RECEIVED
C
LERK'S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
FEB 2 9 2008
P
STATE
ollution
OF
Control
ILLINOIS
Board
DISTRICT OF GREATER CHICAGO,
Petitioner,
v.
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
PCB 08-
41
NOTICE OF FILING
METROPOLITAN WATER RECLAMATION
TO:?
Clerk
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
PLEASE TAKE NOTICE that on Friday, Feb
.
Me" •
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11:
.
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Petition for NPDES Permit Appeal and Appearance
with the Clerk of the Pollution
Control Board, a copy of which is herewith served upon you.
METROPOLITAN WATER RECLAMATION
DISTRICT
,
OF GREA R CHICAGO,
Frederick M. Feldman,
Armsor))
its Attorney
Frederick M. Feldman
Ronald M. Hill
Lisa Luhrs Draper
Metropolitan Water Reclamation
District of Greater Chicago
100 East Erie Street
Chicago, IL 60611
(312) 751-6576
LLD:cb?
THIS FILING IS SUBMI'l 1ED ON RECYCLED PAPER
BY:
SUBSCRIBED and SWORN to before
me this 29th day of February, 2008.
(rtre..u:
ary Public
STATE OF ILLINOIS
) SS.
COUNTY OF COOK
CERTIFICATE OF SERVICE
I4A,b(1?
O_IikafttS4
I,
being duly sworn on oath, certify that I caused a copy
of the attached Petitioner's
Petition for NPDES Permit Appeal, PCB 08-
?
and
Appearance,
to be sent via first class U.S. Mail to the below named at their addresses as
shown, with proper postage prepaid, from 100 E. Erie Street, Chicago, Illinois, at or near the
hour of 4:00 p.m., this 29th day of February, 2008.
Clerk
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
OFFICIAL SEAL
ROSALIE BOTTARI
NOTARY PUBLIC - STATE OF ILLINOIS
MY COMMISSION EXPIRES:04/10/10
LLD: cb
THIS FILING IS SUBMITTED ON RECYCLED PAPER
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD CLERK
R EC
E
'S
OFFICE
IVED
FEB 2 9 2008
METROPOLITAN WATER RECLAMATION
DISTRICT OF GREATER CHICAGO,
Petitioner,
v.
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
STATE OF ILLINOIS
Pollution Control
Board
PCB 08-
41
APPEARANCE
I hereby file my appearance in this proceeding on behalf of the Metropolitan Water
Reclamation District of Greater Chicago.
Metropolitan Water Reclamation District
of Greater Chicago
rederick M. Feldman, Attorney
DATED: February 29, 2008
Metropolitan Water Reclamation
District of Greater Chicago
Frederick M. Feldman
Ronald M. Hill
Lisa Luhrs Draper
100 East Erie Street
Chicago, Illinois 60611
(312)751-6576
THIS FILING IS SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
R EC eivED
CLERK'S OFFICE
FEB 2 9 2008
STATE OF ILLINOIS
Pollution Control Board
Petitioner,
v.
?
PCB 08-
ish
ILLINOIS ENVIRONMENTAL PROTECTION )
AGENCY,
Respondent.
PETITION FOR NPDES PERMIT APPEAL
Petitioner, Metropolitan Water Reclamation District of Greater Chicago ("District"),
by its Attorney, Frederick M. Feldman, petitions the Illinois Pollution Control Board
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51
METROPOLITAN WATER RECLAMATION )
DISTRICT OF GREATER CHICAGO,
)
5/40(a), to grant the District a hearing to contest one or more of the conditions contained in
the NPDES peimit (NPDES No. IL0028070) issued by the Illinois Environmental Protection
Agency ("Agency"). Specifically, the District challenges the use of the value of 42 MGD
with respect to discharge number 002, which is contained in Special Condition 14.1.b. In
support hereof, the District states as follows:
1. On March 16, 2006, the District applied to the Agency for reissuance of its
existing permit to discharge from its Lemont Water Reclamation Plant ("Lemont WRP"),
located at 13 Stephen Street, Lemont, Illinois, to the Chicago Sanitary and Ship Canal. The
Agency subsequently prepared a draft permit, and the District submitted written comments
and objections thereto.
2.
The Agency issued a final permit on January 25, 2008, a copy of which is
marked Exhibit "A" and attached hereto. The permit is effective on February 1, 2008.
3.
The Lemont WRP is one of seven treatment plants operated by the District.
The Lemont WRP is a wastewater treatment facility incorporating the advanced activated
sludge process for the removal of water-borne pollutants. The current average design
capacity of the Lemont Plant is 2.3 million gallons per day (mgd) and the current maximum
design capacity is 4.0 mgd.
4.
The final permit contains one set of design flows (Design Average Flow
"DAF" and Design Max Flow "DMF") that reflect the current operating conditions and
capacity of the Lemont WRP as indicated above. The final permit also contains another set of
design flows (DAF and DMF), which the permit indicates are applicable only after the
proposed future expansion of the Lemont WRP is completed. An expansion of the Lemont
WRP was proposed by the District in an application for modification in March of 2006 in
recognition of studies indicating that the current capacities of the Lemont WRP as referenced
above will be insufficient to meet the needs of a sharply rising population in the Lemont
Basin. The District decided to expand the Lemont WRP to accommodate the anticipated
population growth in the area through the year 2020, and the final permit recognizes the
proposed expansion.
5.
Special Condition 14 of the permit authorizes the District to discharge to the
Chicago Sanitary & Ship Canal at one specified location, identified in the permit as discharge
number 002, without full treatment at the Lemont Plant. This particular outfall is designated
as a combined sewer overflow ("CSO").
2
6.
Special Condition 14.1.b. states that for outfall 002, "[a]dditional flows, up to
42 MGD,
shall receive a minimum of primary treatment and disinfection with adequate
retention time." (emphasis added).
7.
The 42 MGD value is not reflective of the average dry weather flow that is
currently being treated at the existing Lemont WRP. The 42 MGD value appears to have
been inserted in error in Special Condition 14.1.b. of the permit as 10 times the DAF of the
proposed
expanded
Lemont WRP. Inconsistent with other sections of the permit, Special
Condition 14.1.b. of the permit does not distinguish between existing plant capacity and the
proposed expanded plant capacity.
8.
Section 306.305 of Title 35 of the Illinois Administrative Code, regarding
"Treatment of Overflows and Bypasses," does not reference any specific DAF value as is
eluded in the
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only to "not less than ten times the average dry weather flow". That section states as follows:
Additional flows, as determined by the Agency but not less than ten times the average
dry weather flow for the design year, shall receive a minimum of primary treatment
and disinfection with adequate retention time;
9.
The District's Petition is based upon the fact that the permit condition is not
necessary to accomplish the purposes of the Illinois Environmental Protection Act and Board
regulations, or otherwise arbitrary and capricious.
10.
The District requested a review of Special Condition 14.1.b. during the
comment period. (See October 16, 2007 correspondence from MWRD to S. Alan Keller, a
copy of which is marked Exhibit "B" and attached hereto).
3
WHEREFORE, the Metropolitan Water Reclamation District of Greater Chicago
requests the Board to authorize a hearing and remand the decision to the Agency to reissue the
NPDES permit consistent with the concerns addressed in this Petition. Specifically, this relief
should include the following:
1.
Modify Special Condition 14.1.b. to indicate that the 42 MGD value is
applicable only after the start of operation of the proposed expanded Lemont WRP, or, in the
alternative,
2.
Modify Special Condition 14.1.b. to restate the language of Section 306.305 of
Title 35 of the Illinois Administrative Code regarding "ten times the average dry weather
flow."
Respectfully submitted,
Metropolitan Water Reclamation District
of Greater Chicago
Frederick M. Feldman, Attorney
DATED: February 29, 2008
Metropolitan Water Reclamation
District of Greater Chicago
Frederick M. Feldman
Ronald M. Hill
Lisa Luhrs Draper
100 East Erie Street
Chicago, Illinois 60611
(312)751-6576
THIS FILING IS SUBMI'TT'ED ON RECYCLED PAPER
4
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 NORTH GRAND AVENUE EAST, P.O. Box 19276, SPRINGFIELD, ILLINOIS 62794-9276 - ( 217) 782-3397
JAMES R. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601 - (312) 814-6026
217/782-0610
ROD R.
BLAGOJEVICH, GOVERNOR
?
DOUGLAS P.
SCOTT, DIRECTOR
JAN 2 5 2008
Metropolitan Water Reclamation District of Greater Chicago
100 East Erie Street
Chicago, Illinois 60611
Re:
Metropolitan Water Reclamation District of Greater Chicago
MWRDGC Lemont WRP
NPDES Permit No. IL0028070
Final Permit
Gentlemen:
Attached is the final NPDES Permit for your discharge. The Permit as issued covers discharge
limitations, monitoring, and reporting requirements. Failure to meet any portion of the Permit could
result in civil and/or criminal penalties. The Illinois Environmental Protection Agency is ready and
willing to assist you in interpreting any of the conditions of the Permit as they relate specifically to
your discharge.
The Agency has reviewed your comments dated September 28, 2007 and October 16, 2007 and
offers the following response:
1.
The Agency has received your letter dated September 28, 2007 indicating that the Lemont
Water Reclamation Plant (WRP) will be replaced with a new pump station and wet weather
reservoir and the effluent pumped via pipeline to the collection system that is tributary to the
Stickney WRP. A detailed engineering report, along with a basis of design for the proposed
piping and reservoir, must be submitted to the Agency prior to modification of the permit.
2.
After reviewing the current Pretreatment Streamlining Final Rule, Part 403 regulations, the
Agency has revised Special Condition 9.A.Lb as requested. A reference to the July 24, 1997
and September 27, 2005 Pretreatment Program Amendments has also been added to Special
Condition 9.A.8.
3.
Special Condition 9.c.2.a has been revised as requested.
4.
Special Condition 14.6 requires that a Pollution Prevention Plan be developed unless one has
already been prepared. The public information meeting and submission of documentation
are permit requirements that have been approved by USEPA. Therefore, this condition has
not been revised.
5.
Special Condition 14.8 has been revised to reflect the current status of the CSO operational
and maintenance plan.
6.
Special Condition 14.11 has been revised to be consistent with the existing reporting
requirements.
7.
Special Condition 14.12 has been revised to reflect the current status of the public
notification program.
ROCKFORD –
4302 North Main Street, Rockford, IL 61103 - (815) 987-7760 •
DES PLAINES –
9511 W. Harrison St., Des Plaines, IL 60016 - (847) 294-4000
ELGIN –
595 South State, Elgin, IL 60123 - (847) 608-3131 •
PEORIA –
5415 N. University St., Peoria, IL 61614 - (309) 693-5463
BUREAU OF LAND - PEORIA –
7620 N. University St., Peoria, IL 61614 - (309) 693-5462 •
CHAMPAIGN –
2125 South First Street, Champaign, IL 61820 - (217) 278-5800
SPRINGFIELD –
4500 S. Sixth Street Rd., Springfield, IL 62706 - (217) 786-6892 •
COLLINSVILLE – 2009
Mall Street, Collinsville, IL 62234 - (618) 346-5120
MARION - 2309 W. Main St., Suite 116, Marion, IL 62959 - (618) 993-7200
?
EXHIBIT
A.
Page 2
8.
Please note that the Agency has revised the submittal date for the Discharge Monitoring
Report (DMR) forms to the 25th day of every month.
9.
Special Condition 14.14 has been revised to eliminate the reference to the Public Notice
Public Information Meeting and submission of the meeting summary.
10.
The daily maximum total residual chlorine limit of 0.05 mg/L in the effluent, referenced in
Special Condition 8, applies only to Discharge No. 001 (001 WRP Outfall).
11.
Special Condition 17 has been added to the permit in response to comments during the
comment period regarding the Chicago Area Waterway System Use Attainability Analysis
(UAA)•
The Agency has begun a program allowing the submittal of electronic Discharge Monitoring Reports
(eDMRs) instead of paper Discharge Monitoring Reports (DMRs). If you are interested in eDMRs,
more information can be found on the Agency website, http://epa.state.il.us/wateriedmr/index.html.
If your facility is not registered in the eDMR program, a supply of preprinted paper DMR Forms for
your facility will be sent to you prior to the initiation of DMR reporting under the reissued permit.
Additional information and instructions will accompany the preprinted DMRs upon their arrival.
The attached Permit is effective as of the date indicated on the first page of the Permit. Until the
effective date of any re-issued Permit, the limitations and conditions of the previously-issued Permit
remain in full effect. You have the right to appeal any condition of the Permit to the Illinois
Pollution Control Board within a 35 day period following the issuance date.
ou • you ave ques ions concerning e ermi , p ease con ac
number indicated above.
•
s aia e eep one
Alan Keller, P.E.
Manager, Permit Section
Division of Water Pollution Control
SAK:ALD:MRA:07082202.bah
Attachment: Final Permit
cc:
Records
Compliance Assurance Section
Des Plaines Region
US EPA
NIP C
NPDES Permit No. IL0028070
Illinois Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
Reissued (NPDES) Permit
Expiration Date:
January 31, 2013
Name and Address of Permittee:
Metropolitan Water Reclamation District of Greater Chicago
100 East Erie Street
Chicago, Illinois 60611
Receiving Waters: Chicago Sanitary and Ship Canal
Issue Date:
January 25, 2008
Effective Date:
February 1, 2008
Facility Name and Address:
MWRDGC Lemont WRP
13 Stephen Street
Lemont, Illinois
(Cook County)
In compliance with the provisions of the Illinois Environmental Protection Act, Title 35 of the III. Adm. Code, Subtitle C, Chapter I, and the
Clean Water Act (CWA , the above-named Permitte i
stream in accordance with the standard conditions and attachments herein.
Permittee is not authorized to discharge after the above expiration date. In order to receive authorization to discharge beyond the
expiration date, the Permittee shall submit the proper application as required by the Illinois Environmental Protection Agency (IEPA) not
later than 180 days prior to the expiration date.
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Alan Keller, P.E.
Manager, Permit Section
Division of Water Pollution Control
SAK:MRA:07082202.bah
Page 2
NPDES Permit No. IL0028070
Effluent Limitations, Monitoring, and Reporting
FINAL
Discharge Number(s) and Name(s): 001 WRP Outfall (existing)
Load limits computed based on a design average flow (DAF) of 2.3 MGD (design maximum flow (DMF) of 4.0 MGD).
Excess flow facilities (if applicable) shall not be utilized until the main treatment facility is receiving its maximum practical flow.
From the effective date of this Permit until the start of operation of the expanded plant ( 4.2 MGD ), the effluent of the above discharge(s)
shall be monitored and limited at all times as follows:
LOAD LIMITS lbs/day
?
CONCENTRATION
DAF (DMF)*?
LIMITS MG/L
Monthly
?
Weekly?
Daily
?
Monthly
Weekly
Daily
?
Sample
Sample
Parameter
Average?
Average?
Maximum
?
Average
Average Maximum
?
Frequency
Type
Flow (MGD)
Continuous
RIT
CBOD
5
**
384 (667)?
767 (1334)?
20
40
2 Days/Week
Composite
Suspended Solids
480 (834)?
863 (1501)?
25
45
2 Days/Week
Composite
pH
Shall be in the range of 6 to 9 Standard Units
2 Days/Week
Grab
cee•Sfesign average flow.
**Carbonaceous BOD
5 (CBOD5 ) testing shall be in accordance with 40 CFR 136.
Flow shall be reported on the Discharge Monitoring Report (DMR) as monthly average and daily maximum.
pH shall be reported on the DMR as minimum and maximum value.
RIT: Recording, Indicating, Totalizing.
oo
Page 3
NPDES Permit No. IL0028070
Effluent Limitations,• Monitoring, and Reporting
FINAL
Discharge Number(s) and Name(s): 001 WRP Outfall (after plant expansion)
Load limits computed based on a design average flow (DAF) of 42 MGD (design maximum flow (DMF) of 8.5 MGD).
Excess flow facilities (if applicable) shall not be utilized until the main treatment facility is receiving its maximum practical flow.
From the start of the operation of the expanded plant until the expiration date of the permit, the effluent of the above discharge(s) shall be
monitored and limited at all times as follows:
LOAD LIMITS lbs/day
?
CONCENTRATION
DAF (DMF)*
?
LIMITS MG/L
Monthly
?
Weekly
?
Daily?
Monthly
?
Weekly?
Daily
?
Sample?
Sample
Parameter
?
Average
?
Average
?
Maximum Average Average Maximum
?
Frequency
?
Type
Flow (MGD)
?
Continuous
CBOD
5
?384 (667)
?
767 (1334)
?
20?
40?
2 Days/Week Composite
Suspended Solids
?
876 (1772) 1576 (3190)?
25?
45?
2 Days/Week
?
Composite
pH
?
Shall be in the range of 6 to 9 Standard Units?
2 Days/Week
?
Grab
Ammonia Nitrogen
April-October
?
88(177)
?
175 (354)?
2.5
?
5.0
?
5 Days/Week
?
Composite
Nov.-March?
140(284)
?
280 (567)?
4.0
?
8:0?
5 Days/Week
?
Composite
Phosphorus.?
35 (71)?
1.0?
5 Days/Week
?
Composite
*Load limits based on design maximum flow shall apply only when flow exceeds design average flow.
'Carbonaceous BOD
5
(CBOD
5) testing shall be in accordance with 40 CFR 136. Load limits for CBOD
5
are based on a DAF of 2.3 MGD
(DMF of 4.0 MGD).
Flow shall be reported on the Discharge Monitoring Report (DMR) as monthly average and daily maximum.
pH shall be reported on the DMR as minimum and maximum value.
Page 4
NPDES Permit No. IL0028070
Effluent Limitations, Monitoring, and Reporting
FINAL
Discharge Number(s) and Name(s): 002 Wet Weather Treatment Outfall
These flow facilities shall not be utilized until the main treatment facility is receiving its maximum practical flow.
From the start of operation of the expanded plant until the expiration date of the permit, the effluent of the above discharge(s) shall be
monitored and limited at all times as follows:
CONCENTRATION
LIMITS mq/L
Parameter
Monthly Average
Sample Frequency
Sample Type
Total Flow (MG)
See Below
Daily When Discharging
Continuous
BOD,
Suspended Solids
Daily When Discharging
Daily When Discharging
Grab
Grab
Fecal Coliform
Daily Maximum Shall Not Exceed 400 per 100 mL
Daily When Discharging
Grab
pH
Shall be in the range of 6 to 9 Standard Units
Daily When Discharging
Grab
Chlorine Residual
0.75
Daily When Discharging
Grab
Total flow in million gallons shall be reported on the Discharge Monitoring Report (DMR) in the quantity maximum column.
Report the number of days of discharge in the comments section of the DMR.
Fecal Coliform shall be reported on the DMR as daily maximum.
Chlorine Residual shall be reported on the DMR as a monthly average concentration.
pH shall be reported on the DMR as a minimum and a maximum.
BOD, and Suspended Solids shall be reported on the DMR as a monthly average concentration.
Page 5
NPDES Permit No. IL0028070
Influent Monitoring, and Reporting
The influent to the plant shall be monitored as follows:
Parameter
?
Sample Frequency?
Sample Type
Flow (MGD)
?
Continuous
BOD,?
2 Days/Week?
Composite
Suspended Solids
?
2 Days/Week
?
Composite
Influent samples shall be taken at a point representative of the influent.
Flow (MGD) shall be reported on the Discharge Monitoring Report (DMR) as monthly average and daily maximum.
BOD, and Suspended Solids shall be reported on the DMR as a monthly average concentration.
Page 6
NPDES Permit No. 1L0028070
Special Conditions
SPECIAL CONDITION 1. This Permit may be modified to include different final effluent limitations or requirements which are consistent
with applicable laws, regulations, or judicial orders. The IEPA will public notice the permit modification.
SPECIAL CONDITION 2. The use or operation of this facility shall be by or under the supervision of a Certified Class 1 operator.
SPECIAL CONDITION 3. The IEPA may request in writing submittal of operational information in a specified form and at a required
frequency at any time during the effective period of this Permit.
SPECIAL CONDITION 4. The IEPA may request more frequent monitoring by permit modification pursuant to 40 CFR § 122.63 and
Without Public Notice in the event of operational, maintenance or other problems resulting in possible effluent deterioration.
SPECIAL CONDITION 5. The effluent, alone or in combination with other sources, shall not cause a violation of any applicable water
quality standard outlined in 35 III. Adm. Code 302.
SPECIAL CONDITION 6. Samples taken in compliance with the effluent monitoring requirements shall be taken at a point representative
of the discharge, but prior to entry into the receiving stream.
SPECIAL CONDITION 7. This Permit may be modified to include requirements for the Permittee on a continuing basis to evaluate and
detail its efforts to effectively control sources of infiltration and inflow into the sewer system and to submit reports to the IEPA if necessary.
SPECIAL CONDITION 8. For Discharge No. 001, any use of chlorine to control slime growths, odors or as an operational control, etc. shall
not exceed the limit of 0.05 mg/L (daily maximum) total residual chlorine in the effluent. Sampling is required on a daily grab basis during
the chlorination process. Reporting shall be submitted on the DMR's on a monthly basis.
SPECIAL CONDITION 9.
A. Publicly Owned Treatment Works (POTW) Pretreatment Program General Provisions
1. The Permittee shall implement and enforce its approved Pretreatment Program which was approved on November 18, 1985 and all
approved subsequent modifications thereto. The Permittee shall maintain legal authority adequate to fully implement the Pretreatment
Program in compliance with Federal (40 CFR 403), State, and local laws. The Permittee shall:
a.
Carry out independent inspection and monitoring procedures at least once per year, which will determine whether each
significant industrial user (SIU) is in compliance with applicable pretreatment standards;
b.
Perform an evaluation, at least once every two (2) years, to determine whether each SIU needs a slug control plan. If needed,
the SIU slug control plan shall include the items specified in 40 CFR § 403.8 (f)(2)(vi);
c.
Update its inventory of Industrial Users (lUs) at least annually and as needed to ensure that all Sills are properly identified,
characterized, and categorized;
d.
Receive and review self monitoring and other IU reports to determine compliance with all pretreatment standards and
requirements, and obtain appropriate remedies for noncompliance by any IU with any pretreatment standard and/or
requirement;
e.
Investigate instances of noncompliance, collect and analyze samples, and compile other information with sufficient care as to
produce evidence admissible in enforcement proceedings, including judicial action;
f.
Require development, as necessary, of compliance schedules by each industrial user for the installation of control technologies
to meet applicable pretreatment standards; and,
g.
Maintain an adequate revenue structure for continued operation of the Pretreatment Program.
2. The Permittee shall issue/reissue permits or equivalent control mechanisms to all SlUs prior to expiration of existing permits or prior
to commencement of discharge in the case of new discharges. The permits at a minimum shall include the elements listed in 40 CFR
§ 403.8(f)(1)(iii).
Page 7
NPDES Permit No. IL0028070
Special Conditions
3.
The Permittee shall develop, maintain, and enforce, as necessary, local limits to implement the prohibitions in 40 CFR § 403.5 which
prohibit the introduction of specific pollutants to the waste treatment system from any source of nondomestic discharge.
4. In addition to the general limitations expressed in Paragraph 3 above, applicable pretreatment standards must be met by all industrial
users of the POTW. These limitations include specific standards for certain industrial categories as determined by Section 307(b) and
(c) of the Clean Water Act, State limits, or local limits, whichever are more stringent.
5.
The USEPA and IEPA individually retain the right to take legal action against any industrial user and/or the POTW for those cases
where an industrial user has failed to meet an applicable pretreatment standard by the deadline date regardless of whether or not such
failure has resulted in a permit violation.
6.
The Permittee shall establish agreements with all contributing jurisdictions, as necessary, to enable it to fulfill its requirements with
respect to all Ills discharging to its system.
7.
Unless already completed, the Permittee shall within six (6) months of the effective date of this Permit submit to USEPA and IEPA a
proposal to modify and update its approved Pretreatment Program to incorporate Federal revisions to the general pretreatment
regulations. The proposal shall include all changes to the approved program and the sewer use ordinance which are necessary to
incorporate the regulations commonly referred to as PIRT and DSS, which were effective November 16, 1988 and August 23, 1990,
respectively. This includes the development of an Enforcement Response Plan (ERP) and a technical re-evaluation of the Permittee's
local limits.
8.
The Permittee's Pretreatment Program has been modified to incorporate a Pretreatment Program Amendment approved on February
6, 1995, July 24, 1997, and September 27, 2005. The amendment became effective on the date of approval and is a fully enforceable
provision of your Pretreatment Program.
Modifications of your Pretreatment Program shall be submitted in accordance with 40 CFR § 403.18, which established conditions
for substantial and nonsubstantial modifications.
B. Reporting and Records Requirements
1. The Permittee shall provide an annual report briefly describing the permittee's pretreatment program activities over the previous
calendar year. Permittees who operate multiple plants may provide a single report providing all plant-specific reporting requirements
are met. Such report shall be submitted no later than June 30 of each year, and shall be in the format set forth in IEPA's POTW
Pretreatment Report Package which contains information regarding:
a.
An updated listing of the Permittee's industrial users.
b.
A descriptive summary of the compliance activities including numbers of any major enforcement actions, (i.e., administrative
orders, penalties, civil actions, etc.), and the outcome of those actions. This includes an assessment of the compliance status
of the Permittee's industrial users and the effectiveness of the Permittee's Pretreatment Program in meeting its needs and
objectives.
c.
A description of all substantive changes made to the Permittee's Pretreatment Program. Changes which are "substantial
modifications" as described in 40 CFR § 403.18(c) must receive prior approval from the Approval Authority.
d.
Results of sampling and analysis of POTW influent, effluent, and sludge.
e.
A summary of the findings from the priority pollutants sampling. As sufficient data becomes available the IEPA may modify this
Permit to incorporate additional requirements relating to the evaluation, establishment, and enforcement of local limits for
organic pollutants. Any permit modification is subject to formal due process procedures pursuant to State and Federal law and
regulation. Upon a determination that an organic pollutant is present that causes interference or pass through, the Permittee
shall establish local limits as required by 40 CFR § 403.5(c).
2. The Permittee shall maintain all pretreatment data and records for a minimum of three (3) years. This period shall be extended during
the course of unresolved litigation or when requested by the IEPA or the Regional Administrator of USEPA. Records shall be available
to USEPA and the IEPA upon request.
Page 8
NPDES Permit No. IL0028070
Special Conditions
3.
The Permittee shall establish public participation requirements of 40 CFR 25 in implementation of its Pretreatment Program. The
Permittee shall at least annually, publish the names of all IU's which were in significant noncompliance (SNC), as defined by 40 CFR
§ 403.8(f)(2)(viii), in a newspaper of general circulation that provides meaningful public notice within the jurisidiction of the District
or based on any more restrictive definition of SNC that the POTW may be using.
4.
The Permittee shall provide written notification to the Deputy Counsel for the Division of Water Pollution Control, IEPA, 1021 North
Grand Avenue East, P.O. Box 19276, Springfield, Illinois 62794-9276 within five (5) days of receiving notice that any Industrial User
of its sewage treatment plant is appealing to the Circuit Court any condition imposed by the Permittee in any permit issued to the
Industrial User by Permittee. A copy of the Industrial User's appeal and all other pleadings filed by all parties shall be mailed to the
Deputy Counsel within five (5) days of the pleadings being filed in Circuit Court.
C. Monitoring Requirements
1. The Permittee shall monitor its influent, effluent and sludge and report concentrations of the following parameters on monitoring report
forms provided by the IEPA and include them in its annual report. Influent and effluent samples shall be taken at weekly intervals at
the indicated reporting limit or better and consist of a 24-hour composite unless otherwise specified below. Monthly sludge samples
shall be taken of final sludge and consist of a grab sample reported on a dry weight basis.
STORET
Minimum
CODE
PARAMETER
reporting limit
01097
Antimony
0.07 mg/L
01002
,Arsenic
0.05 mg/L
01007
Barium
0.5 mg/L
01012
Beryllium
0.005 mg/L
01027
Cadmium
0 no1 moil
01032
Chromium (hex - grab not to exceed 24 hours)*
0.01 mg/L
01034
Chromium (total)
0.05 mg/L
01042
Copper
0.005 mg/L
00718
Cyanide (grab) (weak acid dissociable)*
5.0 ug/L
00720
Cyanide (grab) (total)
5.0 ug/L
00951
Fluoride*
0.1 mg/L
01045
Iron (total)
0.5 mg/L
01046
Iron (Dissolved)*
0.5 mg/L
01051
Lead
0.05 mg/L
01055
Manganese
0.5 mg/L
71900
Mercury (effluent grab using USEPA Method 1631 or equivalent)
1.0 ng/L'
01067
Nickel
0.005 mg/L
00556
Oil (hexane soluble or equivalent) (Grab Sample only)*
5.0 mg/L
32730
Phenols (grab)
0.005 mg/L
01147
Selenium
0.005 mg/L
01077
Silver (total)
0.003 mg/L
01059
Thallium
0.3 mg/L
01092
Zinc
0.025 mg/L
* Influent and effluent only
'1 ng/L 1 part per trillion.
Other approved methods may be used for influent (composite) and sludge
Unless otherwise indicated, concentrations refer to the total amount of the constituent present in all phases, whether solid, suspended or
dissolved, elemental or combined including all oxidation states. Where constituents are commonly measured as other than total, the phase
is so indicated.
2. The Permittee shall conduct an analysis for the one hundred and ten (110) organic priority pollutants identified in 40 CFR 122 Appendix
D, Table II as amended. This monitoring shall be done annually and reported on monitoring report forms provided by the IEPA and
shall consist of the following:
Page 9
NPDES Permit No. IL0028070
Special Conditions
a.
The influent and effluent shall be sampled and analyzed for the one hundred and ten (110) organic priority pollutants. The
sampling shall be done during a day when industrial discharges are expected to be occurring at normal to maximum levels.
Samples for the analysis of acid and base/neutral extractable compounds, pesticides, and PCBs shall be 24-hour composites.
Six (6) grab samples shall be collected during a 24-hour period, to be analyzed for volatile organic compounds. A single analysis
for volatile pollutants (Method 624) may be run for each 24-hour period by compositing equal volumes of each grab sample directly
in the gas chromatograph (GC) purge and trap apparatus in the laboratory, with no less than one (1) mL of each grab included
in the composite.
Wastewater samples must be handled, prepared, and analyzed by gas chromatograph/electron capture detector in accordance
with USEPA Method 608 and GC/MS in accordance with USEPA Methods 624 and 625 of 40 CFR 136 as amended.
b.
The sludge shall be sampled and analyzed for the one hundred and ten (110) organic priority pollutants. A sludge sample shall
be collected concurrent with a wastewater sample and taken as final sludge.
Sampling and analysis shall conform to USEPA Methods 608, 624 and 625 unless an alternate method has been approved by
IEPA.
c.
Sample collection, preservation and storage shall conform to approved USEPA procedures and requirements.
3. In addition, the Permittee shall monitor any new toxic substances as defined by the Clean Water Act, as amended, following notification
by the IEPA.
4?
Permittee shall report any noncompliance with effluent or water quality standards in accordance with Standard Condition 12(e) of this
Permit.
5. Analytical detection limits shall be in accordance with 40 CFR 136. Minimum detection limits for sludge analyses shall be in
accordance with 40 CFR 503.
SPECIAL CONDITION 10. The Permittee has undergone a Monitoring Reduction review and the influent and effluent sample frequency
has been reduced for BOD
5 , CBOD
5
, suspended solids and pH due to sustained compliance. The IEPA will require that the influent and
effluent sampling frequency for these parameters be increased to 5 days/week if effluent deterioration occurs due to increased wasteload,
operational, maintenance or other problems. The increased monitoring will be required Without Public Notice when a permit modification
is received by the Permittee from the IEPA.
SPECIAL CONDITION 11. By August 31 of each year the Permittee shall submit annual fiscal data regarding sewerage system operations
to the Illinois Environmental Protection Agency/Division of Water Pollution Control/Compliance Assurance Section. The Permittee may
use any fiscal year period provided the period ends within twelve (12) months of the submission date.
Submission shall be on forms provided by IEPA titled "Fiscal Report Form For NPDES Permittees".
SPECIAL CONDITION 12. The Permittee shall conduct biomonitoring of the effluent from Discharge Number(s) 001.
Biomonitorinq
1. Acute Toxicity - Standard definitive acute toxicity tests shall be run on at least two trophic levels of aquatic species (fish, invertebrate)
representative of the aquatic community of the receiving stream. Testing must be consistent with Methods for Measuring the Acute
Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms (Fifth Ed.) EPA/821-R-02-012. Unless substitute tests
are pre-approved; the following tests are required:
a.
Fish - 96 hour static LC, Bioassay using fathead minnows (Pimephales promelas).
b.
Invertebrate 48-hour static LC„ Bioassay using Ceriodaphnia.
Page 10
NPDES Permit No. IL0028070
Special Conditions
2.
Testing Frequency - The above tests shall be conducted using 24-hour composite samples unless otherwise authorized by the IEPA.
Samples must be collected in the 18th, 15th, 12th, and 9th month prior to the expiration date of this Permit.
3.
Reporting - Results shall be reported according to EPA/821-R-02-012, Section 12, Report Preparation, and shall be submitted to IEPA,
Bureau of Water, Compliance Assurance Section within one week of receipt from the laboratory. Reports are due to the IEPA no later
than the 16th, 13th, 10th, and 7th month prior to the expiration date of this Permit.
4.
Toxicity Reduction Evaluation - Should the results of the biomonitoring program identify toxicity, the IEPA may require that the
Permittee prepare a plan for toxicity reduction evaluation and identification. This plan shall be developed in accordance with Toxicity
Reduction Evaluation Guidance for Municipal Wastewater Treatment Plants, EPA/833B-99/002, and shall include an evaluation to
determine which chemicals have a potential for being discharged in the plant wastewater, a monitoring program to determine their
presence or absence and to identify other compounds which are not being removed by treatment, and other measures as appropriate.
The Permittee shall submit to the IEPA its plan for toxicity reduction evaluation within ninety (90) days following notification by the
IEPA. The Permittee shall implement the plan within ninety (90) days or other such date as contained in a notification letter received
from the IEPA.
The IEPA may modify this Permit during its term to incorporate additional requirements or limitations based on the results of the
biomonitoring. In addition, after review of the monitoring results, the IEPA may modify this Permit to include numerical limitations for
specific toxic pollutants. Modifications under this condition shall follow public notice and opportunity for hearing.
SPECIAL CONDITION 13. For the duration of this Permit, the Permittee shall determine the quantity of sludge produced by the treatment
facility in dry tons or gallons with average percent total solids analysis. The Permittee shall maintain adequate records of the quantities
of sludge produced and have said records available for IEPA inspection. The Permittee shall submit to the IEPA, at a minimum, a semi-
annual summary report of the quantities of sludge generated and disposed of, in units of dry tons or gallons (average total percent solids)
by different disposal methods including but not limited to application on farmland, application on reclamation land, landfilling, public
distribution, dedicated land disposal, sod farms, storage lagoons or any
other specified disposal method. Said reports shall be submitted
to the IEPA by January 31 and July 31 of each year reporting the preceding January thru June and July thru December interval of sludge
disposal operations.
Duty to Mitigate. The Permittee shall take all reasonable steps to minimize any sludge use or disposal in violation of this Permit.
Sludge monitoring must be conducted according to test procedures approved under 40 CFR 136 unless otherwise specified in 40 CFR
503, unless other test procedures have been specified in this Permit.
Planned Changes. The Permittee shall give notice to the IEPA on the semi-annual report of any changes in sludge use and disposal.
The Permittee shall retain records of all sludge monitoring, and reports required by the Sludge Permit as referenced in Standard Condition
23 for a period of at least five (5) years from the date of this Permit.
If the Permittee monitors any pollutant more frequently than required by the Sludge Permit, the results of this monitoring shall be included
in the reporting of data submitted to the IEPA.
Monitoring reports for sludge shall be reported on the form titled "Sludge Management Reports" to the following address:
Illinois Environmental Protection Agency
Bureau of Water
Compliance Assurance Section
Mail Code #19
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
SPECIAL CONDITION 14.
AUTHORIZATION OF
COMBINED SEWER AND TREATMENT PLANT DISCHARGES
Page 11
NPDES Permit No. IL0028070
Special Conditions
The IEPA has determined that at least a portion of the collection system consists of combined sewers. References to the collection system
and the sewer system refer only to those parts of the system which are owned and operated by the Permittee unless otherwise indicated.
The Permittee is authorized to discharge from the overflow(s)/bypass(es) listed below provided the diversion structure is located on a
combined sewer and the following terms and conditions are met:
Discharge Number
?
Location
?
Receiving Water
002?
MWRDGC Lemont WRP
?
Chicago Sanitary & Ship Canal
Treatment Requirements
1.?
All combined sewer overflows and treatment plant bypasses shall be given sufficient treatment to prevent pollution and the violation
of applicable water quality standards. Sufficient treatment shall consist of the following:
a.
All dry weather flows, and the first flush of storm flows shall meet all applicable effluent standards and the effluent
limitations as required for the main STP outfall;
b.
Additional flows, up to 42 MGD, shall receive a minimum of primary treatment and disinfection with adequate retention time;
and,
c.
Additional flows, shall be treated to the extent necessary to comply with applicable water quality standards and the federal
Clean Water Act, including any amendments made by the Wet Weather Water Quality Act of 2000.
2.
?
All CSO discharges authorized by this Permit shall be treated, in whole or in part, to the extent necessary to prevent accumulations
u. - d- sosits floatin debris and solids in acc rdance with 35 III. Adm. Co
?
.2
levels below the applicable water quality standards.
3.
Overflows during dry weather are prohibited. Dry weather overflows shall be reported to the IEPA pursuant to Standard Condition
12(e) of this Permit (24 hour notice).
4.
The collection system shall be operated to optimize transport of wastewater flows and to minimize CSO discharges.
5.
The treatment system shall be operated to maximize treatment of wastewater flows.
Nine Minimum Controls
6.
The Permittee shall comply with the nine minimum controls contained in the National CSO Control Policy published in the Federal
Register on April 19, 1994. The nine minimum controls are:
a.
Proper operation and maintenance programs for the sewer system and the CSOs (Compliance with this Item shall be met
through the requirements imposed by Paragraph 8 of this Special Condition);
b.
Maximum use of the collection system for storage (Compliance with this Item shall be met through the requirements imposed
by Paragraphs 1, 4, and 8 of this Special Condition);
c.
Review and modification of pretreatment requirements to assure CSO impacts are minimized (Compliance with this Item shall
be met through the requirements imposed by Paragraph 9 of this Special Condition);
d.
Maximization of flow to the POTW for treatment (Compliance with this Item shall be met through the requirements imposed
by Paragraphs 4, 5, and 8 of this Special Condition);
e.
Prohibition of CSOs during dry weather (Compliance with this Item shall be met through the requirements imposed by
Paragraph 3 of this Special Condition);
I
?
.is
•.. - -. .-. -
?'..
?
!-N
f.?
Control of solids and floatable materials in CSOs (Compliance with this Item shall be met through the requirements imposed
by Paragraphs 2 and 8 of this Special Condition);
Page 12
NPDES Permit No. IL0028070
Special Conditions
g.
Pollution prevention programs which focus on source control activities (Compliance with this Item shall be met through the
requirements imposed by Paragraph 6 of this Special Condition, See Below);
h.
Public notification to ensure that citizens receive adequate information regarding CSO occurrences and CSO impacts
(Compliance with this Item shall be met through the requirements imposed by Paragraph 12 of this Special Condition); and,
i.
Monitoring to characterize impacts and efficiency of CSO controls (Compliance with this Item shall be met through the
requirements imposed by Paragraphs 10 and 11 of this Special Condition).
A pollution prevention plan (PPP) shall be developed by the Permittee unless
re has already been prepared)or
this collection
system. Any previously-prepared PPP shall be reviewed, and revised if necessary, by file Permittee to address the items contained
in Chapter 8 of the U.S. EPA guidance document,
Combined Sewer Overflows, Guidance For Nine Minimum Controls, and any items
contained in previously-sent review documents from the I EPA concerning the PPP.
Combined Sewer Overflows, Guidance For Nine
Minimum Controls
is available on line at http://www.epa.gov/npdes/pubs/owm0030.pdf. The PPP (or revised PPP) shall be
presented to the general public at a public information meeting conducted by the Permittee within nine (9) months of the effective
date of this Permit. The Permittee shall submit documentation that the pollution prevention plan complies with the requirements
of this Permit and that the public information meeting was held. Such documentation shall be submitted to the IEPA within twelve
(12) months of the effective date of this Permit and shall include a summary of all significant issues raised by the public, the
Permittee's response to each issue, and two (2) copies of the "CSO Pollution Prevention Plan Certification" one (1) with original
signatures. This certification form is available online at
http://www.epa.state.il.us/water/permits/waste-water/forms/cso-pol-prev.pdf.
Following the public meeting, the Permittee shall implement the pollution prevention plan within one (1) year and shall maintain a
current pollution prevention plan, updated to reflect system modifications, on file at the sewage treatment works or other acceptable
location and made available to the public. The pollution prevention plan shall be submitted to the IEPA upon written request.
Sensitive Area Considerations
7.
Pursuant to Section II.C.3 of the federal CSO Control Policy of 1994, sensitive areas are any water likely to be impacted by a CSO
discharge which meet one or more of the following criteria: (1) designated as an Outstanding National Resource Water; (2) found
to contain shellfish beds; (3) found to contain threatened or endangered aquatic species or their habitat; (4) used for primary contact
recreation; or, (5) within the protection area for a drinking water intake structure.
he IEPA has tentatively
determined that none of the outfalls listed in this
Special Condition dischar e o s-e-rigit-RieareaHowever,
if informs ion becomes available that causes the IEPA to reverse this determination, the IEPA will notify the Permittee in writing.
Within three (3) months of the date of notification, or such other date contained in the notification letter, the Permittee shall submit
two (2) copies of either a schedule to relocate, control, or treat discharges from these outfalls. If none of these options are possible,
the Permittee shall submit adequate justification at that time as to why these options are not possible. Such justification shall be
in accordance with Section II.C.3 of the National CSO Control Policy.
Operational and Maintenance Plans
?
00 WE b
it
t
y
ADi
v
m.)
kc_cEPTAn->CE. Fo12_
8.
The IEPA received a CSO operational and maintenance plan ("CSO O&M plan") for this sewerage system on March 15,2007. The
Permittee shall review and revise if needed, the CSO O&M plan to reflect system changes and any comments previously sent to
the Permittee by the IEPA. The CSO O&M shall be presented to the general public at a public information meeting conducted by
the Permittee within nine (9) months of the effective date of this Permit. The Permittee shall submit documentation that the public
information meeting was held. Such documentation shall be submitted to the IEPA within twelve (12) months of the effective date
of this Permit and shall include a summary of all significant issues raised by the public, the Permittee's response to each issue, and
two (2) copies of the "CSO Operational Plan Checklist and Certification", one (1) with original signatures. Copies of the "CSO
Operational Plan Checklist and Certification" are available online at http://www.epa.state.il.us/water/permits/waste-water/forrns/cso-
checklist.pdf. Following the public meeting, the Permittee shall implement the CSO O&M plan within one (1) year and shall maintain
a current CSO O&M plan, updated to reflect system modifications, on file at the sewage treatment works or other acceptable location
and made available to the public. The CSO O&M plan shall be submitted to the IEPA upon written request.
The objectives of the CSO O&M plan are to reduce the total loading of pollutants and floatables entering the receiving stream and
to ensure that the Permittee ultimately achieves compliance with water quality standards. These plans, tailored to the local
government's collection and waste treatment systems, shall include mechanisms and specific procedures where applicable to
ensure:
Page 13
NPDES Permit No. IL0028070
Special Conditions
a.
Collection system inspection on a scheduled basis;
b.
Sewer, catch basin, and regulator cleaning and maintenance on a scheduled basis;
c.
Inspections are made and preventive maintenance is performed on all pump/lift stations;
d.
Collection system replacement, where necessary;
e.
Detection and elimination of illegal connections;
f.
Detection, prevention, and elimination of dry weather overflows;
g.
The collection system is operated to maximize storage capacity and the combined sewer portions of the collection system are
operated to delay storm water entry into the system; and,
h.
The treatment and collection systems are operated to maximize treatment.
Sewer Use Ordinances
9.
a. The District shall report to the IEPA's compliance Assurance Section on an annual basis the progress obtained in its efforts
to meet the goals of the Sewer Summit Agreement between MWRDGC and tributary communities of 1) Prevention of water
pollution; and 2) Elimination of basement sewage backups and adverse surcharging conditions that cause health hazards and
financial losses. Also included in this report shall be the results of the District's efforts to reduce and effectively control sources
e • - • e • / e •
October 1 through September 30 time period.
b.?
The District shall implement and enforce all conditions and requirements of the Sewer Summit Agreement between MWRDGC
and tributary communities that are the responsibility and/or under the jurisdiction of the District in the Agreement.
Long-Term Control Planning and Compliance with Water Quality Standards
10.
a. Pursuant to Section 301 of the federal Clean Water Act, 33 U.S.C. § 1311 and 40 CFR § 122.4, discharges from the CSOs,
including the outfalls listed in this Special Condition and any other outlet' listed as a "Treated Combined Sewage Outfall", shall
not cause or contribute to violations of applicable water quality standards or cause use impairment in the receiving waters.
In addition, discharges from CSOs shall comply with all applicable parts of 35 III. Adm. Code 306.305(a), (b), (c), and (d).
b. Based on available information, it appears that the CSOs authorized in this Permit meet the criteria of Section II.C.4.a.i of the
federal CSO Control Policy of 1994 (Policy), not more than four overflow events per year, and are presumed to meet the water
quality-based requirements of the federal Clean Water Act. Pursuant to Section l.C.1 and Section II.C.9 of the Policy, the
Permittee shall develop a post-construction water quality monitoring program adequate to verify compliance with water quality
standards and to verify protection of designated uses in the receiving water(s) and to ascertain the effectness of CSO controls.
This program shall contain a plan that details the monitoring protocols to be followed, including any necessary effluent and
ambient monitoring, and if appropriate, other monitoring protocols such as biological assessments, whole effluent toxicity
testing, and sediment sampling. This plan shall be submitted to the IEPA and be presented to the public at an informational
meeting within nine (9) months after the start of operation of the expanded plant. Within twelve (12) months after start of
operations at the expanded plant, the Permittee shall submit a summary of all significant issues raised by the public, the
Permittee's response to each issue, and two (2) copies of the final plan (revised following the public meeting, if necessary)
implementing the post-construction monitoring program. The post-construction monitoring plan shall be implemented within
six (6) months of the date of IEPA approval. The Permittee shall respond to an IEPA review letter in writing within ninety (90)
days of the date of such an initial review letter and within thirty (30) days of any subsequent review letter(s), if any. Within
thirty (30) months of the approval of the plan, the results shall be submitted to the IEPA along with recommendations and
conclusions as to whether or not the discharges from any of the CSOs (treated or untreated) authorized by this Permit are
causing or contributing to violations of applicable water quality standards or causing use impairment in the receiving water(s).
Page 14
NPDES Permit No. IL0028070
Special Conditions
c. Should the results of the post-construction water quality monitoring plan or if information becomes available that causes IEPA
to conclude that the discharges from any of the CSOs (treated or untreated) authorized to discharge under this Permit are
causing or contributing to violations of water quality standards or are causing use impairment in the receiving water(s), the
IEPA will notify the Permittee in writing. Upon receiving such notification, the Permittee shall have an opportunity to review
and comment on the findings and conclusions of the IEPA. If the findings and conclusions are confirmed, the Permittee shall
develop and implement a CSO Long-Term Control Plan (LTCP) for assuring that the discharges from the CSOs (treated or
untreated) authorized in this Permit comply with the provisions of Paragraph 10.a above. The LTCP shall contain all applicable
elements of Paragraph 10.d below including a schedule for implementation and provisions for re-evaluating compliance with
applicable standards and regulations after complete implementation. Two (2) copies of the LTCP shall be submitted to the
IEPA within twelve (12) months of receiving the IEPA written notice. The LTCP shall be:
1.
Consistent with Section II.C.4.a.i of the Policy; or,
2.
Consistent with either Section II.C.4.a.ii, Section II.C.4.a.iii, or Section II.C.4.b of the Policy and be accompanied by data
sufficient to demonstrate that the LTCP, when completely implemented, will be sufficient to meet water quality standards.
d.?
Pursuant to the Policy, the required components of the LTCP include the following:
1.
Characterization, monitoring, and modeling of the Combined Sewer System (CSS);
2.
Consideration of Sensitive Areas;
3. Evaluation of alternatives;
4.
Cost/Performance considerations;
5.
Revised CSO Operational Plan;
6.
Maximizing treatment at the treatment plant;
7. Implementation schedule;
-
r3Post-Construction
mom ()tiny
?
1
9. Public participation.
Following submittal of the LTCP, the Pemiittee shall respond to any initial IEPA review letter in writing within ninety (90) days
of the date of such a review letter, and within thirty (30) days of any subsequent review letter(s), if any. Implementation of the
LTCP shall be as indicated by IEPA in writing or other enforceable mechanism.
Monitoring, Reporting and Notification Requirements
11.
The Pemiittee shall monitor the frequency of discharge (number of discharges per month) and estimate the duration (in hours) of
each discharge from each outfall listed in this Special Condition. Estimates of storm duration and total rainfall shall be provided for
each storm event.
For frequency reporting, all discharges from the same storm, or occurring within 24 hours, shall be reported as one. The date that
a discharge commences shall be recorded for each outfall. Reports shall be in the form specified by the IEPA and on forms provided
by the IEPA. These forms shall be submitted to the IEPA quarterly along with the February, May, August, and November DMRs
and covering the same reporting period as the DMRs. Parameters (other than flow frequency), if required in this Permit, shall be
sampled and reported as indicated in the transmittal letter for such report forms.
12.
A public notification program in accordance with Section 11.B.8 of the Federal CSO Control Policy of 1994 and the Wet Weather
Act of 2000 shall continue to be implemented by the Permittee and the CSO Public Notification Plan and Program shall be modified
should conditions change since the original plan was approved. The Permittee shall review the plan on an annual basis and make
any needed changes and implementations by the commencement of the recreation season.
13.
If any of the CSO discharge points listed in this Special Condition are eliminated, or if additional CSO discharge points, not listed
in this Special Condition, are discovered, the Permittee shall notify the IEPA in writing within one (1) month of the respective outfall
elimination or discovery. Such notification shall be in the form of a request for the appropriate modification of this NPDES Permit.
Page 15
NPDES Permit No. IL0028070
Special Conditions
Submission of CSO Monitoring Data (Paragraph 11)
Elimination of a CSO or Discovery of Additional CSO
Locations (Paragraph 13)
Control (or Justification for No Control) of CSOs to
Sensitive Areas (Paragraph 7)
Development of post-construction water quality
monitoring program ( Paragraph 10 )
Final Post-Construction monitoring water quality plan ( Paragraph 10 )
Sewer Use Ordinance Review ( Paragraph 9 )
Implement Post-Construction Monitoring Plan (Paragraph 10)
No Submittal Due with this Milestone
Conduct Pollution Prevention and OMP Meeting
( Paragraphs 6 and 8 )
No Submittal Due with this Milestone
Submit Pollution Prevention Certification and OMP Certification
( Paragraphs band 8 )
—.a- —e?---- —a-
25th of every month
1 month from discovery or elimination
3 months from IEPA notification
9 months after start of operation of the expanded
Plant
12 months after start of operation of the expanded
plant
November 15th of each year
6 months from the date of IEPA plan approval
9 months from the effective date of this permit
12 months from the effective date of this Permit
I .?
S?
a?
.
Submit Results
Results of Post-Construction Monitoring Plan (Paragraph 10)
?
30 months from the date of IEPA plan approval
All submittals listed in this Special Condition can be mailed to the following address:
Illinois Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
Attention: CSO Coordinator, Compliance Assurance Section
All submittals hand carried shall be delivered to 1021 North Grand Avenue East.
Reopening and Modifying this Permit
15. The IEPA may initiate a modification for this Permit at any time to include requirements and compliance dates which have been
submitted in writing by the Pemiittee and approved by the IEPA, or other requirements and dates which are necessary to carry out
the provisions of the Illinois Environmental Protection Act, the Clean Water Act, or regulations promulgated under those Acts. Public
Notice of such modifications and opportunity for public hearing shall be provided.
SPECIAL CONDITION 15. The Permittee shall record monitoring results on Discharge Monitoring Report (DMR) Forms using one such
form for each outfall each month.
In the event that an outfall does not discharge during a monthly reporting period, the DMR Form shall be submitted with no discharge
indicated.
Page 16
NPDES Permit No. IL0028070
Special Conditions
The Permittee may choose to submit electronic DMRs (eDMRs) instead of mailing paper DM Rs to the IEPA. More information, including
registration information for the eDMR program, can be obtained on the IEPA website, http://www.epa.state.il.usiwateriedmr/index.html.
The completed Discharge Monitoring RepOa forms shall be submitted to IEPA no later than the 25th day of the following month, unless
otherwise specified by the permitting authority.
Permittees not using eDMRs shall mail Discharge Monitoring Reports with an original signature to the IEPA at the following address:
Illinois Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
Attention: Compliance Assurance Section, Mail Code # 19
SPECIAL CONDITION 16. The Permittee shall notify the IEPA in writing once the treatment plant expansion has been completed. A letter
stating the date that the expansion was completed shall be sent to the following address within fourteen (14) days of the expansion
becoming operational:
Illinois Environmental Protection Agency
Bureau of Water
Compliance Assurance Section, Mail Code #19
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
SPECIAL CONDITION 17. This Permit will be modified to include alternative or additional final limitations pursuant to revisions in 35 Illinois
Administrative Code Subtitle C pursuant to the Chicago Area Waterway System Use Attainability Analysis (UAA) report or any associated
rule making by the IPCB.
Attachment H
Standard Conditions
Definitions
Act means the Illinois Environmental Protection Act, 415 ILCS 5 a's Amended.
Agency
-means
the Illinois Environmental Protection Agency.
Board means the Illinois Pollution Control Board.
Clean Water Act (formerly referred to as the Federal Water Pollution Control Act) means
Pub. L 92-500, as amended. 33 U.S.C. 1251 et seq.
NPDES (National Pollutant Discharge Elimination System) means the national program for
issuing, modifying, revoking and reissuing, terminating, monitoring and enforcing permits, and
imposing and enforcing pretreatment requirements, under Sections 307, 402, 318 and 405
of the Clean Water Act.
USEPA means the United States Environmental Protection Agency.
Daily Discharge means the discharge of a pollutant measured during a calendar day or any
24-hour period that reasonably represents the calendar day for purposes of sampling. For
pollutants with limitations expressed in units of mass, the "daily discharge' is calculated as
the total mass of the pollutant discharged over the day. For pollutants with limitations
expressed in other units of measurements, the "dairy discharge' is calculated as the average
measurement of the pollutant over the day.
Maximum Daily Discharge Limitation (daily maximum) means the highest allowable daily
discharge.
Average Monthly Discharge Limitation (30 day average) means the highest allowable
average of daily discharges over a calendar month, calculated as the sum of all daily
discharges measured during a calendar month divided by the number of daily discharges
measured during that month.
Average Weekly Discharge Limitation (7 day average) means the highest allowable
average of daily discharges over a calendar week, calculated as the sum of all daily
discharges measured during a calendar week divided by the number of daily discharges
measured during that week.
Best Management Practices (BMPs) means schedules of activities, prohibitions of practices,
maintenance procedures, and other management practices to prevent or reduce the pollution
of waters of the State. BMPs also include treatment requirements, operating procedures, and
practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage
from raw material storage.
Aliquot moans a s
ample of perifiert volt ime tiaert to make imp a total rnmposite
Rample
Grab Sample means an individual sample of at least 100 milliliters collected at a randomly-
selected time over a period not exceeding 15 minutes.
24 Hour Composite Sample means a combination of at least 8 sample aliquots of at least
100 milliliters, collected at periodic intervals during the operating hours of a facility over a 24-
hour period.
8 Hour Composite Sample means a combination of at least 3 sample aliquots of at least 100
milliliters, collected at periodic intervals during the operating hours of a facility over an 8-hour
period.
Flow Proportional Composite Sample means a combination of sample aliquots of at least
100 milliliters collected at periodic intervals such that either the time interval between each
aliquot or the volume of each aliquot is proportional to either the stream flow at the time of
sampling or the total stream flow since the collection of the previous aliquot.
(1)
Duty to comply. The permittee must comply with all conditions of this permit. Any
permit noncompliance constitutes a violation of the Act and is grounds for enforcement
action, permit termination, revocation and reissuance, modification, or for denial of a
permit renewal application. The permittee shall comply with effluent standards or
prohibitions established under Section 307(a) of the Clean Water Act for toxic
pollutants within the time provided in the regulations that establish these standards or
prohibitions, even if the permit has not yet been modified to incorporate the
requirement.
(2)
Duty to reapply. If the permittee wishes to continue an activity regulated by this permit
after the expiration date of this permit, the permittee must apply for and obtain a new
permit. If the permittee submits a proper application as required by the Agency no later
than 180 days prior to the expiration date, this permit shall continue in full force and
effect until the final Agency decision on the application has been made.
(3)
Need to halt or reduce activity not a defense. It shall not be a defense for a
permutes in an enforcement action that it would have been necessary to haft or reduce
the permitted activity in order to maintain compliance with the conditions of this permit.
(4)
Duty to mitigate. The permittee shall take all reasonable steps to minimize or prevent
any discharge in violation of this permit which has a reasonable likelihood of adversely
affecting human health or the environment.
(5)
Proper operation and maintenance. The permittee shall at all times property operate
and maintain all facilities and systems of treatment and control (and related
appurtenances) which are installed or used by the permittee to achieve compliance
with conditions of this permit. Proper operation and maintenance includes effective
performance, adequate funding, adequate operator staffing and training, and adequate
laboratory and process controls, including appropriate quality assurance procedures.
this provision requires the operation of back-up, or auxiliary facilities, or similar
systems only when necessary to achieve compliance with the conditions of the permit.
Permit actions. This permit may be modified, revoked and reissued, or terminated
for cause by the Agency pursuant to 40 CFR 122.62. The filing of a request by the
permittee for a permit modification, revocation and reissuance, or termination, or a
notification of planned changes or anticipated noncompliance, does not stay any
permit condition.
Property rights. This permit does not convey any property rights of any sort, or any
exclusive privilege.
Duty to provide information: The perrriittee shall fumish to the Agency within a
reasonable time, any information which the Agency may request to determine whether
cause exists for modifying, revoking and reissuing, or terminating this permit, or to
determine compliance with the permit. The permittee shall also famish to the Agency,
upon request, copies of records required to be kept by this permit.
Inspection and entry. The permittee shall allow
en
authorized representative of the
Agency, upon the presentation of credentials and other documents as may be required
by law, to:
Enter upon the perrnittee's premises where a regulated facility or activity is
located or conducted, or where records must be kept under the conditions of this
permit;
(b) Have access to and copy, at reasonable times, any records that must be kept
under the conditions of this permit;
Inspect at reasonable times any facilities, equipment (including monitoring and
control equipment), practices, or operations regulated or required under this
permit; and
(d) Sample or monitor at reasonable times, for the purpose of assuring permit
compliance, or as otherwise authorized by the Act, any substances or parameters
at any location.
(10) Monitoring and records.
Samples and measurements taken for the purpose of monitoring shall be
representative of the monitored activity.
(b)
The permittee shall retain records of all monitoring information, including all
calibration and maintenance records, and all original strip chart recordings for
continuous monitoring instrumentation, copies bf all reports required by this
permit, and records of all data used to complete the application for this permit, for
a period of at least 3 years from the date of this permit, measurement, report or.
application. This period may be extended by request of the Agency at any time.
(c)
Records of monitoring information shall include:
The date, exact place, and time of sampling or measurements;
The individual(s) who performed the sampling or measurements;
The date(s) analyses were performed;
The individual(s) who performed the analyses;
The analytical techniques or methods used; and
The results of such analyses.
(d)
Monitoring must be conducted according to test procedures approved under 40
CFR Part 136, unless other test procedures have been specified in this permit.
Where no test procedure under 40 CFR Part 136 has been approved, the
permittee must submit to the Agency a test method for approval. The permittee
shall calibrate and perform maintenance procedures on all monitoring and
analytical instrumentation at intervals to ensure accuracy of measurements.
(11) Signatory requirement. All applications, reports or information submitted to the
Agency shall be signed and certified.
(a) Application. All permit applications shall be signed as follows:
(1)
For a corporation: by a principal executive officer of at least the level of
vice president or a person or position having overall responsibility for
environmental matters for the corporation;
(2)
For a partnership or sole proprietorship: by a general partner or
the
proprietor, respectively; or
(3)
For a municipality, State, Federal, or other public agency: by either a
principal executive officer or ranking elected official.
(b) Reports. All reports required by permits, or other information requested by the
Agency shall be signed by a person described in paragraph (a) or by a duly
authorized representative of that person. A person is a duly authorized
representative only if:
(1)
The authorization is made in writing by a person described in paragraph (a);
and
(2)
The authorization specifies either an individual or a position responsible for
the overall operation of the facility, from which the discharge originates, such
as a plant manager, superintendent or person of equivalent responsibility;
and
(3)
The written authorization is submitted to the Agency.
(6)
(7)
(B)
(9)
(a)
(c)
(a)
(c) Changes of Authorization. If an authorization under (b) is no longer accurate
because a different individual or position has responsibility for the overall
operation of the facility, a new authorization satisfying the requirements of (b)
must be submitted to the Agency prior to or together with any reports, information,
or applications to be signed by an authorized representative.
(12). Reporting requirements.
(a) Planned changes. The permittee shall give notice to the Agency as soon as
possible of any planned physical alterations or additions to the permitted facility.
(b) Anticipated noncompliance. The permittee shall give advance notice to the
Agency of any planned changes in the permitted facility or activity which may
result in noncompliance with permit requirements.
(c) Compliance schedules. Reports of compliance or noncompliance with, or any
progress reports on, interim and final requirements contained in any compliance
schedule of this permit shall be submitted no later than 14 days following each
schedule date.
(d) Monitoring reports. Monitoring results shall be reported at the intervals
specified elsewhere in this permit.
(1)
Monitoring results must be reported on a Discharge Monitoring Report
(DMR).
(2)
If the permittee monitors any pollutant more frequently than required by the
permit, using test procedures approved under 40 CFR 136 or as specified
in the permit, the results of this monitoring shall be included in the calculation
and reporting of the data submitted in the DMR.
(3)
Calculations for all limitations which require averaging of measurements
shall utilize an arithmetic mean unless otherwise specified by the Agency in
the permit.
(e) Twenty:
,
-four hour reporting. The permittee shall report any noncompliance
which may endanger health -or the environment Any information shall be
provided orally within 24 hours from the time the permittee becomes aware of the
circumstances. A written submission shall also be provided within 5 days of the
ti methe permittee becomes aware of the circumstances. The written submission
shall contain a description of the noncompliance and its cause; the period of
noncompliance, including exact dates and time; and tithe noncompliance has not
been corrected, the anticipated time it is expected to continue; and steps taken
orplanned to reduce, eliminate, and prevent reoccurrence of the noncompliance.
The following shall be included as information which must be reported within 24
hours:
(1)
Any unanticipated bypass which exceeds any effluent limitation in the
permit;
(2)
Violation of a maximum daily discharge limitation for any of the pollutants
listed by the Agency in the permit to be reported within 24 hours.
The Agency may waive the written report on a case-by-case basis if the oral
report has been'received within 24 hours.
(f) Other noncompliance. The permittee shall report all instances of
noncompliance 'not reported under paragraphs (12)(c), (d), or (e), at the time
rrkoniforing reports are submitted. The reports shall contain the information fisted
inAaragraph (12)(e).
(9)
Dther
,
Inforrnation.
Where the permittee
becomes aware that
it failed to submit
apy relevant facts in a permit application, or submitted incorrect information in a
permit`application, or in any report to the Agency, It shall promptly submit such
facts,or information.
(13) TragOg.
of permits. A permit may be automatically transferred to a new permittee
if:
(a)
The current permittee notifies the Agency at least 30 days in advance of the
Proposed
transfer :date:
(b)
The
)notice
includes a written agreement between the existing and new permittees
cohlatning a specific 'date for transfer of permit responsibility, coverage and
(c)
The'
lititty
Agency
betweenthe
•
does not
current
notify
and
the
new
existing
permittees;
permittee
and
and the proposed new
pennittee of
its
intentto modify or revoke and reissue the permit. If this notice is
notr,
er-eived,thelransfer is effective on the
date specified in the agreement
(14) All manufacturing,
commercial; mining,
and slivicultural dischargers must notify the
AgenWas
rpoon
as Meyknow or have reason to believe:
That any activity has occurred or will occur which would result in the discharge of
anyioxic
pollutant
identified under Section 307 of the Clean Water Act which is
nottirnited in the permit, if that discharge will exceed the highest of the following
notMcation levels:
(1)
One hundred micrograms per filer (100 uciff);
(2)
Two hundred micrograms per Iffer (200 ugh) for acrolein and acrylonthile;
. five hundred micrograms per liter (500 ugh]) for 2,4-dinitrophenol and for 2-
methyl-4,6 dinitrophenol; and one milligram per liter (1 mg/1) for antimony.
(3)
Five (5) times the maximum concentration value reported for that pollutant
in the NPDES permit application; or
(4) The level established by the Agency in this permit.
(b) That they have begun or expect to begin to use or manufacture
as
an intermediate
or final product or byproduct any toxic pollutant which was not reported in the
NPDES permit application.
(15) All Publicly Owned.
reatment Works (POT)Ns) roust provide adequate notice to the
Agency of the following:
(a) Any new introduction of pollutants into that POTW from an indirect discharge
which would be subject to Sections 301 or 306 of the Clean Water Act if it were
directly discharging those pollutants; and
(b) Any substantial change in the volume or character of pollutants being introduced
into that POTW by a source introducing pollutants into the POTW at the time of
issuance of the permit
(c)
For purposes of this paragraph, adequate notice shall include information on (i)
the quality and quantity of effluent introduced into the POTW, and (ii) any
anticipated impact of the change on the quantity or quality of effluent to be
discharged from the POTW.
(16) If
the permit
is issued to a publicly owned or publicly regulated treatment works, the
permittee shall require any industrial user of such treatment works to comply with
federal requirements concerning:
(a)
User charges pursuant to Section 204(b) of the Clean Water Act, and
applicable
regulations appearing in 40 CFR 35;
(b)
Toxic pollutant effluent standards and pretreatment standards pursuant to Section
307 of the Clean Water Act; and
(c)
Inspection, monitoring and entry pursuant to Section 308 of the Clean Water Act.
(17) If an applicable standard or limitation is promulgated under Section 301(b)(2)(C) and
(D). 304(b)(2), or 307(3)(2) and that effluent standard or limitation is more stringent
than any effluent limitation in the permit, or controls a pollutant not limited in the
permit, the permit shall be promptly modified or revoked, and reissued to conform to
that effluent standard or limitation.
(18) Any authorization to construct issued to the permittee pursuant to 35111. Adm. Code
309.154 is hereby incorporated by reference as a condition of this permit.
(19) The permittee shall not make any false statement, representation or certification in any
application, record, report, plan or other document submitted to the Agency or the
USEPA, or required
to
be maintained under this permit.
(20) The Clean Water Act provides that any person who
violates a
permit condition
implementing Sections 301, 302, 306, 307, 308, 318, or 405 of the Clean Water Act
is subject to a civil penalty not to exceed $10,000 per day of such violation. Any
person who willfully or negligently violates permit conditions implementing Sections
301, 302, 306, 307, or 308 of the Clean Water Act is subject to a fine of not less than
$2,500 nor more than $25,000 per day of violation, or by imprisonment for not more
than one year, or both.
(21) The Clean Water Act provides that any person who falsifies, tampers with, or
knowingly renders inaccurate any monitoring device or method required to be
maintained under permit shall, upon conviction, be punished by a fine of not more
than
$10,000 per violation, or by imprisonment for not more than 6 months per violation, or
by both.
(22) The Clean Water Act provides that any person who knowingly makes any false
statement, representation, or certification in any record or other document submitted
or required to be maintained under this permit shall, including monitoring reports or
reports of compliance or non-compliance shall, upon conviction, be punished by a fine
of not more than $10,000 per violation, or by imprisonment for not more than 6 months
per violation, or by both.
(23) Collected screening, slurries, sludges, and other solids shall be
disposed
of in such
a manner as to prevent entry of those wastes (or runoff from the wastes) into waters
of the State. The proper authorization for such disposal shall be
obtained from the
Agency and is incorporated as part hereof by reference.
(24) In case of conflict between these standard
conditions and any other condition(s)
included in this permit, the other condition(s) shall govem.
(25) The permittee shall comply with, in addition to the requirements of the permit, all
applicable provisions of 35
III. Adm. Code, Subtitle C, Subtitle
D, Subtitle E, and all
applicable orders of the Board.
(26) The provisions of this permit are severable, and if any provision of this permit, or the
application of any
provision of this permit is held invalid, the remaining provisions of
this permit shall continue in full force and effect.
(Rev. 3-13-98)
(a)
BOARD OF COMMISSIONERS
Terrence J. O'Brien
President
Kathleen Therese Meany
Vice President
Gloria AIM° Majewski
Chairman of Finance
Frank Avila
Patricia Horton
Barbara J. McGowan
Cynthia M. Santos
Debra Shore
Patricia Young
Metropolitan Water Reclamation District of Greater Chicago
100 EAST ERIE STREET?
CHICAGO, ILLINOIS 60611-3154
?
312.751-5600
Osoth Jamjun, P.E.
Chief of Maintenance and Operations
312 .
751-5101?
FAX 312-751-5145
Mr. S. Alan Keller, P.E.
Manager, Northern Municipal Unit
Division of Water 'Pollution Control
Illinois Environmental Protection Agency (IEPA)
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Dear Mr. Keller:
Subject: National Pollution Discharge Elimination System (NPDES)
Lemont Water Reclamation Plant (LWRP)
Draft/Public Notice Permit No. IL 0028070
October 16, 2007
The Metropolitan Water Reclamation District of Greater Chicago (District) acknowledges receipt of the
subject documents transmitted with letters from the IEPA dated September 11, 2007 and October 11,
2007. The District's comments are listed below:
1.
General Comment.
The Lemont WRP will not be expanded. A letter has recently been forwarded to the IEPA
(September 28, 2007) that details the District's plan to replace the Lemont WRP with a new pump
station and wet weather reservoir. Lemont's sewage will be pumped via pipeline to the collection
system that is tributary to the Sticicney WRP. The wet weather reservoir will be sized to essentially
eliminate overflow events at the District's CSO point in Lemont. All references to the expanded plant
should be replaced with a reference to the new pump station and wet weather reservoir.
The approximate schedule for the pump station, pipelines, and reservoir is as follows:
Reservoir Contract:
Award Date - April 2009; Completion Date - April 2011
Pump Station and Pipeline Contract:
Award Date - October 2009; Completion Date - October 2012
2.
Page 2 – 001 WRP Outfall (existing), third sentence.
The reference to the expanded plant (4.2 MGD) should be replaced with a reference to the new pump
station and wet weather reservoir.
3.
Page 3 – 001 WRP Outfall (after plant expansion).
These load limits will no longer be applicable since the plant will not be expanded.
EXHIBIT B
Mr. Al Keller
2
October 16, 2007
IEPA
4. Page 4 – 002, Wet Weather Treatment Outfall.
The reference to the expanded plant should be eliminated. A DMR for 002 is currently being
submitted with the monthly DMR for the LWRP.
5. Pages 6 and 7 – Special Conditions 9.A.1.b and 9.A.8.
Special Condition 9.A.Lb should be modified to reflect the revised rule citation, 40 CFR 403.8(f) (2)
(vi), and substitute language providing for the revised requirements regarding the evaluation of slug
discharge potentials of SlUs. Special Condition 9.A.8 of the draft permit should be modified to
reference the Pretreatment Program Amendments approved by USEPA on September 27, 2005.
6. Pages 8 and 9 – Special Condition 9.C.2.a.
The following sections should read as follows:
a. (2'd
paragraph) Samples for the analysis of acid and base/neutral extractable compounds,
pesticides, and PCBs
shall be 24-hour composites.
b.
(3rd paragraph)
Six
(6)
grab samples shall be collected
during
a
24-hour period.
A single
analysis for volatile pollutants (Method 624) may be run for each
24-hour period
by
compositing equal volumes of each grab sample in the purge and trap apparatus in the
laboratory.
c. (4th
paragraph) Wastewater samples must be handled, prepared and analyzed by
gas
chromatographielectron capture detector in accordance with USEPA Method 608 and
625 of 40
I
CFR
?I Il•
136
?
ILI
as
•
amended.
II?II•
I •
?
II I • I?
•?
•
ki?
• • •?• • __g?
7. Page 11 – Special Conditions 14.1.b. and c.
Since the LWRP will be replaced with a new pump station and wet weather reservoir (in lieu of
primary treatment and disinfection), it is requested that the applicability of these conditions be
revaluated.
7.
Page 12 – Special Condition 14.6.
A District wide pollution prevention plan is currently in place. All required public notices and
submittals were made after the effective date (June 1, 2002) of the existing permit. The language in
this condition should reflect ongoing compliance.
8.
Pages 12 and 13 – Special Condition 14.8.
Please note that a District wide CSO Operation and Maintenance Plan (OMP) has previously been
submitted to the IEPA as required under the previous permit effective June 1, 2002. The latest
version of the CSO OMP was submitted with the District's letter dated January 9, 2007. The District
is currently awaiting administrative acceptance. The language in this condition should reflect the
current status of the CSO OMP and ongoing compliance.
9.
Pages 13 and 14 – Special Conditions 14.10.b, c, and d.
The Long Term Control Plan should reflect the District's intent to decommission the LWRP and
replace it with a new pump station and wet weather reservoir.
Mr. Al Keller
3
October 16, 2007
lEPA
10.
Page 14 – Special Condition 14.11.
The District is also submitting Quarterly CSO Monitoring Reports by February 15
th
, May 15
th
, August
15th, and November 15th
for the January through March; April through June; July through September,
and the October through December quarters. The representative outfall in this permit (002) is also
documented in the above report when it discharges.
11.
Page 14 – Special Condition 14.12.
A Public Notification Plan (PNP) has already been developed and implemented in accordance with
the requirements under the previous permit effective June 1, 2002. The PNP was presented to the
general public at a public information meeting; documentation submitted with a summary of all
significant issues raised by the public along with the District's response to each issue; and
modifications made to the program as a result of the meeting were identified. To date, the District
has not yet received final approval of the program. The District has, however, implemented the
program. The language in this condition should be revised to reflect the current status of the PNP and
ongoing compliance.
12.
Page 15 – Special Condition 14.14.
This Special Condition requires that the CSO Monitoring Data for the LWRP be submitted by the 15
1 of
every month. Please note that this data is submitted every month with its DMR. The District currently
submits DMRs for all of its facilities on the 20th
of every month. The submittal date should therefore be
revised to the 20th
of every month.
The following items should be eliminated from this special condition since it references the expanded
plant or has been previously submitted: 1) Development of Post-Construction Water Quality
Monitoring
Program; 2) Final Post-Construction Monitoring Water Quality Plan; 3) Implement Post-Construction
Monitoring Plan; 4) Conduct Pollution Prevention, OMP, and PN Information Meeting Summary, 5)
Submit Pollution Prevention Certification, OMP Certification, and PN Information Meeting Summary; 6)
Submit CSO Long-Term Control Plan; and 7) Submit Results of Post-Construction Monitoring Plan.
13.
Page 16 – Special Condition 16.
The reference to the expanded plant should be replaced with a reference to the new pump station and
wet weather reservoir.
If you have any questions, please contact Mr. Adam Gronsld of my staff at 312.751.5107.
Very truly yours,
fo
C-
Osoth Jamjun
Chief of Maintenance and Operations
Enclosures
c: Sulski, LEPA Des Plaines
Kollias/Feldman/Sobanski/Conway
