IEPA EXHIBIT

Ig-

'11.

National

No.

• ••

Steel

October] 4,2002

Mr Tom McSwiggin, Manager

Permit Section

Division

afWater PolJutian Control

Illinois Environmental Protection Agency

]021 North Grand Ave. East, P.O. Box 19276

Springfield, Illinois 62706

Dear

Mr McSwiggin

Subject: Application for Renewal of NPDES Discharge Permit

NO. IL0000329

Gronlle City D,vlSlon

t'-Joltonol

Sleel

Corporollon

20fh & Stole Sireeis

Gronite Cty, illinoIS 62040

(6181 4S 1 3456

RECEIVED

OCT 17

LUUL

EnVifonmerHdl PrOicl-tiOn Agency

WPC,. Permit Log in

Enclosed is an application for renewal of the NPDES Discharge Permit for the Granite City Division

of National Steel Corporation.

Granite City Division requests that the

30] (g) variances for ammonia and phenol and the

background credit for zinc

be maintained.

Granite City Division continues to believe that our facility has been granted the central treatment

exemption. Specifically, the limitations should be based on the current systems ability to treat.

With respect

to Outfall 001, Granite City Division requests that the monitoring for dissolved iron

and weak acid dissociable cyanide

be waived. The existing limitations for total iron and total cyanide will

assure the protection

of human health and the environment

With respect to Outfall OOIA, Granite City Division requests that the monitoring for benzene be

waived. The new USEPA

Emuent Limitation Guidelines no longer have limitations for benzene for

cokemaking operations. Therefore the monitoring at Outfall

OOIA for benzene is not required

With respect

to Outfall 00 IB, Granite City Division requests that the monitoring be waived Outfall

0018 is not a direct discharge

to

the waters of the state and is further treated through the central treatment

system. Outfall 00

IB has consistently met the existing limitations, and is a safety concern in terms of

accessibility. The ne,v USEPA Effluent Limitation Guidelines no longer have limitations for

tetrachlorethylene and naphthalene for cold rolling operations. Therefore the monitoring at Outfall 00 IB

is

not required.

Should you have any questions or requij'e additional information, please contact me at (618) 451-

3013

Very tnlly yours,

Carl

~~

E. Cannon

Manager Environmental Control

Enclosure

MCSWIG.CEC

135

Electronic Filing - Received, Clerk's Office, December 10, 2008

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August 6 through 10, 2002 Test

Test Solution

Laboratory Control

Horseshoe Lake Control

6.25% Effluent

12.5% Effluent

25% Effluent

50% Effluent

100% Effluent

a =NOEC

Selenastrum capncornutum

Mean No.Cells per mL (xl 0°)

4.3292

3.5250

33750

34375

35667

33708

38208

a

>100%

I

The results of the July 16 through 23, 2002 tests show that:

I

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•

•

•

The effluent was not acutely toxic to

Ceriodaphnia dubia

or fathead mmnows at the 100 percent

concentration, using the 50 percent lethality criteria. The LC

50

values were greater than 100

percent for both

species.

The first effluent sample was chronically toxic to

Selenasrrum capricomurum

at all

concentrations tested, based on significant difference and the 25 percent inhibition analysis. The

NOEe was 0 percent (control water) and the

lC

25

for algal growth (cell density) was 456

percent.

The effluent samples were not chronically toxic to

Ceriodaphnia dubio

through the 100 percent

concentratIOn,

based on significant difference and the 25 percent inhibition analysis. The NOEC

was 100 percent and the

lC

25

for reproduction was greater than 100 percent.

The effluent samples were not chronically toxic to fathead minnows through the 100 percent

concentration, based on the 25 percent inhibitlOn analysis. However, the effluent was

chronically tOXlC to fish weight at the 100 percent concentration, based on significant difference

The NOEC was 50 percent and the IC

25

for biomass was greater than 100 percent

•

Horseshoe Lake and laboratory control water data were acceptable in all bioassays.

The results of the August 6 through 10, 2002 retest show that:

•

The effluent sample was not chronically toxic to

Selenosrrum capricomwum

at aJ]

concentrations tested, based on significant difference and the

2S

percent inhibition analysis. The

NOEC was 100 percent and the

lC

25

for algal growth (cell density) was greater than 100 percent

effluent

•

Horseshoe Lake and laboratory control water data were acceptable in the bioassay.

158

Electronic Filing - Received, Clerk's Office, December 10, 2008

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Chronic Bioassays

Table 7 presents the results of the July 16 through 23 chronic bioassays. The first eftluent

sample was chronically toxic to

Selenastrum capncomurum

at all concentrations tested, based on

significant

difference and the

2S

percent inhibitIOn analysis. The NOEC was 0 percent (control

water) and the

IC

25

for algal growth (cell density) was 4.56 percent.

The effluent samples were not chronically toxic to

Ceriodaphnia dubia

through the 100 percent

concentration, based on significant difference and the 25 percent inhibition analysis. The NOEC

was 100 percent and the

lC

15

for reproduction was greater than 100 percent.

The effluent samples were not chronically toxic to fathead minnows through the 100 percent

concentration, based on the 25 percent inhibltion analysis. However, the effluent was chronically

toxic to fish

weight at the 100 percent concentration, based on significant difference. The NOEC

was

SO

percent and the IC

25

for biomass was greater than 100 percent.

Horseshoe Lake and laboratory control water data were acceptable in all bioassays

Table 7

Summary of Results of Chronic Bioassays

Conducted for National Steel Corporation

Granite City, IJIinois

July 16 through 23, 2002

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II

Test Solution

Laboratory Control

Horseshoe

Lake Control

625% Efnuenl

12.5% Effluent

25% Efnuent

50% Efnuenl

100% Effluent

Selenastrum

Ceriodaphnia dubia

Fathead Mjnnow

capricornutum

Mean No.

Mean

Mean No.

Mean

Mean

Cells

%

of

%

Growth

per mL (xl0

6

)

Survival

Offspring

Survival

(mg)

1.8333

100

27.3

100

0723

1.5688

100

253

100

0.674

10307*

100

26.5

846

0.675

0.8183*

100

26.2

100

0626

0.4033*

100

26.7

92.S

0.556

0.0883*

100

25.7

95

0.619

0.1167*

90

247

92.5

0517*

4.56%

>100%

>100%

*

Indicates significant

(p~O.OS)

difference (reduction) from lake control data

Table 8 presents the results of the August 6 through 10 chronic toxicity retest. The effluent

sample was not chronically toxic to

Selenastrum capricomutum

at all concentrations tested,

based on significant difference and the

2S

percent inhibition analysis. The NOEC was 100

i68

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

....,.. 4..

l!.J1. ••

• aua •

N

0.

2Z

_

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021

NORTH GRAND

AVENUE

EAST,

PO Box 19276, SPRINGFIELD, ILLINOIS 62794-9276,217-782-3397

JAMES

R.

THOMPSO"i

CENTER, 100 WEST

R/\NDOLPH,

SUlrE11-30G, C,il(,\(;O, IL 60601, 312-814-6026

DATE:

TO:

FROM:

ROD R. BLACOJEVICH, GOVERNOR

l\tlemorandum

July 9, 2003

Ukanno Foxworth

RENEE CIPRIANO, DIRECTOR

ILLINOtS ENV/RONilAENTAL

PROTECTION

AGENCY

B8WNVPC/PERi\H SECTiON

SUBJECT:

US Steel Corp, - Granite City Water Quality Based Effluent Limits

NPDES Permit No. IL0000329

Madison County

The subject facility, fonnerly known as National Steel- Granite City Division, discharges Outfall 001 [mal

effluent to Horseshoe Lake, which has zero How during critical 7Q 10 low-flow conditions. The facility

has had a highest monthly average flow

of 21 MGD in recent years. Average monthly flow is 16 MGD.

The facility withdraws water from the Mississippi River and discharges to the lake.

Horseshoe Lake is classified as a General Use Water and

is not rated under the Agency'sBiological

Stream Characterization (BSC) program. Horseshoe Lake, Waterbody Segment, RJC,

is found on the draft

2002 Illinois 303(d) list. The lake is listed as non-supportive

of swimming uses and partially supportive of

overall, aquatic life, fish consumption and secondary contact uses. The potential causes of impainnent

given for the segment at that time were PCBs, pH, suspended solids, excessive algae growth, ammonia

(un-ionized), nutrients, phosphorus and inorganic N (nitrate). The potential sources associated with the

impairment are agriculture, crop related sources, nonirrigated crop production, habitat modification and

streambank modification! destabilization.

Cadmium, Chromium (Trivalent), Copper, Lead, Nickel, and Zinc standards are based on hardness data

collected from Horseshoe Lake by the facility, with a critical hardness value

of 320

mg/L

as CaC0

3

.

Water quality standards identified in tbe table are expressed in units of

mglL.

Dissolved metals standards

have been converted

to total metal except where noted.

Max. Eff. No.

of

Multiply

95%

Acute

Chronic

302208(g)

Further

Substance

Cone.

Samples

by

Potential

Standard

Standard

standard

Analysis?

Arsenic

<0.025

1

6.2

0.155

0.3600

0.1900

-

NoRP*

Barium

0.081

20

14

0.1134

I

-

-

5.0

NoRP*

Cadmium

,

<0.005

20

1.4

0.007

0.0362

0.0028

-

Yes

I

Chromium (Hex)

0

0.0

0

0.0160

0.0110

-

No Data

Chromium (Total)

<0.005

20

1.4

0.007

4.5019

0.5366

-

No RP*

Cyanide (WAD)

I

0.066

312

1.0

0.066

0.0220

0.0052

-

Yes

I

Copper

0.0093

20

1.4

0.0]3

0.0530

0.0319

-

NoRP*

Fluoride

4.1

331

1.0

4.1

I

-

-

1.4

Yes

Iron (Dissolved)

1

312

10

1.0

-

-

1.0

Yes

ROCKfORD - 4302 North Main Street, Rockford, It. 61103 - (815) 987-7760

•

DES Pl.AINES - 9511 IN Hamson St, Des Plaines, It. 60016 - (847) 294-4000

ELGIN-595 South State, Elgin, It. 60123 - (847) 608-3131

•

PEORIA-5415 N. UniverSity St, Peoria, It. 61614 -(309) 693-5463

BUREAU Of LAND. PEORIA - 7620 N. University St, Peoria, It. 61614 -. (309) 693-5462

•

CH.~MPAICN

- 2125 South First Street, Champaign, It. 61820 - (21 7) 278-5800

SPRINGfiELD - 4500 S Sixth Street Rd., Springfield, It. 62706.. (217) 786-6892

•

COLLINSVILLE - 2009 Mall Street, Collinsville, It. 62234 - (618) 346.5120

MARION - 2309 W Main St, SUite 116. Manon, It. 62959 - (618) 993.7200

PRINTFn

312

('1"1

kcrvrl

cr.

D ......

,.r'

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

I

GC~;

ENV I RNMENT Al

2cT and State Streets

Granite City, Illinois 62040

618-451-3013

Fax:6184514020

Dec 17 2003 13:25

P. 01

IEPA EXHIBIT

Noo

3la

~

Tt):

United

States Steel

CorporatIon

Granite City Works

Erlvtromnental Control Depwtment

From:

carl Cannon

F:oc

217-782-9891

Phone:

Rll:

Pages: 3

08*

12117/03

cC:

o

Urgent

• Comments:

Ukanno-

o

For Review

0

P~e

Comment

0 PI-ase Reply

o

Please R-.cycle

Per your request, attached is the information on the 301(9) variances from the USEPA

Also, we do not have any storm water flows discharged through a conveyance that

is

not limited

by

an

NPDES permit at the point of discharge. Therefore

we

were not required

by

the federal stormwater

regulations

to

submit application forms 1 and 2f.

SOfTy for taking so long

to

supply the information. f:'lease let me know if you have any questions.

Th~lnks

.

.Carl

371

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

!f

GCS ENVIRNMENTAL

Fax:6184514020

~T

13

"32

11; 10AM NRTIONRL

STEEL

Dec 17 2003 13:25

P.02

Fuelic

~ot\ce

NO.:

TGM:TRK:5F~:bis/Z015j.~~

PubliC N9

t1e

&

Date:

MAY 2 8 1992

~ct1~:

Not1cf

of

a

te~tatfvt d~c's10n

to grant, pUTsuant to Sfct10n 301(9)

of

th.

Clean

~.t~r

Act. a variance from BAT for nonconventlonal pollutants

a~nl.

(H) and

p~anQl$

(4AAP, for:

~attooal

Steel CorporatIon

Crl"1te City 01vls1on

Granite

Cay,

1111,,0\s

HPOE~ P~rmlt

No. IL000032S

Sulllftiry: Nltlonal Steel Corooration. ;>urSUlnt tv S.'t1ons

30l(~)

and

~O'(j)(t)(8)

of

t~e

Clean water Act (CWA) requtsted a varf.net from the best

ava~'_ble tr8atmt~t

econom1eally

.,hleva~l,

<SAT) tftltment requirements

tor

the

no"conv@~tional

po11utants

l~nla(N)

and phenols (4AAP)

~or

tht

dis'~lrge

of

tftet~d

pl.nt

~astewat.r

throv9h Outftl1 001 to

Horses~ La~e.

Nationil

stefl

Cor;)ora.':'onprOduces coke. molten

fron, 'teel, And

flnl&MQd

and

s~m~-(~1i1S'h~d

rolied :tul ::lrQduCt$ at Hs

Gr~nitt

City Ofvis1Qn.

Sfct10~

301(9) of tn@ CWA authorizes tht U.S.

£nv'r¢~nt4'

Prot~~tion

Agcnty

(U.S.

EPA) to mod1fy thi BAT

r~quilem!nts

fOr

nQnconyent1on~1

pol1utants

pl"c'f1ded ii at1sf.c.tol'Y

drmonstl"H1on is

mad.

that, amon9 otl'lt" .factors,

suctl

,~d\f1catlon

w111 not interftre w1th

t~!

attalnmtnt

of

vattr quality

~lCh

'wnl Hsore ttle prottct'on

¢f

Duolle \tater

!lJpplh~

and aqtJatle life 'lid .,11

'lot pou an :.Ii1actepUble dsk.

to hU/Ilan hnlth or

the

elw~'onll.nt,

~;h~

Illinois Env'ronmentai P

r

otlct1on.AQency

r~v'.wed

~at'ona!

Steel

Corperat'cn'~

appl~eat~on

and

r~c~nded

that U.S. EPA

a~prov.

the variance.

ne proposed rnod\f'td efflvint 11lr.ltat1oM {PMELH. _h'e" would

be 10

effect

~~ld

the var1ance be grant.d, arQ

~omp~r.d

w,t~

the best

~ract'c'bl.

Cont~l

t

t?chno109Y (BPnatld b.i

t

aVi.l h.b 1e ttctmo100)' eeooQlII1 ca 11)'

.~t1

hVib 11 {SAT>

lil1lHat1ons {in lbs/da::f}:

Olscharge

Lo.d'n9S (lbs/dly) through Outf."

001

W'J.j

leI

W

~!mQnJl

00 Apr11.Qc.tobtr

Mclnth Iy A'fIYi911

SOO

1013

94

Oa,

i 1y Ha l( t

mum

900

3~

303

~BQnja.

00

~yember-~

Mot\thly Avtr.gt

600

1013

94

Da t 1

y

t'la:»:' mom

900

3040

303

f-!l!.

QQ.!

s

(iBAe.~

Mol~th

ly

Av.ra9~

5

32.4

0.49

ua

~I

1

y

Ma

~

, mum

lO

g~.7

0.98

Th., 'MtLS a.rq reflHtfve of the effllJtnt loadlnQ5 presently b;lng n"orted and

w~'1

~Qet

Applicable Illlno1s

~ater

Quality stlndards at the outfall. U.S.

tPA'~

r~1~~

of the aVlflable

1nformltlo~

IndIcates' that

~lter

qua"ty

372

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

GC~;

ENII IRNMENT AL

Fax:61845i4020

Dec 17 2003 13:25

P.03

standardS are protl"Ct1ve

of

llquatlc lIfe lod hUNO "'ta.Hh. U.S. EPA has

&:la1yud the tnIrHs of National Steel Corporation's

var~lnce

rtquest

and

bel'ev@s that

it

satisfies 111 of th, statutory cr1teri.a. Therefore R.9'on V

of

th~

U.S.

£P~

I!

~ropos1n9

to grant Nattonal St@!l

Co~~rat1on's

reQuest for

a SEctIon

301(~)

variance

for its

Grlnln

City 0:'II510r,

.'if

UItIlCtl1il(N) lne

phtflols(4AAP).

p..!QU.O!l.rtLto",

f.1.t'l1l1..~Jte[m1

OLtl.Q!l

Intere,ted persons

m~y

submit

w~ltt~n ~~nts

on the Tentative Oeciston to

9rant

the

Sec~lor.

301(g} vArianC€ to

tnt u.s.

EPA

Re9'Oflal Adm1nlstrato

r

~Ithln

th'rty (30)

d~y~

of th. dati of tnis pub11c nottee at the address

e~te~

belew.

Comm~nt~

snou1d be specifIc and lnclud. the basi, and r.levarot fatt$

upon

_~jch

thty

~rt

made.

Anyone who Is tnttrtsted in comment1ng on thIs

Ter.tltjv~

DecisIon

shoul~

be IWlre of the

ob'19at~on

to ralii IS5ves. and to

pr0Yld9 supporting

1nforma~lon,

for

c6ns\derltio~

QurinQ th1s pub'"

comment

~erlod

in order to

rals~

thoSQ

lS5U~$

\~

i

subs!qut~t

app.al.

A11 commfnt5

wIll ee considered 1n the formulltlon of a f'ni1 dt(I$lon on th'5 vlr1ance.

;.., Clubl

1

c

~et\n9

on thIs tentlthe

de~·js\on

will bt held If s1gnifleant PlJblic

lnt!~est

,n a publIC mtrt\ng Is exertSsed,

tnterlst@d persons should

su~it

tnf'r rtquests for a publIc

~tt1n9

.long wtth IssVtS of concern.

rOl

i

o

p

lng the

'1~se

of tht publ'c

C~"t

period. U.S. EPA wi" make I final

d9Clsl0~

on

Ni~\ohal Ste~l Cor~ratlon's

S.ction

~Ol(9)

var11nc.

reQuest.

Htt~ln

30 dty:

:o110~1"~

the tssuance

of

U.S. EPA's fin.1

dte1~to".

any

lnterfSted

p~r,·~n

may

requ~!t

an

adjod\~at~ry heatl~g wit~

ri$peet to Issues

raIsed for ,oosid@ration 6utinv th. oubl'e

,omme~t Qer1~

(40 CF. 124.76). An

iooea1 Of the final decision 01 thl varlanc@ may bt made under 40 efR 124

Subpart. E and F.

.

:ne

ape\lc~tjo~,

rentatlve Oecisfon, T!ntattve Oecis'on Support Oo'wmEnt ind

.ldmln1~trat've

ficord

ire

!va11l=le for

revt.~

it U.S. EPA'S Reg.¢o V office

.t the

id~re5s

btlow and at the 111inoti

£"vir~ment.,

Prot.,tton Ag.ncy,

Sprln;f1e'd,

111~no1s.

A

fee

may be charged

for

cooy~n9 t~tl'

docu~nts.

AODRESS£S~

Ali comments

regardln~

the

T.nt~tiv6 Decl~1on

wh1ch art

~ubrnitted

on

~r be~ore

30

days

aftQr

pu~l1'ltlon

of th1$

nott~i

.111

~

~ons'derfd

ard

sho~ld

bt

se~t

to

Re~lonal

Adm1n'strltor; U.S. £nv1ronmental

?rot~ct\on

Agency, Att@nt\on:

Water D1vision (SWQP.16J) 17

~est

Jackson

oQu~,vard,

C~'cl90,

Il't~o;s

60604

~lth

1 copy to the Illtnois

Env1ro~~nt.l

~rctiction

Agency. 0ivlsion

of

water Pollut1on Control,

2Z00

Churchill Road.

Springfield.

!ll'no'~

6Z794-9276.

Re~ut$t

for further \nformat10n regarding this

var11~'t

d.e1,1on and for

copi~s

of the

Te~tatlve

0,c11100 and rentat1vt

O~,ls'on

sup~ort

eo,umtnt

maj

l>f

dl!'"!chd

to

I'1r.

'aclc.

Helfman, U.S. Envlron

,

nenh}

Protection

AQency,

77

West

JacJ.son

Bou!eVl,.d, Chieaqo. trL

1

lnol $

60604.

Sf~:b1SJ2015j.sp

373

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Granite

City

Works

Uniled Slales Sleel

20th & State Streets

Granite City, IllinoIs 62040

(618) 451-3456

April 5, 2004

CERTIFIED MAll NO. 70012510000645804258

RETURN RECEIPT REQUESTED

Mr. Blaine Kinsley,

PE

Acting Industrial Unit Manager

Pennit Section

Ulinois EnvirOIlmental Protection Agency

Division

of Water Pollution Control

1021 North grand Avenue East

PO Box 19276

Springfield, lllinois 62794-9276

RE NPDES Permit No. ll0000329 Renewal;

Dear

Mr.

Kinsley

(~)

ILLINOIS ENVJFiOiWv'IENT/lI

.~

PROTECTION AGENCY -

oOW;WPC/PERMIT SECTION

cLN.

~

m;Cc;rremwlffi

..

u

-

.

..

~.~"rD·\

"~'

I 1

APR 09 2004

'''~J

Envjro~mental

Protection Agency

WPC--Permit Log

In

Per our previous discussion, attached for you information/use are the outst311ding issues, as I understand

them, as well as a draft

pennit based on my understanding.

United States Steel Corporation, Gr31ute City Works would like to proceed with

tl1e subject permit

renewal which incorporates

an internal mOlutoring point (Outfall 00 I C) for the landfillleachates, per our

meeting \vith

the Agency on June 26, 2003.

Should you have any questions or need additional information please contact me at 618-451-3013

Sincerely,

!U~

Carl Cannon

Environmental Manager

NPDESRNLCEC

374

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

mIEcgIEJ1\fIE)~

lJNITED STATES STEEL CORPORATION

Apo

1\.

a

7

Wi-A

')fir}

~

J

D

,)

GRANITE CITY "YORKS

ILLINOIS ENVIRON/t1E/1'

NPDES PERMIT

RE~'EW

AL ISSlJES

B6~?:ECTIONAGEN~~L

/vv.

C/PERMi~

SE

~

I

CI/ON

1. Outfall 001. Oil

&

Grease 30-day average lbs/day GCW requests the 80" Hot

Strip Mill be included in the allowable calculation for the 30 day average The

industry standard

is to allow for Y2 of the daily max.

2. Outfall 001. Available Cyanide 30-day average decreased form 0.02 to 00052

ppm to reflect the current water quality standard GCW requests sampling method

OIA-1677

be specifIed with a one day per month sampling frequency

3. Outfall 001. Ammonia Water quality standard changed to a three season

allowable.

4. Outfall OOL 301 (g) GCW previously requested to continue to incorporate the

variance

in the permit for ammonia and phenol

5. Outfall 001 Zinc GCW previously requested the central treatment exemption for

zinc

GCW proposes 556 lbs/day daily maximum and 11.5 lbs/day 30-day

average, which is based on actual plant data, see the attached graph

6 Outfall

OOIA GCW requests the central treatment exemption for B(a)P and

Naphthalene. GCW proposes 0

15 lbs/day daily max, and 0 13 Sibs/day (99

percentile) 30-day average for B(a)P. GCW proposes 0 10 Ibs/day daily max, and

0.085 lbs/day (99 percentile) 30-day average for naphthalene. The daily

maximums are based on actual plant data, see the attached graphs. The 30 day

averages are estimated based on actual plant data. The plant data is sampled at a

frequency on once per month, therefore actual 30 day averages

is not available.

This includes additional allowable loading associated the addition

of water used

for the optimization

of the coke plant biological treatment system per Section

420.

13 (a)(3). Should IEPA not agree with the applicability ofthe central

treatment exemption,

then GCW requests a two-year compliance schedule to

install additional controls on the By-products wastewater treatment plant.

7 Outfall 001

C.

NSC landfill leachate GC\V previously requested a new NPDES

monitoring point prior to entering the steelworks ditch

375

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Acute Toxicity - The initial acute toxicity testing should be run on at least three trophic levels of

aquatic species (fish, invertebrates and plants) which represent the aquatic community for the

receiving-stream

.. Suggested speciesiriclude the FatheredMinnow,Ceriodaphnia, and-

Selenastrum Capricornufum. All tests should be done in accordance with "Measuring Acute

Toxicity of Effluents

to Freshwater and Marine Organisms (Fourth Edition)", (USEPA/600-4-90/027)

and "Environmental Effects Tests Guidelines" (USEPA/560-6-82/002). The IEPA specification and

guidelines for these tests, given

in "Effluent Biomonitoring and Toxicity Assessment - Aquatic Life

Concems," must also be met.

/

/

-/

NPDES Pennit No. IL0000329

Special Conditions

SPECIAL CONDITION

1. The pH shall be in the range 60 to 9.0. The monthly minimum and monthly

maximum values shall be reported on the DMR form.

SPECIAL CONDITION 2. Samples taken

in compliance with the effluent monitoring requirements for outfall

001A shall be taken at a point representative of the discharge, but prior to mixing with blast fumace

wastewater. Samples taken

in compliance with the effluent monitoring requirements, for outfall 001 B shall be

taken at a point representative of the discharge of the Cold Rolling Mill Wastewater, but prior to mixing with

other wastewaters. Samples taken for outfall 001C shall be taken at a point representative of the discharge of

this National Steel Corp. and United Sates Steel Corp. Landfill Leachate Wastewater but prior

to mixing with

other wastewaters.

(

Q'

SPECIAL CONDITION 3. The use.sf operation of this facility shall be by or under the supervision of a Certified

Class K operator.

SPECIAL CONDITION 4. The Permittee shall be required to conduct an effluent toxicity evaluation prior to the

renewal of this permit. Elements

of the toxicity evaluation should include but not be limited to the following:

A.

Aquatic Toxicity Screening

b

if

~r./

11\1

.

jl

j

y.

-

~

,

o.p.J\r

Chronic Toxicity - The initial short-term chronic toxicity testing should be run on at least three

V

J

,trophic

I~vels

of

aquati~ ~pecies

(fish, invertebrates

a~d ~Iants)

which

repre~ent

the aq.uatic

.

\~Y,J

t.

community for the receiving stream. Suggested species Include Fathead Minnow, Cenodaphnla,

If

\f' .

and Selenastrum Capricomutum (green algae). All tests should be done in accordance with "Short-

f) ,j-"" l

term

~ethods

for

Estima~ing

the Chronic Toxicity of Effluents and

Rec~ivin~

Water to F

:es~water

bY

Organisms (Second Edition)", (USEPA/600/4-89/001). The IEPA specifications and gUidelines for

these tests, given in "Effluent Biomonitoring and Toxicity Assessment - Aquatic Life Concerns,"

must also be met.

Testing shall be conducted on fish and algae

over a 96-hour period while invertebrates should be

tested over a 48-hour period. Tests should be performed on 100% effluent.

B.

Human Health Effects

Chemical specific testing shall analyze the effluent for 113 priority pollutants (see 40 CFR

136

Appendix A, Methods 624 and for non-priority pollutants (except for those already being monitored

and limited on page 3). Samples shall be handled, prepared, and analyzed by GC/MS

in

accordance with 40 CFR 136 Methods 624 and 625 (October 26, 1984 Federal Register). GClMS

procedures for direct injection of water samples using appropriate GC columns such as 10%

396

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

United States Steel Corporation

Granite City Works

20th

&

State Streets

Granite City,

IL 62040

618 451 3241

tax 618 451 3707

email mstein@uss.com

July 22, 2004

CERTIFIED MAIL

NO 7001 2510 000017602437

RETURN RECEIPT REQUESTED

Mr. Blaine Kinsley, PE

Manager, Industrial Unit

Permit Section

Division of

Water Pollution Control

IllinoIs Environmental Protection Agency

1021 Grand Avenue East

POBox 19276

Springfield, Illinois 62794-9276

Dear Mr Kinsley

6MB

General

Merle

R.ManagerStein

lEnA

r n

No.

4-5

l§~lrs©\-!'~l:rg1J~;

'_,'T.

IW

()

~

3

Re United States Steel Corporation - Granite City Works

NPDES Permit Number IL0000329

United States Steel CorporatIOn - Granite City

Works (GCW) has reviewed the current NPDES permit and

requests that the following changes be Incorporated into the NPDES permit

renewal

~

Remove special condition 8 and the permit limitation for total chlonne residual Breakpoint

<:J

chlorination is no longer necessary at GCW and has not been performed since the early 1980's

GCW has no plans to use breakpoint chlorination in the future

2

Remove special condition 4 The specified monitoring has been performed during the last

two

permit renewal cycles GCW believes there is sufficient data available and no additional testing is

needed

Remove special condition 5 The oil and grease composite sampling has been performed semi-

:-Li' annually since 1998, The data demonstrate that individual grab samples are significantly less

Q

than 75 mg/l, and the composite samples are significantly less than the permit limitations GCW

has demonstrated consistent control of the oil and grease parameter, Additional composite testing

is not needed

~.~

Remove special condition 12 Special condition 12 is not applicable to the current ammonia

limitations

~, ~)3CW

requests that the load limits for iron (dissolved), fluoride and cyanide (available/weak acid

;:::/,'

'~dissociable)

be removed from the permit These are water quality based limitations and as such

~,\f ~the

concentration limitatIOns are protective of the environment.

0)-~

ij-

Thank)oVin advance for your consideration of these issues Should you require additional information,

please contact Carl Cannon at (618) 451-3013

Sincerely,

re .Steln

General Manager

Granite City

Works

United States Steel Corporation

H:IUSERSIWORDICEC\NPDES penni! renewal cleanup] ,DOC

432

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

US Steel-Granite City Works

IL0000329

Beth

Iv1. Burkard

Page

38!~O

08-19-2004

Response: This

is acceptable. The graphs are attached to the letter from US Steel, dated

Apri15,2004 The graphs show actual plant data. The two graphs show the daily

maximw11 load limits for each pollutant for each month from January 1998, to October

2003. The daily

maximum load limit selected for each parameter is the maximum value

on each graph. This is appropriate, as these two parameters are only tested once per

month.

Because these two parameters are tested only once per month, a 30-day average

load

limit is not necessary. The proposed daily maximum value for each parameter is

0.15 and 0.10 Ibs/day for B(a)P and naphthalene, respectively.

7) Outfall

CO 1: NSC landfill leachate: (Jew previously requested a new NPDES

monitoring point prior to entering the steelworks ditch.

Response: Outfall

CO 1 will be added to the renewed permit. Outfall eo 1 will be sampled

after leaving the landfill,

but before mixing with any other wastewater sources. Only

flow will be limited for CO l, as the wastestream will undergo treatment before final

discharge.

The data submitted on Form 2C (for COl) ofihe application does not indicate

any pollutant

of concern that will not be sufficiently treated in the treatment works before

discharge. Internal Outfall COl will be named Landfill Leachate Wastewater. This

wi]]

indicate that this wastestream if for waters from the two landfills still owned by National

Steel Corp and the other landfills owned

by US Steel.

Response to Letter, Dated July

22,2004 from Merle Stein

1) Remove special condition 8 and the permit limitation for total chlorine residual:

Breakpoint chlorination is no longer necessary

at GCW and has not been performed since

the early 1980s.

GCW has no plans to use breakpoint chlorination in the future.

Response: (See also page 28

of notes.) In a meeting of July 8, 2004, Mr. Carl Cannon

stated that breakpoint chlorination is not used at (JCW, and will never in the foreseeable

future be

used again. Thus, the special condition (8 in the previous permit) stating that

TRC shall be sampled when breakpoint chlorination is occurring will be removed, as will

the limits for TRC.

2)

Remove special condition 4: The specified monitoring has been performed during the

last two permit renewal cycles. GCW believes there is sufficient data avai lable and no

additional testing is needed.

Response: The Planning Department memo

of July 9, 2003, states:

"A review of recent whole effluent toxicity test results found that no acute

toxicity was present in the effluent.

The June 19,2003 memo from Aly

Grady recommends that one round of acute testing using

Ceriodaphnia

and fathead mimlOw be conducted 12 months prior to the expiration of the

permit."

This significantly reduces the burden

of toxicity testing, as the I-Iuman Health Effects

portion, the

Selenastrum capricornutum

(green algae) portion of the Acute Toxicity

478

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

US Steel-Granite City Works

Page 39/q \)

lL0000329

Beth M. Burkard

08-19-2004

Screening, and the Chronic Toxicity Screen have all been removed, leaving only the

Acute Toxicity Screening for

Ceriodaphnia

and fathead minnow. This is only required

once in the length

of the permit.

3) Remove special condition 5: The oil and grease composite sampling has been

performed semi-annually since 1998. The data demonstrate that individual grab samples

are significantly less than

75 mg/L, and the composite samples are significantly less than

the permit limitations. GCW has demonstrated consistent control

of the oil and grease

parameter. Additional composite testing is not needed.

Response: Due to the frequent grab sampling, composite testing

is redundant. The table

below demonstrates that the composite sampling is represented by the 30-day average

value orthe twice per week grab sampling. Continuation ofthe composite testing is not

necessary. The special condition and the corresponding requirements will be removed

in

the renewed permit.

Table. Composite Testimo!

~

of Oil

&

Grease

I

Date

Value with Composite

Monthly Average

of Grabs

I

(mg/L)

(mg/L)

66

--

December, 2003

June, 2003

7

<5

I

December, 2002

0.9

<S

-------_._

..

-

June, 2002

1

<5

I

December, 2001

1

<5

June, 2001

1

_I

<5

December, 2000

1

<S

June, 2000

1

1<5

4) Remove special condition 12: special condition 12 is not applicable to the current

ammonia limitations.

Response: Special condition

12 states "The permittee is prohibited form effluent

acidification to lower effluent pH if the purpose is to increase the total ammonia nitrogen

concentration." It is no longer necessary for the ammonia limits that will be included in

the renewal permit. This special condition will not be included in the renewal.

5) GCW requests that the load limits for iron (dissolved), fluoride, and cyanide

(available/weak acid dissociable) be removed from the permit. These are water quality

based limitations and as such, the concentration limitations are protective

of the

environment.

!

Response: The Planning Department analysis for Water Quality Based Effluent Limits

(dated July 9, 2003) states that limits should be included in the permit for Cyanide

(\VAD), Fluoride, Iron (Dissolved), and Zinc, because each

of these components has a

reasonable potential to exceed water quality standards. This is based on data submitted

by the Permittee, analyzed by the Planning Department.

479

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

STATE OF

ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY

No.

Sf

Subject: lJS Steel-Granite City \Vorks

Data IL0000329

Reviewed

By Beth i"1. Burkard

Page 1 of 3

Date:

1

0/22/2004,

11/

1/2004

lINITED STATES STEEL CORPORATION

GRANITE ClTY WORKS

NPDES PERMIT DRAFT CLEAN-tIP ISSUES

1. Page 1 of 1:1ct sheet. Our cold mill h3s always been a once through system.

Response:

Change Fact Sheet to remove the line stating that the system has been modified to a once through

system.

2. General:

Some limits are different between the fact sheet and public notice draft

Response:

Checked notes and changed Draft Permit and Fact Sheet to reflect correct limits.

3. Outfall 001: Significant figures request Iron (total) 30 day average of2 as in previous

permit \Is. 2.0 mg/l; daily

maximum of

4

vs. 4.0 mg/l.

Response:

The limits are promulgated in the regulations as 2.0

mg/L

for monthly average concentration

limit for Iron (total).

The limit in the permit must be consistent with the regulations. Regardless

of how many significant digits a limit is assigned in the permit, the permittee must report the

value,

without ri:mnding, up to six decimal places (eight characters). Iftbe lab reports to seven or

more decimal places (nine or more characters), then the permittee may report. on the DMR a

value rounded

to the sixth decimal place (eight total characters). Please see "Guidelines for the

Completion of Preprinted Discharge Monitoring Report Forms", Completion, #5.

4. Outfall 001:

Request Lead (total) 30 day average of 0.09 mgll be removed, sampling is

on a quarterly basis.

Has not been in previous permits.

Response:

The purpose

ofthe monthly average limit is to verify that, should the permittee monitor more

frequently than required, and obtain suffLCient analyses to produce a monthly average, the

Agency may verify compliance with the limit. The permittee is not required to sample more than

once per quarter, but should they choose to monitor more than once per month, they shall

provide the

Agency with data indicating the results of those analyses. See also Attachment H-

Standard Conditions.

5. Outfall 001: Request Cyanide (total) sample type be a composite as in previous permit vs.

a grab, since previous permit and data collected

bas been based on composite sampling.

Significant figures: request a 30 day average

of 01 as in previous permit vs 0.10 mg/L

The daily maximum of 0.2 as in previous permit vs. 020 mg/L

489

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

STATE OF ILLINOIS

ENVIRONMENTAL PROTECTION

AGENCY

Subject: US Steel-Granite City Works

Data IL0000329

Reviewed

By Beth M. Burkard

Page 2

of 3

Date: 10/22/2004, ]

111/2004

Response:

40

CFR Part 136 specifies that grab samples must be collected for cyanide. Per 40 CFR

§

136.3,

the Permittee

may apply for an alternative test procedure from those test procedures established

in 40 CFR 136. Regarding significant digits, please see response to #3 above.

6. Outfall 00] : Request Cyanide (available) sample type should be composite as in previous

permit for weak acid dissociable cyanide, and

not grab, since data collected was based on

composite samples. Outfall 00]: Signitlcant figures: Request Phenol (4AAP) 30 day

average

of 5 as in previous permit vs. 5.0 Ibs/day; daily maximum of 0.1 vs. 0.10 mg/l as

in previous permit.

Response:

Regarding Cyanide, Available: 40 CFR Part 136 specifies that grab samples

must be collected

for cyanide.

Regarding Phenol (4AAP):

The concentration limit established in 35 lAC 302.208 is 0.] mg/L.

The permit writer edited the Draft Permit and Fact Sheet to reflect consistency with the

regulation.

The load limit of 5.0 lb/day will remain in the permit. It is Permit Section protocol

to

round load limits that are between land 10 to the nearest tenth of a pound.

7. Outfall 001: Significant figures: Request Fluoride of 4 as in previous permit vs. 4.0 mg/I.

Response:

The limit for Fluoride is provided in the Illinois Pollution Control Board Adjusted Standard AS

90-4.

The Board established an alternative limit of 4.0 mg/L.

8. Outfall B01: Request Flow sample frequency of2 days/year as in previous permit vs.

continuous.

Response:

The permit writer edited the Draft Permit to read Measure When Monitoring to clarify the flow

reporting requirements.

9. Outfall AOl: Is there going to be a 30 day average for B(a)P and Naphthalene? If so,

request 0.085 lb/day for naphthalene and 0.135 for B(a)P

per our previous submittal of99

percentile of daily maximum data. Propose we monitor only the 30 day average without a

limitation for this permit cycle and review

the need and appropriate 30 day average

limitations

based on the central treatment exemption.

Response:

The permit will only contain daily maximum limits for Benzo(a)Pyrene and Naphthalene;

monthly average load limits were included

in error. The permit writer edited the Draft Permit to

reflect this correction.

490

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

STATE OF lLLlN01S

ENVIRONMENTAL PROTECTJON AGENCY

Subject: US Steel-Granite City Works

Data:

lL0000329

Reviewed By: BethM, Burkard

Page 3

of 3

Date:

10122/2004,

1111/2004

10,

Outfall 001: New weekly average limitation for ammonia nitrogen: Review of data shows

for 3/11/03 (7,5 mg/l) and

3/12/03

(64 mg/l) weekly average would have been 6,95 mg/l

VS,

proposed limitation of 7,0 mg/I. request weekly average limitations be removed, If

they remain, request the limitation be 7 vs, 7,0 mg/I.

Response:

The limits for Ammonia-Nitrogen are based upon methods outlined in

35 lI1inois Administrative

Code (lAC) Section 355, Weekly average load limits are determined using the chronic standard

(monthly average) developed in Section 355,

as described in 35 lAC 302,212(b)(3), Because the

permittee

is required to sample more than once per week, the weekly average limit will remain,

11. Page 5 of fact sheet: Second paragraph, Outfall AOI enters the blast furnace lagoon only,

Response:

Fact Sheet has been updated to reflect this correction

12, Page 5 of fact sheet: Second paragraph, the sentence starting with "With the exception of

wastewater from the Blast iron furnaces" Change blast iron furnaces to "Iron Making

complex including stonnwater",

Response:

Fact Sheet has been updated to reflect this correction,

13, Flow diagram: Propose submittal of and update flow diagram showing internal

monitoring point

COl

with contributions from Nation Steel Corp, section lIT and IV

landfills and United States Steel corp, landfill section Vas part ofthe permit record,

Response:

Permittee is mailing to Agency, Will include updated flow diagram in records, Agency received

updated flow diagram

on October 20,2004,

Total residual Chlorine: Vye do use large quantities of city water; the major users are the #1

and #2 continuous casters and the boilers, However, due to the nature of our system, i,e, the

surface impoundments, the total chlorine residual has not been an issue at Outfall

00 I,

Response:

Notes have been updated to indicate that city water is used, and that because the treatment works

will remove chlorine

to below detectable limits, the TRe limits and conditions may still be

removed from the

permit

11/01/2004:

Per Unit Manager, Compliance will determine rounding/significant digit issues Permit will

contain limits

of 2 mg/L rather than 2,0 mg/L

491

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

UnIted States Steel Corporation

Granite City Works

20th

& State Streets

GrarHte CIty. IL 62040

618 451 3241

fax

618

451 3707

email' mste;n@usscorn

November 15, 2004

CERTIFIED MAIL NO

7004116000024231 5163

RETUR~~

RECEIPT REQUESTED

Mr. Blaine Kinsley, P E

Manager, Industnal Unit

Permit Section

DivISion of Water Pollution Control

IllinOiS Environmental Protection Agency

1021 Grand Avenue East

PO Box 19276

Springfield, Illinois 62794-9276

Dear

Mr Kinsley

Re: United States Steel Corporation - Granite City Works

NPDES Permit Number IL0000329

IfPA EXHIBIT

Merle

R.

Stein

No._S__3

_

General Manager

fLLfNOj5' C(\:,Vi,=.

.~j>'}~IEi\jj'i.\L

PROTEe riC):'':;'

~(~·EI\/C'}"

BOVViVVPC;PE?:-J:T

~;Ec-no~,,;

United States Steel Corporation - Granite City Works (GCW) has reviewed the November 4, 2004 draft

NPDES permit and provides the following comments.

1. The Granite City Works Stabilization Ponds are an integral part of the Central Waste Water Treatment

System The Stabilization Ponds are the primary means

of organics stabilization by Natural Biological

Processes The Granite City

Works Stabilization Ponds are facultative, using both aerobic and

anaerobic breakdown

of organic matenal. In the upper aerobic layer, a unique relationship eXists

between bacteria and algae The bacteria metabolize organic matter and releases nutrients, those

nutrients are then used by the algae

With energy from sunlight The algae in turn releases oxygen for

use by the bacteria. The algae undergo respiration at night and do not release oxygen. The resulting

variation

in the oxygen content in the surface water of the stabilization ponds will likely affect the

biological activity

of the aerobic bacteria as well as the facultative bacteria In the transition zone

between aerobic and anaerobic

Based on this daily variation, Granite City Works is requesting the total cyanide sample type to

remain as a 24 hour composite

2

Granite City Works has reviewed our DMR data and compared it to the draft NPDES Permit

The

review indicates

Granite City Works would have exceeded the 30 day average Spring/Fall Ammonia-

Nitrogen Limitation of 28 mgll during March 2002 (2.93 mgtl) and March 2003 (447 mg/I)

Granite City

Works requests that credit be given for attenuation of ammonia-nitrogen within

Horseshoe Lake for Spring/Fall penod, as provided

in the previous permit

Thank you

In advance for your consideration of these issues Should you require additional information,

please contact Carl Cannon

at (618) 451-3013

Sincerely,

~~

General Manager

Granite City

Works

United States Steel Corporation

HIUSERSIW0 RDICEC\NPDES permit renewal cleanup 1

DOC

507

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

IEPA EXHIBIT

No.

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(,ci

Carl E Cannon <CECannon@usscom>

<Beth Burkard@epa.state.il.us>

12/3/20049:3727

AM

NPDES permit

From:

To:

Date:

Subject:

Beth-

Thank you for your quick response Below please find some additional

information regarding your 11/30/04 email.

.

Cyanide

Ammonia

We believe the alternative for mathematical composites is a good solution

GCW filed a petition for an adjusted standard with regard to the general

use standards for ammonia on 1/16/97 (PCB 92-161) As part of the

negotiation process with the IEPA, the water quality planning group

reviewed the discharge into Horseshoe Lake and allowed for the attenuation

of ammonia

in an 85 acre area of the lake which was still protective of the

water quality. The NPDES permit ammonia discharge limitation was adjusted

accordingly As a result, GCW withdrew the petition on 6/4/98.

We are requesting the same analysis be performed by the water quality

planning group to allow for attenuation within the area of the discharge,

which is still protective of the water quality

of Horseshoe Lake We are

requesting this for either the Spring/Fall period or for the month of

March, whichever the water quality planning group determines

is

appropriate.

Additionally, we are requesting

to preserve the 301 (g) variance for Ammonia

through the special condition provided

in the previous permit The 301 (g)

variances for ammonia and phenol in the previous permit stated "Special

Condition 9 For purposes of this permit load limits for Ammonia (as

N) and

Phenol (4AAP) have been based on actual plant discharges and are included

in accordance with a 301 (g) variance approved by the USEPA Any changes to

theses load limits can only be made following Public Notice and opportunity

for hearing." We believe this language is appropriate since the load limits

are based

on water quality limitations as in the original 301 (g) based

permit and the previous permit The load limits in the previous permit were

adjusted from the original 301(g) variance based

on new water quality

limitations, and the above Special Condition 9 was included

in the permit

Likewise, the existing load limits for Ammonia are being adjusted from the

previous permit limitations based once again on new water quality

limitations, and we believe the Special Condition should continue

to

include Ammonia as part of the 301 (g) variance in the new permit

Thank You Again for your assistance in our permit renewal

Carl

508

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

IEPA EXHIBIT

ILLINOIS ENVIRONMENTAL PROTECTION ACENCY

No.__

5_5

_

1021

ORTH GRAND ;\VENUE EAST, PO. Box 19276, SPRINGfIELD,ILL;NOIS 62794-9276, 2! 7-782-3397

JAMES R THOMPSON (£I'HER,

100

WEST RANDOLPH.

SU!T£11-300, CHICAGO,!L 60601,312-814-6026

ROD R. BtACOJEVICH, GOVER"JOR

RENEE CIPRIA"JC), DIReCTOR

DATE:

TO:

FROM:

SUBJECT:

J\1emorandum

6 December 2004

Beth Burkard

Scott Twait

,jr

Ammoni3 WQBELs

US Steel Corporation - Granite City NPDES Permit No, IL0000329

(Madison County)

ThiS memorandum readdresses the amffiODla recommendation m Bob Mosher's memorandum to Ukanno

Foxworth on July 9, 2003 Smce this d1scharge 15 to a large lake, a small amount ofmL'cing is available, as

per

Bob Mosher's February 4, 1998 memorandum.

1recommend

tha1 a March 30 day average penDlt hmlt of

4.0

mgfL be placed in the pernllt as a water

qua lit

l'

based effluent 111111 t, whJch tal<es mto account a small amount of mIxing, This is based on the best

degree of treatment The weekly average penml hmlt should be 100

mg/l"

based on 25 times the chromc

limH.

A ZID is not avallable and the dally maximum permit hmit should remam at the limit contained in

the Ju

ly 9, 2003 memorandum of 15.0 mg/L.

These recommendations rel1ect a water quality standards perspective only and should not be construed as bell1g

lI1clusive

of all factors that must be taken into consideration by the pennit writer

cc

Bob Mosher

Nick Mahlandt

Bob I-hie

Chion

ROCK'ORD 4302 North Main Street, Rockford, Il. 61103 - (815) 987-7760

•

DES PLAINES -. 951 I W Hamson St., Des Plaines, It 60016 (847) 294-4000

ELGIN - 595 South State, Elgin, It 60123 - (847) 608-313 I

•

PEORIA - 541 5 N. University St., Peorra, It 61614 - (309) 693-5463

BUREAU Of l.AND -- PEORIA - 7620 N. University St., Peoria, IL 61614 - (309) 693-5462

•

CHAMPAIGN - 2125 South First Street, Champaign, It 61820 - (217) 278-5800

SPRINGfiELD - 45005 Sixth Street Rd., Springfield, It 62706 - (217) 786-6892

•

COLLINSVillE - 2009 Mall Street, Collinsville, It 62234 - (618) 346-5120

MA.RION - 2309 W. Main St., SuitellS09arion, It 62959 - (618) 993-7200

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

ILLINOIS

ENVIRO~MENTAL

PROTECTION AGENCY

1021

NORTH

GRAND AVENUE

["Sf,

PO 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

2171782-0610

RENEE CIPRIANO, DIRECTOR

DEC 1 4

2004

United States Steel Corporation

Granite City Works',

20th and State

Streets:~;~

.. :,

Granite Cit\" IIlinois:62040

-;i~~~~t

I'

Re:

United States Steel Corporation

NPDES

PermitN~.

IL0000329

Public Notice Permit

Gentlemen:

-~

.

Please post the attached'PublicNotice for the subject discharge for at least a period of thirty days from the date

on the Notice in a conspicuous place on your premises,

We have enclosed a copy of the draft NPDES permit on which this official Public Notice is based. If you wish

to comment on the

draft

permit, please do so within 30 days of the Public Notice date. If there are any

questions, please contact Beth M. Burkard at the indicated telephone number and address.

j~:~;f--"

.

The Agency has examined the ammonia limits for March and determined that a small amount of mlxmg is

available. The Agency recommends that a March 30 day average permit limit of 4,0 mglL be placed in the

permit as a water quality based effluent limit, which takes into account a small anlOunt of mixing. 1ne weekly

average permit limit should be 10,0

mgiL,

based on 25 times the chronic limit. A ZID is not available for

anunonia and the daily maximum pem1it limlt should remain at the limit contained in the draft permit of 15,0

mgiL

Thank you for your cooperation,

Blaine

A

Kinsley, P.E.

Manager, Industrial Unit, Pennit Section

Division of Water Pollution Control

BAK:BMB :04090 I0 l.bah

Attachments: Draft Permit, Public Notice/Fact Sheet

cc:

Records Unit

Compliance Assurance Section

Collinsville Region

SIMAPC

ROCKFORD - 4302 North Main Street, Rockford, IL 61103 - (81 SI

':iRi

.;;eo •

DES PLAINES - 9511 W Harrison St., Des Plaines. IL 60016 - (1347) 294-4000

ELGIN - 595 South State. Elgin, IL 60123 - (847) 608-3131

•

PEORIA - 5415 N, U"iversiry St., Peorta, IL 61614 - (309) 693-5463

BUREA,U Of

LAND - PEORIA - 7620 N. UniverSity St., Peoria, IL 61614 - 13091 69

3-5~62

•

CHAMPAIGN - 2125 South First Street, Champaign. IL 61820 - (21 7) 278-5800

SPRINGfiELD -- 4500 S. Sixth Street Rd, Springfield, IL 62706 - (217, ; 86.f,1392

•

COlliNSVillE - 2009 Mall Street. Collinsville, IL 622 34 - (618) 346-5120

MARION - 2309 W Ma,n St,. Suite 11 E51 Ton, IL 62959 - (618) 993,7200

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

NPDES Permit No IL0000329

Notice No. BMB04090101.bah

Public Notice Beginning Date December 19,

2004

Public Notice Ending Date January 18, 2005

National Pollutant Discharge Elimination System (NPDES)

Permit Program

Draft Reissued NPDES Permit

to Discharge into Waters of the State

Public Notice/Fact Sheet Issued

By

~:llIinois

Environmental Protection Agency

Bureau

of Water,

DiviSion of Water Pollution Control

Permit Section

1021 North Grand

Avenue East

Post Office Box 19276

Springfield, Illinois 62794,9276

217/782-0610

Name and Address of Discharger:

United States Steel Corporation

Granite City

Works

20th and State Streets

Granite City, Illinois 62040

Name and Address of Facility:

United States Steel Corporation

Granite City

Works

20th and State Streets

Granite City, Illinois 62040

(Madison County)

The Illinois Environmental Protection Agency

(I EPA) has made a tentative determination to issue a NPDES permit to discharge into the

waters of the state and has prepared a draft permit and associated fact sheet for the above named discharger. The Public Notice period will

begin and end on the dates indicated

in the heading of this Public Notice/Fact Sheet. The last day comments will be received will be on the

Public Notice period ending date unless a commentor demonstrating the need for additional time requests an extension to this comment

period and the request is granted by the

IEPA Interested persons are invited to submit written comments on the draft permit to the IEPA at

the above address.

Commentors shall provide his or her name and address and the nature of the issues proposed to be raised and the

evidence proposed to be presented with regards to those issues. Commentors may include a request for public hearing. Persons

submitting comments and/or requests for public hearing shall also send a copy

of such comments or requests to the permit applicant. The

NPDES permit and notice number(s) must appear on each comment page.

The application, engineer's review notes including load limit calculations, Public Notice/Fact Sheet, draft permit, comments received, and

other documents are available for inspection and may be copied at the

IEPA between 930 am. and 330 p.m Monday through Friday when

scheduled by the interested person.

If wntten comments or requests indicate a significant degree of public interest in the draft permit, the permitting authority may, at its

discretion, hold a public hearing. Public notice will be given 45 days before any public hearing. Response to

comments will be provided

when the final permit is issued For further information, please call Beth M Burkard at 217/782-0610.

The applicant is

engaged in production of flat rolled steel products in an integrated steel mill (SIC 3312, 3316, and 2999). Plant operation

results in an average discharge

of 25 MGD of treated process wastewater from outfall 001, 0455 MGD of coke by-products wastewater

from outfall A01, 0.604 MGD of cold rolling mill wastewater from outfall B01, and 0.20 MGD of landfill leachate wastewater from outfall C01.

The following modificalion is proposed This facility was purchased from National Steel Corp. by United States Steel, with the exception

of

Landfill III and Landfill IV. The facility no longer use Sintering, and Sulfuric Acid Pickling System has been removed. Internal outfall C01

has been added, for the landfill leachate, pnor to treatment and discharge with outfall 001

Application is made for

new and existing dischargers) which are located in Madison County. Illinois. The follOWing infonmation identifies the

discharge point, receiving stream and stream classifications:

Outfall

001

Receiving Stream

Horseshoe Lake

Latitude

38° 41' 31"

North

Longitude

90° 06' 28"

518

West

Stream

Classification

General Use

Biological Stream

Characterization

Not Rated

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Public Notice/Fact Sheet -- Page 2 -- NPDES Permit No IL0000329

To assist you further

In identifying the location of the discharge please see the attached map

The stream segment receiving the discharge from outfall 001 is on the 303 (d) list of impaired waters. The following parameters have been

Idenlified

as the pollutants causing impairment:

Pollutants

PCBs. pH, suspended solids, excessive algal growth,

ammonia (unionized), nutrients, phosphorus, total

ammol1la-N

Potential Contributors

Agriculture, crop-related sources, non-irrigated crop

production, habitat modification, stream bank

modification/destabilization

"

The discharge(s) from the facility shall be monilored and limited at all times as follows

Outfall

001 Treated Process Wastewater

jo, ,

LOAD LIMITS Ibs/day

OAF (DMF)

CONCENTRATION

LIMITS mg/I

4170

35 lAC

304120

5004

35 lAC

304120

3492

40 CFR 420

834

35 lAC 304 124

209

35 lAC

302208

17

40 CFR 420

56

40 CFR 420

35

40 CFR 420

46

35 lAC 302208

10

Variance of

301(g) of CWA

834

IPCB AS 90-4

3128

35 lAC 355

3128

35 lAC 355

3128

35 lAC 355

3128

35 lAC 355

Measure

6.0

-

90

10

20

12

24

15

30

24

PARl\,METER

Flow (MGD)

pH

CBOD

5

Total Suspended Solids

Oil

& Grease

Iron (total)

Iron (dissolved)

Lead (total)

Zinc (total)

Cyanide (total)

Cyanide (available by

OIA 1677)

Phenol (4AAP)

Fluoride

Ammonia Nitrogen.

Spring/Fall

Summer

Winter

March

30 DAY

AVERAGE

2085

2502

1511

417

56

12

19

1.1

50

584

459

1501

834

DAILY

MAXIMUM

REGULATION

30 DAY

AVERAGE

009

0.17

01

001

2.8

22

72

4.0

DAILY

MAXIMUM

0.4

02

002

0.1

4

15

15

15

15

REGULATION

35 lAC 304.125

35 lAC 304.120

35 lAC

304120

35 lAC 304.124

35 lAC 304.124

35 lAC 302.208

35 lAC 302

35 lAC 302.208

35 lAC 304.124

35 lAC 302,208

35 lAC 302.208

IPCB AS 90-4

35 lAC 355

35 lAC 355

35 lAC 355

35 lAC 355

.Spring/Fall is April-May and September-October Summer is June-August.

Winter is November-February, Weekly average limits

apply for Spring/Fall, Summer, and March Weekly average limits are as follows Spring/Fall 7.0 mg/L: Summer: 5.5

mg/L:

March:

10 mg/L. No weekly average limit applies in Winter.

519

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Public

~~otice/Fact

Sheet -- Page 3 -- NPDES Permit No. IL0000329

LOAD LIMITS Ibs/day

OAF rDMF)

PARAMETER

30 DAY

AVERAGE

DAILY

MAXIMUM

REGULATION

30

DA,y'

AVERAGE

DAILY

MAXIMUM

REGULATION

Outfall AOl - Coke By-Products Wastewater

Flow (MGD)

Naphthalene

Benzo(a)pyrene

Total Suspended Solids

Outfall BOl - Cold Rolling Mill

Wastewater

Flow (MGD)

Tetrachloroethylene

Naphthalene

Outfall COl - Landfill Leachate Wastewater

Flow (MGD)

Load Limit Calculations

010

015

11

073

40 CFR 420

40 CFR 420

40 CFR 420

40 CFR 420

Measure

Monitor

Measure

Measure

A

Load limit calculations for the following pollutant parameters were based on an average flow of 25 MGD and using the formula

of

average flow (MGD) X concentration limit (mg/I) X 834

=

the average or maximum load limit (Ibs/day) for outfall 001, CBODs, Total

Suspended SOlids, Iron (total), Iron (dissolved), Cyanide (available), Fluoride, and Ammonia as Nitrogen

B.

Production based load limits were calculated by multiplying the average production by the effluent limit contained in 40 CFR

420

Production figures utilized in these calculations for the following sUbcategories are as follows:

Subcategory

Subpart A - Coke Making Subcategory

Subpart C - Iron Making Subcategory

Subpart D - Steel Making Subcategory

Subpart F - Continuous Casting Subcategory

Subpart G - Hot Forming Subcategory

Subpart I - ACid Pickling SUbcategory

Subpart J - Cold Forming Subcategory

Subpart K - Alkaline Cleaning Subcategory

SUbpart L - Hot Coating Subcategory

Production Rate

1619 tons/day

7192 tons/day

8565 tons/day

8433 tons/day

9187 tons/day

2370

tons/day

2198 tons/day

2451 tons/day

2451 tons/day

For outfall

001'

Oil & Grease, Lead, Zinc, Cyanide (total), and Phenol (4.AAP); for outfall A01, Naphthalene and Benzo(a)pyrene; for outfall

801 Naphthalene and Tetrachloroethylene were limited using Federal production based load limits The following sample calculation

shows the methodology utilized to determine production based load limitations

For outfall 801, Naphthalene Daily Maximum Load Limit

=

Effluent Limitation from 40 CFR 420 103(a)(5)-8AT x Production Rate

=

0000167

Ib/1000 Ib product x 2198 tons/day x (2000 Ib/ton)

=

073 Ib/day

=

Naphthalene Daily Maximum Load Limit at outfall 801

When several subcategones have effluent limitations for a pollutant, the load limits from each subcategory are added to obtain the total

federal production based load

limit

The load limits appearing in the permit will be the more stringent of the State and Federal Guidelines

520

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Public Notice/Fact Sheet -- Page 4 -- NPDES Permit No IL0000329

The following explain the conditions of the proposed permit'

Special Conditions are used to clarify discharge and mOnitoring requirements, Samples for each outfall shall be taken at points

representative

of each waste stream A Certified Class K operator IS required, An Aquatic Toxicity Screening Study must be conducted

12 months pnor to permit expiration, using Ceriodaphnla and Fathead minnow, Non-compliance loads of zinc may be demonstrated to

not be

In violation of the permit limits by submitting calculations for zinc background credits, which will account for any zinc that is drawn

Into the system when the Influent water

IS taken from ttle MissisSiPPi River,

-.\

..

521

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Public Notice of Draft Permit

Public Notice Number BMB04090101 bah

IS hereby given by illinoIS EPA, Division of Water PollulJon Control, Permit Section, 1021 North

Grand Avenue East, Post Office Box 19276, Spnngfield, illinoIs 62794-9276 (herein Agency) that a draft Nalional Pollutant Discharge

Eliminallon System (NPDES) Permit Number IL0000329 has been prepared under 40 CFR 124.6(d) for United States Steel Corporation,

Granite City Works, 20th and State Streets, Granite City,

illinOIS 62040 for discharge into Horseshoe Lake from the United States Steel

Corporation, Granite City Works, 20th and State Streets, Granite City, Illinois 62040, (Madison County). Facility is an integrated steel mill,

located

In Granite City, in Madison County, in Southeastern Illinois. The plant makes its own coke in on-site Coke Ovens. Two Iron Blast

Furnaces are used to make molten iron. Steel is made in two Basic Oxygen Furnaces, using scrap steel and molten iron. Ihe steel is

formed into slabs by two Continuous Casters Steel slabs are converted into rolls by an 80-inch Hot Strip Mill, pickled

In a Hydrochloric

Acid Pickling station, and cold formed by a Direct Application Cold-Rolling Mill. The facility also employs three Galvanizing Lines for

finishing of the

steel The final product from the facility is coiled sheet steel, though some steel is sold as cast slabs or unfinished coils.

The Coke-Plant By-products (Internal Outfall A01) are treated with activated sludge before entering the Blast Furnace Lagoon. Internal

Outfall B01, the wastewater generated by the Cold Rolling Mill, is treated in an Oil Skimming Basin before entering the Steelworks Lagoon.

Internal Outfall COl is the leachate from the landfills

at the facility, and the leachate is treated in an Oil Skimming Basin, and then treated

In the Steelworks Lagoon With the exception of wastewater from the Blast Iron Furnace complex including stormwater, all other

wastewater sources

enter an Oil Skimming BaSin, and then are treated in the Steelworks Lagoon, inclUding storm water, water from the

pickling-s'crubber, wastewater from the galvanizing lines, and all other water sources in the plant. Water generated at the Blast Iron

Furnaces is directed to the Blast Furnace Lagoon, after treatment in a separate Oil Skimming Basin Water is pumped from the Blast

Furnace and Steelworks Lagoons into either the Tertiary Treatment Plant for filtration, or recycled to be used as source water for the plant.

From the Tertiary Treatment Plant, the treated wastewater

is pumped through a flume and into Horseshoe Lake for discharge at Outfall

001

The application, draft permit and other documents are available for inspection and may be copied

at the Agency between 9:30 A.M. and

330 PM Monday through Friday. A Fact Sheet containing more detailed Information is available at no charge. For further information,

call the Public Notice Clerk

at 217/782-0610

Interested persons are invited to submit written comments on the draft permit to the Agency at the above address. The NPDES Permit

and Joint Public Notice numbers must appear on each comment page All comments received by the Agency not later than 30 days from

the date

of this publication shall be considered In making the final deCision regarding permit issuance.

Any interested person

may submit written request for a public hearing on the draft permit, stating their name and address, the nature of

the issues proposed

to be raised and the evidence proposed to be presented with regards to these issues in the hearing. Such requests

must be received by the Agency not later than 30 days from the date of this publication.

If written comments and/or requests indicate a significant degree of public interest in the draft permit, the permitting authority may, at its

discretion, hold a public hearing Public notice will be given 30 days before any public hearing

SAKBAKBMB04090101.bah

PU8UC NOTlCE

522

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

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Electronic Filing - Received, Clerk's Office, December 10, 2008

---

NPDES Permit No. IL0000329

ililnols EnVIronmental ProtectIOn

Agency

Division of Water Poliution Control

1021 North Grand Avenue East

Post Office Box 19276

Springfield.

llilnols 62794-9276

NATIONAL

POLLUTANT DISCH,c\RGE ELIMINATION SYSTEM

Reissued (NPDES) PermIt

Expiration Date

Name and Address of Permittee

United States Steel Corporation

Granite City

Works

20th and State Streets

Granite City. Illinois 62040

Discharge Number and

Name

Issue Date:

Effective Date:

Facility Name and Address:

United States Steel Corporation

Granite City

Works

20th and State Streets

Granite City, llilnols

62040

Receiving Waters

001

AOl

801

COl

Treated Process Wastewater

Coke By-Products Wastewater

Cold Roliing Mill Wastewater

Landfill Leachate Wastewater

Horseshoe Lake

In compliance with the provisions

of the illinoIs Environmental Protection Act. Title 35 of III. Adm. Code, Subtitle C and/or Subtitle D. Chapter

1, and the Clean

Water Act (CWA). the above-named permittee is hereby authorized to discharge at the above location to the above-named

receiving stream

in accordance With the standard conditions and attachments herein.

Permittee

is not authorized to discharge after the above expiration date In order to receive authorization to discharge beyond the expiration

date, the permittee shall submit the proper application as required by the Illinois Environmental Protection Agency (IEPA) not later than

180 days prior to the expiration date.

Alan Keller, P E

~,,1anager.

Permit Section

Division

of Water Pollution ContrOl

SAKBMB04090101.bah

524

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Page 2

NPDES Permit No IL0000329

Effluent Limitations and

MOnltonng

From the effective date of this permit until the expiration date, the effluent of the following discharge(s) shall be monitored and limited

at ali times as follows

~

..

Outfal!(s) 001 Treated Process Wastewater

LOAD LIMITS Ibs/day

OAF (DMF)

CONCENTRATION

LIMITS mq/l

PARAMETER

30 DAY

AVERAGE

DAILY

MAXIMUM

30 DAY

AVERAGE

DAILY

MAXIMUM

SAMPLE

FREQUENCY

SAMPLE

liPE

Flow (MGD)

See Special Condition 1

Measure

When

Monitoring

pH

CBOD

s

Total Suspended Solids

Oil

& Grease

See Special Condition 2

2085

2502

1511

4170

5004

3492

60 - 9.0

10

12

15

20

24

30

2IWeek

2IWeek

2IWeek

2IWeek

Grab

Composite

Composite

Grab

Iron (total)

Iron (dissolved)

Lead (total)

Zinc (total)

Cyanide (total)

Cyanide (available by

OIA 1677)

Phenol (4AAP)

Fluoride

Ammonia-Nitrogen*

Spring/Fall

Summer

Winter

March

417

5.6

12

19

1.1

50

584

459

1501

834

834

209

17

56

35

4.6

10

834

3128

3128

3128

3128

2

009

017

01

0.01

28

2.2

72

40

4

04

02

002

0.1

4

15

15

15

15

2IWeek

2IWeek

1/Quarter

2IWeek

2IWeek

2/Month

2IWeek

2IWeek

2IWeek

2IWeek

2IWeek

2IWeek

Composite

Composite

Composite

Composite

Mathematical

Composite~

Mathematical

Composite"

Composite

Composite

Composite

Composite

Composite

Composite

"For Ammonia as Nitrogen, Spring/Fall is April-May and September.October Summer is June-August Winter is November-February

Weekly average limils will apply. For Spring/Fall. weekly average limit is 70 mg/L (1460 Ib/day). Summer weekly average limit is 5.5 mg/L

(1147 Ib/day). March weekly average limit is 10 mg/L (2085 Ib/day) No weekly average limit for

Winter

**See Special Condition 10

525

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Page 3

NPDES Permit No IL0000329

Effluent Limitations and Monitoring

1 From the effective date of this permit until the expiration date, the effluent of the following dischargers) shall be monitored and limited

at all times as follows'

Outfall(s) A01. B01. C01

LOAD LIMITS

Ibs/day

OAF (DMF)

CONCENTRATION

LIMITS

mgll

PARAMETER

30 DAY

AVERAGE

DAILY

jJ1A-X,IMUM

30 DAY

AVERA,GE

DAILY

MAXIMUM

SAMPLE

FREQUENCY

SAMPLE

TYPE

Outfall

A01 - Coke By-PrOducts Wastewater

Flow (MGD)

Total Suspended Solids

Naphthalene

Benzo(a)pyrene

See Special Condition 1

010

015

Monitor

Continuous

1!Month

2NVeek

2NVeek

Measure

Composite

Composite

Composite

Outfall 801

- Cold Rolling Mill Wastewater

Flow (MGD)

Tetrachloroethylene

Naphthalene

See Special Condition 1

11

073

When

MOnitoring

2!Year

1/Month

Measure

Grab

Grab

Outfall:

C01 - Landfill Leachate Wastewater

Flow (MGD)

See Special Condition 1

526

Continuous

Measure

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Page 4

NPDES Permit NO.'IL0000329

Special Conditions

SPECIAL CONDITION

1. Flow shall be reported as a daily maximum and a monthly average, and shall be reported on the monthly

Discharge Monitoring Report Form.

r- ."; .

SPECIAL CONDITION 2. The pH shall be in the range 6.0 to 9.0. The monthly minimum and monthly maximum values shall be reported

on the DMR form.

SPECIAL CONDITION

3. If an applicable effluent standard or limitation is promulgated under Sections 30.1 (b)(2)(C) and (0), 304(b)(2),

and 307(a)(2) of the Clean Water Act and that effluent standard or limitation is more stringent than any effluent limitation in the permit or

controls a pollutant not limited in the NPDES Permit, the Agency shall revise or modify the p'ermit in accordance with the more stringent

standard or prohibition and shall so notify the

permittee.'

SPECIAL CONDITION 4. The use or operation of this facility shall be by or under the supervision of a Certified Class K operator.'

SPECIAL CONDITION

5. For purposes of this permit, load limits for Phenol (4AAP) have been based on actual plant discharges and are

included

in accordance with a 301 (g) variance of the Clean Water Act approved by the USEPA. Any changes to these load limits can only

be made following

Public Notice and opportunity for hearing.

SPECIAL CONDITION

6. The permittee may show that an apparent noncompliance of load limits for zinc is not a violation by applying

background credits for intake waters and by submission

of calculations as defined below

The load calculations for comparison to Zinc load limits shall be made as follows:

M

=

(C

e

-

C

I

)

x Fx 834

Where:

M

=

Outfall 001 load limit (Ibs/day)

C

e

= Outfall 001 effluent concentration

(mgJI)

C

r

= Intake water concentration (mg/I)

F

=

Outfall 001 effluent flow (MGD)

Concentrations limits for outfall

001 are absolute and no background credit shall be allowed.

SPECIAL CONDITION 7 The permittee shall record monitoring results on Discharge Monitoring Report (DMR) forms using one such form

for each discharge each month. Semi-annual monitoring

resl,Jlts shall be submilled with the DMR forms for the months of June and

December, and shall be submitted to the IEPA no later than July 15 and January 15 unless otherwise specified by the Agency, to the

following address:

Illinois Environmental Protection Agency

Bureau

of Water

Division

of Water Pollution Control

Compliance Assurance Section, Mail Code #19

1021 North Grand Avenue East

Post Office Box 19276

Springfield, Illinois 62794-19276

SPECIAL CONDITION 8 The Permittee shall be required to conduct an effluent toxicity evaluation prior to the renewal

of this permit.

Elements

of the toxicity evaluation should include but not be limited to the following:

.

A

Aquatic Toxicity Screening

Acute Toxicity - The initial acute toxicity testing should

be run on at least three trophic levels of aquatic species (fish, invertebrates

and plants) which represent the aquatic community for the receiving stream. Suggested species include the Fathead Minnow and

Ceriodaphnia. All tests should

be done in accordance With "Measuring Acute Toxicity of Effluents to Freshwater and Marine

Organisms (Fourth Edition)", (USEPAl600-4-90/027) and "Environmental Effects Tests Guidelines" (USEPAJ560-6-82/002). The

IEPA speCifications and guidelines for these tests, given in "Effluent Biomonltoring and Toxicity Assessment - Aquatic Life

Concerns,"

must also be met.

527

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Page 5

NPDES Permit No IL0000329

Special Conditions

Testing shall be conducted on fish over a 96-hour period while invertebrates should be tested over a 48-hour penod Test should be

periormed on 100% effluent

ft"-' .,.;

B

Sampling Frequencv

The test referenced above shall be performed dUring the final year of this permit. Upon completion, test results may be submitted with ,the

faCility renewal application.

.j

.

. ..

....

-~~t·~~~;

SPECIAL CONDITION 9. Samples taken In compliance With the effluent monltonng requirements for Internal outfall A01 shall betaken

at a pOint representative of the discharge of Clf-e By-Products Wastewater, but prior to mixing with any other wastewater sources.

Samples taken in compliance with the effluent monitoring requirements for internal outfall 801 shall be taken at a point representative of

the discharge of Cold Rolling Mill wastewater, but pnor to mixing with any other wastewater sources Samples taken in compliance with

the effluent monitoring requirements for internal outfall C01 shall be taken at a point representative of the discharge of Landfill Leachate

Wastewater. but prior

to mixing with any other wastewater sources. Samples taken in compliance with the effluent monitoring requirements'

for outfall 001 shall be taken at a point representative of the discharge. but before entering the receiving water....

SPECIAL CONDITION 10 Mathematical composites for Cyanide (available by OIA 1677) and Cyanide (total) shall consist of a series of

grab samples collected over any 24-hour consecutive period. Each sample shall be analyzed separately and the arithmetic mean of all

grab samples collected dunng a 24-hour period shall constitute a mathematical composite.

.,.-:".

528

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Health

&

Environmontal

EducaJinn, l?espol1sibiliIJ',

Justice

Action

- St. Louis

PO

.Bt~X

)).}~~.

s~

1".';''H}\;).}, to

(:.~

i

~:\

IEPA EXHIBIT

No.

0\

_

Hj~

J.

~c

L

l~llJ~

(i\hlJJ~jLf

O!(~5:I.I)f>

bmllci

n(,f~

.

.\1'0

0IH}'!,1}in~~

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KQI,'t.:.11

J

1

1.1,1.1'S;

AGfin

e

P(t:';\(!i:fl~

M~lt;(;

to.

,\{«i)l~

Vn.(.P;\:.::i(kftt

!i<lyY.Khn

~,(;<".:re~~lry

f:Jthfec!I

L(1!}~1n

S.o,ith

lrtJl:-;~IF'Ct<

January 17,2005

Illinois Environmental Protection Agency

Division

of Water Pollution Control

] 021 N.

Grand Ave. East

P.O

Box 19276

Springfield,IL

62794-9276

RE:

NPDES Permit No. TL0000329

Notice Number BMB:04090101.bah

United States Steel Corporation, Granite City Works

Dear TEPA:

Please hold a public hearing on the IJS Steel Corp.

NPDES permit referenced

above and extend the comment period for three weeks on the above referenced

permit This permit warrants public involvement because it impacts directly a

recreational body

of water promoted by the Illinois Department of Natural

Resources for boating, fishing, bird watching, and waterfowl hunting.

This permit would allow additional discharges

of toxic heavy metals known to

accumulate

in biological organisms. Over three, five or ten years, the quantity

of lead, a persistent, bioaccumulative toxin, discharged into the Lake, would

add up to hundreds

of pounds and may have a serious detrimental effect on

organisms living in the lake. The IDNR website proclaims Horseshoe Lake's

(Madison County) fishing opportunities, 'The lake contains channel catfish,

bass, crappie, bluegill, carp, and buffalo."!

The lake is favored spot for

flshing, often for individuals who rely on fish caught as protein sources.

These individuals, who are often low income and minority individuals, are

already exposed

to excessive levels of PCB's from fish consumption. At least

two species

of flsh, channel catfish and carp, carry consumption advisories

2

This permit would add several other toxins to their body burden. Hunters who

consume waterfowl from Horseshoe Lake could also be potentially exposed.

A public hearing would give citizens an opportunity

to ask questions aboLlt the

permit, voice concerns, and hear explanations.

Please consider this request.

Sincerely,

Kath leen Logan Smith, for the Board

1 httpl/w\.vw.idphstate.il.usienvhea Ithi flshadv/horseshoehtm

532

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

............lEPA.EXHlBIT-

No.

ro2

American Bottom Conservancy

Health

&

Environmental Justice-St. Louis

Neighborhood Law Office

Sierra Club

Webster Groves Nature Study Society

January 18, 2005

Ms Marcia

Willhite

Bureau of Water

Illinois EPA

via fax (217) 782-5549, (217) 782-9891 and email

Re

NPDES IL0000329 U S Steel-- Request for Hearing/Extension

Re

NPDES Permit No IL 0000329, Notice No BMB04090101bah

Dear Ms. Willhite

Our organizations request that the Agency hold a publiC hearing for the above-entitled permit

The receiving waters for this permit is Horseshoe Lake at Horseshoe Lake State Park in

Madison County The lake is used recrealionally by outdoor enthUSiasts, bird watchers, nature

lovers, fishers, hunters and fa.milies It IS also used by low-income and minority folks for

subsistence fishing

Horseshoe Lake is Impaired Your notice indicates the pollutants are PCBs, pH, suspended

SOlids, excessive algal growth, ammonia (unionized), nutrients, phosphorus, total ammonla-N.

We Ilave seen fish caught at Horseshoe Lake With melanoma An IDNR fish biologist

confirmed fish With melanoma at Horseshoe

Prof. Richard Brugam and his students at Southern Illinois University at Edwardsville have done

testing of the sediment at Horseshoe Lake, which has shown high concentrations of lead

Canteen Lake, which is part of the same lake, but privately owned, tested high in cadmium

Granite City Steel in this permit would be allowed to put additional lead into the lake It would be

allowed to

put additional ammonia Into the lake That appears to be contrary to the Clean

Water Act and to the Bureau of Water's stated mission to ensure that Illinois' fivers, streams

and lakes Will support all uses for which they are deSignated including protection of aquatic life

and

recreation

You list as potential contributors to the Impairment of the lake agriculture, crop-related sources,

non-Irrigated crop production, habitat modification, stream bank modlficatlon/destabilizalion

We believe industrial effluent from Granite City Steel should be added to the list

In the latest US EPA Enforcement & Compliance History Onlme (ECHO) report, US

Steel/National Steel/Granite City Steel (the facility is known by all three names, but has one

NPDES 10) is listed as being out of compliance six quarters in the last three years, with one

Informal enforcement action and one formal enforcement adon taken.

Page 2 Re NPDES Permit No IL 0000329. No ice No BMB04090101 bah

533

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

IDem

I/_~",:,:~":,:~,·~~,::,:;::";::~;,:,,,,,,-,;;_~·.o..=::-¥.:...:...

ourKard - npdes

•

.::r·~_:

gcsteeLwpd

__ ,,:.:.. ....

...:~

....

--:...--:.~_:

__ .

.:.

.:_".. _....":'__.•.::...:..:."; •. _, __

'~ ,_,:_~

,!._v..-...:........

-'.

,_,:_~-,_~,_:;"

... _.

P~g;;2

!

_.:.'--:....

~._--

."

According to the EPA facility information site, pasted below, the faclht has signiflcant!y Violated

Its

ammonia limits, Horseshoe Lake IS impaired With ammonia GC Steel has also Violated

other limits

CWA/NPDES Compliance Status

Slalute:Source

IDCVVA,IL0000329

OTRl OTR2 OTR3 OTR4 OTRS OTR6 OTR7J OTR8AOTR9J OTRl OTRl OTRl

JUf-Se Oct,D Jan,M Apr-Ju Jui,Se Oct-D an-Mar pr,Jun ul,Sep OOct- 1Jan- 2Apr-J

pOl

ec01 ar02 n02

p02

ec02 03

03

03

Dec03 Mar04 un04

Non-compliance in

Ouarter

SNCiRNC Status

»»

No

No

Yes

No

No

No

Yes

Yes

Yes

Yes

Yes

No

EHluent Viotat,ons

by NPDES Parameter,

Discharge point:001

r:!

$OLlDS, TOTAL

Mt

SUSPENDED

h

!~

NITROGEN,

illY

AMMONIA TOTAL

(AS N)

.t!

CY ANIDE, WEAK Mt

ACID,

DISSOCIABLE h

Mt

IRON,

TOTAL (AS blY

Ell

534

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

1':1

OIL

AND

GREASE M!

t

1':1

BENZOfA)PYRENE [y1J

b

t:1

NAPHTHALENE

fv...1!

b

Effluent Violations are displayed as higl1est percentage by which the permit limit was exceeded for the guarter Bold.

largepnntlndlcates Significant Non.compllang; (SNC) effluent violations

;?J2J:?C.::L2iS"";

indicate unresolved SN(..

violations

Page 3 Re NPDES Permit No IL 0000329. Notice No BMB04090101 bah

According to the EPA ECHO website, GC Steel is also In significant noncompliance with Its

Clean Air Act permit and RCRA permit

We ask that you hold a public hearing in order to allow citizens to ask questions and present

information and testimony. We have just recently received the SlUE reports and have not had

time to review them or to get technical guidance as to their meaning.

If you deny this request for a hearing, we ask for a meeting with you and your staff. followed by

a

30.day extension of the public comment period.

Thank you for your consideration of our request

Kathy Andria

American Bottom Conservancy

614 N 7

th

St, East SL Louis

(618)

875-9960

Kathleen Logan.Smlth

Health & Environmental Justice-St LOUIS

Kathleen O'Keefe

535

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

...

DUII

;-.

~ :.-!.~._·:.;:

DUIKClIO

.. .>_2_'.

~';'~~;"":"'._-o....:.-e:.

- npdes

~""

gcsteelwpd

..;.....__--,-_.:......i.",---'

'--_"',

:.. _

'..'.'-

__ .•

Neighborhood Law Office, East St LouIs

Jack Norman

Sierra Ciub

Yvonne Homeyer

Webster Groves Nature Study Society

email copies sent

to

marcia. wi Ilhite@epa state.

Ii

us, tobyfrevert@epastate.dus, alkel ier@epa.state iIus,

blll.hammel@epastateil.us

536

Page 4

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

FROM

Nelghborhood Law Office

PHONE NO.

618 271 0835

if

ILe!!~

JAN. 18 2005 06:34PM P1

American Bottom Conservancy

Health &

Environmental

Justice-St.

Webster

Groves Nature

Study

Society

January 18, 2005

Ms. Marcia Willhite

Bureau

of Water

Illinois EPA

via fax (217) 782-5549. (217) 782-9891 and email

Re: NPDES IL0000329 U.S. Steel-- Request for Hearing/Extension

Re: NPOES

Pennrt No. IL 0000329, Notice No. BMB:04090101.bah

Dear Ms. Willhite:

Our organizations request that the Agency hold a public

h~aring

for the above-entitled permit.

The receiving waters for this permit is Horseshoe Lake at Horseshoe LaKe State Park in

Madison County. The lake is u'sed recreationafly by outdoor enthusiasts, bird watchers. nature

lovers, fishers, hunters and families. It is also used

by low-income and minority folks for

subsistence fishing.

Horse5hoe

lake is impaired. Your

notice

indicates

the pollutants

are PCBs, pH, suspended

solids,

~xcessive

algal growth, ammonia (unionized), nutrients, phosphorus, total ammonia-No

We have seen fish caught

a1

Horseshoe Lake with melanoma An lONR fish biologist confirmed

fish with

melanoma at Horseshoe.

Prof. Richard Brugam and his students at Southern Illinois University at Edwardsville have done

testing

of

the sediment

at

Horseshoe Lake, which has shown high concentra1ions of lead.

Canteen Lake, which is part

of the same lake, but privately owned, tested high in cadmium.

Granite City Steel in ttlis

pennit wuuld be at/owed to put

additional

lead into the lake. It would be

allowed to

put

additional ammonia into the lake. That appears to be contrary to the Clean Water

Act and to ttle 8ureau of Water's stated mission to ensure that l\Iinois' rivers, streams and lakes

will support all

uses for which they are designated including protection of aquatic life and

recreation.

You list as potential contributors

to the impairment of the lake: agriculture, crop-related sources,

non-irrigated

crop production, habitat modification, stream bank modification/destabilization. We

believe industrial effluent from Granite City Steel should be added to the list

In the latest U.S.EPA Enforcement

&

Compliance History Online (ECHO) report, U.S.

steel/National Steel/Granite

City

Steel (the facility is known

by

all three names,

but

has one

NPOES 10) is listed as being out of compliance six quarters in the last three years, with one

informal enforcement action and one formal enforcement action taken.

537

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

FROM: Neighborhood Law OffIce

PHONE NO.

618 271 0835

JAN. 18 2005 06:35PM P2

Page 2 Re: NPDES Permit No. IL 0000329, Notice No. 8M8:04090101.bah

According to the EPA facility information site, pasted below, the facility has significantly violated

its ammonia limits. Horseshoe Lake is impaired with ammonia. GC Steel has also violated other

limns.

CWAlNPDES Compliance Status

Stalute:Souree ID

QTR1

QTR2 QTR3 QTR4 QTRS QTR6 OTR7

OTR8 OTR9

OTR1 QTR1 QTR1

CWAIlOOOO329

Jul-

Oct-

Jan-

Apr-

Jul.

Oct- Jan-

Apr-

Jul-

0

1

2

Sep01 Dec01 Mar02 Jun02 Sep02 DecO2 Mar03

Jun03

Sep03

Oct-

Jan-

Apr-

Dec03 MarQ4 Jun04

Non-compliance in

No

No

Yes

No

No

No

Yes

Yes

Yes

Yes

Yes

No

Quarter

SNCIRNC Status »»

EIEfNi.

R{Res

2!l.

olvdl

Emuent VTolatlons

by

NPDES Parameter.

Discharge point:001

SOLIDS, TOTAL

!::!

29%

SUSPENDED

M.!

!2

NITBOGEN~

MI

115%

10%

AMMONIA T01"AL

~

(AS N)

~

8%

Mt

l:!

CYANIDE, WEAK

~

195"&

.6lli..

82%

ACID, DISSOCIABLE Mt

}]

IRON, TOTAL

(AS

Mt

25%

FE)

bJy

~

22%

130%

Mt

!l

OIL

AND

GREASE

~

20%

MI

l:!

BENZO(AIPYRENE

N

18%

MI

n

NAPHTHAJ,.gNE

t:!

~

MI

!!

Effluent Violations are displayed as hi!lhest percentage by which the l2ermit limit was exceeded for the quarter.Bold.

largeprint indicates Significant Non-eompliance

(SNCl

effluent

violations,?.!.!3.cJ'!p~oxl?~

i09i91le unf!;lsol'ied SNC

yjoJ4llions.

538

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

FROM

Neighborhood Law Or ice

PHONE NO.

6i8 271 0835

JAN. 18 2005 06:35PM P3

Page 3 Re: NPOES Permit No. lL 0000329, Notice No. BMB:04090101.Mh

ACCOrding to the

EPA ECHO

website, GC Steel

is

also in significant noncompliance

with

its

Clean

Air Act permit and RCRA permit.

We ask that you hold a public hearing in order to allow citizens to ask questions ana present

information and testimony. We have just recently received the SrUE reports and have not had

time to review them or to get technical guidance as to their meaning.

If you deny this request for a hearing, we ask for a meeting with you and your staff, followed by

a 30-<Say extension of the public comment period.

Thank you

for your consideration of our request.

Kathy

Andria

American Bottom Conservancy

a 6

I

614 N.

]ltl

St., East 81. Louis

b

()L

(618) 675-9960

----

Kathleen Logan-Smith

Health

& Environmental Justice-St. Louis

Kathleen O'Keefe

Neighborhood

Law Office, East st. Louis

Jack Norman

Sierra Club

Yvonne

Homeyer

Webster Groves Nature S1udy Society

email copies sent to

marcia.willhite@epa.state.iI.us, toby. frevert@epll.stateitus, aLkeIIer@epa.state.iLus,

bill.bammel@epa.state.i1.us

539

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

r.... -.........._-.-......_.....

__..__

._._._.

- .._

_~._._-

_.- .__

..

State of Illinois

Environmental Protection Agency

Subject: US Steel-Granite City Works

Data: lL0000329

Reviewed By: Beth M. Burkard

Page 1 of I

Date: l/24/2005

The Agency issued to National Steel Corp.-Granite City Works, now United States Steel-Granite

City Works, NPDES Permit No. IL0000329 on May 11, 1998, with expiration on April 30, 2003.

US Steel submitted renewal applications

111

a timely fashion. The CUITent permit allows the

discharge of Treated Process Wastewater at Outfall 001, with Internal Outfalls AOl (Coke

Byproducts WW) and BOI (Cold Rolling Mill WW) tnbutary to Outfall 001. Granite City

Works (GCW) is an integrated steel mill, with discharge through a plume to Horseshoe Lake.

The changes to the existing permit in the proposed reissued permit are:

•

US Steel purchased most of plant from National Steel Corp.-Name Change

•

Landfills III and IV are still owned by National Steel; these are designated as containing

hazardous waste; US Steel has requested the creation of an internal outfall for the leachate

from these two landfills; the leachate is treated in the WWTP-Create Internal Outfall CO 1

•

Sintering and Sulfuric Acid Pickling are no longer used at the facility

•

Facility production has changed, yielding higher production-based load limits for Lead, Zinc

for Outfall 001; and Tetrachloroethylene and Naphthalene at BOI

•

Load limit for Benzo(a)Pyrene at Internal Outfall AO 1 (Coke Byproducts WW) has increased

from 0.11 Ib/day in current permit to 0.15 Ib/day in proposed pennit; BaP limits are based on

actual plant discharges, per Central Treatment Exemption

The Agency received conunents from OS Steel; Health and Environmental Justice of East St.

Louis; and a group letter from several public interest groups. US Steel specified that they did not

require a Public Hearing. The other two letters requested a Public Hearing.

The Agency received a letter from Ms. Kathleen Logan Smith on behalf of Heath and

Environmental Justice of East St. Louis via email on January 17,2005. Ms. Logan Smith

requests that the Agency hold a Public Hearing. Ms. Logan Smith's concern is the

bioaccumulation of lead and other heavy metals that may adversely affect the fish population,

and the public who consume the fish and waterfowl.

The group letter from American Bottom Conservancy, Heath

&

Environmental Justice of St.

Louis, Neighborhood Law Office, Sierra Club, and Webster Groves Nature Study Society,

hereafter referred to as Group Letter. expresses concem regarding the impact ofGCW's

discharge on Horseshoe Lake. The major concern is that Horseshoe Lake is impaired, which has

a negative impact on the community that utilizes the Lake for recreation and for a food source.

The comment specifically relating to the pem1it relssuance is the increase in load limits for lead

and ammonia. Regarding Lead, the load lImits included in the updated permit are production-

based. It is not considered backsliding if limits increase because of increased production or

facility alternation. Regarding Ammonia-N, the new limits are based upon water quality

standards. The Planmng Department's updated method for calculating water quality-based

Anunonia-N standards does not constitute backsliding even if the new limits are less stringent

than previous limits. The other comments address GCW's noncompliance with its NPDES

pennit, CAA Pennit, and RCRA permit. GCW has had 6 quarters with non-compliance, (one

545

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

IJ~

JOhnSon - ehregdoc

State of Illinois

Environmental Protection Agency

Subject:

US Steel-Granite City Works

Page 2 of 1

Data: IL0000329

Reviewed By: Beth

M. Burkard

Date:

1124/2005

quarter of Significant Non-compliance (SNC») for NPDES pen11lt in past 3 years.

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

From:

To:

Date:

Subject:

Thanks Beth,

. .

, __ ", '" , .......

~v

......

~"u

Blaine Kinsley

Burkard, Beth

1/24/2005

11 :40:30 AM

Re: US Steel-GCW Summary

of Hearing Requests

IEPA EXHIBIT

No.

tol

__

Pc:g

e

1J

All that was necessary was the comment summary of Environmentalist concerns. Did Bob Mosher's

memeo address anti-degradation?

>>>

Beth Burkard 01/24/05 11 :33 AM

>>>

Blaine:

As requested, here is my summary of the responses we received.

In the summary, I didn't mention what

comments US Steel made. They were technical things like sample types and whether

301 (g) variance

applied

to Ammonia, nothing to do with a hearing request. They specifically said they didn't need a public

hearing.

Thanks. -beth m burkard

547

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

From:

To:

Date:

Subject:

.. '3m' ...... ";;1 .......... Vl,V

Blaine Kinsley

Burkard, Beth

1/24/200511 :46:18 AM

Re: US Steel-GCW Summary of Hearing Requests

IEPA EXHIBIT

No.

~

9'

Page

.1]

I'll touch base with Bob.

>>> Beth Burkard 01/24/05 11 :43 AM »>

Blaine:

None of the Planning memos address antidegradation for this reissuance, only reasonable potential and

water quality limits, and 303(d)/BSC evaluation.

-beth m burkard

548

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

STATEOT

ILliNOiS

E

'VlRONMENTAL

PROTECTION AGENCY

Subje.ct: US Steel-CJrallite City Works

Data

IL0000329

Reviewed By: Beth M. Burkard

30-Day Public Notice Review Notes

ItrA tX.111lSll

No.

toCJ

_

Page 1 of 4

Date 0

1/2)).0

1/3 1/2

00 5

The Agency received comments from several parties during the Public Notice period The

comments are from Mr. Merle Stein of US Steel, General Manager of Granite City Works:. Ms

Kathleen Logan Smith ofI-leath and Environmental Justice of Sf. Louis; and a group comment

from Ms. Kathy Andria of American Bottom Conservancy, 'Is. Kathleen Logan Smith of Health

and Environmental Justice of St. Louis, Ms. Kathleen O'Keefe of Neighborhood Law Office of

East Sf. Louis, Mr. Jack Norman of Sierra Club, and 1\1s Yvonne Homeyer of Webster Grove

Nature Study Society.

The Agency received from Iv1r. Stein of US Sleel a letter on January 13,2005, indicating three

concerns as follows.

].

"GCW continues to believe the 30] (g) variance for ammonia is applicable to

outfall

00] _ We are requesting to preserve the 30] (g) variance

f<)Y

ammonia

through the special condition provided in the previous permit The 301 (g)

variances for

ammonia and phenol in the permit stated: "Special Condition 9 For

purposes of this permit, load limits for ammonia (as N) and Phenol (4AAP) have

been based on actual plant discharges and are included in accordance WIth a

301(g) variance approved by the LJSEPA Any changes to these load limits can

only be made following Public Notice and opportun9ity for hearing" We believe

this language is

appropriate since the load Innits are based on water qualIty

limitations as in the original

301

(g) based permit and tbe previous permit The

load limits in the previous permi t were adjusted from the original 301 (g) vanance

based on new water quality limitations, and the above Special Condition 9 was

incl uded in the permit. Likewise, the existing load lirlli ts

foy

ammonia are bei ng

adjusted from the previous permit limitations based once again on

nnv

water

quaJity limitations, and we believe the Special Condition should continue to

include

ammonia as part of the 301(g) variance in the new permit"

Response 30](g) is a section of the

Clean

Water Act that a]]ows for the iSSllaJ1CC of'3

variance_ The variance prOVides relief from BAT standards. but requlles limits tCl

be protective of water quality. This variance has been applied, in that BAT limits

are

not incl uded in the permit and protection of water quality is maintained by

including

water quality-based lirnits. The 301(g) variance issued specifically to

GCW specifies an Ammollia-N loading limits, or proposed modifIed effluent

limitations (PMELs), as follows:

~.

-----~--------------,------------C"----------.-----,

L

I'vlolJthly A

ver~ge

J

Daily Maxlmurn

-------!

April-October

sao

II'

900

----~J

_______________________________________________________

November-March

600

l..:

900

_

549

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

STATE OF

ILLlN01S

E, VIRONMENTAL PROTECTION

ACiENCY

Subject: US Steel-Granite City \Vor!cs

Data: IL0000329

Reviewed By: Beth M Burkard

Page

20f4

Date 01/22+0113112005

The PMELs included in the 301 (g) variance as issued to GCW "are renective of

the eflluent loadings presently being reported and will meet applicable IJlinois

water quality standards at the outfall". One drawback to

USll1g these PMELs IS

that the water quality standards are no longer evaluated as April-October and

November-March.

The draft reissued permit does require maintenance of water

quality standards, but the limits in the draft permit are

110t the PMELs established

by the

301 (g) variance. Thus, the

301

(g) variance did determine the limits for

Ammonia-N in the permit, in that relief from

BAT is included in the draft

reissued permit, but the load limits are not based

upon acll.l31 plant loading

GCW's concern is the wording of Special Condition 5 (Special Condition 9 m rhe

previous permit). Speci31 Condition 5 currently reads that the load limits for

Phenol were determined by actual plant discharges, in accordance with the

301 (g)

variance.

GCW would like Special Condition 5 to say that load limits for Phenol

and

Ammonia (as N) are both determined by aClllal plant discharges, etc The

load limits for Ammonia (as N) are determined by water quality standards, nor

actual plant discharges. Thus it would be inaccurate to say that load limits for

Ammonia (as N) are determined by actual plant discharges. Because it is

important to GCW for the permit to specify that load limits for Ammoni3 (as

N)

are dictated by the 301 (g) Valiance, the permIt writer will add a line to Special

Condition 5

of the draft reissued permit to state that PIlenol load limits are based

upon actual plant discharges, but that

Ammonia (as N) load limits are based upon

water quality standards.

Action:

Change the special condition to indicate that the 301(g) variance has been applied

for

Ammonia-N discharge, but indicate that only the load limits for phenol are

based upon actual facility discharges.

2.

"We are requesting an option for the mathematical composite, which allows the

laboratory to composite the individual grab samples versus analyzing separatelv

The laboratory adds preservatives

to the sample col1ection bottles prior

Lo

collecting the grab samples for total and available cyanides. Therefore, the

individual grab samples will be preserved at the time

of collection and prior to

compositing in the laboratory GCW is proposing a series of 3 grab samples over

any 24-hour period for the composite. This option should give the sample

analytical results

as the mathematical composite but at a lower laboratory cost"

Response: The permit writer's intention in initially requiring a grab sample for the cyanides

was that the

method found in 40 CFR 136 requires that analyses for cyanide

compounds

be performed within 24 hours, and that the sample must be in

(1

sealed, light-protected container, under refrigeration. [t is difficu It to obtai n

(l

composite sample while maintaining each of these reqUirements. After the

550

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

STATE

OF ILLJNOIS

E)\;VIRONMENTAL PROTECTfON ACENC'(

Subject: US Steel-Granite City Works

Data:

]L0000329

Reviewed By Beth M. Burkard

Page 3 of 4

Di1te. 01/22-7'01/3 1/200 5

Action:

3.

primary notice period, GeW requested a composite sample so that the

representative changes throughout a 24-hour period could be Included

III

the

analysis A mathematical

composite provides protectIOn of the integrity of e8ch

sample, as well as a value demonstrating a

d8y's discharge 'rhe concern \-vilh

changing to a this type of sample is that the first portion collected for the

composite

sample may be held for over 24 hours Per 40 CFR 136, if Sulfide 1S

present in the waste\.vater (Sulfide is present in outfall 001, per application 2C),

maximum holding time is 14 hours. Ifthe nrst portion is collected at 0500. the

second at 1200, and the third at 1900, and the lab analyzes the

sample the ncxt

day, the portion collected

at 0500 is over 24 hours old

If

the permittee

h

ahle

In

sample the discharge within 24 bours of tlle initial collection, and the method

outlined in 40

CFR 136 for the appropriate storage and preparation

IS

followed.

this will be an acceptable

method of analyzing the discharge for Cyanide, Tolal,

and

Cyanide by QJA-1677

Require that GC\V analyze the sample less than 24 hours from the inilial

sample

collection, and use methods consistent with 40 CFR 136.

"We agree with JEPA's interpretation of the applicability of the central treatment

exemption to GGCW and the continued use of the 301 (g) exemptions /\ [so, lhe

consideration

of the attenuation of ammonla near the outfall IS conSIstent wlth the

previously issued

NPDES permit"

Response: Agreed. No action necessary.

The group letter from American Bottom Conservancy, HeatlI

&

Environmental Justice of St

Louis, Neighborhood Law Qt1lce, Sierra Club, and Webster Groves Nature Study Society,

hereafter referred

to as Group Letter, expresses concern regarding tbe impact of GCW's

discharge

on Horseshoe Lake The major concern is that Horseshoe Lake is impaired, which has

3 negative impact on the community that utilizes the Lake for recreation and for a foocl source

The comment speciftc.ally relating to the permit reissuance is the increase in load limits for lead

and

ammonia The other comments address GCW's noncornpliance history with its NPDES

permit, Clean Air Act Permit, and RCRA permit. The permit writer is not qualified to address

any issues regarding Clean

l\ir Act or

RCRA.

permits

1.

"Granite City Steel in this permit would be allowed to put additional lead into the

lake.

It

would be allowed to put additional ammOllla into the lake. Thal appears

to be contrary to the

Clean Vlater Act and to the Bureau of Water's stated mIssion

to ensure that Illinois' rivers, streams and lakes will

support all uses for which

they are designated incl uding protection of aquatic life and recreation"

Response: The existing and proposed load and concentration limits are as follcw,s

551

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

STATE OF ILL!

ors

ENVIRONMENTAL PROTECTION AGENCY

Subject: S Steel-Granite City Works.

Data: 1L0000329

Reviewed By: Belli M. Burkard

P ge 4

of 4

Date:

01/22+01/31/2005

Cunent Pennit Limits

Proposed Permit Limits

Load Limit

Concentration Load Limit

Concentration

Limit

Limit

30-0 Daily

30-D Daily

,

30-D

Daily

30-D

Daily

Avg.

Max.

Avg.

Max.

Avg.

Max.

Avg.

Max.

Lead

5.28

15.8

0.1

5.6

17

0.09

0.4

Ammonia-N:

Summer

313

2,752

1.5

13.2

459

3128

12.2

15

Winter

834

1,772

4.0

8.5.

1501 3128

17.2

IS

I

SpringlFall

I

584

3128

2.8

15

March

834

3128

4.0

15

Regarding Lead, the load limits included in the updated permit are production-

based.

It

is not considered backsliding if limits increase because of increased

production, as is outlined in 40 CFR 122.44(1)(2)(i).

Regarding Ammonia-N, the

new limits are based upon water quality standards.

At the time of previous issuance, llie Planning Department provided water quality

standardsfor Ammonia-N in April-October (Summer) and November-March

(Winter). The current and proposed limits for Ammonia"N are water

quality-

based, and depend upon temperature and pH of the receiving waters. The

increase in limits does not constitute backsliding.

Action:

Draft letter to Group, explaining the increased load limits for Lead and Ammonia-

N. Possible Public Meeting or Hearing.

The Agency received a letter from Ms. Kathleen Logan Smith on

behalf of Heath and

Environmental Justice of East St. Louis via email on January 17,2005. Ms. Logan Smith

requests that the Agency hold a Public Hearing. Ms. Logan Smith'sconcern is the

bioaccumulation

ofIead and other heavy metals that may adversely affect the fish population,

and the public who consume the fish and waterfowL

Response: The limits included in the draft permit for Lead and Zinc are based upon the

production-based categorical limits provided in

40 CFR 420.

Action:

Draft a letter to Health and Environmental Justice

of East S1. Louis clarifying tbe

increase in load limits for Lead.

552

Action: Submit a summary of above information to Bureau of Water Management for review. If

Public Hearing or Public Meeting is necessary, issue appropriate notices

ff

no meetings

are

necessary, send responses to all interested parties, explaining Agency ratIonale

Jnd

thanking

them for their participation.

.

("

~n

aD

V..J

~\'7

~~\:,1J

o

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

,.

BOlfJi\/V{:"~C/;::~:~;~i\.

~:T ~.::t:·:C ~

.j/.....

)r,Yf\

~l\nI1111

Douglas P. 80ye-ci,

No.

Jr.

to

r,Jianager

Reg~1ato0"

Cornpliar;ce,

V',f8~_ef

EnvironrT12nta!

/;f~aif's

United

St:na~

Steel Corporation

GOG Grcet Street

Pii'lsbcrgh, Pft.. 1521;]-2800

4124335914

Fax 4124335820

25 April 2005

VIA FEDERAL EXPRESS

(ADVANCE COPY VIA FAX)

Mr. Blaine Kinsley

Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box 19276

Springfield,

rr~

62794-9276

Re: NPDES Permit No. IL0000329

United States Steel Granite City Works

Response to Various En"ironmental Advoc3C)' Groups Comments

Dear

Mr.

Kinsley

Accompanying this letter are United States Steel's (USS) responses to comments submitted to

Illinois Environmental Protection Agency (IEPA) by various environmental advocacy

organizations (Health & Environmental Justice - St. Louis, American Bottom Conservancy,

Neighborhood

Law Office, Sierra Club and Webster Groves Nature Study Society) regarding the

renewal of United States Steel (USS) Granite City Works' NPDES Permit (No. IL0000329)

Their comments were submitted as part of their request for a public hearing on the permit.

USS believes the comments submitted to IEPA are largely irrelevant to the permit, and are

adequately addressed in this correspondence. Therefore, a public hearing is unjustified and

further delay

in the reissuance of permit

rr~0000329

is unwarranted. USS requests IEPA reissue

NPDES Permit

lN0000329 immediately.

cc

1. D. Moniot

C. Cannon

L.

Siebenberger

D. Baker

553

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

The following are the comments submitted by Health

&

Environmental Justice

-

Sf

Louis with

responses from United States Steel.

All text wrillen by

(I

S Steel is in iwlics.

Please hold a public hearing on the US Steel Corp. NPDES permit referenced above

and extend the comment period for three weeks

on the above referenced perm]!. This

pennit warrants public involvement because it impacts directly a recreational body of

water promoted by the Illinois Department of Natural Resources for boating, fishing,

bird watching, and waterfowl hunting.

This permit would allow additional discharges

of toxic heavy metals known to

accumulate in biological organisms. Over three, five or ten years, the quantity oflead, a

persistent, bioaccumulative toxin, discharged into the Lake, would add up

to hundreds

of pounds and may have a serious detrimental effect on organisms Living in the lake.

United Steel

Response:

This is not a new permit, but rather a renewal ofan

existing

NPDES permit that has been held by thisfaeility since NPDESpermits were

required The reissuanee

of this permit will not degrade the quality of water in

Horseshoe Lake or have an adverse effect on the aquatic fauna, aquatic flora or

surrounding wildlife habitat. The limits

for lead comply with USEPA Ejjluent Limit

Guidelines (ELG)

and Best Available Technology (BAT) controls Lead discharges

are regulated

on the Federal level under

40

CFR 420 and on the Illinois State level

under

35

lAC 302. This permit cornplies with both criteria.

The

facility has no

history oflead discharge exceedenees.

The IDNR website proclaims Horseshoe Lake's (Madison County) fishing

opportunities, "The lake contains channel catfish, bass, crappie, bluegill, carp, and

buffalo."

The lake is favored spot for fishing, often for individuals who rely on fish

caught as protein sources. These individuals, who are often

low income and minority

individuals, are already exposed to excessive levels

of PCB's from fish consumption. At

least two species of fish, channel catfish and carp, carry consumption advisories. This

pennit would add several other toxins to their body burden. Ifunters who consume

waterfowl from Horseshoe Lake could also be potentia]]y exposed.

United

States Steel Response:

The fish advisories mentioned are for PCB

content only. There are no consumption advisories for fish in Horseshoe Lake for

any contaminant other than PCBs. U S Steel does not use, generate or discharge

PCBs to Horseshoe Lake. PCBs are

nOl part of the permit, nor have they ever

been.

PCBs are present on the site in detectable amounts in sorne electrical

equipment such as fluorescent lighting ballasts, but PCB transformers

and other

such equipment were

removedfrom the sire a number ofyears ago. Evaluation of

PCBs was a required part of the permit application process.

If

there were

concerns

for any other constituents affecting fish in Horseshoe Lake, these would

have been included in the Illinois Department of Natural Resources' (IDNR)

advisory

A public hearing would give citizens an opportllnity to ask questions about the permit,

voice concerns, and hear explanations.

554

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

The following are the comments submiued by American Bo[[om Conservancy, Health

&

Environmental Justicr:-

Sf

Louis, Neighborhood

Law

Office, Sierra Club and Webster Groves

Nature Study Society with responses from United States Sleel.

All text written by U

S.

Steel is

in italics.

Our organizations request that the Agency hold a public hearing for the above-entitled

permit.

The receiving waters for this pennit is Horseshoe Lake at Horseshoe Lake State

Park

in Madison County. The lake is used recreationally by outdoor enthusiasts, bird

watchers, nature lovers, fishers, hunters and families.

It is also used by low-income and

minority folks for subsistence fishing.

Horseshoe

Lake is impaired. Your notice indicates the pollutants are PCBs, pH,

suspended solids, excessive algal gwwth, ammonia (unionized), nutrients, phosphorus,

total ammonia-No

We have seen fish caught at Horseshoe Lake with melanoma. An

IDNR fish biologist confinned fish with melanoma at Horseshoe.

United States Steel Response:

The information presented in the

paragraph above is

posted on the illinois Environmental Protection Agency

(IEPA) website. Horseshoe Lake is classified as Jvfoderately Impaired. This

assessment is based on chemical/physical data collected within the previous

five years as

part of an Ambient Lake Monitoring Program, and upon jish-

tissue analysis.

lEPA '.I' study concluded the factors contributing to the

impaired status

of Horseshoe Lake were agriculture, crop-related sources,

non-irrigated crop production, habitat modification

and stream bank

modification/destabilization The fish-tissue study resulted in an advisory by

the flfinois Department

of Health for two species, (Channel Catfish and

Carp) due to PCBs in their tissue. As previously stated, PCBs are not used at

the U

S.

Steel Granite City Facility or discharged into Horseshoe Lake from

the facility. The list

ofpollutants in the above paragraph

is

also from the

IEPA website

and it is important to note that the only parameter listed as

being present with a high confidence level

is

PCB. A "no confidence level"

is assigned

to all ofthe other parameters. The statement, "We have seen}ish

caught at Horseshoe Lake with melanoma.

"

is anecdotal, undocumented

and

therefore irrelevant.

Prof Richard Brugarn and his students at Southern Illinois University at Edwardsville

have done testing

of the sediment at Horseshoe Lake, which has shown high

concentrations of lead. Canteen Lake, which is part of the same lake, but privately

owned, tested

high

in

cadmium.

United States Steel Response:

The

study

performed

by

Professor Brugam may show elevated concentrations

of lead in the

Horseshoe Lake sediments, but this comment fails

to mention what Professor

Brugam considered elevated, what comparative baseline determined the

elevated concentration, the source

of the lead or the specific sample

collection locations. The qualizy control

and quality assurance (QAIQC)

methods governing the study are unknown. There

is

no reference to Canteen

Lake

in the IEI'A list of impaired waters.

Additionally, any cadmium

concentration is irrelevant as cadmium

is

not a constituent in U

S.

Steel

'.I'

efJluent and is not part ofthe permit.

555

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Granite City Steel in this pennit would be allowed to put additional lead into the lake. It

would be allmved to put additional

ammonia into the lake. That appears to be contrary to

the Clean

Water Act and to the Bureau of Water's stated mission to ensure that Illinois'

rivers, streams and lakes ,vill support all uses for which they are designated including

protection

of aquatic1ife and recreation.

United States SteeL Response:

Lead is discussed in the first commenr

re.sponse on page

2.

Ammonia (Nitrogen) is regulated by lllinois under 35

lAC

355

It should also be noted that lead is not listed by the IEPA as a

contributingfactor

to the impaired designation ofHorseshoe Lake.

You list as potential contributors to the impainnent of U1e lake: agriculture, crop-related

sources, non-irrigated

crop production, habitat modification, stream bank

modifLcationldestabilization.

We believe industrial effluent from Granite City Steel

should be

added to the l.ist.

United States Steel Response:

This information is posted on

from the

IEPAwebsite.

It should also be noted that these sources of

impairment are determined from data collected during the past five years.

All are nonpoint sources and specifically listed as such. United States Steel's

Granite City facility is not considered a source

of the impairment based on

the assessment

of these scientific data. The commenters present no alternate

scientific evidence to include the U S Steel faCility as a source

of the

impaired designation.

In

the latest U.S.EPA Enforcement

&

Compliance History Online (ECHO) report, U.S.

Steel/National Steel/Granite City Steel (the facility is

known by all three names, but has

one NPDES ID) is listed as being out of compliance six qU311erS in the last three years,

with

one infomJal enforcement action and one formal enforcement action taken.

United States SteeL Response:

The U. S E'PA ECHO reports

compiles data quarterly. This is grossly misleading, as a one sample spike in

an efJluent parameter will be reported as a quarterly incident A comparison

ofthe information submitted by the commenters with the actual data reported

on the NPDES Discharge Monitoring reports (DMR) show that the alleged

noncompliance events with the exception

of Total Ammonia-N during the first

quarter 2003 were primarily one-sample events in that quarter that did not

result in a monthly loading exceedence.

Benzo(a)Pyrene_exceeded the daily concentration limit twice

in January 2003

with no exceedence ofthe daily or monthly loading limit

Weak acid dissociable

(FVAD) Cyanide exceeded daily limits twice in January

and February 2003 and once in March 2003 There were no month(v loading

exceedences.

Exceedences

for Total Iron and Total Suspended Solids (rSS) were both one-

sample events with no monthly load exceedence

The monthly

Ammonia

exceedence that occurred in the first quarter of 2003 was due to an upset

condition at the

end ofJanuary, recurred in February and was corrected in

556

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

lvfarch 2003.

This condition resulted in monthly

exceedencesfor those months

averaoe

I::>

loading

171e non-compliance event for monthly Ammonia listed for the first quarter of

2004 is a minor exceedence in the 3D-day average concentration that did not

translate into a loading exceedence. All the other noncompliance indications

are one-sample events.

Therefore, with the exception

ol the Ammonia-N

incident, the U S Steel Ciranile Cityfc](:ility exceeded one or more discharge

parameter limits

onlyfive single limes in three years.

The Iron exceedence in the first quarter 2004 was a one-sample event that

resulted in a monthly average load exceedence

for February.

The Oil

and Grease exceedence occurring in the first quarter 2004 was a

one-sample event resulting

in no load exceedence.

Naphthalene

and WAD Cyanide exceeded concentration limits for one

sampling event

in October and December respectively Neither resulted in a

loading exceedence.

According to the EPA ECHO website, GC Steel is also in significant noncompliance with

its Clean Air

Act pemlit and RCRA permit

United States Steel Response:

These are air exceedences and

are irrelevant to the NPDES Permit renewal.

We ask that you hold a public hearing in order to allow citizens to ask questions and present

information and testimony. We have just recently received the SUn: reports and have not had

time to review them

Of to get technical guidance as to their meaning.

United States Steel Response:

Presumably,

the

reports

referenced above consist

of the study performed by Professor Brugam of

Southern University of Illinois at Edwardsville. The subject of this study

according to the commenters is lead

and cadmium concentrations in the

Horseshoe Lake sediments.

As previously stated, Horseshoe Lake is not

impaired

from lead and cadmium. Review the comment response above

pertaining to this study.

If

you deny this request for a bearing, we ask for a meeting with you and your

staff~

followed by

a 30-day extension

of the public comment period.

Thank you for your consideration of our request

557

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

ST.:..

lE OF lLU1"OlS

E1"VIRO"'MENTAL PROTECTlON

AGENCY

Subject: US Steel-Granite City Works

Data: IL0000329

Reviewed By: Beth M. Burkard

No.1Y-

Page 1 of 1

Date: 01/24, 05

/2012005

The Agency issued to 'ational Steel Corp.-Granite City Work, now United States Steel-Granite City

Works, NPDES Permit No. IL0000329 on

May 11, 1998, with expiration on April 30,2003. tiS Steel

submitted renewal applications

in a timely fashion. The current pennit allows the discharge of Treated

Process Wastewater

at Outfall 001, with Internal Outfalls AOI (Coke Byproducts WW) a.nd 801 (Cold

Rolling Mill WW) tributary to Outfall

001 Granite City Works (GC\V) is an integrated steel mill,

with discharge tlu-ough a Hume to Horseshoe Lake.

The changes to the existing pennit in the proposed reissued pernlit are:

•

US Steel purchased most of plant from National Steel Corp.-Name Change

•

Landfills 1lI and IV are still owned by National Steel; these are designated as containing hazardous

waste; US Steel has requested the creation

of an internal outfall for the leachate from these two

landfills; the leachate is treated in the \V\VTP-Create Internal Outfall COl

•

Sintering and Sulfuric Acid Pickling are no longer used at the facility

•

Increase

in production yielded an increase in production-based load limits for Lead, Zinc for

Outfall 001; and Tetrachloroethylene and Naphthalene at BOl

•

Load limit for Benzo(a)Pyrene at Internal Outfall

AO 1 has increased from 0.11 to 0.15 Ib/day in

proposed pennit; BaP limits are based on actual discharges, per Central Treatment Exemption

The Agency received comments from US Steel; Health and Environmental Justice of East St. Louis;

and a group letter from several public interest groups. US Steel specified that they did not require a

Public Hearing:

The other two letters requested a Public Hearing.

Following are the comments in the letters:

•

Bioaccumulation

of Lead and heavy metals in fish (people consume the fish)

•

Increase

of Lead and Ammonia load limits

o Response: Lead: Increased Lead load limit is due to production changes, and load limit is

consistent with

ELGs established at 40 CFR 420; Ammonia: The new Ammonia-N limits

are based

upon the pH and temperature in Horseshoe Lake

•

Horseshoe

Lake is impaired per 303(d) list

o Response: Horseshoe

Lake has been evaluated as a Medium Priority, impaired for PCBs

(not generated at

US Steel), SS, Algae, Ammonia (Unionized), Nutrients, Phosphorus, and

Total Arm11onia-N; Horseshoe Lake is not impaired for Lead or heavy metals; Industrial

Point Sources

is

not

a source of impairment

•

US Steel-GCW has been non-compliant with NPDES, CAA, and RCRA pennits.

o Response: USEPA has issued one

NOV and one Fonnal Enforcement Action to GCW

The pennit writer, the Industrial Unit Manager, and three US Steel representatives met at Sangamo

Complex on

May 13, 2005, to discuss the Public Hearing issue. The group discussed the option of

retaining the Lead load limits from the previous reissued pennit, but this is not desirable to US Steel.

The facility does not use Lead, and the increased load limits are due to increased production. The US

Steel employees

noted that Horseshoe Lake is currently and has historically been a hunting ground,

and lead shot may be contaminating the lake. US Steel cited an Ames Test that found the effluent

to

not be mutagenic, a.nd cited the Fluoride discharge as a benefit to the lake, per the US Dept. of

ConservatIOn.

601

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

State of Illinois

Environmental Protection Agency

Subject: US Steel-Granite City Works

Data: IL0000329

Reviewed By: Beth

':'v1. Burkard

No. /5'

Page 1 of.:+

Date: 05/13-05120/2005

The Agency received a letter addressed to the Industrial Unit Manager dated April 25, 2005,

from Mr. Douglas

P. Boyea, Jr., Manager of Regulatory Compliance, Water, Environmental

Affairs.

The letter includes an attachment in which US Steel responds to the comments made in

the letters the Agency received from the environmental groups following Public Notice. The

letter indicates that US Steel feels the comments are not relevant to the

NPDES permit

reissuance, and that there is not justification for a Public Heming. Per the letter,

<'US Steel

requests reissuance

ofNPDES Pelmit No. IL0000329 immediately."

The attachment to the letter includes a segment

of text from the comment letters, followed by US

Steel's response to the comments in the segment oftcx1. Following is a summary

of those

comments.

Regarding Health and Environmental Justice-East

S1. Louis Letter:

•

Comment Letter: Requests a Public Hearing, and extension

of comment period. Group has

interest because receiving water

is a recreational lake promoted by IDNR. Pennit allows

discharge

ofbioaccumulative heave metals, especially Lead. Discharge of metals may have

detrimental effects

oflake organisms eventually.

•

US Steel: Reissuance

of existing NPDES permit. Permit protects water quality, will not

adversely affect lake flora, fauna, and surrounding wildlife. Lead load limit

is based on ELG

for BAT, per 40 CFR 420, and 35 lAC 302.

•

Response: Acceptable.

•

Comment Letter:

The IDNR promotes fishing in Horseshoe Lake. Many low-income

residents rely on fish from Horseshoe Lake for sustenance. Channel catfish and carp have

Fish Consumption Advisories. The permit will allow discharge of additional

bioaccumulative compounds. Also, hunters

may consume waterfowl from the lake and be

exposed.

•

US Steel:

The fish advisories arc for PCBs only. US Steel is not a source of PCBs.

•

Response: Acceptable.

Regarding Group Letter:

•

Comment Letter: Requests Public Hearing.

Lake is used for recreation, as part of Horseshoe

Lake State Park in Madison County. Also used for sustenance

inlow-income and minority

citizens. The lake is 303(d) listed with sources

of impairment as PCBs, pH, Suspended

Solids, Excessive Algal Growth, Ammonia (Unionized), Nutrients, Phosphorus, and Total

Ammonia-N. Group has witnessed fish caught in Horseshoe Lake to have melanoma, as

confim1ed by

an IDNR fish biologist.

•

US Steel: The 303(d) listing is as Moderately Impaired, with sources of agriculture, crop-

related sources, non-irrigated crop production, habitat modification, and stream

bank

modification/destabilization. The IL Dept. ofllealth lssued the Fish Consumption

Advisories for Channel Catfish and Carp because

of PCBs found in those species' fish tissue

in fish from Horseshoe Lake. US Steel is not a source of PCBs. Of the 303(d) sources of

602

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

State oflllinois

Environmental Protection Agency

Subject: US Steel-Granite City Works

Data: lL0000329

Reviewed By: Beth

M. Burkard

Page 2

01'4

Date: 05/13-05/2012005

impairment, PCBs is the only parameter with a high confidence level, with all other

parameters listed as "no confidence lever'. US Steel feels the fish with melanoma statement

to be anecdotal.

•

Response: The 303(d) list does not specify Industrial Point Sources as a source of the

impainnent. More infonnation is needed on the fish with melanoma issue-was this reported

as part of an IDNR study, or did one fish appear with melanoma, and was confilmed by an

JDNR fish biologist?

•

Comment Letter: A professor at SIU-E perfonned a study on sediment

of Horseshoe Lake,

demonstrating high Lead concentration. The sediment from Canteen Lake (part of

Horseshoe Lake, but privately owned) was high in Cadmium.

•

US Steel:

The comment provides insufficient infOlmation-what constituted elevated Lead,

what was the comparison, what was the source

of Lead, where were the samples collected,

what was the QA/QC

of the study. Canteen Lake is not 303(d) listed by IEPA. Cadmium is

not a pollutant generated by US Steel and is not limited

by the pennit.

•

Response: A copy

of the SIU-E study would be beneficial to detennine its relevance in this

matter. The application Form 2C, Part

V, of October 17, 2002, indicates a concentration of

<0.002 mg/L as the maximum daily Cadmium concentration. Cadmiwl1 is not a parameter of

concern.

•

Comment Letter: Additional loading

of Lead and Ammonia to the lake. Appears contrary to

CWA and BO\V Mission Statement.

•

US Steel: See above comment. Ammonia limit is based on water quality criteria at 35 lAC

355. Lead is not listed in 303(d) as an impainnent in the lake.

•

Response: The increased loading of Lead is based upon the ELGs at 40 CFR 420, which are

based upon production.

As production increases at the facility, the amount of Lead they are

authorized to discharge increases proportionally.

The ELGs were developed with

consideration

of Best Available Technology, and are based UpOll the best-designed, well-

operated plants available. The discharge must still meet the concentration limits.

•

Comment Letter: Lists the 303(d) sources

of impairment. Group believes that GCW's

effluent should be added to the list of sources.

•

US Steel: Based on tbe IEPA five year Ambient Lake Monitoring Program studies, the JEPA

did not find tbat USS-GCW effluent was a source

of impainnent. Conunentors present no

scientific evidence for the inclusion

of the effluent as a source of impairment.

•

Response: Agreed. The IEPA study did not show that the effluent from the facility was a

contributing source

of impainnent to Horseshoe Lake.

•

Comment Letter: US EPA ECHO reports GCW has been non-compliant with the permit in six

qU3J.ters of the past three years. One informal compliance action, and one fonna1 compliance

action were taken.

603

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

State of Illinois

Environmental Protection Agency

Subject: US Steel-G-ranite City Works

Data: IL0000329

Reviewed By: Beth M. Burkard

Page 3 of 4

Date:

05/13-05/20/2005

•

US Steel: The ECHO reports are misleading due to the quarterly reporting-a violation of

pennit limits for one parameter appears as a violation for the qumter. All but one of those

events were single parameter violations in each quarter. Many of the violations were

concentration limit violations in which the loadings were below pemlit loading limits. One

quarter of nonct)mpliancc involved a treatment plant upset that caused Ammonia-N

exceedences.

•

Response:

The IEPA and USEPA have monitored the compliance and have take appropriate

actions in response to pennit exceedences.

•

Comment Letter: Per USEPA ECHO, USS-GCW is in non-compliance with the Clean Air

Act and RCRA pennits.

•

US Steel: Not relevant to NPDES permit.

•

Response:

Agreed-not relevant.

•

Comment Letter: Requests Public Hearing. Group has not reviewed the aforementioned

study thoroughly.

•

US Steel: Assuming the study referred to is Professor Brugam's study with SIU-E students,

the study is not

relevant to the pennitted discharge, as the study is regarding Lead and

Cadmium in sediments (per the commentors).

•

Response: Agency management will evaluate the requests and detenninc whether the Agency

will initiate a Public Hearing. The commentors did not provide a copy of the study, and thus

it is not possible to know the nature of the study. The following is an Abstract for Prof.

Brugam's study.

Brugam, Richard, Indu Bala, Jennifer Martin, Brian Vermillion, and

William Retzlaff

The Sedimentary Record

of Envirollmental

Contamination in Horseshoe

Lake, Madison County, Illinois

Industrial development over the last 110 years has contaminated many parts of the

American Bottoms, an extensive floodplain of the Mississippi River just east of

St. Louis, MO. Water resources in this region have been severely impacted by

long-tenn mismanagement of hazardous waste disposal by local industries. Toxic

refuse from metal smelting, steel making, and wood-treatment industries has been

released on site to percolate into the ground or to run off into local streams

(Colten 1988). A record of metal contamination exists in the sediment of

Horseshoe Lake, a natural oxbow lake in the most industrialized portion of the

American Bottoms. We examined two dated sediment cores from Horseshoe Lake

to reconstruct the historical record of enviromncntal contamination. We used

isotopes of nitrogen to track the history of sewage contamination finding that

sediment d 15

N

increased to

values> 10 0/00 in the 1920's. Because such high

values of d15N are only associated with the presence of human or animal wastes,

we deduce that major contamination of the lake by sewage began at that time.

604

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

State of Illinois

Environmental Protection Agency

Subject: S Steel-Granite City 'Works

Data: 1L0000329

Reviewed By: Beth M. Burkard

Page 4

of4

Date:

05/13-05120/2005

Lead, cadmium, and zinc concentrations in reased in the sediment after the

1940's. The increase in heavy metals is probably related either to increased input

to the lake from local industrial activities or the use oflead shot by local

waterfowl hunters. Our results provide a physical record

of contamination that is

consistent with CoIten's (1988) description ofhazardous waste disposal in the

American Bottom .

This text is excerpted from http://www.il-st-acad-sci.org/transactions/96_3a.html , Transactions

of the Illinois State Academy of Science Volume 96, number 3, 2003. This indicates that the

study did not specifically study the area around the US Steel GCW discharge point.

It

indicates

that the study authors acknowledged that lead shot from hunting activities is a source

of Lead in

the lake water. The tlnding of cadmium is not relevant, as Cadmium is not found in the US Steel

GC\V effluent, and Zinc is limited in the pennit

by the federal effluent limitation guidelines.

605

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

1021 NORTH GRAND AVENUE EAST, PO. 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

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

IEPA EXHIBIT

No.

~Lf

ROD R. BLAGOJEVICH, GOVERNOR

DOUGLAS

P. Scon,

DIRECTOR

217/782-0610

March 31, 2006

C. Daniel Baker Jr.

United States Steel Law Department

600 Grant Street

Pittsburg, Pennsylvania 15219

Re:

United States Steel Corp. - Granite City Works

NPDES Permit No. IL0000329

Rescission

and Reissuance of NPDES Permit

Dear

Mr.

Baker:

In order to

be consistent with procedural regulations, the Agency has made the decision to rescind the Granite

City Works NPDES pennit issued March

8, 2006 and reissue this subject permit on March 31, 2006. The

effective date

of the pennit will remain April 1, 2006. There will be no lapse in pennit coverage since the

pennit issued March 8

th

is not yet effective. Therefore, an administrative'continuance of the expired NPDES

permit remains in effect until the effective date

of the reissued NPDES pennit. The reissuance ofthe Granite

City Works NPDES pennit will reset the pennit appeal time period so that parties who filed timely comments

on the draft NPDES pennit, on or before January 18,2005, will have a full 35 days with which to consider the

Agency's responses.

The Agency appreciates your cooperation in this matter.

If you have any questions or comments regarding

this issue please contact Blaine Kinsley

of my staff at the address or telephone number listed above.

Sincerely,

Alan

Mw~

Keller,P.E.

Manager,

Pennit Section

Division

of Water Pollution Control

Enclosure:

cc:

NPDES pennit

Records Unit

Collinsville Region

SAK:bak:]:\ I296\docs\permits\gcsteelrescission.doc

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 - 59S 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 5t., 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 5t., Suite 116. Marion, Il 62959 - (618) 993-7200

644

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

1021

NORTH GR.A,NO AVENUE EAST,

P.O. Box 19276,

SPRINGFIELD, ILLINOIS

62794-9276 - (217) 782-3397

•

)A,"iES R. THOMPSON CENTER,

100

WEST RANDOLPH,

SUiTE 11 -300,

CHICACO,

IL 60601 - (31 2) 81 4-6026

ILLINOIS ENVIRONMENTAL PROTECTION A.GENCY

IEPA EXHIBIT

No.

~5

Roo R. BLAGOJEVICH, GOVERNOR

DOUGLAS

P.

SCOTT, DIRECTOR

217/782-0610

March 31,2006

Kathleen Logan Smith

Health

&

Environmental Justice-St. Louis

P.O. Box 2038

St. Louis, Missouri 63158

Re: United States Stee-Granite City Works

NPDES Pennit No, 1L0000329

Rescission and Reissuance

of NPDES Pennit

Dear Ms. Smith:

This letter

is to infonn you that in order to be consistent with procedural regulations the Agency has

made the decision to rescind the above referenced NPDES pennit that was issued March

8, 2006 and

reissue this subject

pennit on March 31,2006. The reissuance of the Granite City Works permitwill

reset the pennit appeal time period so that you and other parties who filed timely comments

on the

draft permit, on or before January 18,2005, will have

35 days with which to consider the Agency's

responses. A copy

of the Agency response letter to you dated March 24,2006 is enclosed for your

convenience along with a copy

of the reissued NPDES pennit.

Should you have any questions or comments regarding the above; please contact Blaine Kinsley

of

my staff at the indicated telephone number and address. Thank. you very much for participation in

the NPDES process.

Sincerely,

Alan

CIw~

Keller, P.E.

Manager, Permit Section

Division

of Water Pollution Control

Enclosures:

Cc:

NPDES Permit

Response letter

Collinsville FOS

Records

Binds

SAK:bak\L:epa 1269\docs\0000329resc.doc

ROCKFORD - 4302 North Main Street, Rockford, IL 61103 - (81 5) 987-7760

•

DES PtAINES - 9511 W. Harrison St., Des Plaines, IL 60016 - (847) 294-4000

ELGIN -595 South State, Elgin, IL 60123 -(847) 608-3131

•

PEORIA -541S N. University St., Peoria, IL 61614 -(309) 693-5463

8UREAU OF LAND - PEORIA - 7620 N. University St., Peoria, IL 61614 - (309) 693-5462

•

CHAMPA'CN - 2125 South First Street, Champaign, IL 61820 - (2l7) 278-5800

SPRINGFIELD - 4500 5. 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, lL 62959 - (618) 993-7200

645

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

•

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST, P.O. 80x 19276, SPRINGFIELD, I lINOIS 62794.9276 - ( 217) 782-3397

jAIYIES R.

THOMPSON

CENTER, 100 WEST

RANDOLPH,

SUITE 11.300,

CHICAGO, II

60601 - (312) 814-6026

ROD R. BlAGOjEVICH, GOVERNOR

DOUGLAS

P. Scon,

DIRECTOR

2171782-0610

March 24. 2006

Kathleen Logan Smith

Health

&

Environmental Justice-St. Louis

P.O. Box 2038

St. Louis, Missouri 63158

Re: United States Stee-Granite City Works

NPDES Permit No. IL0000329

Response to Comment Letter

Dear Ms. Smith:

Thank you for your letter dated January

17, 2005 in which you express your concern for the

reissuance ofthe above referenced permit. The Illinois EPA apologizes for the delay in responding

to your concerns after the issuance

ofthe permit. In response to your concern the Illinois EPA offers

the following responses.

1. Horseshoe Lake impairment and concern over discharges of lead and ammonia by Granite

City Works (GCW).

Response. As you are aware, lead is not listed as an impairment ofHorseshoe Lake. Fish

consumption advisories have been issued for Channel Catfish and Carp because

of PCB's.

GCW is not listed as a source of impairment. The Illinois EPA has taken note of your

concern, both in your comment letter regarding GCWand in your comments .during recent

303(d) hearings at the Agency.

In

addition, lead is not used as a raw material or an additive

in the steel making process. The increased load limit for lead

is based on Federal Categorical

production standards. These standards must be placed in categorical discharge permits

regardless

of the reasonable potential of anyone parameter to exceed a water quality .

standard. Regarding ammonia, the permit reflects revised ammonia water quality

standa.i:ds

which were not in place at the time of the last renewaL

.

\

"

.

!

"}.

..

\~

2. Compliance history ofGCW.

'.>

Response. The Agency is aware of the compliance history ofthe GCW facility. The Agency

has taken, and will continue to take, all'necessary and'appropriate action regarding

compliance issues with this facility.

--

Should you have any questions or conunents regarding the above, please

contactBlain~Kinsley

of

my staff at the indicated telephone number and address. Thank you very much for partfeipation in

the NPDES

process.~,.

ROCKfORD -

4302

North Main Slreel. Rockiord.

IL 61 103 - f81

S)

987-7760

•

DES PU<'NES -

9511

W. Harrison St., Des Plaines,

IL 60016 - (11471 294.4000

ELCIN -

595

South State, Elgin,

IL 60123 - (847) 608-3131

•

PEOR,,, -

5415

N. University St., Peoria,

IL 61614 - (309) 693-5463

".'

BUREAU OF LAND. PEOR'" -

7620

N. University St.. Peoria.

IL 61614 - (309)693-5462

•

CHAMP"'CN -

2125

'South First Street, Champaign,

IL 61820 - (217) 278-5800

SPRINGfiELD -

4500

S. Sixth Street Rd .• Springiield.

IL 62706 - (217) 786-6892

•

COllJNSV'llE -

2009

Mall Street, Collinsville,

IL 62234 - (618) 346.5120

MAR'ON -

2309

W. Main St.. Suite

116,

Marion.

IL 62959 - (618) 993-7200

646

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

to the end of the public conunent period. Specifically, the conunent letter received from the

Washington University Civil Justice CliniclInterdisciplinary Environmental Clinic dated December 9

2005.

The Agency regrets that you were unable to attend a scheduled meeting on the above

mentioned issues

on March 14,2006. We are still willing to meet with you should you wish to

reschedule. Should you have any questions or comments regarding the above, please contact Blaine

Kinsley

of my staff at the indicated telephone number and address. Thank you very much for

participation in the NPDES process.

Sincerely,

Alan

~~

Keller, P.E.

Manager, Permit Section

Division

of Water Pollution Control

SAK:bak\L:epaI269\docs\0000329.doc

Attachment: NPDES Permit

cc: Binds

647

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

1021

NORTHGRANDAVENUEEA5T,

r,o, Box 19276,

SPRINGFIELD, ILLINOIS

62794-9276-(217)782-3397

•

JAI'vIES R THOMPSON CENTER,

100

WEST RANDOLPH,

Sum 11-300,

CHICAGO,

IL 60601 -

(J

12) 814-6026

ILUNOIS ENVIRONMENTAL PROTECTION AGENCY

No.

8b

ROD R, BLACOJEVICH, GOVERNOR

DOUGLA,S P.

Scan,

DIRECTOR

217/782-0610

March 31, 2006

American Bottoms Conservancy

Health and Environmental Justice-St. Louis

Neighborhood Law Office

Sierra Club

Webster Groves Nature Society

C/o Kathy Andria

607

North 7

11J

Street

East St. Louis, Illinois 62201

Re: United States Steel-Granite City Works

NPDESPermit No. IL0000329

Rescission and Reissuance

ofNPDES Permit

Dear Ms, Andria:

This letter is to inform

you that in order to be consistent with procedural regulations the Agency has made the

decision to rescind the above referenced NPDES permit that was issued March

8, 2006 and reissue this subject

permit on March

31,2006. The reissuance of the Granite City Works pennit will reset the permit appeal time

period

so that you and other parties who filed timely comments on the draft permit, on or before January 18,

2005, will have 35 days with which to consider the

Agency'sresponses, A copy ofthe Agency response letter

to you dated March 24, 2006 is enclosed for your convenience along with a copy of the reissued NPDES

permit.

Should you have any questions

or comments regarding the above, please contact Blaine Kinsley ofmy staffat

the indicated telephone number and address. Thank: you very much for participation in the

NPDES process.

Sincerely,

Alan Keller, P.E,

Manager, Permit Section

Division of Water Pollution CODtrol

Enclosures:

Cc

NPDES Permit

Response letter

Collinsville FOS

Records

Binds

ROCJ(FORD - 4302

North Main Street, Rockford,

Il 61103 - (815) 987-7760

•

DES PLAiNES -

9511 W.

Harrison St., Des Plaines,

IL 60016 - (847) 294-4000

SAK:bak\L:tljDaiNl~9~OOl\i2~j-gil1;,lldOOl23

- (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 - (09) 693.5462

•

CHAMPAICN -

2125

South Firs! Street, Champaign. IL

61820 - (217) 27 8.5800

SPRINGFIELD -

4500 5

Sixth Street Rd, Springfield,

Il62706 - (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

648

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021

NORTH GRANO AVENUE EAST,

P.O. Box 19276,

SPRINGFIELD, ILLINOIS

62794-9276 - ( 217) 782.3397

JAMES

R.

THOMPSON CENTER,

100

WEST RANDOLPH,

Sum' 11 .300,

CHICAGO,

IL 60601 - () 12) 814.6026

ROD R. BLAGOJEVICH , GOVERNOR

DOUGLAS P. SCOTT, DIRECTOR

217/782-0610

March 24. 2006

American Bottoms Conservancy

Health

& Environmental Justice-St. Louis

Neighborhood Law Office

Sierra Club

Webster Groves Nature Society

C/o Kathy Andria

607 North

7

th

Street

East St. Louis. Illinois 62201

Re: United States Stee-Granite City Works

NPDES Permit No, IL0000329

Response to Comment Letter

Dear Ms. Andria:

Thank you for your letter dated January 18, 2005

in which you express your concern for the

reissuance

ofthe above referenced pennit. The Illinois EPA apologizes for the delay in responding

to your concerns after the issuance of the pennit. In response to your concern the Illinois EPA offers

the following responses.

1. Horseshoe Lake impainnent and concern over discharges of lead and ammonia by Granite

City Works (GCW).

Response. As you are aware, lead

is not listed as an impainnent of Horseshoe Lake. Fish

consumption advisories have been issued

for Channel Catfish and Carp because ofPCB 'so

GCW is not listed as a source of impainnent. The Illinois EPA has taken note of your

concern, both in your comment Jetter regarding GCW and in your comments during recent

303(d) hearings at the Agency. In addition, lead is not used as a raw material or an additive

in the steel making process. The increased load limit for lead is based

on Federal Categorical

production standards. These standards must be placed in categorical discharge pennits

regardless of the reasonable potential of anyone parameter to exceed a water quality

standard. Regarding ammonia, the pennit reflects revised ammonia water quality standards

which were not in place

at the time ofthe last renewal.

2. Compliance history of GCW.

Response. The Agency

is aware of the compliance history ofthe GCW facility. The Agency

has taken, and will continue

to take, all necessary and appropriate action regarding

compliance issues with this facility.

In addition to the responses to the ab9ve comments, which were received prior to the end of the

public notice period, responses are being generated for the comments that were received subsequent

ROCKFORD - 4302 North Main Street, Rockford,

IL

61103 - (815) 987-77.60

•

D,s PLAINES - 9511 W. Harrison SI., Des Plaine" Il 60016 - (847) 291-4000

EtCIN - 595 Soulh SIdle, Elgin,

IL

60123 - (847) 608.3131

•

PEORIA - 541 $ N, University

5t..

Peori.,

IL

61614 - (309) 693-$1&)

BU",AU 0' LAND - PWRIA - 7620 N. University St.. Peoria. Il 61614 - (309) 69).$462

•

CHo'IMP"ICN - 2125 South Fir't Street, Champaign.

IL

61820 _ (217) 278• .5Il()O

S'RII"UIILO 4500 S, Sixth Street

Rd ..

SPringfield

IL

62706 - (217) 786-6892

•

COlllNSVltLf - 2009 M.II

Sueel,

Collinsville,

IL

62234 - 161

BJ

346.5120

MARIOi': - 2309 W. Main 5r" SUite 116, M.Tion,

IL

62959 - 16181 993-7200

649

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

to the end of the public comment period. Specifically, the comment letter received from the

Washington University Civil Justice CliniclInterdisciplinary Environmental Clinic dated December 9

2005. The Agency regrets that you were unable to attend a scheduled meeting

on the above

mentioned issues on March 14, 2006.

We are still willing to meet with you should you wish to

reschedule. Should you have any questions or comments regarding the above, please contact Blaine

Kinsley

of my staff at the indicated telephone number and address. Thank you very much for

participation

in the NPDES process.

Alan Keller, P.E.

Manager,

Pennit Section

Division

of Water Pollution Control

SAK:bak\L:epa1269\docs\0000329.doc

Attachment: NPDES Pennit

cc: Binds

650

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

.

,

NPDES Permit No. IL0000329

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: March 31,2011

Name and Address

of Permittee:

United States Steel Corporation

Granite City Works

20th and State Streets

Granite City, Illinois 62040

Discharge Number and Name:

Issue Dale: March 31, 2006

Effective Date: April

1, 2006

Facility Name and Address:

United States Steel Corporation

Granite City Works

20th and State Streets

Granite City, Illinois 62040

Receiving Waters:

001

AOl

801

COl

Treated Process Wastewater

Coke By-Products Wastewater

Cold Rolling Mill Wastewater

Landfill Leachate Wastewater

Horseshoe Lake

In compliance with the provisions of the 1I1inois Environmental Protection Act, Title 35 of 1I1. Adm. Code, Subtitle C and/or Subtitle D, Chapter

1, and the Clean Water Act (CWA), the above-named permittee is hereby authorized to discharge at the above location to the above-named

receiving stream

in accordance with the standard conditions and attachments herein.

Permittee is not authorized

to discharge after the above expiration date. In order to receive authorization to discharge beyond the

expiration date, the permittee shall submit the proper application

as required by the Illinois Environmental Protection Agency (IEPA) not

later than 180 days prior

to the expiration date.

Alan Keller, P,E.

Manager, Permit Section

Division of Water Pollution Control

SAKBMB04090101.bah

651

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Page 2

NPDES Permit No. IL0000329

Effluent Limitations and Monitoring

1

From the effective date of this permit until the expiration date. the effluent of the followingdischarge(s) shall be monitored and limited

at all times as follows:

Outfall(s): 001 Treated Process Wastewater

LOAD LIMITS Ibs/day

OAF (DMFl

CONCENTRATION

LIMITS mgll

See Special Condition 1

PARAMETER

Flow (MGD)

30 DAY

AVERAGE

DAILY

MAXIMUM

30 DAY

AVERAGE

DAILY

MAXIMUM

SAMPLE

FREQUENCY

Measure When

Monitoring

SAMPLE

TYPE

pH

CBOD

s

Total Suspended Solids

Oil

&

Grease

Iron (total)

Iron (dissolved)

Lead (total)

Zinc (total)

Cyanide (total)

Cyanide (available by

OIA 1677)

Phenol (4AAP)

Fluoride

Ammonia-Nitrogen'

Spring/Fall

Summer

Winter

March

See Special Condition 2

2085

2502

1511

417

5,6

12

19

1,1

5,0

584

459

1501

834

4170

5004

3492

834

209

17

56

35

4,6

10

834

3128

3128

3128

3128

10

12

15

2

0,09

0,17

0,1

0,01

2,8

2,2

72

4,0

6,0 - 9,0

20

24

30

4

0,4

0.2

0,02

0,1

4

15

15

15

15

2IWeek

2IWeek

2IWeek

2IWeek

2/Week

2IWeek

1/Quarter,

2IWeek

2IWeek

2/Month

2IWeek

2fWeek

2fWeek

2fWeek

2fWeek

2fWeek

Grab

Composite

Composite

Grab

Composite

Composite

Composite

Composite

Mathematical

Composite"

Mathematical

Composite"

Composite

Composite

Composite

Composite

Composite

Composite

'For Ammonia as Nitrogen, Spring/Fall is April-May and September-October. Summer is June-August. Winter is November-February,

Weekly average limits will apply, For Spring/Fall. weekly average limit is 7,0 mg/L (1460

Ib/day),

Summer weekly average limit is 55 mg/L

(1147 Ibfday), March weekly average limit is 10

mg/L

(2085 Ibfday), No weekly average limit for Winter

.'See Special Condition 10

652

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Page 3

NPDES Permit No. IL0000329

Effluent Limitations and Monitoring

1. From the effective date of this permit untillhe expiration date, the effluent of the following dischargers) shall be monitored and limited

at

all times as follows:

Outfall(s): A01, B01,

C01

LOAD LIMITS Ibs/day

OAF (OMF)

CONCENTRATION

LIMITS

mq/l

PARAMETER

30 DAY

AVERAGE

DAILY

MAXIMUM

30 DAY

AVERAGE

DAILY

MAXIMUM

SAMPLE

FREOUENCY

SAMPLE

TYPE

Outfall

A01 • Coke By-Products Wastewater

Flow (MGD)

Total Suspended Solids

Naphthalene

Benzo(a)pyrene

See Special Condition

1

0.10

0.15

Monitor

Continuous

1/Month

2M1eek

2M1eek

Measure

Composite

Composite

Composite

Outfall: 801 • Cold Rolling

Mill

Wastewater

Flow (MGD)

Tetrachloroethylene

Naphthalene

See Special Condition 1

0.73

When

Monitoring

2/Year

1/Month

Measure

Grab

Grab

Outfall:

C01 . Landfill Leachate Wastewater

Flow (MGD)

See Special Condition 1

653

Continuous

Measure

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Page 4

NPDES Permit No. IL0000329

Special Conditions

SPECIAL CONDITION 1. Flow shall be reported as a daily maximum and a monthly average, and shall be reported on the monthly

Discharge Monitoring Report Form.

SPECIAL CONQITION

2. The pH shall be in the range 6.0 to 9.0. The monthly minimum and monthly maximum values shall be reported

on the DMR form.

SPECIAL CONDITION

3

If an applicable effluent standard or limitation is promulgated under Sections 301(b)(2)(C) and (D), 304(b)(2),

and 307(a)(2)

of the Clean Water Act and that effluent standard or limitation is more stringent than any effluent limitation in the permit or

controls a pollutant not limited

in the NPDES Permit, the Agency shall revise or modify the permit in accordance with the more stringent

standard

or prohibition and shall so notify the permittee.

SPECIAL CONDITION 4. The use or operation

of this facility shall be by or under the supervision of a Certified Class K operator

SPECIAL CONDITION

5. For purposes of this permit, load limits for Phenol (4AAP) have been based on actual plant discharges, and load

limits for Ammonia (as N) have been based on water quality standards, and

are included in accordance with a 301 (g) variance of the Clean

Water Act approved

by the USEPA. Any changes to these load limits can only be made following Public Notice and opportunity for hearing.

SPECIAL CONDITION

6.

The permittee may show that an apparent noncompliance of load limits for zinc is not a violation by applying

background credits for intake waters and by submission

of calculations as defined below.

The load calculations for comparison to Zinc load limits shall be made as follows:

M

= (C. - C,)

x

F

x

8.34

Where:

M

= Outfall 001 load limit (Ibstday)

C. = Outfall 001 effluent concentration

(mgtl)

C, = Intake water concentration (mg/l)

F

= Outfall 001 effluent now (MGD)

Concentrations limits

for outfall 001 are absolute and no background credit shall be allowed.

SPECIAL CONDITION

7. The permittee shall record monitoring results on Discharge Monitoring Report (DMR) forms llsing one such form

for each discharge each month. Semi-annual monitoring results shall be submitted with the

DMR forms for the months of June and

December, and shall be submitted to the IEPA no later than July 15 and January 15 unless otherwise specified by the Agency, to the

following address:

Illinois Environmental Protection Agency

Bureau

of Water

Division

of Water Pollution Control

Compliance Assurance Section, Mail Code #19

1021 North Grand Avenue East

Post Office Box 19276

Springfield, Illinois 62794-19276

SPECIAL CONDITION 8. The Permittee shall be required to conduct an effluent tOXicity evaluation prior to the renewal of this permit.

Elements

of the tOXicity evaluation should include but not be limited to the following:

A.

Aquatic Toxicity Screening

Acute TOXicity - The initial acute toxicity testing should be run on at least three trophic levels

of aquatic species (fish, invertebrates

and plants) which represent the aquatic community for the receiving stream. Suggested species include the Fathead Minnow

and Ceriodaphnia. All tests should be done in accordance with "Measuring Acute Toxicity

of Effluents to Freshwater and Marine

654

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

Page 5

NPDES Permit

No. IL0000329

Special Conditions

Organisms (Fourth Edition)", (USEPAl600-4-90/027) and "Environmental Effects Tests Guidelmes" (USEPAJ560-6-82/002). The

IEPA specifications and guidelines for lhese tests, given in "Effiuent Biomonitoring and Toxicity Assessment - Aquatic life

Concerns," must also be met.

Testing shall be conducted

on fish

over

a 96-hour period while invertebrates should be tested

over

a 48-hour period. Test should be

performed on 100% effluent.

B

Sampling Frequency

The test referenced

above

shall be performed during the final year of this penmit. Upon completion, test results may be submitted with the

facility renewal application.

SPECIAL CONDITION

9. Samples taken in comptiance with the effluent monitoring requirements for internal outfall A01 shall be taken

at a point representative

of the discharge of Coke By-Products Wastewater, but prior to mixing with any other wastewater sources.

Samples taken

in comptiance with the effluent monitoring requirements for internal outfall 801 shall be taken at a point representative of

the discharge of Cold Rolling Mill wastewater, but prior to mixing with any other wastewater sources. Samples taken in compliance with

the effluent monitoring requirements for internal outfall

C01 shall be taken at a point representative of the discharge of Landfill Leachate

Wastewater, but prior

to mixing with any other wastewater sources. Samples taken in compliance with the effluent monitoring requirements

for outfall 001 shall be taken

at a point representative of the discharge, but before entering the receiving water.

SPECIAL CONDITION

10. Samples for Cyanide (available by OIA 1677) and Cyanide (total) shall consist of a series

of

grab samples

collected over any 24-hour consecutive period, stored using methods consistent with

40 CFR 136, and combined after the collection of

the last grab sample. The combined sample shall be analyzed using methods consistent with 40 CFR 136, within 24 hours of the initial

sample collection.

655

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

'_d~

Act

I'NWf\t

I" IKIno,... £O"'ltonn'\oef\tit!PIQ1Kttofl Act Ch 11 1

1/2

Iii. Rev Silt., SK 100 t.

IOS2 "A""""'-'l

~

Wat., Act HOffT\Itrty ,.t.,ntd It> IS I....

f~al

W,I&I PoHvlloO Control "'cU fllebl'tS

/'uO. l. 92.

~OO.

OJ

_~

JJ U.S C. 1251 ., _

W"OaS CNllioNf Poduunt ()U,cNlr'oe EWnNtjon Sy.l.ml

mMftt IN

t\I.~

pt09f'1im 10f"

...una.

modifying.

~ing

and retuv1nQ,.

1etTT\t~hng,

mONioring end

~fon:,;no

oermits. """"

~

lind lint(:wcing

pr.t\'"e;.trnent r.q:u;(amenl', vndat SKDon. 307, 402, 318 .t\d "05

of Iho

C_ W....

Ac"

0eMy

~

..

~

Irw diKharv- 0' • poItJlanl

m..:wt'*:f during •

ca~'

d • .,. Of any

2••

hQIM

period

~t tN~ ~ta

tht' ca"et\d.,.

0.'(

for put'p(.)UI of umpting. f()l

~b

wi", IitniUttonl .1.".......

W'l

Ut'o4b

of

m.SI. tn. ..d...., disch.lfro-..

it

Ukvl.ltd'l

rhI

lolM ".,.... 0'

the

poIulJW'l

dtK.h.,~

0 ....., ..... d• .,..

F~

pol&ut.anh

witf'l

"m.utw:mt

.............. olhw ,-,"". 0'

rne~n".

the "cia"'" diKJ'\afq4"

it.

u.lcu\ale<S" ,.... ,v«loe

,...........,t 01 ""- POlut,"t O¥*" the 0.1'.

..." ........ Oa.lJy

Dl~

.. UmiLatlOt\ Id.ity mtJlimuml melfi. I.... htghe-sl .no......Ne d.lly

--"e.

A".... Mon"',

O~

.. Umlt.-doft 130 dav .......reg.) fnNIru Ihe

h.io~'1

."o......bW

~ o~

cS.My diachargea 0YtiI' • ,."ndaf tnQf\th, cak:ut.ted II

tht

tUm of ,. dlJty

~

__ <luting •

cole..,... monlto

~Ovidod

by''''numb.< 01 doily dn<htIV"

_

dLa1flg IN' month.

...".,..... W ....V

~

Umitlltlof'l 17 day Ivtra041 mufti the h'ghnl

~web6e

....... 01

deity

~harvn

ov•• e.eJ.endar

w ..

k.

u.lcu"(~

as

It-..

.um of ,II d.ity

diKh~

...

....

...

~

,

_.

"~t

during •

c.&itnder

fl'TKtlc:..

\IlI"M4(

dNtded

C8MP,)

by

m......

1M nutnMf

.C"-du'e.

01

c.ily

of

d*~.

ecti'viu..,mq.~

pt'ohibhi()o,

d\.lringof

pnc~

mttnten.tnC:lt

poctd~

•.

and

othet tNNog"""'"

prac;tic:,M

to

~t

or radue.

fh,e

poIu1ion of ....... 01 Iho SIA...

ilMP••

100 indudo tr •• _,

~monU.

optfOting

~ ~

pr8Cticea to conlr04 plent

,lia

runoff•

.p;~

or .......

Ioi~

Of

WUtA

dirIpoul

or

drlnao-

~

raw rneWilol

.to~.

~

,.,...,... ....mpie of

.apecifMd

voIutft.

LINd

to R\lk.. up •

tOLal

compotil* ...

m~

Gtatt

~ ~nt

In

indlvIduaI

urnp6e of at ....1 tOO

mItMi.,..

cofle.eled

'I •

tlndom... .

~

time

over • period not •• oeeding 15 minul...

J4 Hou'

~t1t

.......

,.,..ns • eombinetion ot It lent 8 ...mple

.lk:Iuon

01

II "'''I

100

mAitrMrI.

coIec':tld ,t perriod.ic

intwvatl

during the op.,ting

h>Oura

ot. facility ov.,.. 24.

hooIPoriod.

.Ho..r~tta"""""'''~.combin.non

of ,t Iea.t) ...

~

.ftqlJOuol .......

t

100

".....,.... ,oIecled It

penodic

interval. during thl op."ting houri of. f.ciltty Ov.r In 8.hOyr

poriod.

leJ

P"wmlt ecOoN.

ThI' pennit

may be modi'ted.

ITWc*ed..nd

re;uued.

Of I.rmNI.d

.JorcauM by lhe

AQrtncy

put-Want to 40 CfA 122.62. The riWYJ of

.~u."b'l

tha:

perm.itt.. for.

permit modific.Liot\.

""-'OCAltion.nd

,.;~.

Of'"

I~lion<

or •

notrr~tiotl

Of

~

Chotnoel

Of

~~t14

l\OnCOtnpl&ence.

0041

nol Hev

''''Y

pwm;t

condition

(71

~ r~u_

This P«mit do*, not convt'y .ny

Of"0()¥tY

nohl' 01 .ny sort,

Qtf

any ..du$tYO:

pMvt'eo'

(8l

Duty to

pto't'fCle

In'O*tNlliot1. Th,

perm11f..

,,,,tI furnish 10 the Agency w'lh,'l •

~bie

Itme,

tny

m/orm.hon whtCh the "'O-l'l(;y mal' '6Qu"

j

10 o.ultrnine

whelh.r uuu ._.,u 101 modityiflQ. revoi.ltlg

.~d

''';UIJfl1iO.

01

t.amnaling lhl\

permit.

or

to Ootlenni,... comp4i.nce with Ihe permll. The potrmitt.. Ih.ll ,Iso

hJl''''''si'l10

t~.

AO.ncy. upon ,-.q\,4'l capote. of t"KOf"ds

.-.qvtftd

to be hopt bv Ih••

pennit

t9.

~'0fJ

and .nlry. The pe<tnitl" "tao .now .n authoriZed ,oPftwnt.tN, of

the AQeocY. uPOn tn. pre,ontl:tion.

01

~nliell

tf'lod OIM' doc:um.no IS

",.y

be

~bv~w,lo·

ta)

(nl.,

upon th.

~ill,,'1

poftl'rli..1

w~

e

'~IJI'led

lacility

0' .'I.....il... I'

iOc~lld

0' conduc.ted. on...h.r. flCord, must

be

kepi unde' tho condilions

of this pwmit;

fb)

Ha.... ,celis '0 and copy. at reuonaMe limes.•ny record' 'hal rno" be

hpt unO.f lhe'

CO!\dil~na

of Ihi, ponnit:

iel

lo!.s.poIICI .1 (oason.I)" limn anv ,.,ili,i... eQvlpmeo,

lincll.,ldino

mOnil()l"ln~

.nd controt

equtpmtnt),

pt,c1iC.". 0' oP-e'attons (ooulahrd or 'OQ"...

.o

~ lh~

pennit;

end

ki)

SampHt or

mo~tQ(

II "UOf\4Il)M lH'N1. '0'lhe purpOM Of

."uril"lQ

pe'rNl

complilnce, or .1

ot~i

....",thorhad by I". Act.. .ny lubll.nca. or

pel.mel.,. .t .ny loG.ticn.

Samp&...

nd

m...urenwnla t.lc.ln lor

the

purpOM of monitOfiog ,h.1I

be

reprael\lI~

of rhe monrtot"ed activity.

The

pwmm..

.na« ,.tain rtCoro' of .d

,nonitoring

tn'om"l.tion. includir.g

eM c.elitxltion and

maint~

fKonh•. and 1M

onginal

.trip ch.rt

n.<oroir,g. to( continUOUI tnQf'Mt0rit't9 inltrul'f'loll"UUon, eopie. of I.

~

-.quirod by Itli,

pom1l~

Ind _.01 .. d...

vM<!

'0 eompIo .. tho

oppIicttion

II)(

!hi.

pollTll~

II)(

I po<iod

01 .1 I".., J

y.."

Irwn tho do.. 01

tIVo

potmi~ ..-~~

_

Of

.pp1ietllon. TM

porio<l

""y

be

ellt.nd14 by

~UNt

01 the

.6.g-"'Cy

.1 .ny

time.

13)

Tho doltltl .",tv... -. portOtmld;

(4)

.n,.

indiv'dl.ttll(,)

who plrformed

the

lnety...;

151

Th•• notybc.Hlt<:hn;q1Jll1 Of mathods uNd:

.n~

~ "':~f

~tt.

Sampt.

".....0' I

cornb~lion

01

~

aMquot$ of

_t ....

I

\00 mllilit.... colecltd ,t

~ic

int,rvlh sue:h lh"t ,i,h..- It. time inleN" be'....... n each

IIiQuot

Of'

the votvmo

01

a.ch

.Iiquot

;s.p4opot1ionet

10 .ither

t~

s-It,.m

no\ollr

.t lhe tim. of

~

01 thlJ lot.l .',umHow since the colec.tlon of

lhe

Oi'vio", aliquot.

(\)

Ovty to cCNnQty. The pwm,n.. MUlt

COI'Tl~V

with ,II cotK1ition. of lhil

~rrnil.

Any permit

oon~nce

con"titut.... viQletio"

01

th. Act and i$ Of1:luodl

1o,

entorcement .ction. ponTIil t..-mln.lton. '....OC.1ion IN3 ,.i"\,I.nc•. moditication.

or

tor ch-nial of • poe,"",il r.newal .pplM:llk>tl. Th4 p.nnittM ,had compty with

• H......

t

.~nd.fdl

or prohibCliofts e.tabtil!\4ld unClel Section 3071.) 01

I~

C)..n

W.tw Acl

fOf

toait. pollulenu. wlttlin 'h. ,ime PcovK;fad.....

~

'''OUf.hons\h.,

at,b'i.h tn....lInd.,ds

or

orohibttlons, .""n

if tr.. permn.

hu 001 vet 0.-"

modil'ed to inc«pot,l. the f'IiClu".mcw"

U)

0"1, to lea09ly.

If

the

~t\M

wilnes to continue In

~ti"ity

ftgul.l.c' by thi.

permit

,It.

the ,-.pirItiott

~t.

0'

thi.s

pennit". I'l'l. peP"l"l\ittH

mUll .pply

fOf

.nd

obllin • new pemWl If 1h4 j)toI'TnI"" $\.lbmils ,

pto,*"

'pplte.tion II requ".d bv

the "'genc:y

~

t,t., Ul.n 180 day. p.'M)r to the ex.pir,tion dat.: this pe'mit''hIlS

con~

jn, '\lU tOfce

.nd

.U~I

vntil the fin.1

Agency o.eillon ottlh. lppMc:ation

has

been

m.ec:H.

())

He" ,,,. heft Of r.duet aC'lvity not • del.n..

It

,h,' not

be ,

dllen., fOf •

pec-mi"" in .n enlore.mont ,e'ion thll .1 ,"",oold h ..... bMln oec:euary 10 hall

()f

'edUCt the pwmint<J Kti¥'ity in ord.r 10

f'(\~jnl.in

camp/iooct with the conditionl

of thIs. J:*'TI'l'l.

.

'.1

. Duly to ",lIiga'e The pe,"'''Uee,h,)W

I~"

•

.lit

te..on..

~

Iteps '0 minimiu Of

9'"8"e,1I toy ",loscheIO_ in ...iol.hOn

01

'hiS p;':frnit

which

has .. '.UOOoIt)6e likolihood

01 otdv...

sely o"ecling

humAn

heallh Of Ihe en",iI"onm.nl.

IS)

,.'....

op..,t.,H>n end mein'.Ntrn:;.

The

pell1'ultee

shillt

ot all

timn

C)(o~

nc:-ra.e .nd

",.It'll...!"l

aU

f.cllll'"

onl.J

SV,l""U

of Ire.t",.nt .nd contlol

t.nd

f ••

llll.! tPPiJI"tll...ut,,;:.sl wh'ch

,jr..

m~;Iollod

,)1 lIs.-d hy lhe pefTTMlI.. 10 -en......

con'u1iunc. wl'h Ihe cOC'ldil'(,Jns of

Ih'~

parm., P,ope, C!'J)4'rliionand m.inten.ance

.r<.ktdes e1l1l".;II.... poetlo,rn;u\Ce. lldOC,ju.lo IUftdihg. adequale operw'o,

.~lti~

and

uai"ing.•

hd .dequoll l.b<v_IOrv ,nd ploeeu conlro

l

,. tnetudln9 .pptopria"

Qvality ."ut.neo

Pf

OCedVfC~

This Pfo...iaion reQuire. Iha O()ItaUon of

bKi.~op>

Ot

'V"Mary

I.cili"".

or similar IYllems ollly when n.....

T}'

III achie.e

coropliancc wilh lhe c:undilHJf'lO of

lh~ ~rmil

Ill)

lot

Monitoring must

be

conduCI-.:1 according to teJt

pt"<lCedUf.'

.pptu\r.cJ

under 40 CfR Pa" 13e. unJeU other te.1 proc.du(el

~",a

boNn

~il~

.... thit. perm;t,. w...,..

~

t•• t proc.edurw

uf'idw

40 CfR

part

136 h••

~

approved. the permih.. Mull lubmit to the

Aganc;v~.

t.lt method fOf'"

.ppro....... Tha p.rmitt••• ".U ulibfue ,nd parlp,m m.int.n.nce

procedUl"'e't

on IU

l'\'loOni\oOng

.nd an.ly1icei inelNt1"llttlution ., w,......." 10

eNu'" 'CCurKy of mulurtrnantl.

'~IOfY

,..qulfement.

All

.pplic.tionl. .repOrt.

Of

inlorm.'ion .ubtn4tt.d to

l~

~oncy

shtU be

';0_"n<! e.rtlhod.

01

,«. COfpOi".llon:

by •

principel •• .cUIi've offic.r of.t " ..I lhoe

le.....t of vic. pt't$id,nl

Of" •

~rton

or po.ilK>n h.",Wtg 0'Vffa_

....ponaibiolity

for *lvirontnentll man.n for

tht

corpO(ltior't;

(21

FCM • p.trt".,.hlp or .01. procirietonhlp: by • general

~

at"

"'- proprietor, ,..

pecti....ty;

or

(31

For. munlclP4l1ty, SUiI., F.d.,.I,

0#

oth... pubUc aog.ncy:

by

..tn. I princip.lexec:vtl.... oflicti Of

flnlt,~ .5ec~

oflici.IJ.

Aeporu All

,..poru

requit1ld by

~tmitl. ~ o~r

tn'of1"N'ionf'lqWltwd by

Ih. Agency Ih,lI be sigf'lOd by a pe,1&on

o.a.cnbe(l

in PM.graPh tal

01'

by •

doJ#y .utho,ind 'es>ta..enl.tiv.

01

fhll poISOn. A p.rton" • duty

.l,lthoriud

,.pr.sen'.I;....e onty

if:

tt i

Th•• uthoriulion II m.de

In

Writing by • pat"toOn detoeribed

in

peragr.ph 1.01: ond

12)

Thoo euthonlllton 'Pecil'" .ith.,. an inoividual or •

po..

tlOn

fospOnsib4e 'or

l~

O\r.,.eh

o~.tion

of II'-.a

'"itily.

horn .....

h~h

'he

di$Cheroe o'ig;n.toli. Jueh II • pfant m.neg." ,upoerintenoWH

Of

pe~n

of

equt....

nt '..ponlibflity; end

PRINTED ON RECYCLEO PAPEP.

656

Electronic Filing - Received, Clerk's Office, December 10, 2008

---

-_

.

.,.,... _.

~--'-"--'.

~c~.,-·t.c

• ..:... a dUtennl tnd.vidual Of p(Hil'on h ..

~POn.ab.hrv

fOf tM

ov-.... opt,aUO" 01

I~

hcti.ty.• ,.,..... .vU)OnUbot'l uti.fyWoQ th.

~~.

of

lb) mutt 0.. Su'bmiM60 10 lhot

AO.ncy pno, to

Of

looelhoti

1¥itt. .n.,

~

•. mfortn.tlio".

Of

appt«:;.IKm. to be

'~NKl

by An ,vlhOt\t1t.d

,...,.,.Mflt.ti,..e.

Kryio..wtn,,;

,~ hlJ~

m,icrogl"lm, p« lit.,

(~OO

U9/J)

fOt

2....

diNtTOP~fJOl.nd

tOt

2.melhy·I-"',e·d#'l~nol:

.hd 0,..,.

~Utor.rn

pet litet II mg/II

fot

entimony:

13)

five IS) htntts the muimom (.OOC81lnOOt'l ....ilA

~

tor th.l

po\ltuunl in 'roe

NPDES pem'li1

~t.io!':

Ot

1.1

Pla""ed ch,n;a. 'The peHn;ll.. stull 9;ve nol«:e to the Age",",y as 5,oon

U.

j)OHlbJe 01 ,nV pllH\roed phYSIc.a: a1te,.,fct\$ 01 addtlionl 10 the

I>tlrn4l1ed Ilc.lily.

(bi

That lhe-y he .... boeg'Jn or IllI.DOCI 10 !:>eOin to ust Of m ..nulac!ure 's

.r.

inlillfmed\.el. Of

!j~1

PfodUCI 0: byprOdvcl .ny to_tC pOllute,,\ whiCh wu

f\Of fePOned In the NP'OES Pem1it epptic.ttl()l'l.

•

~tki~tN

nonc:otnpU.ru:a. The V'drmlt"teoe ah.1t gh... adv.nc• .,011<:. 10

1h4 Af1'Incy

of .n"

~.I'tned

ct\.anou ,n tn.

~tm;H.d

f&cilit) or

IJC\lvity

........ich mey , •• utl In

noncompli..nc. _ilh penY'ltt reQ\J.ron\tlnU.

115t AI! Publicty Owned Trutm-enl Wcw" t?Orw,llrtV'Sf prov,o.

l~uale

nol>e. 10

the ....

O.ncy of 1M lol\o...,tng:

1<1

ldl

eompu.,..c. achedl.t'-'.

ReportJ

Of complience or noncompliAnce witt"

01

,n... Pfooress ,.pon, on. inl8f;m .nd "nal rO'QlJI,..me"I, conle",8(l .n eny

COl'T\Pllanct Ut-oeduM 01 Ihi. petmtl 'hall be submille<l no leler thon 14

c:t..,. toUow.ng uch t.e:hedu,-" Oat.

...

~hQti"'t

,-.pori' Monilorit'WJ

f ..vlls

~"'atl

be

r.port.c

el

lh.

int.rv.l.

tpKilioe<J ..........hent

W'\ !hi,

pefm,i

(e~

Ibl

Any .........

introduction

of

potlulonU

into

lnet

POTW

from

en

...ow-.e:t

disc:hlfO.f which

ould

be

lubject 10 S-e:Honl 3C

~

Ot

306 01

I~

Ci.an

Wat., Act

if

II

,.. di,..cl)y dilCJlIrging Ih(.'Nl pollutants; af1d'

Anv ,vb'\Mltia

l

cheng, il'\ tt-. volume Or

C~&C111'

01 pOlluUlnlt biting

;ntroduud inlo th.t POTW by • lOufce i1'lJToouetnog poUu"'f\t. into Ih•

POTW .t

~

lim. of

it.....l"lG.

of

I~

permit

III

12\

Mooilont\Q "_vlh mVII be rtporle(1 on e O'SCh,ffO' MonilOltng

R.port IOMA).

tf

lhe p.tmih" ,,",ornlo,. I"V POllulenl I"\Ore lteQuontty than

~utnJd

by ,h. permil u,ing last procedure, Ipproved vnd(U 40

CFA 13e

Of u

,pecified in th, pefmlt. the r..ullS ot Ihi,

",onitOti~

,h.,U be

includ.o in Ihe Calcul.ftton and rlporting of Ihe d&11

tubmtMad in Ihe OMR

1161

tel

Fo, pu",..,,... 01 Ihi, P.'''Offlph.• d<aqu.te (\0"". ,halt InckJOl ,n1onn.hon

on

Ii)

Ihe QU.t1ry ond Quarility 01 .ffluent inlTo<h.ced tnlo

lh.

rOTW. ,rod liil

any

.nl~i~teo

Impact of tho

Chang_

on

Ihe

quantitf

~

Quality

01

.U'v."t

10

~

dl"hergfKS hom tha POTW.

If

the pctrmtl

Is

iulAd

to e J)Vbl.icly oW'''*'

~

putMtety reQulated tnI,tma-n1

won.•.

lhe Parmi"" 1of'1alt lequire Iny indu.lrial ua., of loch t,..,.lf"I'\'enl work. 10 comp)y

with

f.o-.I

rOQuatwments- cooc.miOQ

Tr.n.',,, of perml ... A permil may

be

olutomelicaUy "anslerred to • new

p"rrnin.e It:

~a)

Tht cI"tenl p,,,m;ttee notifies the A9t1fll.V

~t

liJasl 30 dey, ,n achinci of

the PIOPOS.cj Ifatls-fer det.,

(22) TM Cun WIle, ACt provid.. th.t Iny penon who knowiootv

m~k"

.ny 'al..

sLilemen!. repr-eunt.lion.- or c.rtihc.t'on

in

.ny f.cord or olher document

submitted

Of

reQu....d to

be

l'1"-intaillad und., Ihis p.et'mil .h.n.

iocl~inog

fTloOrKIOlif\9 fepons

Ot

~pon,

or compli.nce Or non-comclianca 'haM. upon

COnv~l;on.

bot pvni,t'1ed by I 'in. of no'.mo... th.n S 10.000

PI"" ....

oll1lOn. or bV

imprie.onmenl for "01

I'T\M

than 6 monlh, per vio\elion. or by 001t'1.

13l

Int~bon.

monilorillQ .nC:J tntt)' puflIJ.nt to SKliol'l 308 of lhe Cw.an

Wele,

A~l.

u~

ChalO" pursu.nl to S.ction 20.. lb) 0' tM '''.nWetw ACl--end

.~ica~o

rl'gu1ationl .ppearloo

W\

40 CfFt 36;

1",. C\eln W.ler Ad pro"C::J.o. ihlt any P'lr.on who v'olt,., • P"Fit tondition

lmC'am.nring StI'(tlon, 301. 302. 305, 301, 308.318.

Of

406 0(1"" C".n W'IIi

Act

i,

subjeci to I civil pen.flty not to ell:(...d $10,000 p« dey Of .veh vtot.t1Qn

Any

~aotl

who .....illiully Or nooltoenUy vielol.. penn'l

condilio~

imP'el'l'l"lnrino

Se<:lton, 301.

302.

306. 307. 0' 308 o( Ih. C"an WIl.' ACI it'sub;eci to II

fine

0' nol "u 'hflln $2,500.

nor

mot, lhln $25.000 pef d.y 0' "''oJel'on,

Of

bv

emprisonmenl for not mota Ihln on. y•• r, or both..

Tht P«mln.. ,hili

I'\Ot

m.tll, -nv f.l.. U.Ilte1nenl

~.nLltion

or

c...-ttt~.riof1

in

any

.~ic.'IIon.

rKord. ,..port.

pla~

0'o~ doculTl+flt .ubmit1.ed to lhoe Ag.ncy or

the

US EPA.

or required 10

be

mainlau-d lIOder th"

P'ttTnit.

A.ny '\Jt.horization 10 conttrvct iuU4ld 10 the

permi'n..

purluanl 10 35 In, Adm

COde 3009 154 i, ....er.by iIl'eorpotet..-J by rafertnce .. a condition of I.... pennit

The Chlln W.IOr. Act proliid..

lhe.

any P"'f"Son who (alsifies. t.mpe.rs wilh. or

~no~.nglv

rend." tneccu,.tw .ny

fT'oOI\i,o.ino

de"",.

or

meth04 l'9IQuiAd

to be

mltnteinod undtr

~rmil

,h.H. upon.tOn.....ktion.

be

pvnisl'lad by • fin. 'of nol mora

In.n $10,000 pef

vioi.t~n.

ex

by impc-is.onmenl

10'

not more th.n 6 months poor

vloittton. ()( by both,

" en .pphcaM. t"na.ra

or

limit.tion

i,

promu'o.t~

vnder Sa<::hon 30HbH2HC)

o.id.IDI..

3()4(b)(21. or.307t.)121

Ind thol IHl\>ont ,""""td

Of );miIo..,. il

mono

.t:rinQent th.,; any eHIU8fl1 limitation tn the-

~it

or conlrola •

po....

unt nol

IWnittd

in

~he

parmiL lhe permit

.hatl