1. III. THE RECORD SUPPORTS GRANTING THE SITE SPECIFIC RULE
      2. IV. PROPOSED LANGUAGE
      3. v. CONCLUSION
      4. BROWN, HAY & STEPHENS, LLP
      5. 4.3 Southwest STP Effluent Mass Balance
      6. Environmental Effects of a Site Specific Water Quality Standard
      7. 5.1 Nature of Boron
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
PROPOSED SITE SPECIFIC RULE
)
APPLICABLE
TO THE CITY OF GALVA )
SEWAGE TREATMENT PLANTS
)
DISCHARGE
TO EDWARDS RIVER
)
AND MUD
RUN CREEK
)
35 ILL. ADM.
CODE 303.447 AND 303.448 )
R09-11
(Site Specific Rulemaking - Water)
NOTICE OF
FILING
TO:
Mr. John Therriault
Assistant Clerk
of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite
11-500
Chicago, Illinois 60601
(VIA
ELECTRONIC MAIL)
(SEE PERSONS ON ATTACHED LIST)
PLEASE TAKE NOTICE that I have today filed with the Office of Clerk of the Illinois
Pollution Control Board
GAL VA'S POST -HEARING COMMENTS and ADDENDUM TO
TESTIMONY OF STEPHEN M. BRUNER, copies of which are herewith served upon you.
Dated: April
30, 2009
BROWN, HAY
&
STEPHENS, LLP
Claire A. Manning
Registration No. 3124724
Alison
K.
Hayden
Registration No. 6291618
205 S. Fifth Street, Suite 700
P.O.
Box 2459
Springfield,
IL 62705
(217) 544-8491
Fax: (217) 241-3111
Respectfully submitted,
CITY OF GALVA, Petitioner,
By: /s/ Claire A. Manning
One of Its Attorneys
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #2 * * * * *
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
PROPOSED
SITE SPECIFIC RULE
APPLICABLE TO THE CITY OF GALVA
SEWAGE TREATMENT
PLANTS
DISCHARGE TO EDWARDS RIVER
)
)
)
)
)
)
AND MUD RUN CREEK
)
35 ILL. ADM. CODE 303.447 AND 303.448)
R09-11
(Site Specific Rulemaking - Water)
GALVA'S
POST-HEARING COMMENTS
NOW COMES the City of Galva ("Galva"), by and through its attorneys Brown, Hay
&
Stephens, LLP, and hereby provide the Illinois Pollution Control Board ("Board") with the
following post-hearing comments:
I.
PROCEDURAL HISTORY
On October 17, 2008, Galva filed a Petition for Site Specific Rule ("Petition") to apply to
Galva's effluent discharge with respect to boron distinct from the
1.0 mg/L water quality
standard for boron found at 35
IlL Adm. Code 302.208(g), developed by the Board in 1972 as a
"water quality" standard but not as an "effluent" standard.
See In the Matter of Effluent
Criteria,
R70-8;
In the Matter of Water Quality Standards Revisions,
R71-14;
In the Matter of
Water Quality Standards Revisions for Intrastate Waters (SWB-14),
R71-20, (consolidated),
Board
Opinion, March 7, 1972. The proposed Site Specific Rule would constitute an alternative
water quality standard applicable to the effluent discharge
of boron from Galva's two Sewage
Treatment
Plants ("STPs"). Galva also filed a Technical Support Document ("TSD") in support
of the Petition, Pre-filed Testimony of Dr. Brian Anderson, a Motion to Waive Requirement to
Submit
200 Signatures, and a Motion for Expedited Review.
1
On February 5, 2009, the Board issued its First Notice Opinion and Order accepting the
proposal for hearing and granting Petitioners' Motion to Waive Requirement to Submit
200
Signatures, but denying the Motion for Expedited Review. Nonetheless, the Board Opinion
accepted the Proposed Site Specific Rule for First Notice publication, without comment on the
proposal's merits.
See
Board Opinion, R09-11, Feb. 5,2009 and (March 6,2009). The proposed
rule appeared in the Illinois Register on March 6,
2009.
See
Ill. Reg. Vol. 33 Issue 10, p.2898
(March
6, 2009).
On
February 19, 2009, the Hearing Officer issued an Order scheduling a hearing for
March 31,
2009, at 10:00 a.m. in Galva ("Hearing") to fulfill the statutory obligations under
Section 27(b)
of the Environmental Protection Act (Act) (415 ILCS 5/27(b)(2006)).
On February 25, 2009, the Illinois Environmental Protection Agency ("Agency"), filed
the Pre-filed Testimony
of Brian Koch, toxicologist for the Division of Water Pollution Control.
In his testimony,
Mr. Koch discussed Galva's proposed site-specific rule and recommended "that
the Board grant relief from the water quality standard for boron as requested by the Petitioner."
He also stated that the "Illinois EPA believes that a chronic boron standard of 3.0 mg/L and
possibly significantly higher is appropriate."
See
Pre-filed Testimony of Brian Koch.
On March 16, 2009, Galva filed the Pre-filed Testimony of David L. Dyer and Stephen
M. Bruner, witnesses presented at the March 31,
2009 Hearing.
On March 31, 2009, the Hearing was conducted in Galva. David Dyer, Larry Lawson,
Stephen Bruner, Brian Anderson and Claire Manning appeared
as representatives of Galva and
Vera Hurst and Brain Koch appeared as representatives ofthe Agency. Updated information and
responses to technical questions presented at the Hearing and directed to Stephen Bruner are
filed simultaneously with this filing as
"Addendum to Testimony of Stephen Bruner".
2
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #2 * * * * *
On April 6, 2009, the Hearing Officer issued an Order setting the date for fmal comments
on the rulemaking proposal for April 30, 2009, and the Hearing Transcript and Exhibit list was
published.
II.
APPLICABLE STANDARD FOR THE PROMULGATION OF THE PROPOSED
SITE SPECIFIC RULE
Section 27 of the Illinois Environmental Protection Act ("Act") gives the Board the
authority
to adopt substantive regulations that "may make different provisions as required by
circumstances for different contaminant sources and different geographical areas ... " 415 ILCS
5/27(a). This section also provides the appropriate standard for promulgation
of new rules:
the Board shall take into account the existing physical conditions, the character
of
the area involved, including the character of surrounding land uses, zoning
classifications, the nature
of the existing air quality, or receiving body of water, as
the case may be, and the technical feasibility and economic reasonableness
of
measuring or reducing the particular type of pollution.
415 ILCS 5/27(a) (2006).
The Board has acknowledged the applicability
of this standard in previous cases
regarding site specific relief.
See In the Matter of Marathon Oil Co. 's Petition for Site-Specific
Rule Change to
35
Ill. Admin. Code 303.323,
R91-23, Board Opinion, Oct. 7, 1993. The Agency
and the
USEP A have also recognized that the Board may grant specific facilities permanent
relief from the general use water quality standards.
See LTV Steel Co.
v.
EPA,
R91-49, Board
Opinion, June 1, 1995. Therefore Galva urges the Board to approve the Site Specific Ru1e based
on the evidence presented in the record and consistent with the standards set forth
in Section
27(a)
of the Act.
III.
THE RECORD SUPPORTS GRANTING THE SITE SPECIFIC RULE
As explained more in detail as part of Galva's Petition and during the Hearing, Galva is
seeking a Site Specific Rule
to establish an alternative standard for discharge from Galva's two
3
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #1 * * * * *
Sewage Treatment Plants (STPs): the Northeast and Southwest STPs, which discharge into an
unnamed tributary
of the South Branch of the Edwards River and Mud Run Creek, respectively.
The general use water quality standard for boron in 1.0 mg/L and found at 35 Ill. Adm. Code
ยง302.208(g), and the Board has declined to establish an effluent standard for boron.
See In the
Matter
of" Effluent Criteria,
R70-8;
In the Matter of" Water Quality Standards Revisions,
R71-
14; In
the Matter o/Water Quality Standards Revisionsfor Intrastate Waters (SWB-14),
R71-20,
(consolidated), Board Opinion, March 7, 1972. Nonetheless, as explained at Hearing, where
discharge is not capable
of mixing with an existing water body ( as here), the Agency applies the
water quality standard as an effluent standard. Brian Koch
of the Agency verified the Agency
will apply a water quality standard as an effluent standard. Therefore, where. the discharge is
into a zero flow stream at this location, a mixing zone is not available because the STPs
discharge into zero-flow streams. As a result,
"the water quality standard of one milligram per
liter
of boron will have to be the effluent standard."
See
Hearing Transcript, p.31-32.
Accordingly, the Agency has applied the general use standard
as an effluent standard in Galva's
Southwest
STP NPDES Permit (No. IL0023647).
The reason for the Board's establishment of the 1.0 mg/L boron standard was to protect
crops.
Id.
The Galva STP receiving waters do not support irrigation. There are no federal water
regulations concerning boron.
As demonstrated
by water sampling results from the city's two municipal water supply
wells which were submitted to the Board as part of the TSD, boron is an element found naturally
in Galva's Municipal Water Supply.
See
TSD p.6. Galva's Municipal Water Supply ultimately
feeds into Galva's two STPs. The Southwest
STP NPDES Permit was amended, effective
4
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #1 * * * * *
f
August 4, 2004, to require sampling for boron as of September 1, 2007, and to require that its
effluent comply with a boron limitation
of 1.0 mg/L.
See
TSD Appendix B.
As set forth in the Petition and at the Hearing, Galva cannot meet the
1.0 mg/L boron
standard
as applied by the Agency. is a small, rural community, population 2,758, located in
south central Henry County.
See
Petition p. 4. Galva evaluated fhe costs of installing avaiiable
treatment and control options including ion exchange and reverse osmosis,
as well as the costs of
installing new wells or obtaining water from neighboring towns.
See
Petition p.14-23.
At the Hearing, the following witnesses presented testimony
in support of Galva's
petition: David Dyer, Stephen Bruner, Larry Lawson, and Brian Anderson. That testimony can
be summarized
as follows:
David Dyer. David Dyer is the city administrator for the City
of Galva. His pre-filed
testimony establishes that there are no other economically reasonable alternative
solutions for Galva, a small rural municipality,
to use to achieve compliance with the 1.0
mg/L boron standard applied as an effluent standard in the NPDES permit.
Stephen Bruner. Steve Bruner is the Licensed Professional Engineer and Licensed Land
Surveyor employed by Bruner, Cooper
&
Zuck, Inc. His testimony established that over
a three year monitoring period, boron levels were usually less than
2.0 mg/L.
See
Hearing Transcript, p.17. The two elevated results were due to drought conditions.
Id.
at
17-18. The numbers he used in the mass balance calculations were conservative and
based on actual plant flows rather than
7Q10 flows and did not take into account any
other dischargers.
Id.
at 21-23,28.
Larry Lawson. Larry Lawson has been the plant operator for the City
of Galva's STPs
since
1980 and has a bachelor's degree in chemistry and a master's degree in organic
5
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #1 * * * * *
chemistry from Iowa State.
ld.
at 25. His testimony established that Galva's STP flows
are typically higher than the
7QI0 flow numbers.
ld.
at 26. The 0.37 cfs minimum
average flow used
in the mass balance calculations correlates to the years that the boron
samples were collected,
2004-2006, and May of2008.
ld.
at 27-28.
Dr. Brian Anderson. Dr. Brian Anderson is the Director
of the Illinois Natural History
Survey and has a Ph.D. in biology. His pre-filed testimony establishes that a boron water
quality standard
of 1.0roglL is over-protective of aquatic life.
See
Pre-Filed Testimony of
Dr. Brian D. Anderson, p. 8. With respect to boron toxicity, citrus crops and fruit trees
are the more susceptible species, and there are none of concern in Illinois.
ld.
at 4. Dr.
Anderson also highlighted the fact that the U.S. Environmental Protection Agency does
not recommend the establishment
of any water quality standards for boron, not even a
drinking water standard.
ld.
at 7.
Mr. Brian Koch, Water Quality Standards toxicologist from the Division of Water
Pollution Control, testified on behalf of the Agency. Mr. Koch agreed that Galva's Site Specific
Rule should be granted for the following reasons. First, the Agency agrees that "the expenses
and technical infeasibilities
of the assessed alternatives are unreasonable, especially when
considering the unanticipated risks associated with the proposed site-specific boron standard of
3.0 mg/L." See
Pre-filed Testimony of Brian Koch. Second, the Agency is not aware of any
irrigation being provided through the use of the waters associated with this rulemaking, and the
original establishment
of the 1.0mgIL standard was to protect crops from boron in irrigation
water.
ld.
Finally, based on currently available acute and chronic toxicity data, the Agency
believes that a chronic boron standard
of 3. OmglL
and
possibly significantly higher
is
6
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #2 * * * * *
appropriate.
fd.
(Emphasis added). As a result, Mr. Koch and the Agency recommend that the
Board grant relief from the water quality standard for boron
as requested.
fd.
Galva has worked closely with the Agency over the past few years to address the boron
issue
in Galva, and the Agency recommended pursuing this site-specific relief. Galva has
demonstrated through the record
in this proceeding that alternatives to the proposed Site Specific
Rule would be technically infeasible and economically unreasonable. The testimony, and record
as a whole, demonstrate that the proposed Site Specific Rule will not result
in
any environmental
harm and that the prohibitive costs associated with each
of these measures for such a small town
render technical enhancements to reduce the discharge to
1.0 mg/L as inherently economically
unreasonable and environmentally unnecessary.
Thus, site specific relief from Section
302.208(g) is proper.
Subsequent
to the Hearing, and in response to questions of the Board, the Addendum
Testimony
of Stephen M. Bruner ("Addendum") has been prepared and is submitted with this
filing. The Addendum addresses four specific questions.
1. A typographical error
in
the TSD where the concentration of boron was
incorrect and did not match up with that listed
in
Figure 12 of the TSD was
corrected.
It
includes a line which was also inadvertently omitted from the
text
ofthe TSD, so that it corresponds to Figure 12 ofthe TSD.
2. Mr. Bruner clarified that the flow rates used in the mass balance calculations
are the
lowest
average monthly discharge values for July 2006 at the NE STP
rather than the average flow rates. As Mr. Bruner stated at the Hearing, he
used actual values from the
STPs rather than published 7Q10 flows.
7
3. Figure 12 was updated to correct the typographical error regarding the boron
concentration calculated near Mud Run's confluence with Walnut Creek.
4. Finally, subsequent to the Hearing Mr. Brian Koch provided Mr. Bruner
ambient water quality monitoring data from Indian Creek near Galva. This
data suggests that background boron concentrations in area receiving streams
during drought conditions (a worst case scenario) would be
0.140 mg/L,
whereas the
TSD assumed a background concentration of 0 mg/L.
An
additional discharger to Walnut Creek was also discovered subsequent to
Hearing. The Village of Altona's STP discharges into Walnut Creek prior to
its confluence with Mud Run Creek. Mr. Bruner used this background worst-
case scenario data and an additional
STP discharge of 3.0 mg/L from Altona
STP to re-calculate the final boron concentration at the point after Mud Run
Creek joins Walnut Creek to
be 0.5 mg/L, which is well below the 1.0 mg/L
water quality standard, and achieved at the confluence points originally
indicated
in
the TSD.
See
Addendum, p.2.
IV.
PROPOSED LANGUAGE
As discussed with the Agency, the Site Specific Rule proposed by Galva would read as
follows:
Section 303 .34X.
Unnamed Tributary of the South Branch Edwards
River and
South Branch Edwards River
The boron general use water quality standard
of 35 Ill. Adm. Code 302.208(g)
does not apply to the waters of the State that are located from the point of
discharge of the POTW located at 523 NE 9
th
Street in Galva, known as the Galva
Northeast Sewage Treatment Plant, to an unnamed tributary
of the South Branch
of the Edwards River, said point being located in Henry County, Township 14
North, Range 4 East, occupying portions
of Sections 21, 26, 27, 28, 33, 34, and 35
in the Fourth Principal Meridian, Latitude N 41.175ยฐ, Longitude: W 90.035ยฐ, to
8
the confluence of said unnamed tributary with the South Branch Edwards River;
to the confluence with the Edwards River. Boron levels in such waters must meet
a water quality standard for boron
of 3.0 mg/L.
Section 303.40X.
Mud Run Creek
The boron general use water quality standard
of 35 Ill. Adm. Code 302.208(g)
does not apply to the waters
of the State that are located from the point of
discharge of the POTW located
~
mile South of BNSF RR and SW 4th Street in
Galva, known as the Galva Southwest Sewage Treatment Plant, to Mud Run
Creek, said point being located
in Henry County, Township 14 North, Range 4
East
of the Fourth Principal Meridian occupying portions of Sections 21, 26, 27,
28, 33,
34, and 35, Latitude 41.154ยฐ, Longitude 90.053ยฐ, to the confluence of
Mud Run Creek with Walnut Creek. Boron levels in such waters must meet a
water quality standard for boron of3.0 mg/L.
v.
CONCLUSION
The record fully supports the requested site specific relief from the boron standard for
Galva. Galva has consulted with the Agency throughout the development
of this Petition, and
the Agency fully supports and recommends that
"the Board grant relief from the water quality
standard for
boron as requested by the Petitioner."
See
Pre-filed Testimony of Brian Koch,
Agency Toxicologist;
see also
Hearing Transcript, p.30. Although Galva does not agree that the
1.0 mg/L water quality standard is appropriately applied as an effluent standard in Galva's
NPDES permits, given the Agency's position on this point, Galva has deemed it most
expeditious to seek the necessary relief
in the nature of a site specific water quality rule, as the
Agency recommended.
The evidence
in the record has established that it is not technically feasible nor
economically reasonable for Galva, a small rural community, to meet the
1.0 mglL boron water
quality standard. Without this relief, Galva will be materially prejudiced, since an unachievable
and unnecessary permit condition will continue to
be present in its NPDES permit, causing it to
be
in violation of the Act for no legitimate environmental reason. Galva believes a 3.0 mg/L
9
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #2 * * * * *
boron standard is achievable, but conservative.
Should the Board detennine the record
demonstrates that a higher standard is warranted, obviously Galva would not object.
WHEREFORE, for the above-cited reasons, Galva respectfully requests that the Board
grant this Petition and adopt the proposed Site Specific Rule.
Dated: April
30, 2009
BROWN,
HAY
&
STEPHENS, LLP
Claire
A. Manning
Registration No. 3124724
Alison
K.
Hayden
Registration No. 6291618
205 S. Fifth Street, Suite 700
P.O. Box 2459
Springfield, IL 62705-2459
(217) 544-8491
10
Respectfully submitted,
CITY OF GALVA
Petitioner,
By: /s/ Claire A. Manning
One of its Attorneys
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #1 * * * * *
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
PROPOSED SITE SPECIFIC RULE
)
APPLICABLE TO THE CITY OF GALVA
)
R09-011
SEWAGE
TREATMENT PLANTS
)
(SITE SPECIFIC RULE MAKING - WATER)
DISCHARGE
TO EDWARDS RIVER
)
AND
MUD RUN CREEK
35 ILL. ADM. CODE 303.447 AND 303.448
)
ADDENDUM
TO TESTIMONY OF STEPHEN M. BRUNER
On March 31, 2009, I testified before the Illinois Pollution Control Board regarding the above cited
matter. This statement
is in clarification of, and in addition to, the testimony given by me on that date.
1.
On page 15 of the "Technical Support Document, Site Specific Water Quality Standard,
Galva,
Illinois", prepared by me, the last line of this page reads:
CBORON ADDED
=
0.94 mg/L
This line should in fact read:
CBORON ADDED =
1.19 mg/L
=
Boron concentration in South Branch
Edwards River just prior to confluence with Edwards River
The next line, which was omitted, should read:
After the confluence with the Edwards River, the calculated Boron concentration
would be:
CBORON = [0.37 cfs x 3.0 mg/l] / [0.93 cfs
+
0.25 cfs] = 0.94 mg/l
These values agree with the concentrations and flow rates shown on Figure
12 in the
Technical
Support Document.
Revised Document pages
15 and 16 are attached to this Statement..
2.
I was asked by the Board's Engineer about the discrepancy between the published
7QI0
flow rates at Galva's NE and SW STP's and the somewhat different flow rates used in the
Document's mass balance calculations. The values used
(0.37 cfs
@
NE STP and 0.015
cfs @ SW STP) are not the average STP flow rates, but in fact are the lowest average
monthly discharge values for July
2006 at the NE STP (paragraph 4.2, page 15) and
November,
2006 at the SW STP (paragraph 4.3, page 16).
Page 1 00
3.
Figure 12 was found to have a drafting error. Specifically, the note that reads:
Boron Concentration
= 0.03 mg/l
7QIO Flow = 0.015 cfs
near Mud Run's confluence with Walnut Creek should
in fact read:
Boron Concentration
= 1.5 mg/l
7QIO Flow = 0.03 cfs
A revised Figure
12 is attached to this Statement.
4.
The mass balance calculations contained in the Teclmical Support Document assume a
background boron concentration
of 0
mg/l
in the receiving waters prior to accepting the
discharges from the
NE and SW STP's. However, Mr. Brian Koch of the Illinois
Environmental Protection Agency has provided ambient water quality monitoring data
taken from Indian Creek near Galva, that suggests a worst case (during drought
conditions) background boron concentration in area receiving streams
of 0.140
mg/l.
A
copy
of this data is included with this statement.
In addition, it was discovered that the Village
of Altona STP discharges into Walnut
Creek prior to its confluence with Mud Run.. The
7Q10 flow at the Altona STP is 0.01
cfs. If the receiving streams (Mud Run and Walnut Creek) tributary to Galva's SW STP
are assumed to have a background boron concentration of 0.140
mg/l,
and Altona's STP
is assumed to have a maximum boron concentration of 3.0
mg/l,
the final boron
concentration after Mud Run joins Walnut Creek
(7Q10 flow = 0.20 cfs) may be
calculated thus:
CBORON
=
0.01 cfs (3.0
mg/l)
0.20 cfs
(Altona
STP)
+
0.015 cfs (3.0
mg/l)
0.20 cfs
(Galva
SW STP)
which is well below the standard of 1.0
mg/l.
+
0.175
cfs(0.14mg/l)
0.20 cfs
(Receiving
Stream)
0.5 mg/l
A similar calculation can be made at the point where the south Branch of the Edwards
Riverjoins the Edwards River:
CBORON
=
0.37 cfs (3.0
mg/l)
1.18 cfs
(Galva
NE STP)
+
0.81 cfs (0.14 mg/l)
1.18 cfs
(Receiving
Stream)
=
1.0 mg/l
This calculation indicates that a dilution to the water quality standard
of 1.0 mg/l of boron
occurs at this point north
of the NE STP.
Page
2 of3
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #2 * * * * *
It
should be noted that the background boron data provided may in fact be influenced by discharges from
area Sewage Treatment Plants. However, by using the
"worst case" value of 0.140 mg/l as a background
concentration
of boron, the above calculations suggest that dilution to a level of 1.0 mg/l and below is
achieved at the confluence points originally indicated in the Technical Support Document.
Respectfully submitted:
By
City
S~E~L's~
Engineer
Illinois Licensed Professional Engineer No.
40386
Page 3 00
From the data provided in Figure 6, the City of Galva would need permission to
discharge from their existing sewage treatment plants an effluent flow with a
concentration
of up to 3 mg/L of boron. This was the maximum recorded boron
concentration recorded since September
of 2004.
Stream flow data was collected using the 7 Day 10 Year Low Flow Map (7Q 1 0
Map) for the Spoon River Region published by the Illinois State Water Survey
(ISWS)
and the Illinois Streamflow Assessment Model available online from the
ISWS. The low flow stream discharges were assessed at the 7 day-l0 year low
flow event (7QI0).
Using the minimum average monthly discharge data from
the STPs from 2006
(Figure 7), and assuming that the maximum recorded boron concentration was to
occur during a low flow period, the extents of the necessary relief were calculated
using the below equation for each
of the sewage treatment plants.
CBORON ADDED
=
[QSTP
X
C
STP
] / [QSTP
+
QSTREAM]
Where:
CBORON ADDED
=
Final boron concentration in receiving stream (mg/L)
QSTP
=
Discharge from sewage treatment plant (cfs)
CSTP
=
Boron concentration in STP discharge (mg/L)
QSTREAM
=
Water flow in stream during Q710 conditions (cfs)
4.2
Northeast STP Effluent
Mass
Balance
The lowest average monthly discharge for the Northeast STP for 2006 was 0.37
cfs. This was the average discharge for the month of July 2006 (Figure 5).
During low flow periods (7QI0), the discharge from the Northeast
STP would
receive adequate dilution at the point where the South Branch
of the Edwards
River discharges and mixes with the Edwards River.
It
is at this point that the
boron concentration
in the stream would drop below 1 mg/L during 7QI0
conditions.
CBORO
N
ADDED = [QSTP
X
C
STP
] / [QSTP
+
QSTREAM]
CBORON ADDED
=
[0.37 cfs x 3.0 mg/L] / [0.93 cfs]
CBORON ADDED
=
1.19 mg/L
=
Boron concentration in South Branch Edwards River
just prior to confluence with Edwards River
- 15 -
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #2 * * * * *
After the confluence with the Edwards River, the calculated Boron concentration
would be:
CBORON
=
[0.37 cfs x 3.0 mg/l] / [0.93 cfs
+
0.25 cfs]
=
0.94 mg/l
Thus dilution would occur approximately 16.1 miles downstream
of the outfall of
the Northeast STP.
It
should be noted that this is a worst case scenario, and during normal stream
flow conditions, dilution would occur much closer to the discharge
of the
Northeast
STP.
Refer to Figure 12 for a map depicting the point of dilution for the Northeast STP.
4.3
Southwest STP Effluent Mass Balance
The lowest average monthly discharge for the Southwest STP for 2006 was 0.015
cfs. This was the average discharge for the month of November 2006 (Figure 5).
During low flow periods (7Q10), the effluent from the Southwest
STP would
receive adequate dilution at the point
just past where Mud Run discharges into
Walnut Creek. Again, it should be noted that this is a worst case scenario, during
normal conditions, dilution would occur closer to the discharge
of the Southwest
STP.
CBORON ADDED
=
[QSTP x CSTP] / [QSTP
+
QSTREAM]
CBORON ADDED
=
[0.015 cfs x 3.0 mg/L] / [0.20 cfs]
CBO
RON
ADDED = 0.225 mg/L
Thus dilution would occur approximately 7 miles from the outfall
of the
Southwest STP.
Refer to Figure 12 for a map showing the point
of dilution of the Southwest STP.
Detailed mass balance calculations for each of the sewage treatment plants may
be found in the appendix
of this report.
5.
Environmental Effects of a Site Specific Water Quality Standard
5.1
Nature of Boron
Boron is a naturally occurring element that is found in nature in compounds called
borates. Borates are found in the oceans, sedimentary rocks, coal, shale, and
some soils. Borates are naturally released into the environment from the oceans,
-
16 -
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #2 * * * * *
FIGURE 12
POINTS OF DILUTION
\
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #2 * * * * *
USGS 05568800 INDIRN CREEK NERR
~YOHINGI
Il
"'CI 100 + 00
c
o
C.)
G.)
~
"-
G.)
Q.
.,:.
G.)
G.)
c..-
C.)
-,"",
,.Q
::I
C.)
G.)
..
~
"-
ttl
.c
C.)
~
-,"",
c
)-
...J
H
a:
c
10+00
1+00.
0+50
Rpr 01
Hay 01
1994
1994
Jun 01
1994
-
Daily nean discharge
Jul 01
1994
-
Estinated daily nean discharge
Rug 01
1994
Sep 01
1994
Oct 01
1994
---Period of approved data
Organizatic Organizatic Primary St, Secondary Secondary Secondary Station Loc Station Loc Station Loc
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN
CRI UPPER MIS ILLINOIS RI'
211LAMB
ILLINOIS EP
5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB ILLINOIS EP 5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB ILLINOIS EP
5568800 DJL 01.
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB ILLINOIS EP 5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB ILLINOIS EP 5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB ILLINOIS EP 5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
211LAMB ILLINOIS EP 5568800 DJL 01
INDIAN CRI UPPER MIS ILLINOIS RI'
IZI
State
County
Latitude
Longitude Hydrologic
Legacy STO Surface
We
Ground
We
Pipe Indica
Illinois
Stark
41.01833
89.83528
7130005 /TYPA/AMI S
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
.41.01833
89.83528
7130005 /TYPA/AMI S
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005 /TYPA/AMI S
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005 /TYPA/AMI S
Illinois
Stark
41.01833
89.83528
7130005 /TYPA/AMI S
Illinois
Stark
41.01833
89.83528
7130005 /TYPA/AMI S
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005 /TYPA/ AM I S
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005 /TYPA/AMI S
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005 /TYPA/AMI S
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #2 * * * * *
Illinois
Stark
41.01833
89.83528
7130005/TVPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TVPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TVPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Illinois
Stark
41.01833
89.83528
7130005/TYPA/AMIS
Sample Coc Start Date
End Date
UMK
Composite Composite, Sample Del Start Time End Time
13158452
22-Jun-93
B
945
0
13158453
12-Aug-93
B
1030
0
13158456
9-Dec-93
B
1030
0
13158466
16-Mar-95
B
1130
0
13158468
20-Jun-95
B
1030
0
13158479
19-5ep-96
B
1030
0
13158488
25-Sep-97
B
1045
0
13158448
21-Jan-93
B
1015
0
13158457
l-Mar-94
B
1130
0
13158463
25-0ct-94
B
945
0
13158473
14-Feb-96
B
1200
0
13158480
22-0ct-96
B
1045
0
13158486
16-Jul-97
B
1030
0
13158490
3-Dec-97
B
945
0
13158496
27-Aug-98
B
1045
0
13158449
18-Feb-93
B
1000
0
13158476
14-May-96
B
1115
0
13158485
5-Jun-97
B
1030
0
13158489
22-0ct-97
B
1030
0
13158497
24-Sep-98
B
1045
0
13158450
30-Mar-93
B
1030
0
13158465
2-Feb-95
B
1130
0
13158470
13-Sep-95
B
1100
0
13158471
29-Sep-95
B
845
0
13158472
29-Nov-95
B
915
0
13158475
10-Apr-96
B
1045
0
13158478
31-Jul-96
B
1030
0
13158482
29-Jan-97
B
1200
0
13158487
4-Sep-97
B
1045
0
13158454
22-Sep-93
B
1045
0
13158483
27-Feb-97
B
1045
0
13158484
26-Mar-97
B
1015
0
13158492
26-Feb-98
B
1045
0
13158495
14-Jul-98
B
1130
0
13158451
13-May-93
B
1100
0
13158458
24-Mar-94
B
1045
0
13158460
6-Jul-94
B
930
0
13158467
16-May-95
B
1030
0
13158469
25-Jul-95
B
1000
0
13158474
14-Mar-96
B
1100
0
13158477
18-Jun-96
B
1130
0
13158493
2-Apr-98
B
1045
0
13158494
13-May-98
B
1030
0
13158498
10-Nov-98
B
1100
0
13158455
10-Nov-93
B
1030
0
13158461
31-Aug-94
B
1130
0
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #1 * * * * *
13158464
28-Dec-94
B
1115
0
13158491
27-Jan-98
B
1145
0
13158459
4-May-94
B
930
0
13158462
21-Sep-94
B
1030
0
13158481
10-Dec-96
B
1100
0
13158499
17-Dec-98
B
1115
0
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #1 * * * * *
Efluent Mo Replicate
1\
Pipe ID
Primary AcSecondary Parameter Parameter Result Value
Remark Co
1022 BORON, TC
10.00 K
1022 BORON, TC
28.00
1022 BORON,
TC
14.00
1022 BORON, TC
30.00
1022 BORON,
TC
24.00
1022 BORON,
TC
71.00
1022 BORON,
TC
49.00
1022 BORON,
TC
5.00 K
1022 BORON, TC
10.00 K
1022 BORON, TC
87.00
1022 BORON,
TC
64.00
1022 BORON,
TC
100.00
1022 BORON,
TC
54.00
1022 BORON,
TC
31.00
1022 BORON,
TC
72.00
1022 BORON,
TC
5.00
1022 BORON,
TC
49.00
1022 BORON, TC
39.00
1022 BORON,
TC
43.00
1022 BORON, TC
83.00
1022 BORON,
TC
10.00 K
1022 BORON, TC
39.00
1022 BORON,
TC
64.00
1022 BORON,
TC
71.00
1022 BORON, TC
33.00
1022 BORON,
TC
59.00
1022 BORON,
TC
51.00
1022 BORON,
TC
56.00
1022 BORON,
TC
44.00
1022 BORON, TC
10.00 K
1022 BORON, TC
26.00
1022 BORON,
TC
32.00
1022 BORON, TC
22.00
1022 BORON, TC
38.00
1022 BORON,
TC
10.00 K
1022 BORON, TC
10.00 K
1022 BORON, TC
21.00
1022 BORON, TC
50.00 K
1022 BORON, TC
46.00
1022 BORON, TC
51.00
1022 BORON, TC
27.00
1022 BORON,
TC
26.00
1022 BORON, TC
30.00
1022 BORON,
TC
38.00
1022 BORON, TC
17.00
1022 BORON, TC
110.00
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #1 * * * * *
1022 BORON, TC
41.00
1022 BORON,
TC
27.00
1022 BORON,
TC
10.00 K
1022 BORON, TC
140.00
1022 BORON,
TC
76.00
1022 BORON,
TC
31.00
Average=
42.00
Highest Summer Result = 140 ug/L
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #2 * * * * *
Composite Statistic Code
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that I have served the attached GALVA'S POST-
HEARING COMMENTS and ADDENDUM TO TESTIMONY OF STEPHEN M.
BRUNER, upon the following:
Mr. John Therriault
Assistant Clerk
of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite
11-500
Chicago, Illinois 60601
via electronic mail on April 30, 2009; and upon:
Bill Richardson, Chief Legal Counsel
Illinois Department
ofN atural Resources
One Natural Resources Way
Springfield,IL
62702-1271
Marie E. Tipsord
Hearing
Officer
James R. Thompson Center
100 W. Randolph, Suite .11-500
Chicago,IL 60601
Matt Dunn, Chief
Environmental Bureau
Office of the Attorney General
100 W. Randolph,
12th
Floor
Chicago,IL
60601
Vera
Herst
Assistant Counsel
Division
of Legal Counsel
Illinois Environmental Protection Agency
1021 N. Grand Avenue East
P.O. Box 19276
Springfie1d,IL 62794-9276
by depositing said documents in the United State Mail in Springfield, Illinois on April 30, 2009.
BROWN, HAY
&
STEPHENS, LLP
Claire A. Manning
Registration No. 3124724
Alison
K.
Hayden
Registration No. 6291618
205 S. Fifth Street, Suite 700
P.O.
Box 2459
Springfield, IL
62705
(217) 544-8491
Fax: (217) 241-3111
/s/ Claire
A.
Manning
Claire
A.
Manning
Electronic Filing - Received, Clerk's Office, May 1, 2009
* * * * * PC #1 * * * * *

Back to top