Environmental Sciences at the University
of
Colorado. Since then he has had positions as a NATO Senior Research Fellow in Portugal and Visiting
Senior Scientist in Italy and New Zealand. Dr. Burton has served
on numerous national and international
scientific committees and review panels, has had approx. $4.8 million
in grants and contracts, and over 150
publications dealing with aquatic system responses to stressors.
See also:
http://www.\vright.eduJ~aIlen.bUlionlburtol1

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