Exhibit E
Sanitary District of Decatur
Second
erim Report
0
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
June 18 , 2008
sanitary District
of
Decatur
5 01 DIPPER LANE - DECATUR, ILLINOIS 62522 .
217/422.6931 " FAX: 217/4238171
o tec
Attn.: Michael S. Garretson
Bureau of
'ýATater
Compl
No
P .O. Box 19276
Springfield, Illinois 62794-1
R e:
Dear Mr. Garretson:
Enclosed is the Interim Report reg
by Special Condition 1 8 of the S
c
c t of Decatur's NPDES
Perm
Please contact me at 422-6931 ext. 214 or at
tirnk
t.il.us
if you have any questions
Sanitary District of Decatur
Nickel and Zinc Limits
June 2008 Interim Report
The reissued NPDES permit for the Sanitary District of Decatur that became effective
July 1, 2007 contains new limits for nickel and zinc and a two-year compliance schedule
for meeting the limits. Special Condition 18 requires that an interim progress report be
submitted to Illinois EPA by July 1, 2008. A summary of information gathered and
activities since the January 1, 2008 report is provided below.
Plant Influent and Effluent Sampling
Nickel and zinc have been included in quarterly plant influent and effluent sampling for
many years. During 2007, effluent sampling frequency increased to twice weekly as part
of the translator study. Ongoing influent and effluent sampling for nickel and zinc is
planned to continue at a frequency of twice monthly. The District is investigating
purchase of an ICP instrument to perform metals analysis in-house.
An updated summary of influent and effluent values is shown below. Review of past
data shows that the plant discharge would not be able to consistently meet the expected
nickel limit calculated on a hardness of 359 mg/L (per 1/2/08 email from Scott Twait of
Illinois EPA). Recent zinc concentrations appear to be near the expected limit with a few
exceptions.
Influent and Effluent Nickel
0
0.01
0.02
0.03
0.04
0.05
0.06
0.07
1
9
9
8
2
0
0
1
2
0
0
3
2
0
0
6
2
0
0
7
2
0
0
7
2
0
0
7
2
0
0
7
2
0
0
7
2
0
0
7
2
0
0
8
2
0
0
8
Date
Concentration, mg/L
Influent
Effluent
Expected
Permit Limit
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Influent and Effluent Zinc
0
0.05
0.1
0.15
0.2
0.25
0.3
0.35
0.4
0.45
1998
2001
2003
2006
2007
2007
2007
2007
2007
2007
2008
2008
Sample Date
Concentration, mg/L
Influent
Effluent
Expected Permit
Limit (avg.)
Expected Permit
Limit (max.)
Industrial Source Sampling
Analyses for metals including nickel and zinc have been performed semi-annually as part
of the District’s industrial pretreatment program. Sampling of the major industries
(ADM and Tate & Lyle) has been increased to monthly and other industries discharging
metals are now sampled quarterly.
Receiving Stream Sampling
Upstream and downstream sampling at the locations described in the translator study will
be continued at a twice monthly frequency to provide a more complete picture of nickel
and zinc in the Sangamon River.
Chronic WET Testing
Chronic toxicity tests were conducted in July and September 2007. An additional chronic
toxicity test using EDTA to chelate metals in the samples was conducted in December
2007. The EDTA treated tests showed more chronic toxicity than the untreated effluent,
which the laboratory attributed to the possibility that EDTA itself was causing toxicity.
No additional toxicity testing is currently planned.
Industrial Source Investigations
Tentative pretreatment local limits have been calculated based on the expected permit
limits for nickel and zinc. The District’s two major industrial users have been made
aware of the tentative limits and several meetings have been held with each to review
treatment options. Both industries utilize zinc as part of their cooling tower treatment
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
programs, and sampling has not identified any other significant zinc sources at the two
facilities. Each of the industries has been consulting with their cooling tower treatment
supplier, and both expect to be able to achieve the tentative pretreatment limit through
reduced zinc usage and better control of cooling tower operation. Both also have the
option of switching to either a phosphate or a silicate-based treatment program in the
event that zinc control alone is not sufficient.
ADM is the only significant industrial source of nickel, which is used as a catalyst in
hydrogenation processes. Two potential changes to reduce nickel discharges are being
investigated. In one area, improved housekeeping procedures are being implemented to
prevent nickel from entering the wastewater stream. The improved housekeeping will be
followed with testing to determine success. In the second area, dissolved nickel is
proposed to be recovered using a combination of ion exchange to concentrate the nickel,
followed by an electroplating process for removal. While both processes are relatively
common, ADM reports that they have not been used together in this application. They
still anticipate a reasonable probability of success and are currently beginning bench
testing.
Several other industrial users would also be impacted by reduced pretreatment limits for
nickel and zinc. While their concentrations are a concern, they discharge a very small
volume of wastewater relative to the two large users and have an insignificant impact on
concentrations in the plant influent. Use of mass rather than concentration pretreatment
limits is being considered for these small users.
Compliance Plan
Based on current information, the measures necessary to comply with final nickel and
zinc limitations will include a combination of the following:
1. Continued effluent and stream monitoring to determine whether further
adjustment of NPDES permit limits may be justified.
2. Finalization of local pretreatment limits for nickel and zinc, and ongoing
discussions with industrial users to verify that they will be able to meet the limits
by the compliance deadline of July 1, 2009.
3. Ongoing review and analysis of technical information that would be needed to
support a site-specific water quality standard.
The next interim report will be submitted by January 1, 2009 as required by our NPDES
permit.
Exhibit F
itary District
of Decatur
Third Interim Report
December 29,
2008
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Sanita
5 01 DIPPER LANE " DECATUR, ILLINOIS 62522 . 2171422-6931 "
FAX: 2171423.8171
D
ecember
2
al Protection Agency
Attn.: Michael S. Garretson
Bureau of Water Compliance Assurance Section,
MC
#19
1021 North Grand Avenue East
P .O. B ox 19276
4 -9276
Re: NPDES Permit IL0028321
erim Report
Dear Mr.
Garretson:
regarding compliance with nickel
and zinc limits required
by Special Condition 18 of the Sanitary District of Decatur's NPDES Permit.
Sincerely,
Timothy R.
Technical Director
cc: Bob Mosher, DWPC Standards
Rick Pinneo, DWPC Permits
J oe Koro kowski, Champaign Region
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Sanitary District of Decatur
Nickel and Zinc Limits
December 2008 Interim Report
The reissued NPDES permit for the Sanitary District of Decatur that became effective
July 1, 2007 contains new limits for nickel and zinc and a two-year compliance schedule
for meeting the limits. Special Condition 18 requires that an interim progress report be
submitted to Illinois EPA by January 1, 2009. A summary of information gathered and
activities since the July 1, 2008 report is provided below.
Plant Influent and Effluent Sampling
Nickel and zinc have been included in quarterly plant influent and effluent sampling for
many years. During 2007, effluent sampling frequency increased to twice weekly as part
of the translator study. Ongoing influent and effluent sampling for nickel and zinc is
planned to continue at a frequency of twice monthly. The District will begin performing
metals analysis in-house in early 2009.
An updated summary of influent and effluent values is shown below. Review of past
data shows that the plant discharge would not be able to consistently meet the expected
nickel limit calculated on a hardness of 359 mg/L (per 1/2/08 email from Scott Twait of
Illinois EPA). Recent zinc concentrations appear to be below the expected limit.
Influent and Effluent Nickel
0
0.01
0.02
0.03
0.04
0.05
0.06
0.07
0.08
0.09
19
98
20
02
20
06
20
07
20
07
20
07
20
07
20
08
20
08
Date
Concentration, mg/L
Influent
Effluent
Expected
Permit Limit
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Influent and Effluent Zinc
0
0.05
0.1
0.15
0.2
0.25
0.3
0.35
0.4
0.45
1998
2002
2005
2007
2007
2007
2007
2007
2008
2008
Sample Date
Concentration, mg/L
Influent
Effluent
Expected Permit
Limit (avg.)
Expected Permit
Limit (max.)
Industrial Source Sampling
Analyses for metals including nickel and zinc have been performed semi-annually as part
of the District’s industrial pretreatment program. Sampling of the major industries
(ADM and Tate & Lyle) has been increased to monthly and other industries discharging
metals are now sampled quarterly.
Receiving Stream Sampling
Upstream and downstream sampling at the locations described in the translator study will
be continued at a twice monthly frequency to provide a more complete picture of nickel
and zinc in the Sangamon River.
Chronic WET Testing
Chronic toxicity tests were conducted in July and September 2007. An additional chronic
toxicity test using EDTA to chelate metals in the samples was conducted in December
2007. The EDTA treated tests showed more chronic toxicity than the untreated effluent,
which the laboratory attributed to the possibility that EDTA itself was causing toxicity.
Results of the toxicity testing have been reviewed by Illinois EPA personnel.
Industrial Source Investigations
Tentative pretreatment local limits have been calculated based on the expected permit
limits for nickel and zinc. The District’s two major industrial users have been made
aware of the tentative limits. During 2008, three formal meetings have been held with
ADM personnel and one with Tate & Lyle; inspections and other contacts with each
during the year also oncluded discussion of nickel and zinc issues. Both industries
formerly utilized zinc as part of their cooling tower treatment programs, and both have
eliminated or greatly reduced zinc in their towers. At this time, both industries are
meeting the expected zinc pretreatment limit. ADM is continuing to ivestigate the
possible impact of the zinc limit on their planned wasting of solids from the pretreatment
system to the District.
ADM is by far the most significant industrial source of nickel. While it is primarily used
as a catalyst in hydrogenation processes, investigations have found that even very small
amounts that exist in other plant waste streams become important when pretreatment
limits are very low. Incoming grain and sodium hydroxide used in the plant contain
small but significant amounts of nickel. Production swings and changes in product mix
present sampling challenges. A summary of ADM’s investigations and findings to date is
attached. A meeting with ADM early in January 2009 is planned to further review their
investigations and plans for compliance.
Several other industrial users would also be impacted by reduced pretreatment limits for
nickel and zinc. While their concentrations are a concern, they discharge a very small
volume of wastewater relative to the two large users and have an insignificant impact on
concentrations in the plant influent. Use of mass rather than concentration pretreatment
limits is being considered for these small users.
Water Quality Standard Investigations
The year 2008 was unusually wet, and did not present the opportunity to gather additional
data related to a translator for nickel and zinc under critical low flow conditions.
Following consultation with Illinois EPA, the District is continuing to investigate
approaches to a water quality standard adjustment including the biotic ligand model and
the water effect ratio approach. An initial contact has been made with a consultant that
seems to be very familiar with these approaches, and information is being gathered to
evaluate their possible application. In addition, the District has begun to consider what
information might be needed to justify a standard based on a different level of water
quality protection, as allowed for by state and federal regulations.
Compliance Plan
During the next reporting period, the District will continue to work toward compliance
with final nickel and zinc limitations by means of the following activities:
1. Request a modification of the District’s NPDES permit extending the compliance
schedule for meeting the nickel and zinc limits. In spite of ongoing investigations
by the District and ADM, it appears that the current nickel limit cannot be
achieved without changes to treatment processes, operations (in particular,
operations at industrial users), a site-specific adjustment of the water quality
standard, or some combination of these three actions.
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
2. Continued effluent and stream monitoring to determine whether further
adjustment of NPDES permit limits may be justified.
3. Finalization of local pretreatment limits for nickel and zinc, and ongoing
discussions with industrial users regarding pollution prevention or control
measures to enable reductions of nickel and zinc.
4. Ongoing review and analysis of technical information that would be needed to
support a site-specific water quality standard. This information includes both
biological and toxicity data related to the standard, and economic data that would
also be required for a legal proceeding.
The next report will be submitted by July 1, 2009 as required by our NPDES permit.
CURRENT ADM DECATUR COMPLEX BALANCE - 11/2008
Lbs / day
MGD
ppm Ni
lbs Ni / day ppm Zn lbs Zn / day % of Ni from Grain
Ni from Grain, Lbs / day
ALL Water into Complex
18.5
0
0
50% Sodium Hydroxide
215,000
1.7
0.4
ALL Grains into Complex
36,500,000
57
1300
Corn Plant
5.1
0.040
1.70
0.40
16.9
50%
0.85
East Plant
2.5
0.20
4.15
0.80
16.6
100%
4.15
Biochem
1.65
0.030
0.41
0.30
4.1
100%
0.41
West Plant
0.9
0.090
0.67
0.40
3.0
0%
0
TOTAL to ADM WWTP
6.9
40.6
5.4
Clarifier Carryover - Bugs
35,000
100
3.5
800
28.0
Effluent, Soluble Portion
9.3
0.091
7.0
0.11
8.5
C. Twr Blowdown Residual
2.7
0.020
0.45
0.15
3.4
FINAL EFFLUENT to SDD
35,000
12.0
0.11
11.0
0.40
39.8
SDD Avg Limit (Proposed)
0.0365
3.588
0.352
34.605
These numbers represent our best estimates of the current balance however these numbers may not take into account various factors inlcuding:
Storm Water
Future Soy Expansion
Glycol Plant Start-up (Ni Catalyst)
50% NaOH contains nickel & Soda Ash availability
Complex Variability:
Future In-plant Water Re-use efforts, reduced Effluent flow
--- Fructose Production swings
--- New Ion Exchange product, Feb09
--- Changes in IX / Non-IX balance
IN
TO ADM WWTP
EFFLUENT
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
A
ppm Nickel
ppm Zinc
Lbs Dry
Lbs
Lbs
Dry Basis
Dry Basis
Bushels / day
Grain / day
Nickel / day
Zinc / day
Corn:
0.53
32
550,000
26,026,000
14
833
Soybeans:
4.1
46
200,000
10,440,000
43
480
TOTAL with GRAIN
36,466,000
57
1,313
Effluent, Lbs / day Max @ 12 MGD
3.6
34.6
Additional Nickel & Zinc Sources:
-- Nickel Catalysts used at Corn and West Plants.
-- Residual nickel & zinc at Corn Plant Towers, residual zinc at Bio Products Towers.
SOURCES
B
Co-gen:
Boiler Blowdown
RO Reject water
IX Waste Neutralization
#6 Cooling Tower
East Plant:
Refinery (low salt)
Biochem:
Bio Condensate (low salt)
Cooling Tower Blowdowns
Corn Plant:
Mill Hotwell condensate
Feed Scrubber discharge
Waste Heat condensate
Alcohol waste
Cooling Tower Blowdowns
West Plant:
Greasy Tower
Split Box
Car Washer (?)
Bean & Germ Plant Split Boxes
SFI
THESE STREAMS ARE OK
C
Co-gen:
None
East Plant:
8" & 12" Isolate (high salt)
0.2 to 0.3 ppm Ni and 1 ppm Zn.
Biochem:
Biochem Waste (high salt)
Nickel at 0.02 - 0.04ppm. Zinc in 0.3 - 0.6 ppm range.
Corn Plant:
Refinery Fructose & Sorbitol IX regen waste
High Ni and Zn, varies with batch IX operation
Average Ni is 0.15ppm and zinc is 0.14 ppm
West Plant:
24 hour composite at Corn Plant
1st DAF, 2nd DAF and Primary Skimmer
Periods of high Ni and Zn.
Periods of high nickel.
Packaging Plant
SSL waste
Zinc excursions > 1ppm.
Zinc excursions > 1ppm.
Vitamin E
Storm Water
Nickel as high as 0.2 ppm.
Nickel excursions > 0.1ppm.
STREAMS that have shown HIGH LEVELS
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
D
Nickel & Zinc Chronology
2006-2007
●►
Investigated nickel recovery by electroplating…cost savings.
Jan-08
●►
New SDD specs on nickel and zinc: 0.17 to 0.037ppm Ni and 0.45ppm Zn.
●►
Effluent was 0.06 to 0.10 ppm Ni at that time.
●►
Nickel found in West Plant stream & CP Cooling Towers.
Mar - Apr 2008
●►
Hired nickel consultant at Corn Plant.
●►
Ran West Plant High Salt trial.
May-08
●►
Met with SDD representatives.
●►
Began sampling program throughout Corn Plant & Sewer Plant.
●►
Ceased all zinc addition to Cooling Towers.
●►
West Plant in-process sampling began.
●►
Identified zinc analysis issues.
June - July 2008
●►
Opened dialog with nickel catalyst supplier.
●►
Nickel precipitation problems surfaced…nickel-gluconate complex.
●►
Hydrogenation pH looked at again.
●►
SDD changed testing basis.
Aug-08
●►
Widened scope of sampling.
●►
Began sharing samples with EPA lab.
●►
Streams of interest confirmed by EPA lab.
●►
Pursuing nickel-gluconate oxidation.
●►
Sought participation by ADM Research & GE Betz
Sept - Nov 2008
●►
Turned Complex-wide sampling over to individual plants.
●►
Each plant responsible for determining reduction methods.
●►
Determined degree of Sludge nickel and zinc levels.
●►
Learned of lower nickel limit…3.7 lbs / day to 2.3 lbs / day.
●►
Began calculations on effect of Sludge wasting on effluent nickel & zinc.
●►
Ran bench and plant trials on nickel removal methods at Corn Plant.
●►
Determined approx % reduction necessary at each plant to reach nickel limit.
●►
Chemistry change on #4 Tower lowered zinc ppm to <0.5 ppm.
E
●►
Incoming Water (SWTP, NWTP and Well Water) not an issue.
●►
Zinc analysis had issues through mid-summer 2008.
●►
ADM ICP method will under-report nickel vs. EPA lab --- use multiplier.
●►
Both nickel & zinc will bleed from Cooling Tower systems.
●►
Streams with significant zinc-containing suspended solids are very difficult to filter.
●►
Nickel reclamation via electroplating has many issues in facilities of our kind.
Chelating IX resins are not food grade. Expect high Acid / Base usage for any IX system.
Nickel will precipitate at ~9.5 - 10.5 pH if it is not complexed with organic material.
Organic matter can be oxidized with ozone and H2O2 to allow nickel precipitation. Very high ozone usage.
●►
In some plants, there are intermittent processes & discharges which complicate discovery of sources.
●►
Short-term, select streams can be sent to a Co-product, given FDA and quality compliance.
●►
Zinc can be brought under the limit by wasting sludge by removal from the effluent.
Clarifier operation will be critical and may require additional drying equipment with signficant capital expenditure.
●►
If all Corn Plant acid IX waste is treated, approx 2.5MM lbs of 35% HCl per month must be raised to 10pH.
●►
Soy-based operation will need to find a feed / fertilizer outlet to reduce nickel & zinc.
●►
Oil refining operation believes that moving the entire catalyst handling system may significantly reduce nickel.
Electronic
REDUCING
Filing -
NICKEL
Received,
&
Clerk's
ZINC
Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
F
1.2
MGD
0.03
MGD
2.0
MGD
0.6
MGD
0.9
MGD
1.25
MGD
0.4
MGD
MGD
0.35
MGD
1.6
MGD
MGD
0.5
MGD
POND OVERFLOW
ZEEWEED REJECT
1.3
MGD
0.35
MGD
0.1
MGD
2.2
MGD
0.1
MGD
11.5
MGD
0.65
MGD
0.15
MGD
0.5
MGD
TO LOW SALT
BIOCHEM #4 / #5 TOWER BD
CO-GEN NEUT TO CITY
POTABLE AS SANITARY
POLYOL
EAST COMPLEX STORM WTR
BIOCHEM WASTE
BIOCHEM STORM WATER
CORN PLT COOLING TOWER BD
WEST PLT STORM WATER
CO-GEN NEUT WATER
CORN PLANT
TOWERS
FRONT PUMP
STATION
DAMON PUMP
STATION
DECATUR SANITARY DISTRICT
CO-GEN #6 TOWER BD
CORN PLT ALCOHOL
2008
BASIC WASTE WATER TREATMENT LAYOUT
CORN PLT MILL COND
LOW SALT
ANAEROBIC &
AEROBIC
TREATMENT
HIGH SALT
ANAEROBIC &
AEROBIC
TREATMENT
BIOCHEM CONDENSATE
POND &
ZEEWEED
CORN PLT WASTE HEAT
CORN PLT FEED HOUSE
WEST PLANT + VITAMIN E
CORN PLT REFINERY
EAST PLANT REFINERY
EAST PLT 8" & 12" ISOLATE
TRUCK WASH
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Exhibit
G
Sanitary
ary
of Sample Data
Presented to
Illinois
EPA on October 30,
2007
SDD Nickel & Zinc Limits
Influent and Effluent Nickel
0
0.01
0.02
0.03
0.04
0.05
0.06
1
9
9
8
2
0
0
1
2
0
0
3
2
0
0
5
2
0
0
7
2
0
0
7
2
0
0
7
2
0
0
7
2
0
0
7
2
0
0
7
2
0
0
7
Sample Date
Concentration, mg/L
Influent
Effluent
Permit Limit
Influent and Effluent Zinc
0
0.05
0.1
0.15
0.2
0.25
0.3
0.35
0.4
0.45
1998
2001
2003
2006
2007
2007
2007
2007
2007
2007
Sample Date
Concentration, mg/L
Influent
Effluent
Permit Limit (avg.)
Permit Limit (max.)
“Domestic” wastewater concentrations
Nickel – below detection limit
Zinc – approximately 0.066 mg/L
Drinking water supply concentrations
Nickel – below detection limit
Zinc – approximately 0.011 mg/L
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Major Industries Nickel
0.000
0.020
0.040
0.060
0.080
0.100
F
irst
h
al
f
1
99
9
March 2000
April 200
1
March 20
0
2
M
a
y
2
0
03
Ap
ri
l
2
004
March 2005
January 2006
Jan
u
ary
2
00
7
Sample Date
Nickel, mg/L
ADM Point A
ADM Point D
T&L Point A
T&L Point C
Permit Limit
(ADM permit limit for Ni is 0.17 mg/L)
Major Industries Zinc
0.000
0.200
0.400
0.600
0.800
1.000
Fir
st
ha
l
f
199
9
March 2
0
0
0
April 2001
March 2002
May 2003
April 2004
March 2005
January 2006
January
2
0
0
7
Sample Date
Zinc, mg/L
ADM Pt. A
ADM Pt. D
T&L Pt. A
T&L Pt. C
Permit Limit
Ongoing information gathering
Influent, effluent, stream sampling
Industrial and domestic wastewater sampling
Chronic toxicity testing
EIU stream biosurveys
Calculation options
Translator study
Hardness
Biotic ligand model
Questions
Other dischargers affected?
Any federal updates on Ni and Zn criteria scheduled?
Relief options potentially available – site-specific standards, use designation?
Others? Which could IEPA support?
Other information needed?
Five day/week monitoring?
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Exhibit
Public Notice / Fact Sheet of
Draft Modified NPDES Permit for the Sanitary District
of
Decatur
Posted
on Illinois EPA's Website on May S, 2009
NPDES Permit No. IL0028321
Notice No. REP:06120503.bah
Public Notice Beginning Date: May 7, 2009
Public Notice Ending Date: June 8, 2009
National Pollutant Discharge Elimination System (NPDES)
Permit Program
PUBLIC
NOTICE/FACT SHEET
of
Draft Modified NPDES Permit to Discharge into Waters of the State
Public Notice/Fact
Sheet Issued By:
Illinois EPA
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:
S anitary District of Decatur
Sanitary District o
501 Dipper Lane
501 Dipper Lane
Decatur,
Illinois 62522
Decatur, Illinois
(Macon County)
i lity:
T he Illinois Environmental Protection Agency (IEPA) 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. All comments on the draft Permit and requests
for hearing must be received
by the
IEPA
by U.S. Mail, carrier mail or hand delivered by the Public Notice Ending Date. Interested
rsons are invited to submit written comments
on the draft
Permit
to the
IEPA
at the above address. Commentors shall provide his or
nd
address and the nature of the issues proposed to be raised and the evidence proposed to be presented with regards to
issues.
Commentors may include a request for public hearing. Persons submitting comments and/or requests for public hearing
a lso
send
a
copy of such comments or requests to the Permit applicant. The NPDES Permit and notice numbers must appear on
m ent 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 9:30 a.m. and 3:30 p.m. Monday
through Friday
when scheduled by the interested person.
If written comments or requests indicates 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
Richard E. Pinneo
at 217/782-0610.
The following water quality
and effluent standards and limitations were applied to the discharge:
Title 35: Environmental Protection, Subtitle C: Water Pollution, Chapter I: Pollution Control Board and the Clean Water Act were
applied in determining the applicable standards, limitations and conditions contained in the draft Permit.
The applicant is engaged in treating domestic and industrial wastewater for the City of Decatur and the Villages of Forsyth
and Mt.
Zion.
The length of the Permit is approximately 3 years.
The main
discharge number is 001. The seven day once in ten year low flow (7Q10) of the receiving stream, Sangamon River, is 0 cfs.
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Public Notice/Fact Sheet -- Page 2 -- NPDES Permit No. IL0028321
The design average flow (DAF) for the facility is 41.0 million gallons per day (MGD) and the design maximum
flow (DMF) for the facility is
125.0 MGD. Treatment consists of screening, grit removal, primary clarification,
two-stage activated sludge, secondary clarification,
disinfection, discharge to surface water, anaerobic digestion, flotation
thickening, land application of sludge.
This treatment works has an approved pretreatment
program. There are 16 noncategorical SIUs and 7 CIUs.
This modified NPDES Permit
does not increase the facility's DAF, DMF, concentration limits, and/or load limits.
The following modifications are proposed:
1. Extend the existing compliance schedule for nickel and zinc from two years to
three years. This extension is necessary because
work performed to date has not allowed achievement of numeric limitations for nickel
or zinc. Work performed includes a translator
study, source investigation and source elimination or reduction including change
of cooling water additives containing zinc,
housekeeping practices, pH addition and other investigations. The
additional time will be used to investigate other treatment
techniques that would include electro-coagulation
and methods to break the glutin nickel chealating bond.
2.
3.
4.
To place outfall 006 back in
the permit since it was inadvertently removed.
To add seven (7)
existing stormwater discharges to the permit and place stormwater requirements as
a Speci
Removal of Special Condition 8 because a reasonable potential to exceed analysis was performed
showing no potential existed to
exceed water quality
standards for fluoride and dichlorobromomethane.
5 . To change nic
A pplication i
d zinc
d ischarge point, receivi
based on the metals translator.
discharge(s) which is (are) located in Macon County, Illinois. The
following information iden
nd stream classifications:
ies the
Biological Stream
Characterization
0 07 & A07
U nnamed tributary I 39E
52' 12" North ( 88E 57'55" West (
General Use
I
Not Rated
of Spring Creek
The permit authorizes the discharge of stormwater at six locations and stormwater and groundwater at one location.
Stormwater and
groundwater discharges are directed to the Sangamon River, tributaries of the Sangamon River, Stevens Creek or
tributaries of Stevens
Creek.
This permit authorizes discharge from 5 CSOs in accordance with 35 Ill. Adm. Code
306.305 and PCB Order AS 91-7, dated June 23,
1992 into the following waters:
Sangamon River, Unnamed tributary of Spring
Creek and Stevens Creek.
CSO controls consist of first flush storage and pri
flow).
nt utilizing vortex separators (for up to 10 times the average
dry weather
you further in identifying the location of the discharge(s) please see the attached map.
Public Notice/Fact
Sheet --
Page
3 --
NPDES Permit No. IL0028321
The stream segment(s) receiving the discharge from out¬all(s) 001, 002, 003, A03, 004, A04, 008 and A08 is (are)
on the 303 (d) list of
impaired waters.
The following parameters have
been
identified as the pollutants causing impairment:
Potential Causes
Designated Use Impairments
Manganese, nitrogen (total), dissolved
oxygen, PCBs and fecal coliform
Aquatic Life, Fish Consumption, Primary Contact Recreation
The
stream segment receiving the discharge from outfalls 007 and A07 is not on the 303(d) list o¬ impaired streams.
The stream segment receiving the discharge from outfall A06 is on the 303(4) list of impaired streams.
Potential Causes
Methoxychlor
Monthly
Average
The
discharge(s) from the facility is (are) proposed to be men
Discharge Number(s) and Name(s): 001 STP Outfall
ed and limited at all times as follows:
Load limits computed based on a design average flow (DAF) of 41.0 MGD (design maximum flow (DMF) of 125.0 MGD).
The effluent of the above discharge(s) shall be monitored and limited at all times as follows:
LOAD LIMITS Ibs/day*
DAF (DMF)
Parameter
CBOD$
S uspended Solids
Dissolved Oxygen
pH
Fecal Coliform
Chlorine Residual
Ammonia Nitrogen:
March-May/Sept.-O
ct.
June-August
Nov.-Feb.
Zinc
6,839
(20,850)
8,549
(26,063)
Designated
Use
Impairments
Aquatic Life
Weekly
Average
13.678
(41,700)
1 5,387
(46,913)
Shall not
be less than 6 mg/L
S hall be in the range of 6 to 9 Standard Units
CONCENTRATION
LIMITS mq/L
M onthly
Average
20
2 5
W eekly
Average
40
0 .05
Regulation
3 5 IAC 304.120 40
CFR 133.102
D
aily
Maximum
shall
not
exceed
400
per
100
mL
(May
through October)
513 (1,564)
445 (1,355)
513 (1,564)
26(78)
1,026 (3,128)
1,026 (3,128)
1,026 (3,128)
142 (434)
1.5
1.3
1.5
0 .075
45
3.0
3.0
3.0
0.416
35
IAC
304.120 40
CFR 133.102
35 IAC 302.206
3 5 IAC 304.125
3 5 IAC 304.121
35 IAC 302.208
35 IAC 355 and
35 IAC 302
35 IAC 302.208(e)
Nickel
1
5.1 (16)
1
1
1 0.015 1
1
1351AC
302.208(e)
*Load Limits are calculated by using the formula: 8.34 x (Design Average and/or Maximum Flow in MGD) x (Applicable Concentration in
mg/L).
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Public Notice/Fact Sheet -- Page 4 -- NPDES Permit No.
IL0028321
This Permit contains an authorization to treat and discharge excess flow as follows:
Discharge Numbers) and Name(s): 003 Oakland Avenue
Treated Combined Sewage Outfall
004 South Edward
Street Treated Combined Sewage Outfall
007 McKinley Avenue Treated Combined Sewage Outfall
008 Seventh Ward Treated Combined Sewage Outfall
CONCENTRATION
LIMITS mq/L
Parameter
BOD5
S uspended
Solids
Monthly Average
Shall be in the range of
6 to 9 Standard Units
This draft Permit also contains the following requirements as special conditions:
Reopening of this Permit to include different final effluent limitations.
2.
Operation of the facility by or under the supervision
of a certified operator.
Regulation
40 CFR 133.102
40 CFR 133.102
35 IAC 304.125
Submission of the operational data
in a specified form and at a required frequency at any time during the effective
term of this
Permit.
More frequent monitoring requirement
without Public Notice in the event of operational, maintenance or other problems
resulting in
possible effluent deterioration.
Prohibition
against causing or contributing to violati
Effluent sampling point location.
Seasonal fecal coliform I
The Permittee implements
and administers an industri
10. Submission of annual fiscal data.
11
q uality standards.
ment program pursuant to 40 CFR 3403.
1 2. Conditional authorization to discharge from high level
emergency bypasses) based on 40 CFR.
13. Submission of semi annual reports
indicating the quantities of sludge generated and disposed.
14. An
authorization of combined sewer and treatment plant discharges.
for biomonitoring of the effluent.
15. Recording
the monitoring results on Discharge Monitoring Report Forms using one such form for
each outfall each month and
submitting the forms to IEPA each month.
16.
17.
Compl e schedule for nickel and zinc.
Stormwater pollution preven
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Public Notice/Fact Sheet -- Page 5 -- NPDES Permit No. IL0028321
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Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
NPDES Permit No. IL0028321
Illinois Environmental Protection Agency
Division of Water Pollution
Control
1021 North Grand Avenue East
Post Office Box 19276
d, Illinois 62794-9276
Modified (NPDES) Permit
Expiration Date: June 30, 2012
Issue
Date:
April 20, 2007
Effective Date:
July 1, 2007
Modification Date:
Name and Address of Permittee:
Facility Name and Address:
Sanitary District of Decatur
Sanitary District of Decatur Main STP
501 Dipper Lane
501 Dipper Lane
Decatur, Illinois 62522
Decatur, Illinois
(Macon County)
Receivinq Waters: Sanoamon River
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of
the
Illinois Environmental
Protection Act, Title 35 of the Ill. Adm. Code, Subtitle C, Chapter I, 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.
ex
horized to discharge after the above expiration date. In order to receive authorization to discharge beyond the
mit the proper application as required by the Illinois Environmental Protection Agency
(IEPA) not
later than 180 days
pr
t ion date.
A lan Keller, P.E.
Manager, Permit Section
Division
of
Water
Pollution Control
SAK:REP:06120503.bah
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page 2
Modification Date:
NPDES Permit
No. IL0028321
Effluent Limitations Monitoring,
and Reporting
FINAL
Discharge Number(s) and Name(s): 001 STP Outfall
Load limits computed based on a design average flow
(DAF) of 41.0 MGD (design ma
flow (DMF) of
125.0 MGD).
Excess flow facilities (if
applicable) shall not be utilized until the
main treatment facility is receiving its maximum
practical flow.
From the modification date of
this Permit until the expiration date, the effluent
of the above discharge(s) shall be monitored
and limited at
all times as follows:
LOAD LIMITS Ibs/day
(DMF)`
CONCENTRATION
LIMITS MG/L
*Load limits
based on design maximum flow shall apply
only when flow exceeds design average flow.
"Carbonaceous BOD5
(CBOD5) testing shall be in accordance
with 40 CFR 136.
**'*See Special Condition
7.
****See Special Condition
17.
Flow shall be reported on the Discharge
Monitoring Report (DMR) as monthly
average and daily maximum.
Fecal Coliform shall be reported on the DMR as daily
ma
pH shall be
reported on the DMR as a minimum and a
maximum.
Chlorine Residual shall be
reported on DMR as daily maximum.
Dissolved oxygen shall be
reported on DMR as minimum.
Page 3
Modification Date:
NPDES Permit No. IL0028321
Effluent Limitations Monitoring, and Reporting
FINAL
Discharge Number(s) and Name(s): 003 Oakland Avenue Treated Combined
Sewage Outfall
004 South Edward Street Treated
Combined Sewage Outfall
007 McKinley Avenue Treated Combined
Sewage Outfall
008 Seventh Ward Treated Combined Sewage
Outfall
These flow facilities shall not be utilized until the main treatment facility is receiving
its maximum practical flow.
From the
modification date of this Permit until the expiration date, the effluent of the above discharge(s) shall be monitored
and limited at
all times as follows:
CONCENTRATION
LIMITS mg/L
Parameter
Total Flow (MG) I See Below
B OD,
Suspended Solids
pH
Monthly Average
S hall be
in
the
range of 6 to 9 Standard Units
Sample Frequency
Daily When Discharging
Daily When Discharging
Daily When Discharging
Grab
G rab
D aily When Discharging I
Grab
Total flow in million gallons shall be reported on the Discharge Monitoring Report (DMR)
in the
quantity
maximum column.
Report the
number
of days
of discharge in the comments section of the DMR,
pH shall be
reported
on the
DMR as a minimum and a maximum.
Sample Type
and Suspended Solids shall be
reported on the DMR as a monthly average concentration.
Page 4
Modification Date:
NPDES Permit No. IL0028321
Influent Monitoring, and Repa
The
influent
to the plant shall be monitored as
follows:
g
P arameter
Sample Frequency
Sample Type
F low (MGD)
Continuous
*RIT
BOD5
2 days/week
Composite
S uspended Solids
2 days/week
(
- ---- - - - ----------
I
Composite
__ __--
I nfluent samples shall be taken at a point representative of the influent.
Flow (MGD) shall be reported on the Discharge Monitoring Report (DMR) as monthly average and daily maximum.
BOD5 and Suspended Solids shall be reported on the DMR as a monthly average concentration.
*Recording, Indicating, Totalizing.
Page 5
NPDES Permit No. IL0028321
Special Conditions
The Permittee shall implement and enforce its approved Pretreatment Program which was approved on
September 3, 1985 and all
SPECIAL CONDITION 1. This Permit maybe modified to include different final effluent limitations or requirements which are consistent
with applicable laws, regulations, or judicial orders. The I EPA will public notice the permit modification.
SPECIAL CONDITION 2. The use or opera of this facility shall be by or under the sup
of a Certified Class 1 operator.
SPECIAL CONDITION 3. The IEPA may request in writing submittal of operational information in a specified form and at a required
frequency at any time during the effective period of this Permit.
SPECIAL CONDITION 4. The IEPA may request more frequent monitoring by permit modification pursuant to 40 CFR 3 122.63 and
hout Public Notice in the event of operational, maintenance or other problems resulting in possible effluent deterioration.
SPECIAL
CONDITION
5. The effluent,
alone
or in
combination
with
other sources, shall
not
cause a violation of any applicable water
quality standard outlined in 35 111. Adm. Code 302.
SPECIAL CONDITION 6. Samples taken in compliance with the effluent monitoring requirements shall betaken at a point represen
of the discharge, but prior to entry into the receiving stream.
SPECIAL CONDITION 7. Fecal Coliform limits for Discharge Number 001 are effective May thru October. Sampling of Fecal Coliform
is only required during this time period.
The total residual chlorine limit is applicable at all times. If the Permittee is chlorinating for any purpose during the months of November
through April, sampling is required on a daily grab basis. Sampling frequency for the months of May through October shall be as
indicated on effluent limitations, monitoring and reporting page of this Permit.
S PECIAL CONDITION 8.
A.
1.
a pproved subsequent modifications thereto. The Permittee shall maintain legal authority adequate
to
fully i
Pretreatment Program in compliance with Federal (40 CFR 403), State, and local laws. The Permittee shall:
inspection and
monitoring
procedures at
least
once per year, which will determine whether each
dustrial user (SIU) is in compliance with applicable pretreatment standards;
b .
Perform an evaluation, at least once every two (2) years, to determine whether each SIU needs a slug control plan. If needed,
the SIU
slug control
plan
shall
include
the
items specified in 40 CFR 3 403,8 (f)(2)(v);
U pdate its inventory of Industrial Users (IUs) at least annually and as needed to ensure that all SIUs are properly iden
characterized, and categorized;
Receive and review self monitoring and other IU reports to determine compliance with all pretreatment standards and
requirements, and obtain appropriate remedies for noncompliance by any IU with any pretreatment standard and/or
requirement;
Investigate instances of noncompliance, collect and analyze samples, and compile other
9.
2 .
p roduce evidence admissible in enforcement proceedings, including judicial act
e:
rmation with sufficient care
as
to
Require development, as necessary, of compliance schedules by each industrial user for the installation
of control
technologies to meet applicable
pretreatment
standards; and,
Maintain an adequate revenue structure for continued operation of the Pretreatment Program.
The Permittee shall issue/reissue permits or equivalent control mechani
to commencement of discharge in the case of new discharges. The perm
CFR 3 403.8(f)(1)(iii).
o all SIUs prior to expiration of existing permits or prior
is at a minimum shall include the elements listed in 40
3. The Permittee shall develop, maintain, and enforce, as necessary, local limits to implement the prohibitions in 40 CFR 3 403.5 which
prohibit the introduction of specific pollutants to the waste treatment system from any source of nondomestic discharge.
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page 6
Modification Date:
NPDES Permit No. 10028321
Special Conditions
4. In addition to the general limitations expressed in Paragraph 3 above, applicable pretreatment standards must be met by all industrial
users of the POTW. These limitations include specific standards for certain industrial categories as determined by Section 307(b)
and (c)
of
the
Clean Water Act, State limits, or local limits, whichever are more stringent.
5. The USEPA and
IEPA individually retain the right to take legal action against any industrial user and/or the POTW for those cases
where an industrial user has failed to meet an applicable
pretreatment standard by the deadline
date regardless of
whether
or
not
such failure has resulted in a permit
violation.
6. The Permittee shall establish agreements with all contributing jurisdictions, as necessary, to enable it to fulfill its requirements with
respect to all IUs discharging to its system.
7. Unless already completed, the Permittee shall within six (6) months of the effective date of this Permit submit to USEPA and IEPA a
proposal to modify and update its approved Pretreatment Program to incorporate Federal revisions to the general pretreatment
regulations. The proposal shall include all changes to the approved program and the sewer use ordinance which are necessary to
incorporate the regulations commonly referred to as PIRT and DSS, which were effective November 16, 1988 and August 23, 1990,
respectively. This includes the development of an Enforcement Response Plan (ERP) and a technical re-evaluation of the
Permittee's local Ii
8. The Permittee's Pretreatment Program
has
been
modified to incorporate a Pretreatment Program Amendment
approved
on February
6, 1995. The amendment became effective
on the date of approval and is a fully enforceable provision of your Pretreatment
Program.
Modifications of your Pretreatment Program shall be submitted in accordance with 40 CFR 3 403.18, which established conditions for
substantial and
nonsubstantial modifications.
B. Repo
rds
Requirements
1. The Permittee shall provide an annual report briefly describing the permittee's pretreatment program activities over the pre
calendar year. Permittees who operate multiple plants may provide a single report providing all
plant-specific
reporting requirement
are met. Such report shall be submitted no later than
April 28
of each
year,
and shall be in the
format
set forth in [EPA's POTW
Pretreatment Report Package which contains information regarding:
An updated lis of the Permittee's industrial users.
y of the compliance activities including numbers of any major enforcement actions, (i.e., administrative
ions, etc.), and the outcome of those actions. This includes an assessment of the compliance status
trial users and the effectiveness of the Permittee's Pretreatment Program in meeting its needs and
ption of
all substantive changes made to the Permittee's Pretreatment Program. Changes which are "substantial
" as described in 40 CFR 3 403.18(c) must receive prior approval from the Approval Authority.
Results of sampling
and analysis of POTW influent, effluent, and sludge.
A summary of the findings from the priority pollutants
sampling. As sufficient data becomes available the
IEPA may modify
this Permit to incorporate additional
requirements relating to the evaluation, establishment, and enforcement of local limits for
organic pollutants. Any permit modification is subject to formal due process procedures
pursuant
to
State
and Federal law
and regulation. Upon a determination that an organic pollutant
is
present that causes
interference
or pass through, the
Permittee shall establish
local limits as required by 40 CFR 3 403.5(c).
2. The Permittee shall maintain all pretreatment data and records for a minimum of three (3) years. This period shall be extended
during the course of unresolved litigation or when requested by the IEPA or the Regional Administrator of USEPA. Records shall be
available to USEPA and the IEPA upon request.
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page 7
Modification Date:
NPDES Permit No. IL0028321
Special Conditions
3. The Permittee shall establish public participation requirements of 40 CFR 25 in implementation of its Pretreatment Program. The
Permittee shall at least annually, publish the names of all ]U's which were in significant noncompliance (SNC), as defined by 40 CFR
3 403.8(f)(2)(vii),
in the largest daily paper in the municipality in which the POTW is located or based on any more restrictive definition
of SNC that the POTW may be using.
4. The Permittee shall provide written notification to the Deputy Counsel for the Division of Water Pollution Control, IEPA, 1021
North
Grand Avenue East, P.O. Box 19276, Springfield, Illinois 62794-9276 within five (5) days of receiving notice
that any Industrial User
of its sewage treatment plant is appealing to the Circuit Court any condition imposed by the Permittee in
any permit
issued
to the
Industrial User by Permittee. A copy
of the
Industrial
User's appeal and all other
pleadings
filed by all parties shall be mailed to the
Deputy Counsel within five (5) days of
the pleadings being filed
in
Circuit Court.
C. Monitorinq Requirements
1. The Permittee
shall
monitor its
influent, effluent and sludge and report concentrations of the following parameters on monitoring
report forms provided by the IEPA and include them in its annual report. Samples shall be taken at quarterly (four times per year)
intervals at the indicated reporting limit or better and consist of a 24-hour composite unless otherwise specified below. Sludge
samples shall be taken of final sludge and consist of a grab sample reported on a dry weight basis.
STORET
CODE
01097
01002
01007
01012
01027
01032
01034
01042
00718
00720
00951
0104.5
01046
01051
01055
71900
01067
00556
32730
01147
01077
01059
01092
PARAMETER
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (hex - grab not
to exceed
24 hours)*
Chromium (total)
Copper
Cyanide (grab) (weak acid disso
Cyanide (grab) (total)
Fluoride*
Iron (total)
Iron (Dissolved)*
Lead
Manganese
Mercury (effluent grab
Nickel
USEPA Method 1631 or equivalent)***
Oil (hexane soluble or equivalent) (Grab Sample only)*
Phenols (grab)
Selenium
Silver
(total)
Thallium
Zinc
* Influent and effluent only
**1 ng/L
_
1 part per trillion.
*** Other approved methods may be used for influent (composite) and sludge
Minimum
reporting limit
0.07 mg/L
0.05 mg/L
0.5 mg/L
0.005 mg/L
0.001 mg/L
0.01 mg/L
0.05 mg/L
0.005 mg/L
5.0 ug/L
5.0 ug/L
0.1 mg/L
0.5 mg/L
0.5 mg/L
0.05 mg/L
0.5 mg/L
1.0 ng/L**
0.005 mg/L
5.0 mg/L
0.005 mg/L
0.005 mg/L
0.003 mg/L
0.3 mg/L
0.025 mg/L
Unless otherwise indicated, concentrations refer to the total amount of the constituent present in all phases, whether solid, suspended or
dissolved, elemental or combined including all oxidation states. Where constituents are commonly measured as
other than total, the
phase is so indicated.
2.
The Permittee shall conduct an analysis for the one hundred and ten (110) organic priority pollutants identified in 40 CFR 122
Appendix D, Table II as amended. This monitoring shall be done once per year and reported on monitoring report forms
provided by the IEPA and shall consist of the following:
The influent and effluent shall be sampled and analyzed for the one hundred and ten (110) organic priority pollutants.
The sampling shall be done during a day when industrial discharges are expected to be occurring at normal
to
maximum levels.
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page 8
NPDES Permit No. IL0028321
Special Conditions
Samples for the analy
Modifica Date:
id and base/neutral extractable compounds shall be 24-hour
composites.
Five (5) grab samples shall be collected each monitoring day to be analyzed for volatile
organic compounds. A single
analysis for volatile pollutants (Method 624) may be run for each monitoring day by
compositing equal volumes of each
grab sample directly in the GC purge and trap apparatus in the laboratory, with
no less than one (1) mL of each grab
included in
the composite.
Wastewater samples must be handled,
prepared, and analyzed by GC/MS in accordance with USEPA Methods 624
and 625 of 40 CFR 136 as amended.
The sludge shall be sampled and analyzed for the one hundred and ten (110) organic priority pollutants. A sludge
sample shall be collected concurrent with a wastewater sample and taken as final sludge.
Sampling and analysis shall conform to USEPA Methods 624 and 625 unless an alternate method has been
approved
by IEPA.
c. Sample collection, preservation and storage shall conform to approved
USEPA
procedures
and requirements.
In addition, the Permittee shall monitor any new
toxic substances as defined by the Clean Water Act, as amended, following
notification by the IEPA.
Permittee
shall report any noncompliance with effluent or water quality standards in accordance with Standard Condition
12(e)
of this Permit.
5.
Analytical
detection limits shall be in accordance with 40 CFR 136. Minimum detection limits for sludge analyses shall be in
accordance with 40 CFR 503.
SPECIAL CONDITION 9. The Permittee has undergone a Monitoring Reduction review and the influent and effluent sample frequency
has
been
reduced
for CBODS, BOD5, suspended solids, dissolved oxygen, pH, fecal coliform, chlorine residual and ammonia nitrogen
due
t o sustained compl
to the Illinois Environmental Protection Agency/Division
of
Water
Pollution Control/Compliance Assurance Section. The
days/week if effluen
The IEPA will require that the influent and effluent sampling frequency for these parameters be increased
to 5
monitoring will be required Wit
tion occurs due to increased wasteload, operational, maintenance or
other
problems.
The increased
is Notice when a permit modification is received by the Permittee from the IEPA.
SPECIAL CONDITION 10. During January of each year
the
Permittee
shall submit annual fiscal data regarding sewerage system
use any fiscal year period provided the period ends within twelve (12) months of
the submission date,
ion shall be
on
forms
provided by IEPA titled "Fiscal Report Form For NPDES Permittees".
SPECIAL CONDITION
11. The Permittee shall conduct biomonitoring of the effluent from Discharge Number(s) 001.
BiomonitoriM
1.
Acute Toxicity - Standard definitive acute toxicity tests shall be run on at least two trophic levels of aquatic
species (fish,
invertebrate) representative of the aquatic community of the receiving stream. Testing must be consistent with Methods
for
Measurinq the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms
(Fifth Ed.)
EPA/821-R-02-012. Unless substitute tests are
pre-approved; the
following
tests are
required:
a.
Fish - 96 hour static LC50 Bioassay using fathead minnows (Pimephales promelas).
b.
Invertebrate
48-hour static LC50 Bioassay using Ceriodaphnia.
Testing Frequency - The above tests shall be conducted using 24-hour composite samples unless otherwise authorized by
the IEPA. Samples must be collected in the 18th, 15th, 12th, and 9th month prior to the expiration date of this Permit.
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page 9
Modification Date:
NPDES Permit
No. IL0028321
vial Conditions
Reporting - Results shall be reported according to EPA/821-R-02-012, Section
12, Report Preparation, and shall be submitted
to IEPA, Bureau of Water, Compliance Assurance Section within one
week of receipt from the laboratory. Reports are due to
the I EPA no later than
the 16th, 13th, 10th, and 7th month prior to the expiration date of
this Permit.
Toxicity Reduction
Evaluation - Should the results of the biomonitoring program identify toxicity, the ]EPA
may require that the
Permittee prepare a plan for toxicity
reduction evaluation and identification. This plan shall be developed in accordance
with
Toxicity Reduction Evaluation Guidance
for Municipal Wastewater Treatment Plants, EPA/833B-99/002, and shall
include an
evaluation to determine which chemicals
have a potential for being discharged in the plant wastewater, a monitoring
program
to determine their presence or absence and to identify other compounds
which are not being removed by treatment, and other
measures as appropriate. The Permittee shall submit to the
IEPA its plan for toxicity reduction evaluation within ninety (90)
days following notification by the IEPA. The Permittee shall
implement the plan within ninety (90) days or other such date as
contained in a notification letter received from the IEPA.
The IEPA may modify this Permit during its term to incorporate additional
requirements or limitations based on the results of
the biomonitoring. In addition, after review of the monitoring results, the IEPA
may modify this Permit to include numerical
limitations for specific toxic
pollutants. Modifications under this condition shall
follow public notice and opportunity for
hearing.
ONDITION 12. Discharge Number 002
is an emergency high level bypass, Discharges from this overflow
are subject to the
conditions:
(1)
A Bypass- means the intentional diversion of waste streams
from any portion of a treatment facility.
li) ASevere property damage- means substantial physical damage
to property, damage to the treatment facilities which
causes them
to become inoperable, or substantial and permanent
loss of natural resources which can reasonably be
expected
to occur in the absence of a bypass. Severe property damage does not
mean economic loss caused by
delays in production.
(2)
Bypass not exceeding limitations.
The Permittee may allow any bypass to occur which does not cause effluent limitations
to
be exceeded, but only if it also is for essential
maintenance to assure efficient operation. These bypasses are not subject
to
the provisions of paragraphs (3) and (4)
of this section.
(3)
Notice
(1)
A nticipated bypass. If the Perm ittee knows
in
advance
of the need for a bypass, it shall s
at least ten days before the date of the bypass.
if possible
(Ii) Unanticipated bypass. The Permittee shall submit
notice of an unantici
Condition 12(e) of this
Permit (24-hour notice).
ed bypass as required in Standard
(4)
Prohibition of bypass.
Bypas
unless:
(1)
, and the IEPA may take enforcement
action against a Permittee for bypass,
Bypass was unavoidable to prevent
loss of life, personal injury, or severe property damage;
(Ii) There was no feasible alternatives to the bypass,
such as the use of auxiliary treatment facilities, retention of untreated
wastes, or maintenance during normal periods of
equipment downtime. This condition is not satisfied if adequate
back-up equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass
which occurred during normal periods of equipment downtime or
preventive maintenance; and
(Iii) The Permittee
submitted notices as required under Standard Condition 12(e) of this
Per
(5)
Emergency Bypass when discharging,
shall be monitored daily by grab sample for
BOD5
and
Suspended Solids. The
Permittee shall submit the monitoring
results on Discharge Monitoring Report forms using one such
form
for each month
in
which bypassing occurs. The Permittee shall
specify the number of discharges per month that occur and shall report this
number in the quantity daily maximum column.
The Permittee shall report the highest concentration value of BOD5 and
Suspended Solids discharged in the concentration daily
maximum column.
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page 10
NPDES
Permit No. IL0028321
Special Conditions
SPECIAL CONDITION
13. For the duration of this Permit, the
Permittee shall determine the quantity of sludge
produced by the
treatment facility in dry tons
or gallons with average percent total
solids analysis. The Permittee shall maintain adequate
records of the
quantities of sludge produced
and have said records available
for IEPA inspection. The Permittee shall submit to the IEPA,
at a
minimum, a semi-annual summary report
of the quantities of sludge generated
and disposed of, in units of dry tons or gallons (average
total percent solids) by different disposal
methods including but not limited to
application on farmland, application on reclamation
land,
landfilling, public distribution, dedicated
land disposal, sod farms, storage
lagoons or any other specified disposal method. Said reports
shall be submitted to the IEPA by January 31 and July
31 of each year reporting the preceding
January thru June and July thru December
interval of sludge disposal operations.
Duty to Mitigate. The Perm
s hall take all reasonable
steps
to
ize any sludge use or disposal
in violation of this Permit.
Sludge monitoring
must be conducted according to test procedures
approved under 40 CFR 136 unless
otherwise spec
503, unless other
test procedures have been specified in this Permit.
in 40 CFR
Planned Changes. The Permittee
shall give notice to the I EPA on the
semi-annual report of any changes in sludge
use and disposal.
The Permittee shall retain records of
all sludge monitoring, and reports required
by the Sludge Permit as referenced in Standard
Condition
23 for a period of at least five (5) years
from the date of this Permit.
If the Per
in the report
Ilutant
more frequently than required by the Sludge
Permit, the results of this monitoring shall be included
ng of data submitted to the
IEPA.
reports for sludge shall be reported on the
form titled "Sludge Management Reports" to
the following address:
Illinois Environmental
Protec
Bureau of Water
Agency
Compliance Assurance Section
Mail Code #19
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
S PECIAL CONDITION 14.
A UTHORIZATION
OF
COMBINED
SEWER AND TREATMENT
PLANT DISCHARGES
The IEPA has determined that at least a portion of
the collection system consists of
combined sewers. References to the collection
system
and the sewer system refer only to those parts
of the system which are owned
and operated by the Permittee unless otherwise
indicated.
The Permittee is authorized to discharge
from the overflow(s)lbypass(es)
listed below provided the diversion structure is
located on a
combined sewer and the following terms and conditions
are met:
D ischarge Number
A03
A04
A06
A07
A08
Treatment Requirements
1.
of applicable water quality
standards. Sufficient treatment shall co
Location
Oakland Avenue CSO
Treatment Bypass
South Edward Street CSO
Treatment Bypass
Fairview Park CSO
McKinley Avenue CSO Treatment
Bypass
Seventh Ward CSO Treatment Bypass
All combined sewer
overflows and treatment plant bypasses
shall be
Receiv
ncLWater
S angamon
River
Sangamon
River
Stevens Creek
Unnamed tributary of Spring Creek
Sangamon River
en sufficient treatment to prevent pollution
and the violation
of the following:
Treatment as described
in PCB AS 91-7 and dated June
23, 1992 shall be provided. The terms and conditions of this
Board Order are hereby
incorporated by reference as if fully set
forth herein; and,
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page
11
Modification
Date:
NPDES Permit No. IL0028321
Special Conditions
Any additional treatment,
necessary to comply with applicable water quality standards and the federal Clean Water Act,
including any amendments
made by the Wet Weather Water Quality Act of 2000.
All CSO discharges authorized by this
Permit shall be treated, in whole or in part, to the extent necessary to prevent accumulations
of sludge deposits, floating debris and solids in accordance
with 35 Ill. Adm. Code 302.203 and to prevent depression of oxygen
levels below the applicable water quality standards.
Overflows during dry weather are prohibited. Dry weather overflows
shall be reported to the ]EPA pursuant to Standard Condition
12(e) of this Permit (24 hour notice).
4.
The
collee
Proper operation and maintenance programs for the sewer
system and the CSOs (Compliance with this Item shall be met
through the requirements imposed by Paragraph 8 of this
Special Condition);
5.
The
treatment system shall
be operated to maximize treatment of wastewater flows.
Nine Minimum Controls
The Permittee shall comply with the nine minimum controls
contained in the National CSO Control Policy published in the Federal
Register on April 19, 1994. The nine minimum controls
are:
use of the collection system for storage (Compliance
with
this
Item shall be met through the requirements
imposed by Paragraphs 1, 4, and 8 of this Special Condition);
shall be met through the requirements imposed by Paragraph 9 of this Special Con
Review and modification of pretreatment requirements to assure CSO impacts are
min
perated to optimize transport of wastewater flows and to minimize
CSO discharges,
raphs 4, 5, and 8 of this Special Condition);
Prohibition of CSOs during dry
weather (Comp)
Paragraph 3 of this Special Condition);
zed (Compli
m
of flow to the POTW for treatment (Compliance with this Item shall be
met through the requirements
Item shall be met through the requirements imposed by
lids and floatable materials
in CSOs (Compliance with this Item shall be met through the requirements
mposed by Paragraphs 2 and 8 of this Special
Condition);
9.
Pollution prevention programs which focus on source control activities
(Compliance with this Item shall be met through the
requirements imposed by Paragraph 6 of this
Special Condition, See Below);
Public notification to ensure that citizens receive adequate information regarding
CSO occurrences and CSO impacts
(Compliance
with this Item shall be met through the requirements imposed by
Paragraph 12 of this Special Condition);
and,
Monitoring to characterize impacts and
efficiency of CSO controls (Compliance with this Item shall be met through the
requirements imposed by Paragraphs
10 and 11 of this Special Condition).
Page 12
Modification Date:
NPDES Permit No. IL0028321
Special Conditions
A pollution prevention plan (PPP) shall be developed by the Permittee
unless one has already been prepared for this collection
system. Any previously-prepared PPP shall be
reviewed, and revised if necessary, by the Permittee to address the
contained in Chapter 8 of the U.S. EPA guidance document, Combined Sewer Overflows
Guidance For Nine Minimum Controls,
and any items contained in previously-sent review documents from the
IEPA concerning the PPP. Combined Sewer Overflows
Guidance For Nine Minimurn Controls is available online at http://www.epa.gov/NPDES/pubs/owm0030.pdf,
The PPP (or revised
PPP) shall be presented to the general public at a public information meeting conducted by the Permittee within nine (9) months of
the effective date of this Permit. The Permittee shall submit documentation that the pollution prevention plan complies with the
requirements of this Permit and that the public information meeting was held. Such documentation shall be submitted to the I EPA
within twelve
(12)
months of the effective date of this Permit and shall include a summary of all significant issues raised by the
public, the Permittee's response to each
issue,
and
two (2) copies of the "CSO Pollution Prevention Plan Certification" one (1)
with
original
signatures.
This
certification
form
is
available
online
at
§
. Following the public meeting, the Permittee shall
implement the pullution prevention plan within one (1)
yc-.ar
ana shall maintain
a current pollution prevention plan, updated to reflect
system modifications, on file at the sewage treatment
works
or
other acceptable location and made available to the public. The
pollution prevention plan shall be submitted to the
IEPA upon written request.
Sensitive Area Considerations
Pursuant to Section II.C.3 of the federal CSO Control Policy of 1994, sensitive areas are any water likely to be impacted by a CSO
discharge which meet one or more of the following criteria: (1) designated as an Outstanding National Resource
Water;
(2)
found
to contain shellfish beds; (3) found to contain threatened or endangered aquatic species or their habitat; (4) used for
p
contact recreation; or,
(5) within the protection area for a drinking water intake structure.
The IEPA has tentatively determined that none of the outfalls listed in this Special Condition discharge to sensitive areas. However,
if information becomes available
that causes the IEPA to reverse this determination, the IEPA will notify the Permittee in writing.
Within three (3) months of the date of
notification, or such other date contained in the notification letter, the Permittee shall submit
two (2) copies of either a schedule
to relocate, control, or treat discharges from these outfalls. If none of these options are
possible, the Permittee shall submit adequate justification
at that time as to why these options are not possible. Such justification
shall be in accordance with Section II.C.3 of the
National CSO Control Policy.
8. The IEPA reviewed and accepted a CSO operational and maintenance
plan "CSO O&M plan" on February 1, 2000 prepared for
this sewerage system. The Permittee shall review and revise, if needed, the CSO O&M plan to reflect system changes.
The CSO O&M plan shall be presented to the general public at a public information
meeting conducted by the Permittee within nine
(9) months of the effective date of this Permit. The Permittee shall submit documentation that the CSO O&M plan complies
with
the
requirements of this Permit and that the public information meeting was held. Such documentation shall be submitted to the
IEPA within
twelve
(12) months of the effective date of this Permit and shall include a summary of all significant issues raised by the
public, the Permittee's response to each issue, and two (2) copi
(1) with original signatures. Copies
of the "CSO Oper, tional
h
" CSO Operational Plan Checklist and Certification", one
klist and Certification" are available online at
ing the public meeting, the Permittee shall
implement the C
ill yin one
(1)
year and shall maintain a current CSO O&M plan, updated to reflect system
modifications, on file at the sewage treatment works or other acceptable
location and made available to the public. The CSO O&M
plan shall be submitted to the IEPA upon written request.
The objectives of the CSO O&M plan are to reduce the total loading
of pollutants and floatables entering the receiving stream and
to ensure that the Permittee ultimately achieves compliance with water quality standards.
These plans,
tailored to the
local
governments's collection and waste treatment systems, shall include mechanisms
and specific procedures where applicable to
ensure:
Collect
b.
Inspections are made and prevent
system inspection on a scheduled basis;
Sewer, catch basin, and regulator cleaning
and maintenance on a scheduled basis;
d.
Collection system replacement, where necessary;
d el
of illegal connections;
performed on all pump/lift stations;
Page 13
Modification Date:
N PDES Permit No. IL0028321
Special Conditions
Detection, prevention, and elimination of dry weather overflows;
The collection system
is
operated to
maximize storage capacity and the combined sewer portions of
the
collection system
are operated to delay storm entry into the system; and,
The treatment and collection systems are operated to maximize treatment.
Sewer
Use Ordinances
9.
The Permittee, within six
(6) months
of the
effective date of this Permit, shall review and where necessary, modify its existing sewer
use ordinance to ensure
it contains provisions addressing the conditions below. If no ordinance exists, such ordinance shall be
developed and
implemented within six (6) months from the effective date of this Permit. Upon completion of the review of the
sewer use ordinance(s), the Permittee shall submit two (2) copies of a completed "Certification of Sewer Use Ordinance Review",
one (1) with original signatures.
Copies of the
certification form can be
obtained on
line at
o rdinance(s) to the IEPA upon wri
p rohibit introduction of new
The Permittee shall submit copies of the sewer use
e ordinances are to contain specific provisions to:
sources to the sanitary sewer system;
b.
require that new construction tributary to the combined sewer system be designed to minimize and/or delay inflow
contribution to the combined sewer system;
require
that
inflow sources on the combined sewer system be connected to a storm sewer, within a reasonable period of
time, if a storm sewer becomes available;
provide that any
new
building
domestic waste connection shall be distinct from the building inflow connection, to facilitate
disconnection
if
a
storm sewer becomes available;
assure that CSO impacts
from
non-domest
any, are tributary to CSOs and revi
these discharges; and,
c sources are minimized by determining which non-domestic discharges, if
d,
if
necessary,
modifying the sewer use ordinance to control pollutants in
n otify the owners of all publicly owned systems with combined sewers tributary to the
Permittee's
collection system of their
o bligations to have procedures in place adequate to ensure that the objectives, mechani
iven in Paragraph 8 of this Special Condition are achieved.
The Permittee shall enforce the applicable sewer use ordinances.
-Term Control Planning and
Compliance
with Water Quality Standards
10. a.
Pursuant to Section 301 of the federal Clean Water Act, 33 U.S.C. .3 1311 and 40 CFR 3 ,122.4, discharges from the CSOs,
including the outfalls listed in this Special Condition and any other outfall listed as a "Treated Combined Sewage Outfall",
shall not cause or contribute to violations of applicable water quality standards or cause use impairment in the receiving
waters. In addition, discharges from CSOs shall comply with all applicable parts of 35111. Adm. Code 306.305(a), (b), (c),
and (d).
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page 14
Modification Date:
NPDES Permit No. IL0028321
I Conditions
b.
Based on available
information, it appears that the
CSOs authorized in this Permit meet the criteria
of Section ILC.4.a.i of
the federal CSO
Control Policy of 1994 (Policy),
not more than four overflow events per
year, and are presumed to meet
the water quality-based
requirements of the federal
Clean Water Act. Pursuant to
Section I.C.1 and Section II.C.9 of the
Policy, the Permittee
shall develop a post-construction
water quality monitoring program adequate
to verify compliance
with water quality standards
and to verify protection of designated
uses in the receiving water(s) and
to ascertain the
effectness of CSO controls.
This program shall contain
a plan that details the monitoring protocols
to be followed,
including any necessary effluent
and ambient monitoring, and if appropriate,
other monitoring protocols such as
biological
assessments, whole effluent toxicity
testing, and sediment sampling.
This plan shall be presented to the public
at an
informational meeting within nine (9)
months of the effective date
of this Permit. Within twelve (12) months
of the
effective
date of this Permit, the Permittee
shall submit a summary of all significant
issues raised by the public, the
Permittee's
response to each issue, and two (2)
copies of the final plan (revised
following the public meeting, if necessary)
implementing
the post-construction monitoring
program. The post-construction
monitoring plan shall be implemented
within six (6)
months of the date of I EPA approval.
The Permittee shall respond to an IEPA
review letter in writing within
ninety (90) days of
the date of such an initial review
letter and within thirty (30) days of
any subsequent review letter(s), if
any. Within thirty (30)
months of the approval
of the plan, the results shall be
submitted to the IEPA along with
recommendations
and conclusions as to whether
or not the discharges from any of the CSOs
(treated or untreated)
authorized by this Permit are
causing or contributing to
violations of applicable water quality standards
or causing use
impairment in the receiving
water(s).
Should the results of the post-construction
water quality monitoring
plan or if information becomes available
that causes
IEPA to conclude that the discharges
from any of the CSOs (treated
or untreated) authorized to discharge
under this
Permit are causing or contributing
to violations of water quality standards
or are causing use impairment in the receiving
will notify the Permittee
in writing. Upon receiving such
notification, the Permittee shall develop and
mplement a CSO Long-Term Control
Plan (LTCP) for assuring that
the discharges from the CSOs (treated or
untreated)
authorized in this Permit comply
with the provisions of Paragraph
10.a above. The LTCP shall contain all applicable
elements
of Paragraph 10.d below including
a schedule for implementation and
provisions for re-evaluating compliance
with applicable
standards and regulations after
complete implementation.
Two (2) copies of the LTCP shall be submitted
to the I
EPA within twelve (12) months of
receiving the I EPA written notice.
The LTCP shall be:
1.
Consistent
with Section II.C.4.a.i of the
Policy; or,
2.
Consistent
with either Section II.C.4.a.ii,
Section II.C.4.a.iii, or Section II.C.4.b
of the Policy and be accompanied
by data
sufficient to demonstrate that the
LTCP, when completely implemented,
will be sufficient to meet water
quality standards.
Pursuant to the Policy, the
requi
e LTCP
include the following:
1.
Characterization,
monitoring, and modeling of the
Combined Sewer System (CSS);
2.
Consideration of Sensitive
Areas;
3.
Evaluation of alternatives;
4.
Cost/Performance considerat
5.
Revised CSO Operational
Plan;
6.
Maximizing
treatment at the treatment plant;
7.
Implementation
schedule;
8.
Post-Construction
compliance monitoring
program; and
9.
Public participation.
Following submittal of the
LTCP, the Permittee shall
respond to any initial IEPA review letter
g within ninety (90)
d ays of the date of such a
review letter, and within thirty
(30) days of any subsequent
Implementation of the LTCP shall
be as indicated by IEPA
in writing or other enforceable
mechanism.
Monitoring-
Reporting and Notification Requirements
letter(s), if any.
11. The Permittee shall
monitor the frequency of discharge
(number of discharges per
month) and estimate the duration (in hours) of
each discharge from
each outfall listed in this Special Condition.
Estimates of storm duration
and total rainfall shall be provided for
each storm event.
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page 15
Modification
Date:
N PDES Permit No. IL0028321
Special
Conditions
For
frequency reporting, all discharges from the same storm, or occurring
within 24 hours, shall be reported as
one. The date that
a discharge commences
shall be recorded for each outfall.
Reports shall be in the form specified by
the IEPA and on forms
provided by the I
EPA. These forms shall be submitted to the
IEPA monthly with the DMRs and covering the
same reporting period
as the DMRs. Parameters
(other than flow frequency), if required
in
this
Permit, shall be sampled and reported as
indicated in the
transmittal letter for such report forms.
12. A public notification program
in
accordance
with Section II.B.8 of the federal CSO
Control Policy of 1994 shall be developed
employing a process that actively informs the
affected public. The program shall
include at a minimum public notification of CSO
occurrences and CSO impacts, with consideration
given to including mass media and/or
Internet notification. The Perm ittee shall
also consider posting signs in waters likely to
be impacted by CSO discharges at the point of discharge
and at points where these
waters are
used
for primary contact recreation.
Provisions shall be made to include modifications
of the program when
necessary
and notification to any additional member of
the affected public. The program shall
be presented to the general public
at a public information
meeting conducted by the Permittee.
The Permittee shall conduct the public information
meeting within
nine (9) months of the
effective date of this Permit. The Permittee
shall submit documentation that the public
information meeting
was held, shall submit
a summary of all significant issues
raised by the public and the Permittee's response to
each issue and shall
identify any modifications
to the program as a result of the
public information meeting. The Permittee shall submit the
public
information meeting documentation
to the IEPA and implement the public
notification program within twelve (12) months
of the
effective date of this Permit. The
Permittee shall submit copies of the public
notification program to the IEPA upon
written request.
13.
in this CSO Special
Condition
1
4. The following summarizes the dates that submittals contained
in this Special Condition are due
at the IEPA (unless othe
indicated):
S ubmission of CSO Monitoring Data (Paragraph 11)
15th of every month
E limination of a CSO
or Discovery of Additional CSO
1 month from discovery
or elimination
Locations (Paragraph
13)
CSO discharge points listed
in this Special Condition are eliminated,
or if additional CSO discharge points, not listed
in
Condition, are discovered, the
Permittee shall notify the IEPA
in writing within one (1) month of the respective outfall
ion or discovery. Such notification shall
be in the form of a request for the
appropriate modification of this NPDES Permit.
Control (or Justification for No Control)
of CSOs to
Sensitive Areas (Paragraph
7)
cation of Sewer Use Ordinance
Review (Paragraph 9)
6 months from the effe
Implement Post-Construction Monitoring Plan
(Paragraph 10)
6
months from the date of IEPA plan approval
No Submittal Due with this
Milestone
Conduct
Pollution Prevention, OMP, Post-Construction
Monitoring Plan
9 months from the
effective date of this Perm
and PN Public
Information Meeting (Paragraphs, 6, 8,
10 and 12)
No Submittal Due with this Milestone
S ubmit Pollution Prevention Certification,
OMP Certification,
12 months from the effective date of this
Permit
Post-Construction Monitoring
Plan and PN Information Meeting
Summary (Paragraphs, 6, 8, 10 and
12)
Submit CSO Long-Term Control Plan (Paragraph
10)
12 months from the date of IEPA notification
Submit
Results of Post-Constru Mo
Plan
(Paragraph 10)
30 months
from the date of IEPA plan approval
Page 16
Modification Date:
NPDES Permit No. IL0028321
Special Conditions
All submittals listed in this Special Condition can be mailed to the following address:
Illinois Environmental Protection Agency
Division
of
Water Pollution Control
1021 North Grand Avenue
East
Post
Office Box 19276
Springfield, Illinois 62794-9276
Attention: CSO Coordinator, Compliance Assurance Section
All submittals hand carr
R
eopening
and Modifying this Permit
d elivered to 1021 North Grand Avenue East.
15. The IEPA may initiate a modification for this Permit at any time to include requirements and compliance dates which have been
submitted
in
writing by the
Permittee and approved by the
[EPA,
or other requirements and dates which are necessary to carry out
the provisions of the Illinois Environmental
Protection Act, the Clean Water Act, or regulations promulgated under those Acts.
Public
Notice
of such modifications and
opportunity for public hearing shall be provided.
SPECIAL CONDITION 15. The Permittee shall record monitoring
results on Discharge Monitoring Report (DMR) Forms using one such
form for each outfall each month.
In the event that an outfall does not discharge du
indicated.
a monthly reporting period, the DMR Form shall be submitted with no discharge
The Permittee may choose to submit electronic DMRs (eDMRs) instead of mailing paper DMRs to the IEPA. More
r egistration information for the eDMR program, can be obtained on the IEPA website, http://www.epa.state.il.us/water/edmr/index.html.
e ted Discharge Monitoring Report forms shall be submitted to (EPA no later than the 15th day of the following month, unless
ified by the permitt
all
mail Discharge Monitoring Reports with an o
is Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand
Avenue East
Post Office
Box 19276
Springfield, Illinois 62794-9276
Compliance Assurance Section, Mail Code #
19
t o the IEPA at the following address:
S PECIAL CONDITION 16. The Permittee has collected data in support of developing a site-specific metals translator for nic
The IEPA has reviewed the sample data and has revised effluent limitations for these parameters based on the metal
determined
from
the collected
data.
Page 17
Modification Date:
NPDES Permit No. IL0028321
Special Conditions
SPECIAL CONDITION 17.
Project Description: Compliance
with Nickel and Zinc Water Quality Standards
Thirty-six (36) months from the effective date of this Permit the
following nickel and zinc limits and monitoring requirements found on page
two of this permit shall become effective:
Load Limits
Ibs/day
Concentration
DAF.(DMF)*
Limits mq/L
Monthly Avg.
Daily Max.
Monthly Avg.
Daily Max.
Zinc
26(78)
142 (434)
0.075
0.416
Nickel
5.1 (16)
0.015
Load limits based on design maximum flow shall apply
only when flow exceeds the design average flow.
The Permittee shall complete the project described above
in accordance with the following schedule:
(1)
Interim Report on effluent and stream sampling to
6 months from the effective date of this Permit
and what measures are necessary to comply
Final Nickel arid Zinc Lirnitations
(2)
Interim Report
12
months from the effective date of this Permit
(3)
Interim Report
18 months from
the effective date of this Permit
( 4)
(5)
(6)
date of
this Permit
hieves Compliance
luent Limitations
36 months from the effective date of this Perm
This Permit may be modified, with Public Notice, to include revised compliance
dates set out in this Permit that are superseded or
supplemented by compliance dates in judicial orders, Pollution Control
Board orders or grant agreements. Prior to such permit
modification,
the
revised dates in the appropriate orders or grant agreements shall govern the
Permittee=s compliance.
In addition, the IEPA may initiate a modification of the
construction schedule set forth in this Permit at any time, to include other dates
which are necessary to carry out the provisions of the
Illinois Environmental Protection Act, the Federal Clean Water Act or
regulations
promulgated under those Acts or compliance dates which have been submitted
in writing by the Permittee and approved by the IEPA.
Public Notice of such modifications and opportunity
for public hearing shall be provided consistent with
40
CFR 3,122.63.
ORTING
r eport no later than fourteen (14) days
following the completion dates indicated for each numbered item in
the compliance schedule, indicating, a) the date the item was completed,
or b) that the item was not completed. All reports shall be
submitted to
IEPA
at the
following address:
Illinois Environmental Protection Agency
Division of Water Pollution
Control
1021 North Grand Avenue
East
Post Office box 19276
Springfield, Illinois 62794-9276
: Compliance Assurance Section, Mail Code 9
19
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page 18
Modification Date:
NPDES Permit
No. IL0028321
Special. Conditions
SPECIAL CONDITION 18.
STORM WATER POLLUTION
PREVENTION PLAN (SWPPP
1. A storm water pollution prevention plan shall
be developed by the permittee and
submitted to the Agency for each facility
covered by
this permit. The plan shall identify potential sources
of pollution which may
be expected to affect the quality of storm water
discharges associated with the industrial activity at the
facility. In addition, the plan shall describe
and ensure the implementation of
practices
which
are
to be used to reduce the pollutants
in storm water discharges associated
with industrial activity at the facility and
to assure compliance
with the terms and conditions of this
permit. An electronic copy of the plan
shall be submitted to the Agency at
the following email
address:
The permittee shall submit any modified plan
to the Agency, when
such modification includes subskintive
t .I ranges to the plan or
modification is made to the plan for compliance
with this permit.
Waters not classified as
Impaired pursuant to Section 303(d) of the
Clean Water Act
Unless otherwise specified by
federal regulation, the storm water
pollu
equal to or greater than a
25-year 24-hour rainfall event.
b. Waters classified as Impaired pursuant to
Section 303(4) of the Clean Water
Act
ion plan shall be designed
for a storm event
For
any site
which discharges directly to an impaired
water identified in the Agency's
303(d) listing, and if any parameter in the
subject discharge
has been identified as the cause
of impairment, the storm water
pollution prevention plan shall be designed
for
a
storm event equal to or greater than a
25-year 24-hour rainfall event. If required by
federal regulations, the storm water
pollution prevention plan
shall adhere to a more restrictive
design criteria.
Plans for
new
facilities
shall be completed prior to submitting
an NOI to be covered under this permit.
An electronic copy of the st,, ,-m
water pollution prevention
plan shall be submitted to the
Agency at the following email address:
P lans shall provide for compliance
with the terms of this permit prior
to operation of any industrial activity
to be wvered uncles this
[Note: If the plan
has already been required to be developed
under a previous permit it shall be maintained
in accordance
with all requirements of this special
condition J.
The
owner or operator
of an existing facility with storm water
discharges covered by
this permit shall make a copy of the
plan available to the Agency at any
reasonable time upon request,
s ystem shall
also make a copy available to the operator
of
the
3 . The permittee may be notified by the Agency at any
time that the plan does not meet
the requirements of this permit. After such
notification, the permittee
shall make changes to the plan
and shall submit a revised plan
to the Agency, with the requested changes
that
have been made. Unless otherwise provided,
the permittee shall have 30
days after such notification to make the changes.
4. The discharges shall
amend the plan whenever there
is
a
change in construction, operation,
or maintenance which may affect the
discharge of significant
quantities of pollutants to the
waters of the State or if a facility inspection
required by paragraph E.8.of this
permit indicates that
an amendment is needed. The plan should
also be amended if the discharges
is in violation of any conditions of
this permit, or has not achieved
the general objectives of controlling
pollutants in storm water discharges.
Amendments to the plan
shall be made within 30 days
of any proposed construction or
operational changes at the facility,
and shall be submitted to the
Agency.
5. The plan shall provide a description of
potential sources which may be expected
to add significant quantities
of pollutants to storm
water discharges, or which may result
in non-storm water discharges from the facility.
The plan shall include, at a minimum, the
following
items:
A topographic map extending one-quarter
mile beyond the property boundaries of
the facility, showing: the facility, surface
water bodies, wells
(including injection wells), seepage pits,
infiltration ponds, and the discharge
points where the facility's storm
water discharges to
a municipal storm drain system or other
water body. The requirements
of this paragraph maybe included
on the site map if appropriate.
Any map or portion of
map may be withheld for security reasons.
Page 19
Modification Date:
NPDES Permit No.
IL0028321
Special Conditions
b.
A site map showing:
The storm water conveyance and
discharge structures;
An outline
of the storm water drainage areas
for each storm water discharge
point;
iii. Paved areas and
buildings;
iv. Areas used for outdoor
manufacturing, storage, or
disposal of sign
significant quantities of dust
or particulates;
v.
Location of exist
a terials, including
activities that generate
o r future
storm water structural control
measures/practices (dikes, coverings,
detention facilities, etc.);
vi. Surface water locations and/or
municipal storm drain locations;
vii. Areas of ex g and potential soil erosion;
viii. Vehicle service
areas;
ix. Material loading,
unloading, and access areas;
Areas under Items
d ix above may be withheld
from the site map for security
reasons.
d escription of
the following:
The nature of the industrial
activ
n ducted at the site,
including a description of significant
materials that are treated,
s tored or disposed of in a
manne a llow exposure to
storm water;
hicle management practices
employed to minimize contact
of significant materials with storm
ctural control measures/practices
to reduce pollutants
in storm water discharges;
iv. Industrial
storm water discharge treatment
fa
Methods of
onsite storage and disposal of
significant materials.
d. A list of the types of pollutants
that have a reasonable potential
to be present in storm
water discharges in significan
ities. Also provide a
list of any pollutant that is
listed as impaired in the most
recent 303(d) report.
e.
f.
a s pavement or buildings.
the size of the facility
in acres or square feet,
and the percent of the facility
that has impervious areas such
escribing
pollutants in storm
water discharges.
6. The plan shall describe
the storm water management
controls which will
be implemented by the facility. The appropriate
controls
shall reflect identified
existing and potential sources of
pollutants at the facility.
The description of the storm
water management
controls shall include:
Storm Water Pollution
Prevention Personnel - Identification
by job titles, direct telephone
numbers and email addresses of
the
individuals who are responsible
for developing, implementing,
and revising the plan.
b. Preventive Maintenance -
Procedures and frequencies for inspec
devices such as oil/water separators,
catch basins, etc., and inspection
and test
fail
and
result in discharges of pollutants to
storm water.
ce of
storm water conveyance system
and systems that could
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page 20
Modification Date:
NPDES Permit
No. IL0028321
Special Conditions
c. Good Housekeeping - Good
housekeeping requires the maintenance
of clean, orderly facility areas that discharge
storm water.
Material handling areas
shall be inspected and cleaned to reduce
the potential for pollutants to enter the storm water conveyance
system.
d. Spill Prevention and Response -
Identification of areas where significant
materials can spill into or otherwise enter the storm
water conveyance systems and their accompanying
drainage points. Specific
material handling procedures, storage
requirements, spill cleanup equipment and procedures
should be identified, as appropriate.
Internal notification procedures for
spills of significant materials should be established.
Storm
Water Management Practices - Storm water management
practices are practices other than those
which control the
source of
pollutants. They include measures such as installing oil
and grit separators, diverting storm
water into retention
basins, etc. Based on assessment
of the potential of various sources
to contribute pollutants, measures to remove pollutants
from storm water discharge
shall be implemented. In developing
the plan, the following management practices
shall be
considered:
Containment - Storage within berms
or other secondary containment devices
to prevent leaks and spills from ente
water runoff. To the maximum
extent practicable, storm water discharged
from any area where material handling
equipment
or activities, raw materials, intermediate products,
final products, waste materials,
by-products, or industrial machinery are
exposed to storm water should not enter
vegetated areas or surface waters or infiltrate
into the soil unless adequate
treatment
is provided.
ii. Oil & Grease Separation -
Oil/water
separators,
boorns, skimmers or other methods to minimize
oil contaminated storm
water discharges.
Debris & Sediment Control - Screens, booms, sediment
ponds or other methods to reduce debris and
sediment in storm
water discharges.
I Disposal - Waste chemicals such as antifreeze,
degreasers and used oils shall be recycled or disposed
of
proved manner and
in a way which prevents them from entering
storm water discharges.
Storm Water Diversion
- Storm water diversion away from materials
manufacturing, storage and other areas of potential
storm water contamination. Minimize the
quantity of storm water entering
areas where material handling equipment or
ities, raw materials, intermediate products,
final products, waste materials,
by-products, or industrial machinery are
exposed to storm water using green
infrastructure techniques where practicable
in the areas outside the exposure area, and
otherwise divert storm water away from the
exposure area.
vi. Covered Storage or Manufacturing Areas -
Covered fueling operations, materials
manufacturing and storage areas to
prevent contact with storm water.
Mercury Switch
Removal and Recycling - Mercury-containing
convenience lighting switches
and anti-lock brake assemblies
shall be
removed from vehicles, and recycled in an approved
manner, in a way which prevents mercury
from
entering
the
storm water discharges.
uetion -
Install vegetation on roofs of buildings within and
adjacent to the exposure area to detain and
runoff; capture storm water in devices
that minimize the amount of storm
water runoff and use this water as appropr
based on quality.
evapotranspirate runoff where the precipitation
falling on the roof is not exposed
to contaminants, to minimize storm
water
f. Sediment
and Erosion Prevention - The plan shall
identify areas which due to topography,
activities, or other factors, have a high
potential
for significant soil erosion. The plan shall describe
measures to limit erosion.
g. Employee Training -
Employee training programs shall inform
personnel at all levels of responsibility
of the components and
goals of the storm water pollution
prevention plan. Training should
address topics such as spill response, good housekeeping
and material management practices.
The plan shall identify periodic dates
for such
fir
Page 21
Modification
Date:
NPDES
Permit No. IL0028321
Special Conditions
h. Inspection Procedures - Qualified
plant personnel shall
be identified to inspect designated
equipment and plant areas.
A
tracking or follow-up procedure
shall be used to ensure
appropriate response
has been taken in response to an inspection.
Inspections and maintenance
activities shall be documented
and recorded.
7. Non-Storm water Discharges - The plan
shall include a certification
that the discharge has been tested or
evaluated for the presence
of non-storm water discharges.
The certification shall include a description
of any tests for the presence
of non-storm water
discharges,
the methods used, the dates of
the testing, and any onsite drainage
points that were observed during
the testing. Any
facility that
is unable to provide this certification
must describe the procedure
of any test conducted for the presence
of non-storm
water discharges,
the test results, potential sources
of non-storm water discharges to
the storm sewer, and why adequate
tests for
such storm sewers
were not feasible. Except as provided
in C.1. b., discharges
not comprised entirely of storm
water are not
authorized by this permit.
8. Quarterly Visual Observation
of Discharges -The requirements
and procedures for quarterly
visual observations are applicable to all
facilities covered under this
permit, regardless of your sector
of industrial activity.
You must perform and document
a quarterly visual observation
of a storm water discharge associated
with industrial activity from
each outfall. The visual observation
must be made during daylight
hours. If no storm event
resulted in runoff during daylight
hours from the facility during
a monitoring quarter, you are
excused from the visual observation requirement
for that quarter,
provided you document in your records
that no runoff occurred.
You must sign and certify the documentation.
b. Your visual observation must be
made on samples collected as soon
as practical, but not to exceed 1 hour of
when the runoff or
snowmelt
begins discharging from your facility.
All samples must be collected
from a storm event discharge that
is greater than
0.1 inch
in magnitude and that occurs at
least 72 hours from the previously
measurable (greater than 0.1
inch rainfall) storm
event.
The observation must document:
color, odor, clarity, floating
solids, settled solids, suspended solids,
foam, oil sheen,
and
other obvious indicators of storm
water pollution. If visual observations
indicate any unnatural color,
odor, turbidity,
floatable material,
oil sheen or other indicators
of storm water pollution, the permittee
shall obtain a sample and
monitor for the
parameter or the
list of pollutants in Part E.5.d.
aterials or activi
d.
requirement
at a facility that is inactive and unstaffed,
as long as there are
ite is i
If you
exercise this waiver, you
must maintain a certification with
industrial materials
or activities exposed to storm
Representative
Outfalls - If your facility
has two or more outfalls that
you believe discharge substantially
identical effluents,
based
on similarities of the industrial
activities, significant materials, size
of drainage areas, and storm
water management
ithin the drainage areas
of the outfalls, you may conduct
visual observation of the discharge
at just one of
outfalls and report
that the results also apply
to the substantially identical outfall(s).
f. The visual observation documents
II be made available
to the Agency and general
public upon written request.
9. The permittee shall conduct an
annual facility inspection to
verify that all elements of the plan,
including the site map, potential
pollutant sources, and structural and
non-structural controls to reduce
pollutants in industrial storm
water discharges are accurate.
Observations that require a response
and the appropriate response
to the observation shall be
retained as part of the plan. Records
documenting significant observations
made during the site inspection
shall be submitted to the Agency
in accordance with the
reporting
requirements of this permit.
10. This plan should
briefly describe the appropriate
elements of other program
requirements, including Spill Prevention
Control and
Countermeasures
(SPCC) plans required under Section
311 of the CWA and the
regulations promulgated thereunder,
and Best
Management Programs
under 40 CFR 125.100.
y our visual observation reports
onsite with the
SWPPP.
The report must include the observat
c tion personnel,
nature of the discharge
(i.e., runoff or snow melt),
visual quality of the storm water
bservations
of color, odor, clarity, floating solids,
settled solids, suspended solids,
foam, oil
of storm water pollution),
and probable sources
of any observed storm water contam
e xercise a waiver
of the visual observa
is considered a report
that shall be available to the public
at any reasonable time upon
request.
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Page 22
Modification
Date:
N PDES Permit No. IL0028321
Special Conditions
12. The plan shall include the signature and title of the person
responsible for preparation of the plan and include
the date of initial
preparation and each amendment thereto.
13. Facilities which discharge storm water associated with
industrial activity to municipal separate storm sewers may also
be subject to
additional requirements
imposed by the operator of the municipal
system.
REPORTING
1 . The facility shall submit an electronic
copy of the annual inspection report to the Illinois Environmental
Protection Agency. The
report shall include results of the annual
facility inspection which is required by Part 9 of the Storm
Water Pollution Prevention Plan of
this permit. The report shall also include
documentation of any event (spill, treatment unit
malfunction, etc.) which would require an
inspection, results of the inspection, and any subsequent
corrective maintenance activity. The report shall be completed
and signed
by the authorized facility employee(s) who conducted
the inspection(s). The annual inspection report
is considered a public
document that shall be available to the public at any
reasonable time upon request,
2. The first report shall contain
information gathered during the one
year time period beginning with the effective date of coverage under
this permit and shall
be submitted no later than 60 days after this
one year period has expired. Each subsequent report shall
contain
the previous year's
information and shall be submitted no
later than one year after the previous year's report was due.
3. If the facility performs
inspections more frequently than required by
this permit, the results shall be included as additional information
in the annual report.
4 . The permittee shall retain the annual
inspect
E nvironmental Protection Agency
at any time.
port on file at least 3 years.
This period may be extended by request of the Illinois
itted to
the follow
Illinois Environmental Protection Agency
Division of Water Pollution Control
Compliance Assurance Section #19
Annual Inspec
P .O.
Box 1927
Springfield,
Illinois 62794-9276
ng email and office addresses:
5. Any permittee shall
notify any regulated small municipal separate
storm water system owner (MS4 Community) that they
have
received coverage of
a general ILR00 permit. The permittee
shall submit any SWPPP or any annual inspection to the
MS4
community upon request
by the MS4 community.
I
District of Decatur
DES Permit Modification Request Application
January
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
January 12, 2009
t of Decatur
501
DIPPER LANE - DECATUR, ILLINOIS 62522 - 2171422-6931 - FAX: 21714236171
VIA CERTIFIED MAIL
t Requested)
Mr. Alan Ke
ager
Permit Section
of Water Pollution Control
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Boy: 19276
agfield,
Illinois 62794-9276
Dear Mr. Keller:
cation Request
t of Decatur requests
a s follows;
al Cond
to our current
18 of the permit,
( 1) Interim Report on effluent and strearn
sampling to date and what measures
are
11
4n
in
necessary to comply with Final
Nickel and
Zinc
Limitations
6
in mths from the effective
date
of this
Permit (Completed)
(2)
_
Interim Report
_
12 months from the effective date of this
Permit (Completed)
( 3) Interim Report
18 months from the effective date of dais
Permit (Completed)
(4) Interim Report
July 1, 2009
( 5) Interim
Report
ý
January 1, 2010
(6) Interim Report
ý
ýý
July 1, 2010
-
W
(7) Interim Report
January 1, 2011
-Y
(8) Interim
Report
July 1, 2011 .
(9) Interim Report
_
January 1, 2012
(10) Pe> nittee Achieves Compliance with
Final Nickel and Zinc Effluent Limitations
July 1, 2012
the
July 1, 2007 reissuance of our permit, the District has diligently pursued
compliance
with the nickel and zinc effluent limits. Cur efforts are detailed
in in
reports submitted
on December 20, 2007, June 18, 2008, and December 29, 2008 and
translator study, results from extensive sampling
at our plant and industrial users,
and
related information have been
movided
to Illinois EPA,
is
ed in our December 4, 2008 meeting
with Illinois EPA personnel. A metals
t
limit
without changes to treatment processes, operations (in particular,
operations at
ustrial
users), o
industri
is from AD
of the water quality standard.
Several
ve the potential to discharge nickel, but by far the
largest contribution
Despite extensive good faith efforts, changes in operations
or treatment
-ocesses
at ADM that would meet the nickel limit have yet to be identified.
A summary
of
ADM's
investigations is enclosed. We have calculated pretreatment
local limits that
would enable
our discharge to meet our permit limit; ADM's local limit
for nickel would
./day, or approximately one-third of their current
discharge.
wastewater
at the
0 from cooling towers was the largest source
fining cooling tower
treatment
yes
were in use at both ADM and at Tate & Lyle.
eliminated
zinc from their cooling tower treatment
ers have
This
change has greatly
c usage; however, the impact of a reduced zinc limit
still being evaluated. One pa
industrial
on sludge
wasting
from ADM's pretreatment system.
,
of additional adjustments
to the current
ars per gallon of treatment capacity, not including the
cost of any additional
,atially feasible means of treatment to remove
nickel. This estimate is four to
e information shows that we
cannot meet the perm
t required or the cost of brine management.
Determining the point where
e obtained a very preliminary capital cost estimate
for reverse osmos
treatment of a signi
flow would
lil
analysis.
flow or the District's 41
e time would
be utilized
to continue
all of the
escribed above,
as well as possibly o
nt at
this time is that compliance will require some combination of source
ion, treatment, and regulatory relief'. We believe that an extension
of three
additional
years would be required to develop and implement a compli
el and zinc,
that the followin
v
ironniental P rotection Agency (" IJSEPA" ) guidance i
7
should be analyzed to determine whether a compliance
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
schedule is appropriate: how much time the discharger has already
had to meet the Water
Quality Based Effluent Limits ("WQBELs") under prior peiznits; the extent to which the
discharger has
made good faith efforts to comply with WQBELs and other requirements
in its prior permits;
whether
there
is any need for modifications to treatment facilities,
operations or measures to
meet
the WQBELs
and if so, how long would it take to
implement the modifications to treatment, operations
or
other
measures; or whether the
discharger would be expected to use the same treatment facilities,
operations or other
measures to meet the WQBEL as it would have used to meet the WQBEL
in its prior
from James A. Hanlon, Office of Wastewater Management,
USEPA,
regarding Compliance Schedules :For Water- Quality-Based Effluent
Limitations
its (May 10, 2007). Additionally, Illinoi
on compliance schedules. 35 Ill. Admin. Code
§
309.148.
As discussed above, the Sanitary District of Decatur has made good-faith efforts
to
all effluent limits by investigating compliance concerns and researching
since compliance may require changes to processes
or
st an extension to our compliance schedule.
A dditionally;
t
hat the water quality standards at the root of this request
orated into this NPDES permit, and there is no history of
ous compliance issues in prior permits.
2.
Include authorization for discharges of storm water from the District's mai
plant site. A Storm Water Pollution Prevention Plan is enclosed.
3. Reinstate
CSO Outfall 006. This outfall disc
barges
to Stevens Creels and is similar
to
fýe,+
during extreme rainfall events
when
capacity. We request
ondition
15.
A copy
consideration of these requested
p
itional informa
17) 422-6931
ext.
214 or by emai
Enclosures: ADM Investigation Sunnnary
Storm Water Pollution Prevention Plan
EPA Form 3510-2A
Archer Daniels
Midland
Company - Decatur, IL Complex
Summary of Ni & Zn Reduction Efforts
In
January
2008, the Sanitary District of Decatur (SDD) notified
ADM of tightened nickel (Ni) and Zinc
(Zn) water quality limits included in its reissued NPDES permit
for its Decatur Complex. Based on sam
conducted by the SDD, ADM was identified
as a significant contributor of both Ni and Zn. The
SDD requ
ADM
to comply with the new limits
by July 2009.
The Decatur Complex consists of multiple,
separate processing plants which discharge their
wastewater to an on-site pre-treatment
facility operated by the Corn Plant. These processing plants
consist of
a Wet Corn Mill, BioProducts, Cogeneration, two Soybean Processing
plants, Vitamin E, Corn Germ Processing
and Polyols. Each of these unique plants produces multiple
products, using both batch and continuous
processes, and creates wastewaters
which generally are reused multiple times prior to being
discharged to the
onsite treatment
plant.
The wastewater treatment plant (WWTP) treats
approximately 11 million gallons per
day through a newer anaerobic treatment system
followed by aerobic treatment prior to discharge to the
SDD.
Due to the high wastewater flow and very low concentrations
of Ni and Zn in the final effluent,
ADM
concluded that reductions in Ni and Zn would
need to be accomplished at the source. Thus,
in
January
2008
ADM began identifying possible sources of the metals through
Complex-wide sampling and a preliminary
inventory of chemicals and processes that contained the metals.
Through testing ADM was able to eliminate
raw water as a source. Further,
based on process knowledge, ADM initially believed that
the
only source
of nickel
was from the sorbitol process (nickel-catalyzed
hydrogenation) and the zinc was from
cooling tower water chemical additives.
t he SDD informed ADM that the lim
ificant
since the insoluble
po
pling conducted through May was
I' rather than `soluble' basis.
That change is
n in the final effluent
is
approximately
25°% and 75°%,
respectively. This change in measurement
reach appro
`total' basis.
mpling completed w
lusions and could
not be used for data comparisons with future data collections on
a
Second, ADM encountered a problem
with its sample analysis procedures.
ADM became
concerned
zinc data was not making sense. Upon
investigation ADM's research laboratory
learned that the lab
filters used in the zinc analysis contained zinc themselves
which was leaching into the filtrate. This
issue took several weeks to identify and confirm the filters as
the problem. It then took several additional
weeks to find suitable filters to meet the
testing requirements. Periodic split samples
are now also taken for
both Ni and Zn to confirm results
with an EPA approved laboratory.
Third, in addition to known chemical and processing
aids that contained these metals, ADM learned
that there are major sources of
Ni
and
Zn that had not initially been considered. Soybeans
can
contain
approximately 4.1 ppm Ni and
approximately 46 ppm Zn, while corn can contain
approximately 0.53 ppm Ni
and approximately 32 ppm Zn. Given that the Complex processes
approximately 550,000 bushels of corn and
200,000 bushels of soybeans per day, this means
that 15 times more Ni and 25 times
more Zn
than ADM
would be allowed to discharge comes
into
the
Complex just through its raw materials.
Other "non-traditional"
sources were also identified such as the 50% Sodium Hydroxide
(NaOH) which is used in various processes in
Page 1 of 4
01/07/09
the Complex. This material contains small concentrations of Ni but since the Decatur Complex
uses nearly 6
million pounds of NaOH per month, the contribution of
additional Ni to the plant wastewater system is
significant.
While the first half of 2008 focused on the identification of nickel and zinc sources, during this time
ADM also began evaluating various means to reduce or eliminate sources of the metals. Overtime, the
emphasis began transitioning from sampling and identification to identifying and trialing potential
methods to
reduce or eliminate the metals. Following are discussions of these activities to date for both Ni and Zn.
Zinc
The
chemicals used in the cooling
tower water treatment program were identified as the largest source
of Zn in the complex. Beginning in May 2008 ADM worked with its chemical vendor to change the treatment
program to eliminate the addition of Zn to the towers. Unfortunately, the Zn did not decrease
as hydraulics
would suggest even
though
no new Zn was being added to the towers. ADM learned that the Zn continues to
leach from the system for months after the addition of Zn containing materials is ceased. Since one of the
BioProducts towers continued to show elevated Zn levels even after the others had improved, ADM
initiated
a higher pH program in August which reduced the amount of Zn leaching from the system and thereby
lowered the Zn in discharge. However, it was still well into the fall before all the towers were generally below
the Zn targets.
To date, ADM has reduced the Zn going to the onsite treatment to levels that are generally less than
the target. Further, some of the upcoming Ni reduction strategies
discussed below should also provide some
additional reduction in Zn levels. However, there are still two issues which concern ADM regarding its ability
to consistently achieve the Zn limits going forward. First, the product mixes produced in the Complex during
the recent sampling are ones which would be expected to result in expected
lower Zn
concentrations than
other potential product
mixes.
Thus,
as product
mixes change (e.g., production of more fructose), the Zn
concentration may again increase. Therefore, additional ongoing monitoring of the effluent will be necessary
ns. The second outstanding issue for Zn is the formation of
Nicke
ssed in more detail below.
ADM had identified early on that the use of Ni catalysts in the Corn Plant's sorbitol process and in the
West Plant were contributors. ADM had previously looked at Ni recovery from the sorbitol
process
by
electroplating in 2006-2007. However, that evaluation
was put on hold due to technical and economic issues.
In March 2008
the Corn
Plant hired
a
Ni consultant to look specifically at Ni recovery at Sorbitol, primarily to
Unfortunately, a number of problems became apparent: low Ni concentration, very high
sodium and chloride levels, chelating resins which are non-food grade, and the presence
of various
other
cations and anions which all led to the conclusion that
electroplating was not a feasible option.
tigation of a high pH precipitation for the sorbitol stream. However,
it was discovered that gluconic acid forms a complex with
Ni which prevents it from coming out
of solution.
While the organic material could be oxidized with ozone
and hydrogen peroxide prior to the precipitat
would necessitate the addition of extreme amounts of additional chemicals and additional processing steps
which make it infeasible. ADM also opened a dialog with the catalyst supplier who was unable to provide any
other options.
Page 2 of 4
01/07/09
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
To learn
more about the
Ni
losses in the Sorbitol
process, testing continued
throughout the year. One
of the consultants ADM had involved in this project identified a potential process change to reduce the Ni
through a combination
of water capture and redirection. A trial of this option was completed in November
2008 with positive results. ADM is proceeding with making the necessary changes to implement the op
which
involves considerable piping installations and modifications. Completion is expected by the end of
quarter of 2009
with testing to determine reductions achieved during the 2"d quarter.
As noted previously, Sorbitol is not the only Ni source in the Corn Plant; the incoming corn also
contains
significant amounts of Ni and Zn. Testing has shown that after the corn milling process, the resulting
starch slurry contains Ni concentrations. This starch slurry is the feed material for many
of the downstream
value-added products including the various sweeteners. After further processing, much of the resulting
sweetener is ion
exchanged. As a result Ni and Zn are present
in the ion
exchange acid waste. Over 501 of
this waste is routed directly to the WWTP
and cannot
be readily treated. While
testing has shown that
a
high
pH precipitation on this waste stream is about 50% efficient on Ni and 85% efficient for Zn, since the Corn
Plant uses approximately
3 million pounds of 3510 Hydrochloric
Acid
a month, it would require millions of
pounds of NaOH (which also contains Ni) or some other base to raise the pH of this waste material to 10 for
the precipitation to occur. As a result, a precipitation option does not appear to be
Following a meeting in December 2008, Illinois EPA provided information to ADM regarding a Ni-
catalyzed hydrogenation facility in northern Illinois as a possible resource. ADM contacted the source and
learned that
their Ni removal technique is high pH precipitation. Further, because of their feedstock, they do
not have a problem with Ni-gluconate complexing. As a result, their treatment system is not transferable
to
ADM's
processes. Illinois EPA also mentioned elect ro-coagulation, which is a process ADM had not
stigated. Discussions were started with an Oregon company that may be able to provide such a system,
and ADM has sent four samples to them for a trial to determine initial viability of the process. Results are
expected in the first quarter 2009.
ADM's East & West Soybean Processing Plants are also significant Ni contributors. The West Soybean
Plant utilizes Ni catalyst in the hydrogenation process. ADM believes that most of the Ni from the catalyst that
makes it into
the waste water originates from the handling of the material and can be reduced through
n
of housekeeping
procedures
specific to
Ni. These practices were implemented
in the spring
of 2008 and continue to be reviewed for effectiveness. Another option being investigated is moving the entire
catalyst
handling system, which ADM believes could result in a decrease in the amount of Ni ente
waste water stream from
that process. The West Plant is also working
with outside
consultants an
to identify any other potential solutions.
The
East Plant is the single largest contributor of Ni in the effluent, and all the Ni is from the soybeans
processed.
Sampling at the East Plant has identified four primary streams containing Ni. One of the four
streams, which is also the lowest flow, contains roughly half the Ni from the plant. The East Plant is exploring
options to find a feed or fertilizer outlet for this waste water stream. Further, ADM Research is assisting
the
East Plant in investigating any process changes or unique Ni removal options that could be viable for the
remaining three
streams.
Efforts
underway at the Corn
Plant
to evaluate electro-coagulation may also allow
for technology transfer to the East Plant if proven successful.
P age 3 of 4
01/07/09
Metal Sulfide Formation in Anaerobic System
In the Spring of
2007 ADM started up a new anaerobic wastewater treatment system to run
with its existing aerobic system. In addition to improved treatment capabilities,
the new plant was intended
to
allow for improved solids management through reduction of the solids and 'wasting' excess solids through
the effluent to the
SDD. In the fall of 2008, sampling confirmed that the new anaerobic treatment system was
contributing to the Ni and Zn found in the final effluent. Insoluble metal sulfides
had been forming in this
system and had built up in the sludge over the past couple of years. Some of the anaerobic sludge carries over
into the aerobic
system. This aerobic/anaerobic sludge is 'wasted' into the effluent to control the solids in the
system. Through sampling and testing, ADM has determined that the Ni
contained in this sludge alone, even
ignoring the soluble Ni component, is greater than the proposed limit while the insoluble Zn
from
the
sludge
could cause the limit to be exceeded
based on the current rate of solids 'wasting.' ADM has made Inquiries
regarding the mechanics of metal sulfide formation in anaerobic
systems and has sought assistance from ADM
Research
and GE Betz Company to address this source of metals. Work is also underway to gather data
to
decide if solids
capture at the digester discharge is a viable control option.
Page 4 of 4
01/07/09
for the
Decatur,
Illinois 62522
NPDES Permit
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
1. Site Description
This
Storm Water Pollution Prevention Plan
(SWPPP) was developed
to meet the
requirements of
the NPDES program requiring permit coverage for storm water
discharges from municipal wastewater treatment
facilities with design flows of 1 mgd or
more. The Sanitary District of Decatur (SDD) treatment plant occupies a site in the
southwestern portion of Decatur (see Figure
1).
Storm
water from
the site flows via
surface drainage and underground pipes
to
one of
five storm water pumping
stations,
and the pumping stations discharge collected storm water to either Stevens
Creek
or
the
Sangamon River.
Figure 1. Location map
Designed to treat an average flow of 41.5 million gallons per day, the SDD facility
includes screening, grit removal, primary settling, two stage activated sludge treatment,
chlorination/dechlorination,
and anaerobic sludge digestion.
Treated effluent is
discharged to the Sangamon River. District maintenance
and administration
facilities
are
also
located at the site. Digested sludge is transferred to
the
Wyckles Road solids facility
for storage prior to land application.
"No Exposure" certifications have been completed for the Wyckles Road site and four
combined sewer overflow treatment facilities.
The treatment units and facility
equipment are designed to contain wastewater and
sludge so
that storm water is not affected by wastewater treatment operations. However,
a few areas exist where "industrial equipment' 'as described
in
federal
regulations
is
exposed to storm water. A potential also exists for
releases
of
wastewater,
sludge, and
chemicals used
in the treatment process to occur
in the event of a pipe, tank, or pump
failure. This plan describes actions taken to prevent both normal operations and
accidental releases from impacting storm water discharged to receiving waters.
2 . Topographic Map
A topographic map of the SDD site is
shown in Figure 2. Wells numbered 00258, 00259,
00857, 00858, and 00860 are shown on the plant site or within one-quarter mile of the
plant boundary. These wells were installed by SDD for site dewatering, and are not used
as water supply wells.
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
3. Site Map
A
site map showing storm water piping, inlets, discharge
points, paved areas,
b
uildings,
and
drainage basins is attached. Due to the size and
complexity of the facility, areas used
for material
storage,
loading, and handling are not shown on the map but are described in
the narrative below.
t ment plant site is surrounded by a flood protection levee and nearly all storm
water from the site is tributary
to
one of five storm water pump stations. The exceptions
are the West Central and
Northwest
drainage basins; limited amounts of storm water
from these vegetated areas flows through surface ditches to Stevens Creek. For
reference, the drainage basins and associated pump stations are shown in the following
table.
Drainage Basin
Storm Water Pump Station
Inner Plant
_
West (Structure 261)
Northeast
Northeast (Laydown
Area)
Northside
_
North (Structure 218)
Northwest Side ý--_
Gravity flow to Stevens Creek -- ---
_
South Side
South (Structure
263)
Southeast
East (Structure 216)
Upper East Side
Underseepage (Structure 215) to East (Structure 216)
.--
West Central
ýý
Gravity flow to Stevens Creek
West Side
West
(Structure 261)
----
4. Narrative Description of Significant Materials and Chemicals
The following materials are present at the SDD treatment
roperly managed, contaminate storm water discharged front
Under normal operati
c hannel
ite and could, if
onditions, wastewater
is contained in underground pipes or
1
n
d
will
not be
a source of storm water contamina
esult in overflows to the ground surface.
old phase headworks influent channel
following a power
plant grounds. Du
discharges can be avo
iping leading to pooling of sludge on the
and similar occurrences, contamination of
storm
water
by shutting down the impacted
storm water pumping station
or
c ted and
returned to a process tank.
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
b. Septage
adjacent to the influent channel and discharge directly into the
influent channel.
Facilities for cleaning the area are readily available
and used on a regular basis
to keep
the area
clean. In the event of a spill both the Northeast and Southeast drama
could be impacted,
depending on the volume released. Contamin
discharges would be avoided by
shutting down the
impacted
storm water pumping station
or stations until the wastewater can be returned to a process tank.
c. Screenings; grit
Two separate screening and
grit removal facilities exist, one each for the old phase and
new phase. All screens, grit handling facilities (except
for the grit settling tanks), and
stored materials are indoors. Screenings and grit are collected in dumpsters
and picked
d. Ferrous
chloride
The solution is delivered in tank trucks and stored in a tank within
a concrete secondary
A valved drain line from the secondary containment area is
Underseepage
ills; uncontaminated storm water is released to the
outside the structure during unload
empty drums, and associated pallets are temporari
same location and would be managed by shutting down the pumpin
age and grease trap
cks bringing materials to
the
plant
park on a paved area
215). Any materiE
a terial was removed.
e . Caustic soda; odor mas
These two liquid materials are
are managed to meet the "no exposure" criteria in federal guidance.
e,
sodium bisulfite
Liquid sodium hypochlorite
solution is used for effluent disinfection fro
through October 31. The solution is delivered by tank truck and unloaded into
storage
tanks located under roof in Building 44. A plant operator is present for deliveries
of
hypochlorite and other bulk chemicals. A spill during unloading would flow to storm
water drains located in the roadway north of the buil
area,
and would be manage
ed material
was removed. Hypochlorite solution is pumped through underground
piping to
a
second
set of storage tanks in Building 264, located near the south plant levee.
and pumps
are under roof and located within a concrete contaimnent
s tructure. A spill
within the containment structure would not reach storm water.
S odium bisulfate solution is also delivered by tank
truck and is stored in tanks located
inside Building 334. A spill during unloading would
be in the South side drainage
and would be managed
by shutting down the pumpnnt
was removed.
g. Polymer totes
Polymer used in the waste activated sludge
DAF units is received in 2300-lb.
polyethylene tote bins. Full
totes are kept inside the polymer building. Empty totes are
stored on the pavement outside Building 043 until picked up by the supplier. The
empty
totes are managed to meet the "no exposure" criteria in federal guidance.
id storage tanks are provided for gasoline and diesel
putt during bul Etetivery of
Diesel fuel for the Building 203
i th the bases
o rs. A release
from
the
Building 203 tank
er pump
station and a release from the
for tank would likely be conta
ay.
An above-ground kerosene storage tank is used to store fuel for small
portable heaters
cations as needed. t rte tanK is on the west stete of
buttatng t t / ana
a
tributary to a drain in the Inner plant drainage basin and
the West Side
Waste oil is stored in an above-ground
tank west of the DAF building.
would likely occur only
0
shutting down the pumping station
the Inner plant
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
i.
her of other materials and chemicals including lubricants, paint, solvents, cl
icides,
are used
in plant operations and maintenance. All of these
smaller
stored
within buildings and are not exposed to storm water.
hicle Management
The majority of process equipment is either inside buildings (i.e. most pumps, blowers,
n locations where storm water that contacts the equipment enters process
a. Odor Control Units
clarifier drives and flow control gates).
ith top-mounted fans treat air fiom covered channels in
as. The carbon is contained within the units and they are
a source of storm water contamination.
Several locations exist
area near the plant entrance is used to store three land ap
materials such as pipe, fittings, pallets, and some used equipment. The equipment and
materials in this area have been observed to contribute few if any contaminants to storm
utary to the Northeast storm
water pump
station and
of a potential
lnox aeration
north side and south side of the
waste sludge hold
ination exists
from this
stored equipment.
c . Vehicles
for plant operations, in
licensed vehicles a
automobiles, pickup trucks, and vans to semi tractors and trailers
used for land application of sludge, equipment hauling, and sewer or pump station
maintenance.
Smaller
vehicles
and
equipment include
lawn mowers, tractors, and
forklifts.
ante and repair for over-the-road vehicles is performed off-site at
cilities. Any minor maintenance done at the plant is completed in the
shop or vehicle storage building. Maintenance on other vehicles
icles are kept in good repair
and, except for semi
source of stonn water contamination.
6. Waste
materials
a. Trash dumpster
box for general refuse from the plant is located in a fenced area at the west side
area tributary to the West storm water pump station. The potential for
ated storm water from this area is minir
b. Vactor drain area
The District uses a
Vactor
truck for sewer cleaning and maintenance, and an area is
provided at the north
side of the plant
for receiving
the truck's contents after completion
of a job. A three-sided concrete structure is provided to contain large solids (i.e. plastic
bottles, bags, sticks) and underdrains collect the water, conveying it to a pump station
o the plant influent. The potential for contaminated storm water from this area
Storm
Water
Controls
Specific controls are de
tion sources,
lev
stored and
8. Facility Size and Im
The area within
the
s. Virtually all storm
areas and from relatively clean pavement,
area is irnnervious sur
9. Existing Sto
0 acres.
Less than
five percent of this
Storm water sampling has not been conducted in the past and no analysis results are
l regulations do not require sample data to be
they relate to poter
ions from POTWs.
10. SWPPP
Coor
sponsibilities for the pollution prevention team.
ible for implementing the Storm Water Pollution
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
Leader: Tim Kluge
Office
e : (217) 422-6931 ext. 21.4
Cell Phone: (217 620-2033
onsibilities:
Coordinate all stages of plan development, inspections and
implementation; keep all records and ensure that reports are submitted; conduct
inspections and oversee sampling program; oversee good
housekeeping
activities.
O c c Phone: (217) 422-6931 ext. 257
ions Supervisor
Cell Phone: (217) 433-8391
Responsibilities: Operate the storm
water pump
SWPPP; conduct operations staff
training; serve as spill response coordin
inspections.
hone: (217) 521-1918
Responsibilit
7) 422-6931_ ext. 221
Cell Phone: (217}_620-8624
Responsibilities: Assist w
a. Preventive Maintenance
nd training program.
acilities
and equipment is well establis
documented in a computerized maintenance
management system.
good
repair to prevent leaks, and storage tanks and other containers are routinely checked
for leaks. Paved areas and plant grounds are kept clean to prevent storm water
b. Good
In general, good housekeeping prac
include returning of
vehicle
and
equipment washwat
secondary
contaimnent
for bulk chemicals, indoor storage of materials, indoor fluid
imely cleanup of any spills, and proper waste material storage. The following
ovements are planned for implementation within the next year:
1) Dumpster - This storage area is generally
well kept, but
additional efforts
will
be
made to ensure that no materials are stored outside the dumpster.
2) Vactor drain area - Plastic bottles and bags occasionally blow out of this area
after the solid material has dried. Improved housekeeping procedures will be
implemented.
orage tank
- This tank currently has no secondary containment. A
c. S
containment structure or relocation of the tank will be considered.
4)
sene storage tank - Elimination of this tank is being conside
plant must be pumped to the receivin
g un
es, therefore, the response to a
.", . Y
1
r emoved. This generalized procedure will be described
in greater detail in a written spill
response plan within the next year.
rotection
and sediment loss from
the
site
d areas, a plan
ion is maintained so that erosion
al. Should constru
incorporating applicable requirements o
ill be implemented.
e. Employee Training
Employee training
will
be
completed upon completion of the spill response plan
described
above,
and annual refresher training will also be instituted at that time.
be provided for all plant operations
addition, any significant modification of the spill response plan will be followed by an
employee training session.
ility Inspection Schedule
ions require an annual inspection of the facility to verify conditions
described in this SWPPP. The first inspection will be scheduled within one year of the
date the SDD permit is modified to incorporate storm water requirements. An inspection
report will be send to the Illinois EPA within 60 days following the inspecti
will follow at one-year intervals. In addition, ongoing
reviews will
be
1 0
Electronic Filing - Received, Clerk's Office, June 15, 2009
* * * * * PCB 2009-125 * * * * *
conducted during the year to ensure
that operations do not result in storm
water
Appropriate
inspection documentation will be maintained as
required by
conditions.
ements
While good spill prevention practices are
followed and spill control planning is a part of
this SWPPP, the SDD does not have
oil storage facilities that would trigger the SPCC
plan requirements under Section
311 of the Clean Water Act. Also, the Di
NPDES permit does
not contain any BMP requirements as described in
40
CFR
125.1.00.
14.
ature
This Storm Water Pollution Prevention Plan has been prepared
in accordance with good
engineering practices. Qualified personnel
properly gathered and evaluated information
submitted for this plan. The information
in this plan, to the best of my knowledge, is
accurate and complete.
!JJLJýY-
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
N OTICE OF INTENT (N01)
F OR
GENERAL
PERMIT TO DISCHARGE STORM
WATER
ASSOCIATED WITH INDUSTRIAL ACTIVITY
(EXCLUDING CONSTRUCTION ACTIVITY)
OWNER/OPERATOR INFORMATION
LAST
FIRST
MIDDLE INITIAL
(OR COMPANY NAME)
O WNER T YPE:
N AME:
Sanitary
Dist. of
Decatur
special
district
. MAILING
A DDRESS:
501 Dipper Lane
CITY:
Decatur
STATE: J)
ZIP:
62522
CONTACT
T ELEPHONE
Tim
Klu e
A REA CODE
NUMBER
PERSON.
g
NUMBER:
2 17
422-6931
F ACILITY/SITE INFORMATION
S ELECT
127
NEW SITE [] RENEWAL 171 CHANGE OF INFORMATION TO GENERAL NPDES PERMIT NO.: ILR00
ONE:
F ACILITY
S
anitary District of Decatur
N PDES
N AME:
PER M NUMBERS:
IL 0028321
FACILITY
ý ý
501
Dipper Lane
T ELEPHONE
AREA
CODE
217
N UMBER
L OCATION:
N UMBER:
422 - 6931
O ECa.
MIN,
C
O EG.
MIN,
SEC.
CITY:
I
Decatur
ST: IL ZIP:
62522 I
LATITUDE:
1
39 49
1
;S
E
56
ONGITUDE:
89
00 07
COUNTY: I
Macon
SECTION: 17
TOWNSHIP:
1 6N
RANGE:
02E
)
S IC OR DESIGNATED
-
PRIMARY
T_
2 ND
3RD
.ý
4TH
ACTIVITY CODE(S):
ý
4952
STORM
WATER
POLLUTION PREVENTION
PLAN
COMPLETED M YES
EI
NO (IF NO, SEPARATE NOTIFICATION REQUIRED TO
AGENCY
PRIOR
TO
COVERAGE LETTER SENT BY AGENCY)
TER INFORMATION
ATTACH A LIST OF MATERIAL HANDLING ACTIVITIES, RAW MATERIALS, INTERMEDIATE PRODUCTS, FINAL PRODUCTS, WASTE
MATERIALS, BY-PRODUCTS OR INDUSTRIAL MACHINERY THAT IS EXPOSED TO STORMWATER.
ATTACH
A LIST IF YOU HAVE OTHER INDUSTRIAL ACTIVITIES TAKING PLACE AT YOUR FACILITY NOT COVERED BY THE ABOVE SIC
CODES.
FORM 2-F ATTACHED
0 Yes
C
No (SEE INSTRUCTIONS)
I certify under penalty of law that this document and all attachments were prepared under my direction and supervision
system
designed
to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my
person or persons
who manage
this system, or those persons directly responsible for gathering the information, the information submitted
is,
to the best of my knowledge and belief,
true,
accurate, and complete. I am aware that there are significant penalties for submitting false
information,
including
the
possibility of
fine
and imprisonment. In addition, I certify that the provisions of the permit, including the
development and implementation of a storm water pollution
prevention plan and a monitoring program plan, will be complied with I
also
certify that, to the best of my knowledge, the storm
water which is
discharged
from this facility/site does not contain process wastewater,
domestic wastewater, or cooling?water.
T itle:
7
M AIL COMPLETED FORM TO:
(DO NOT SUBMIT ADDITIONAL
DOCUMENTATION UNLESS
REQUESTED)
I nformation requir
being
denied. This to
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
DIVISION OF WATER POLLUTION CONTROL
ATTN: PERMIT SECTION
POST OFFICE
BOX 18276
SPRINGFIELD, ILLINOIS 62784-8276
www.epa.state.il.us
Date:
/ ? (C'J
F OR OFFICE USE ONLY
LOG:
PERMIT NO. ILR00
DATE:
s t be provided to
comply
with 415 ILCS 6/39
(1986). Failure to do so may prevent this form from being processed and could result in your application
eon
approved
by
the Forms Management
Center.
IL 532 2103
WPC 622Rev. 4104
Exhibit
J
ary District of Decatur Email Providing
Supplemental Information to Illinois EPA
April 3, 2009
Katherine Hodge
F rom:
Tim Kluge
[TIMK@SDD.DST.IL.US]
Sent:
Friday, April 03, 2009 1:17 PM
To:
Sonjay.Sofat@illinois.gov
Cc:
Rick.Pinneo@a
illinois.gov; AI.Keller@illinois.gov; Katherine
Hodge;
Joe. Koronkowski@illinois.gov
Subject:
Additional information for Permit Modification Request
Attachments:
IEPA mtg_re_Nickel
&_Zinc.doc; Interim_Report_Ni_and_Zn
Limits.doc;
Translator_Study_forEPA
Jan_2008.doc; Ni_Zn_email_fromScott_Twait-1 02_08.pdf;
Iterim_Ni_Zn_report_June_2008.doc;
Iterim_Ni_Zn_report_December_2008.doc;
Nickel Zinc Overview
L
..i
-
IEPA_mtg_re
Inte
kel
& Zinc.dc4i_a
Rep Translator St Ni_Zn_email Iterim Ni_Zn Iterim_Ni_Zn Nickel-Zinc
Lir for EPA_Jann_Scott_Twaiiort
June 20(brt_Decemberrview-01-0i
Sonjay:
l imits for nickel and zinc
based on standards adopted after
issued.
I was not involved with an,/ discussions at the
ti.m
permit was reissued, but it is my understanding
that both Illinois
personnel. anticipated that
completion of the trans
os
lead to
a higher limit that the District would be a
Work on the translator study began in March 2007 anal
continued through November. As the
study progressed, it became clear
you requested additional information to
help support the
Within 1-2 months after the permit effect
s howed that, as expected, the source
of nickel :9 _n the District's
wastewater
pretreated industrial flow and the most significant
sources of zinc were
from both ADM and
Tate
&
Lyle. I have attached a summary of sample data that
was g
IEPA personnel when we met on October 30, 200`1. Personnel
from ADM and Tate & Lýyle were
of the District's
nickel and zinc limits in Auqust and September
2007,
Other acti
December 20,
Scott
Twait pr
January 2, 2008
of
the
ulated nickel and
zinc
(email attached).
8 are summa
of Decatur's request to
modify the compliance schedule for nickel and zinc
in our NPDES Permit. The permit was reissued in April 2007 and contained
new
) . Early
D istrict calculated
new pretreatment limn
fluent limits for
kel and zinc. These proposed limits
Lyle and
were
was
for nurrcerous discussions
with the
their use of zinc
a.oris
ify
hnolog
ed with our permit modificat
tigate different
treatmen
1, ADM's efforts to
quest.
r eference.
including a recently-completed
trial of electrocoagulation
Unfortunately, it
was found that the process actually
anon,
possibly due to nickel
in the electrode used in the
process.
Additional t
change, a flow-based lim
the
District to investigate opt
stigate
process changes
logy, as well
as to allow ADM to continue
eatment options.
Regarding treatment options
for
f a portion of the effluent
flow is the only
I
treatment technology
identified to meet the current ni
perspective, the consulting firm
Black and Veatch has
capital cost estimate
of $4 per gallon for RO treatment,
disposal and operating costs. Approximately
liance
period of more than two years
25 mgd of the District's
flow would need to be treated to meet the proposed
pe
l imit
o f 0.016 mg/L, resulting in a a capital.
cost of $100 million not considering brine
disposal.
This exceeds the construction cost of the District's entire plant,
to achieve a
removal. of approximately six pounds per day of
nickel from the effluent. Additionally,
upstream flows are
sufficient during all but very dry periods to allow
the water quality
standard to be met at current discharge
levels. We believe the magnitude of this
expenditure justifies
additional time to investigate all options to achieve
compli
Although the
District has diligently pursued meeting
nickel and zinc permit limits, the
process has been much more complex
that. either the District or the Agency
initially
believed
it would be. The possibili
would be needed was discussed
when
mit. To provide a sense of
District a preliminary
not considering the
cost of bri
o nnel met in October
2007. At
that time,
we were advised that a request
p remature, but could
background
information
modification request.
permit compliance schedule was
I hope this additional
ication to
support our
If you have any questions or need additional
information, please feel free to contact
me
by email or phone at
422-6031 ext. 214.
T im
