00316
I CITIZEN GUIDE
OCLC19175746
How to Protect Illinois's Environment
Through Surface Water Discharge Permits
NOVEMBER 1982
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Water Should be Safe Enough to Protect
Life
Recreation
Environment
Introduction
It is illegal to discharge wastewater to Illinois lakes and
streams without a permit issued by the Illinois
Environmental Protection Agency (IEPA). These National
Pollutant Discharge Elimination System (NPDES) permits
place limits on the amount of pollution that can be
discharged and require periodic measurement and analysis
of wastewaters to determine if limits are being met. This
booklet explains how the State of Illinois issues permits,
detailing the responsibilities of various units of
government, and describes how citizens can participate in
the permitting process.
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TABLE OF CONTENTS
Part I
The Permitting Process
Relevant Statutes 5
Permit Issuance Authority 5
Application for a Permit 6
Processing of Permits by the IEPA 7
Review for Completeness 7
Preparation of Draft Permits 8
Permit Comments 11
Review by USEPA 12
Preparation of Final Permit by IEPA 12
Compliance and Enforcement 12
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Part II
Citizens Comments on NPDES Permits
Can Be Effective
Why this Booklet is Important 14
What you need to do 15
Acquire and Organize Information 10
Evaluate the draft NPDES Permit 24
Prepare and Submit Permit Comments 31
Participate in Public Hearings 31
Encourage Others to Participate 32
Monitor Permit Compliance 33
Appendix A
Toxicity Guidance Table 35
Appendix B
Illinois Water Quality Standards 40
Appendix C
List of IEPA District Offices 42
Appendix D
Frequently used calculations 44
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Part I
The Permitting Process
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I. Relevant Statutes
A discharger must obtain a final NPDES permit
before releasing any pollutants into the state's
waterways. The key statutes controlling surface water
discharges are:
A. Federal Law
The Clean Water Act. P.I,. 92-500 of 3972 as
amended by P.L. 95-2l?«{33 O.S.C. §§ 1251,
et. sej.)
B. Illinois Law
Environmental Protection Act, Elinois Bevised
Statutes, Chapter IE 1/2, §S 100H09L
II. Permit Issuance Authority
Permits are issued by the State of Illinois under
authority delegated by the United States Environmental
Protection Agency (USEPA). Draft and final permits
are prepared and issued by the Illinois Environmental
Protection Agency (IEPA).
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Application for a Permit
Dischargers must submit applications for NPDES
permits to the Permits Section, Water Pollution Control
Division of the IEPA at least 180 days in advance of a
new or increased discharge into the waters of the state,
or 180 days before the expiration of an existing NPDES
permit.
Since November 1980, the USEPA consolidated
permit application form 2C, which requires effluent
analyses for "priority pollutants", including numerous
inorganic and organic toxic chemicals, has been used for
larger industrial dischargers. Small industrial and
municipal dischargers use a shorter IEPA permit
application form requiring much less effluent data.
These application forms are available from:
Permits Section
Water Pollution Control Division
Illinois EPA
2200 Churehfll Road
Springfield, Illinois $2786
0.S. EPA, Begion V
Permits Section
26th Moor
230 South Dearborn Street
Chicago, Illinois 60604
(Form 2C only)
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Processing of Permits
Industrial NPDES permit applications are received
at IEPA and assigned to a staff engineer in the
Industrial Permits Unit. Permits for publicly owned
sewage treatment plants follow similar procedures in
the Municipal Permits Unit. The steps leading to a final
NPDES permit include:
:£ Reviewing the permit application for
completeness.
% Preparing a preliminary draft permit, in
consultation with other IEPA sections.
•£ Circulating the preliminary draft permit
to other sections of IEPA and the
Applicant for review.
•jj Reviewing recommendations and
comments from staff and preparing a
final version of the draft permit,
Jfc Sending the final draft permit out for
public review, which may include
hearings,
•£ For significant dischargers, sending the
final draft permit to USEPA for review.
3e Reviewing comments from the public and
USEPA.
^5 Preparing the final NPDES permit
% Issuing the final NPDES permit.
Review for Completeness
Applications are reviewed for completeness by the
permit drafter. If the application is found to be
incomplete, IEPA^ requests additional information.
Processing stops until a completed application is
received.
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Preparation of Draft Permits
Completed application forms are processed by the
staff engineer. IEPA prepares a preliminary draft
permit and later a final draft permit. Draft permits
include:
* Limits on the discharge of particular pollutants
* Monitoring requirements
* Compliance schedules, where construction is
needed
* Reporting requirements
* Permit expiration date
Draft NPDES permits incorporate effluent
limitations established by the Illinois Pollution Control
Board (IPCB). These rules (Illinois Administrative Code,
Title 35 [Environmental Protection], Subtitle C [Water
Pollution]) establish a specific maximum concentration
for conventional and certain toxic chemicals that must
be achieved by all non-mine NPDES dischargers in
Illinois. Rules governing mine related pollution are
found in Title 35 of the Illinois Administrative Code,
Subtitle D [Mine Related Water Pollution].
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In addition to the Illinois standards, USEPA has
established Federal effluent guidelines. These
standards are numerical limits, based on wastewater
technology, which are applicable to specific industrial
categories. Where the USEPA guidelines are more
restrictive than the IPCB regulations, IEPA staff
engineers incorporate the more stringent Federal
limitations into the draft NPDES permits.
Federal effluent guidelines have not been
established for most industrial categories, as of
November, 1982. Where new Federal guidelines are
available, IEPA reissues permits with the new
limitations; where Federal guidelines have not been
issued, the old permit usually remains in effect until the
new guidelines are issued.
The staff Engineer, in consultation with
specialists from the Water Quality Section, reviews the
permit application and stream related data to
determine if effluent limitations established by the
procedure above will ensure that receiving waters will
meet water quality standards established by the IPCB.
These standards, found in Title 35, Subtitle C, of the
Illinois Administrative Code, are designed to protect
fish, aquatic life, and human health.
The water quality review is done by calculating
whether the contaminants in the effluent, after dilution
with the receiving water, will be present at levels below
the water quality standard. In most situations it is
presumed that one-fourth of the lowest 7 day stream
flow for the last 10 years will be used in the dilution
process. When the mathematical check shows, for any
contaminant, that effluent limitations established by
the IPCB or USEPA, will not ensure attainment of
water quality standards, more restrictive limitations
may be set in the permit.
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The permit writer will also consult informally
with the appropriate Field Engineer, the Compliance
section, and the Enforcement section for obvious
problems that must be addressed in the new permit.
Such problems might include defining where the
permittee must sample for effluent testing, when such
sampling must be done, or similar concerns.
When the staff Engineer completes the
preliminary draft permit, it is circulated to the
following IEPA sections and individuals for formal
approval:
* The Field Engineer responsible for that
discharger.
* The Water Quality Section
* The Compliance Section
* The Enforcement Section
The preliminary draft permit is also circulated to
the applicant for review and comment. After 15 days
the various comments are evaluated, any necessary
changes are made, and a final draft permit is prepared
for circulation during the public comment period.
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Permit Comments
The version of the draft permit that emerges
after internal IEPA approval and applicant review
is placed on Public Notice. IEPA sends the notice
to local papers in the vicinity of the discharge and
to a mailing list of individuals. Those wishing to be
added to the list receiving Public Notices should
write to:
NPDES Permits
Water Pollution Control Division
niinois EPA
2200 Churchill Road
Springfield, niinois 62706
During the comment period interested
citizens should provide written and oral comments
to IEPA. (See Part II of this booklet, page 14,
"Citizens Comments on NPDES Permits Can be
Effective", for further details.) Comments must be
made within 30 days after issuance of the public
notice. Comments should be sent to the above
address, and should include : (1) the name of the
permit applicant, (2) the number of the public
notice, and (3) the NPDES permit number. All of
this information is in the public notice.
During the comment period, citizens may
request that the IEPA hold a public hearing on the
permit. A request for a public hearing must be
granted if there is "significant public interest".
When an individual citizen files a request for a
public hearing, the IEPA may grant one. When
many citizens request a public hearing, the IEPA
must hold one.
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Review by USEPA
Some draft permits, usually for larger facilities,
are sent to the Chicago Regional Office of USEPA for
review at the time of the public notice. If USEPA has
problems with the permit, they have 90 days to
disapprove, giving reasons as well as suggested changes.
If the IEPA refuses to alter the permit as USEPA
specifies, USEPA can either deny the permit or issue a
permit containing its own specifications.
Final Permit Preparation and Issuance
After reviewing all comments on the draft NPDES
permit, IEPA prepares a final permit.
For new and reissued permits, the permit is issued
when signed by the Manager of the Permits Section.
If the permit applicant disagrees with the terms
and conditions of the final permit, they may appeal the
permit to the IPCB and seek to have the permit
changed. Only the permit applicant may appeal,
citizens and other interested parties may not.
Compliance and Enforcement
The IEPA staff reviews discharge reports and
other monitoring data every month, to ensure that each
discharger complies with its NPDES permit terms and
conditions. The IEPA prepares a quarterly report of
major non-compliances.
Significant non-compliance may result in a civil or
criminal enforcement action being taken against the
discharger.
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Part II
Public Comments on NPDES Permits
can be Effective
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Why this Booklet is Important
In the past, the public has had very little impact
on NPDES permits issued by the Illinois Environmental
Protection Agency (IEPA), largely because citizen
comments on draft permits have contained only general
expressions of concern about pollution, rather than
specific statements about the condition of the receiving
water, the contents of the discharges going into them,
and the regulatory requirements in the permits. Typical
citizen comments follow:
We live on the Fox River and do not want it
polluted. Please don't let this company
pollute it.
We've lived on the Salt Creek for 30 years,
during that time the fish have disappeared.
Please save our river; don't allow any more
pollution in it.
I do not want this company discharging into
the Illinois River.
While such comments reflect serious concerns,
they are ineffective.
Since the IEPA cannot legally stop all pollution,
they need comments suggesting specific steps for
reducing pollution.
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Comments like the following are more useful to
IEPA.
$ Benzene las been found In Hie company's
ttfedtege. Since this chemical is a
carcinogen, its concentration must be
strietly controlled. Monitoring re
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Acquire and Organize Information
First decide which body of water (lake or stream)
is of concern. There may be one or several dischargers
on this receiving water. The type of industry, size of
the plant, location of discharge in relation to drinking
water supplies or prime fishing areas, and the
composition of the effluent are key factors in deciding
which dischargers are of most concern.
It is advisable to begin collecting information
before a draft permit is issued, to avoid having too
little time to study the relevant materials during the
30-day review period.
Contact the IEPA NPDES Permit Section main
office in Springfield (phone: 217-782-0610) or the IEPA
district office for your area (see Appendix C, page 42)
to request information.
Items that should be available from the IEPA
include:
1. The New NPDES Permit Application
A consolidated permit application Form "2C" or
IEPA Permit Application Form submitted by the
discharger lists concentration of chemicals the company
reports to be present in their discharges, the total
volume of each discharge, the manufacturing processes
sending wastewaters to each outfall (discharge), the
source(s) of intake water, and the wastewater
treatment systems currently employed. There should be
a map showing the exact location of the outfalls and a
schematic drawing of water flows through the plant.
2. The Current NPDES Permit
Permits contain limits on discharges of individual
pollutants, requirements for periodic monitoring of
effluents and reporting to the IEPA.
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3. IEPA Effluent Sampling Data
The Field Operations Section of the IEPA
occasionally measures the concentration of pollutants in
the effluents from major industries in the state (as
frequently as once a month in some circumstances).
Reports of these analyses provide quantitative data on
conventional pollutants and some toxic heavy metals;
these reports also provide a check on the accuracy of
data supplied by the discharger.
On rare occasions, IEPA will conduct special
testing on effluents for toxic organic pollutants.
Results of both IEPA sampling data and special testing
will be in the NPDES permit file for that discharger.
4. Ambient Water Quality Information
Though it may prove difficult to obtain in a simple
format, data on the concentrations of pollutants in the
stream or lake receiving the discharges can be very
useful. Ask for data obtained from sampling a specific
stretch of river or a lake during the last few years.
IEPA also secures data on chemical contamination
of lake and river sediments and various fish species.
Check to see if any fish or sediment analyses are
available for your area of concern.
5. Water Quality Standards
The Illinois Pollution Control Board (IPCB) adopts
Water Quality Standards for each body of water in the
state. These standards consist of two elements: 1) one or
more water use designations (general use, secondary
contact and indigenous aquatic life, etc.) ; and 2) water
quality criteria, which are concentrations of specific
pollutants consistent with the designated uses for the
stream.
Methods for establishing water quality standards
vary depending on the category of pollutants.
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a) Conventional Pollutants
Water Quality Standards for conventional
pollutants (i.e., total dissolved solids,
temperature, oil and grease) depend on the use
classification assigned the stream by IEPA.
For example, waters designated for public and
food processing water supply shall contain not
more than 500 milligrams per liter (mg/1) of
total dissolved solids, while all other waters of
the State shall contain no more than 1,000 mg/1
of total dissolved solids.
Calculating effluent limits for
conventional pollutants based on water quality
standards is a complicated process. First the
total amount of a pollutant that can be
discharged over a period of time into a body of
water by various sources is calculated, then
this allowable load is allocated among the
various dischargers. Because so many factors
must be included in these calculations
computers are often used to perform them.
Citizens concerned about conventional
pollutant contamination of a water body should
ask the IEPA whether a water quality
evaluation has been made on permits for
discharges into this water. If so, the accuracy
of the data entered into the computer should
be checked.
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b) Toxic Pollutants
The IPCB has adopted specific maximum
concentrations for certain chemicals that are
applicable to all waters of the state. In
addition, any substance toxic to aquatic life
cannot exceed one-half of the 96-hour median
tolerance limit (96-hour TLm' tnat
concentration which kills 50 % oiihe test
organisms within 96 hours) for native fish or
essential fish food organisms.
More stringent toxic chemical criteria
apply to waters designated for public and food
processing water supply. However, these
standards apply only at the point water is
withdrawn for such use.
Appendix B, page 40, contains the
specific chemical water quality standards
adopted by the IPCB.
USEPA has published nonbinding Water
Quality Criteria designed to protect aquatic
life and humans against acute and chronic
effects from water borne pollutants. Appendix
A, page 35, lists concentrations of pollutants
which are estimated to have minimal short
term effects on most aquatic life. See the
column marked USEPA Water Quality Criteria.
Once the information from these five categories
has been collected, it can be arranged on a chart similar
to Table 1 on page 20, which can help identify matters
of concern. This chart can form the basis of the citizen
comment on proposed NPDES permits in Illinois.
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EXAMPLE
TABLE 1
NPDES Permit Evaluation Chart
to
o
Acme Industries, Anywhere, IL.
NPDES Permit # : IL 001234
Receiving Water : Fox River
Outfall # : 001
Average Daily Flow : 2.5 MGD
Maximum Daily Flow : 2.5 MGD
All concentrations are in parts per billion (ppb) = micrograms per liter (ug/1)
Background Ambient Regulatory Discharge
Detected in
Fox River Illinois USEPA Permit IEPA
Chemical C* B** D.L. Fish Water WQS WQC Application Survey
Arsenic Yes Yes 2.0 120 1000 440 10 400
Lead Yes 1-50 500 100 56-400 10° 15°
Mercury Yes 0.1-.2 0.24 0.7 0.5 4.1 ND at 100 40
Benzene Yes 10 None None < 6000
Phenols 19.0 100 None 55
Penta-
Chloro Yes Yes 25 0.2 None 55 90
phenols
Permit
Limit in
Draft
Permit
250
None
None
None
None
None
* = Bioaccumulative
** = Carcinogen
< = Less than
D.L. = Lowest Level of Detection
N.D. = Not Detected at a detection limit of
MGD = Million Gallons per Day
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This chart can help identify matters of concern. An
example of a comment based on Table 1, page 20 , would
be the following :
- - Arsenic is a carcinogen and bioaccumulative
in the environment. The IEPA Survey
detected Arsenic at a level of 400 parts per
billion (ppb), but the company only reported
10 ppb. I request that IEPA investigate this
discrepancy. I also request that the Arsenic
limit in this permit be set at a lower level,
to protect public health and the
environment, and that monitoring
requirements for arsenic also be included.
- - Lead is a carcinogen. It has been detected in
the Fox River at levels as high as 500 parts
per billion (ppb), which is five times the
Illinois Water Quality Standard of 100 ppb.
The company reports levels of 100 ppb in
their application, but IEPA has detected
levels of 150 ppb. Since the Fox River
violates Water Quality Standards for lead, I
request that IEPA establish effluent
limitations and monitoring requirements for
lead.
Mercury is bioaccumulative in the
environment and has been detected in fish in
the Fox River. Mercury has been detected in
the effluent by IEPA at levels above the
Federal Water Quality Criteria. The
company did not detect mercury at 100 ppb,
however, that is not a low enough level of
detection. I request that mercury be limited
in this permit because of its presence in Fox
River fish, its detection in the effluent, and
the need to protect public health and the
environment.
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-- Benzene is a known human carcinogen.
Benzene was not reported in this company's
permit application at a detection level of
6000 ppb. Because benzene can be detected
at levels as low as 10 ppb,I request that this
permit application be designated incomplete
until the company performs an adequate
benzene analysis. If the absence of benzene
is not confirmed by subsequent low
detection level analysis, I request that
benzene be limited and monitored in this
permit.
— Pentaehlorophenol is bioaccumulative in
nature. It causes severe taste and odor
problems in the fish. The company reported
55 parts per billion of pentachlorophenol in
this discharge. I request that this chemical
be monitored and limited in this company's
NPDES permit to protect public health and
the environment.
While the preceding statements make a good
comment for the hypothetical Acme Industries, real
permits may present other problems. Citizens should
prepare a chart similar to Table 1 for all permits, then
pay particular attention to:
1. Persistent chemicals in the effluent or
receiving waters. A list of persistent chemicals and the
lowest concentrations at which they can presently be
detected is found in Appendix A. Of particular
concern are those chemicals which bioconcentrate or
biomagnify to higher concentrations in aquatic plants
and animals than in the surrounding water. Appendix A
indicates which chemicals are known to bioconcentrate
or biomagnify.
2. Any detectable concentrations of carcinogens
in the effluent or receiving water. See Appendix A for
a list of chemicals generally recognized as carcinogens.
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3. The effluent concentration of each pollutant
reported in the new permit application compared with
levels found in any IEPA wastewater surveys. If
pollutant concentrations reported by the discharger in
the permit application are significantly lower than
those found in IEPA surveys, seek an explanation.
4. Pollutants found in the effluent at
concentrations higher than Illinois Water Quality
Standards or USEPA Water Quality Criteria.
5. Cases in which concentrations of pollutants in
the receiving waters exceed Illinois Water Quality
Standards or USEPA Water Quality Criteria.
6. Pollutants present in the discharger's effluent
that have contaminated fish in the area.
7. Pollutants found in the effluent which are
associated with violations of Water Quality Standards or
present in fish, on which no limits were set in the
current permit.
This kind of analysis indicates problems that
should be addressed in the new NPDES permit.
Another step that can be taken before the
issuance of a draft permit is checking the application
for completeness. Though the IEPA reviews application
forms, inadequacies can be overlooked on occasion.
Read the application form throughly, making sure all
required information is provided. Pay particular
attention to the levels of detection for toxic chemicals
in the effluent. If a toxic pollutant was found in an
IEPA survey, but is not reported in the permit
application, seek an explanation. If inadequacies are
discovered, report them to IEPA and ask to be sent
additional information when it is received.
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Evaluate the Draft NPDES Permit
Persons on the IEPA permit notice mailing list
(see Part I of this booklet, Page 11) receive an official
notice of the issuance of draft permits by the IEPA.
This notice indicates when the draft permit was issued,
how long the public has to submit comments, where to
send the comments, how to request a public hearing,
and how to obtain additional information. Notices are
accompanied by a fact sheet providing some
information about the discharger, as well as some
specifics about the permit.
The information provided in the notice and fact
sheet is not sufficient to provide a basis for a thorough
permit review, so a copy of the permit application and
draft permit must be obtained from the IEPA. If you
live close to Springfield or an IEPA District office, pick
up the copies; otherwise call and request that they be
sent to you promptly.
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A permit should contain the following:
1. Effluent limits for specific "conventional"
and "toxic" chemicals.
2. A compliance schedule for attainment of
final effluent limits or other permit
conditions.
3. A schedule for monitoring effluent
components.
4. A requirement for periodic reports to the
IEPA.
5. An expiration date for the permit.
6. Miscellaneous conditions.
The adequacy of each of the above components of
the permit should be examined.
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Effluent Limits
All outfalls listed in the application should
have pollutant limits. If not, why?
Discharge limits should be in terms of total
amounts of pollution discharged over a
period of time (Ibs/day), or as pollutant
discharged per unit production (Ibs/ton).
Limits expressed in terms of concentration
in wastewaters should be accompanied by
restrictions on total flows, in order to
prevent mere dilution of pollution.
There should be daily maximum limits in
addition to monthly limits, to prevent
excessive short-term loadings on toxic
chemicals.
Limits should be set for all toxic chemicals
found in the effluent above acute toxicity
values.
Under the Clean Water Act effluent limits
are supposed to be based on best available
technology, applicable to each type of
industry, as determined by USEPA. As of
November, 1982, USEPA had been unable to
publish all of these guidelines. Until the
USEPA guidelines are available, IEPA is
using toxicity information and water quality
data to develop permit limits set low enough
to protect the aquatic life in the receiving
water.
Limits should be set in the permit for all
chemicals found in concentrations above
Illinois Water Quality Standards or USEPA
Water Quality Criteria (these values are
found in Appendix A or B, however some of
these values may be adjusted up or down to
reflect local water hardness).
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Compliance Schedules
A compliance schedule for meeting the conditions
set in the permit should include final compliance
deadlines for interim tasks if new treatment facilities
must be installed. Deadlines on planning, engineering
design, and onset and completion of construction help
assure meeting final compliance dates for effluent
limits.
Monitoring Requirements
The discharger should be required to periodically
test its effuent- for the chemicals limited in its permit.
If a pollutant has been found in the effluent but was not
limited because the concentration was very low,
occasional testing should be required to assure that
amounts discharged do not increase significantly.
The frequency of monitoring required by the IEPA
varies depending on a number of factors including the
volume of the discharge, testing costs and type of
wastewater treatment employed.
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Permits have required monitoring of conventional
pollutants (total suspended solids, biological oxygen
demand, temperature, and pH) as often as once a day.
Plants that send their treated effluent to a
retention pond before it is discharged into a waterway
are usually required to monitor less frequently than
others, as such ponds reduce fluctuations in effluent
composition, lowering the chances of "slugs" of heavily
contaminated waste passing through undetected.
Reporting Requirements
Permits should require that the results of effluent
monitoring be reported to the IEPA in a monthly
Discharge Monitoring Report (DMR).
Permittees are also required to report to the IEPA
malfunctions in the treatment system, permit limit
violations, failures to meet interim or final compliance
deadlines, and plans for significant changes in plant
activities.
Permit Expiration
Permits can be valid for up to five years. They
should contain clauses for reopening of the permit if
new pollutants are detected in the effluent,
concentrations of unregulated detected pollutants rise
significantly, key information in the permit appliction is
found to have been incorrect, substantial changes in the
permitted facility are proposed, new evidence indicates
that the discharge endangers human health or the
environment, or new federal effluent guidelines are
promulgated for that category of industry.
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Miscellaneous Conditions
Other conditions found in many permits
include:
- A requirement for a Best Management
Practice (BMP) plan to control spills, leaks,
and runoff.
- A prohibition of bypassing of wastewater
treatment facilities except in extreme
circumstances.
- A requirement for back-up sources of
power for treatment facilities.
- A statement that the permittee would be
required to reduce or halt operations if
necessary to prevent violations of the
permit.
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Are these safe in your area?
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Prepare and Submit Permit Comments
The most effective permit comments are clear,
concise, well organized, and specific. Specific
suggestions about preparing comments include:
- Provide a brief summary of major
points at the beginning.
- Mention specific problems associated
with the discharge, like fish contamination
and violations of water quality standards.
- Cite provisions of federal, state, or
local law to support requested changes,
rather than just saying something is "wrong"
or "bad".
- Note other NPDES permits that
include the provision being requested, or
permits from other states.
- Include tables, charts, or graphs if
they clarify and support key points.
Comments may only be submitted to the IEPA
during the 30-day public comment period. If more time
is needed, request an extension of time for the public
comment period. Usually two weeks is not an
unreasonable extension to request, probably the
maximum time extension would be a month.
Participate in Public Hearings
In addition to providing written comments,
citizens may request a public hearing on any NPDES
permit issuance. At a public hearing IEPA staff will
briefly describe the permittee, the discharge and the
permit. Citizens will than be allowed to orally express
their views on the permit to the IEPA. In theory,
written comments should be just as effective as those
presented orally at a public hearing.
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However, large numbers of persons expressing
concerns at a public forum can make it clear that a
permit is of interest to broad sectors of the public.
Hearings also can provide the opportunity to present a
cas(- directly to decision makers, rather than having
one's views related by subordinates. In addition,
information presented at a hearing may well be
reported by the media.
Encourage Others to Participate
Remember, there is safety in numbers. The more
citizens that express concerns over a specific discharge,
the more attention will be paid by the decision makers.
Try to find other interested individuals. Contact
persons living in the vicinity of the discharge, civic
organizations, environmental groups, fishing clubs, and
anyone else whose concerns might be affected. Elected
officials can be particularly effective in getting the
IEPA to consider concerns expressed about a permit.
Those who show an interest should be encouraged
to submit written comments and appear at public
hearings.
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Monitor Permit Compliance
Citizens can monitor a discharger's compliance
with a permit by reviewing Discharge Monitoring
Reports (DMR's), and quarterly reports of non-
compliance by major dischargers, all available from
IEPA. These reports will identify the non-complying
permit holders, describe instances of non-compliance,
and specify remedial actions intended. Reviewing these
documents can be one of the most effective ways in
which citizens can monitor progress towards achieving
water quality goals, short of actually going to the
discharge pipe and collecting samples.
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Appendices
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APPENDIX A: TOXICITY GUIDANCE TABLE
Note: These values are USEPA Water Quality Criteria, where such values exist. Otherwise, they are the
lowest value, from USEPA background documents, at which adverse environmental impacts were detected.
1
CARC. = CARCINOGEN
A = Animal
BIOACC. = BIOACCUMULATOR
H = Human
S = Suspected
POLLUTANT
Ammonia
w Chlorine
01 Nitrate-Nitrite N
Sulfide
Iron
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
DETECTABILITY USEPA Water1
LIMIT (ug/1) Quality Criteria CARC.
10-20
40
50-100
20
200
2-3
5
0.1-2
1-20
1-10
1.5-50
0.1-0.2
15-20
16.4
2-50
10000-90000
1.9 as S
1000
9000
440
130
1.15*, 6.3**
21 (+6)
1744(+3)*, 9900**
9.4*, 43**
56.3*, 400**
4.1
919*, 3100**
H
A
A
H
A
H
PERSISTENT
CHEMICAL
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
BIOACC.
yes
yes
yes
yes
yes
-------
POLLUTANT
Selenium
Silver
Thallium
Zinc
Cyanide
2,3, 7 ,8,-Tetrachloro-
dibenzo-p-Dioxin
Acrolein
Acrylonitrile
Benzene
Bromoform
w Carbon Tetrachloride
05 Chlorobenzene
Chlorodibrom om ethane
2-Chloroethylvinyl Ether
Chloroform
Dichlorobromomethane
1,2-Dichloroethane
1,1-Dichloroethylene
1,2-Dichloropropane
DETECTABIUTY
LIMIT (ug/1)
2-4
0.5-10
100
5-10
10-20
.003
100
100
10
10
10
10
10
10
10
10
10
10
10
USEPA Water
Quality Criteria
260
0.84*, 13**
1400
150*, 570**
52
0.000056
68
7550
5300
11000
35200
250
11000
360
28900
11000
118000
11600
23000
CARC.
A
A
A
H
S
A
S
A
S
A
PERSISTENT
CHEMICAL BIOACC.
N/A
N/A
N/A
N/A
soil yes
yes
*based on 40 mg/1 CaCO« Hardness
**based on 200 mg/1 CaC(J3 Hardness
-------
1,3-Dichloropropylene 10
Ethylbenzene 10
Methyl Bromide 10
Methylene Chloride 10
Tetrachloroethylene 10
Toluene 10
1,2-Trans-Dichloroethylene 10
1,1,1-Trichloroethane 10
Trichloroethylene 10
2-Chlorophenol 25
2,4-Dichlorophenol 25
2,4-Dimethylphenol 25
4,6-Dinitro-O-Cresol 250
2,4-Dinitro-phenol 250
2-Nitrophenol 25
4-Nitrophenol 25
P-Chloro-M-Cresol 25
Pentachlorophenol 25
Phenol 25
Acenaphthene 10
Benzidine 10
Bis (2-Chloro-ethoxy) methane 10
Bis (2-Chloro-ethyl) Ether 10
Bis (2-Ethyl-hexyl) Phthalate 10
4-Bromo-phenyl Phenyl Ether 10
Butyl Benzyl Phthalate 10
6060
32000
11000
11000
5280
17500
11600
18000
45000
4380
2020
2120
230
230
230
230
30
55
10200
1700
2500
238000
238000
940
360
940
S
A
S
A
S
S
A
S
H
S
A
A
yes
yes
yes
yes
yes
yes
-------
POLLUTANT
DETECTABILITY
LIMIT (ug/1)
USEPA Water1
Quality Criteria
CARC.
PERSISTENT
CHEMICAL BIOACC.
2-Chloro~naphthalene
4-Chloro-phenyl Phenyl Ether
1,2-Dichlorobenzene
1,3-Dichloro benzene
1,4-Dichlorobenzene
Diethyl Phthalate
Dimethyl Phthalate
Di-N-Butyl Phthalate
2,4-Dinitrotoluene
2, 6-Dinitrotoluene
Di-n-Octyl Phthalate
oo 1,2-Diphenylhydrazine
Fluoranthene
Hexachlorobenzene
Hexaehloro butadiene
Hexachloroeyclopentadiene
Hexachloroethane
Isophorone
Naphthalene
Nitrobenzene
N-Nitrosodimethylamine
N-Nitrosodi--n-Propylamine
N-Nitrosodiphenylamine
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
0.3
10
10
1600
360
1120
1120
1120
940
940
940
330
330
940
270
3980
250
90
7.0
980
117000
2300
27000
5850
5850
5850
S
S
S
S
S
S
S
A soil
A soil
S
A
A
S
yes
yes
yes
yes
yes
-------
CO
CO
Phenanthrene
Pyrene
1,2,4-Trichloro benzene
Aldrin
a -BHC
6 -BHC
X -BHC
6 -BHC
Chlordane
4,4-DDT
4,4-DDE
4,4-DDD
Dieldrin
a-Endosulfan
g -Endosulfan
Endosulfan Sulfate
Endrin
Endrin Aldehyde
Heptachlor
Heptachlor Epoxide
PCB-1242
PCB-1254
PCB-1221
PCB-1232
PCB-1248
PCB-1260
PCB-1016
Toxaphene
Methyl Chloride
10
10
10
10
10
10
10
10
0.04
10
10
10
10
10
10
10
10
0.23
10
10
0.05
0.08
0.1
0.1
0.08
0.15
0.04
0.04
10
250
3
100
100
100
100
2.4
1.1
1050
0.6
2.5
0.22
0.22
0.22
0.18
0.18
0.52
0.52
2.0
2.0
2.0
2.0
2.0
2.0
2.0
1.6
11000
A
A
A
A
A
A
A
A
A
A
pot. A
A
A
A
A
A
A
A
A
A
water
yes
yes
yes
yes
soil
soil
yes
yes
soil
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
soil
soil
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
-------
SUBPART B: GENKRAL USE WATER
QUALITY STANDARDS
Section 302.208 Chemical Constituents
The following levels of chemical constituents shall not be
exceeded.
CONSTITUENT
Arsenic t total I
Barium (total)
Boron
-------
SUBPART D: SECONDARY CONTACT AND INDIGENOUS
AQUATIC LIFE STANDARDS
Section 302.407 Chemical Constituents
Concentrations of other chemical constituents .shiill not exceed
the following standards
CONSTITUENT
Ammonia Nitrogen (as N)
(April-October)
(November-March)
Arsenic (total)
Barium (total)
Cadmium (total)
Chromium (total hexavalent)
Chromium 'total trivalent)
Copper (total)
Cyanide (total)
Fluoride (total)
Iron (total)
Iron (dissolved)
Lead (total)
Manganese (total1'
Mercury (total)
Nickel (total)
Oil, fats and grease
Phenols
Selenium (total)
Silver
Zinc (total)
Total Dissolved Solids
CONCEN-
STORET TRATION
NUMBER (mg/1)
00610
00610
01002
01007
01027
01032
01033
01042
00720
00951
01045
01046
01051
01055
71900
01067
00550, 00556
or 00560
32730
01147
01077
01092
70300
2.5
4.0
1.0
5.0
0.15
0.3
1.0
1.0
0.10
15.0
2.0
0.5
0.1
1.0
0.0005
1.0
15.0 *
0.3
1.0
1.0
1.0
1500
SUBPART E: LAKE MICHIGAN WATFR
QUA! 'TY STANDARDS
Section 302.504 Chemical Constituents
The following levels of chemical constituents shall not be
exceeded'
CONSTITUENT
Ammonia Nitrogen
Chloride
Sulfate
Phosphorus (as P)
Total Solids (Dissolved)
Cyanide (total*
STORET
NUMBER
00610
00940
00945
00665
70300
00720
CONCEN-
TRATION
(mg/D
002
120
24.0
0.007
180.0
0.025
-------
Appendix C
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
DIVISION OF
WATER "DILUTION CONTROL
REGIONA1 OFFICES
Region 1
ur. flcrris Chlen, Manager
-•302 North Main Street
Rickford, Illinois 61103
'315) ^37-7755
"egion 2
Mr . Ted Denning
Suite 1105
~ne IrnerContinental Center
1701 First Avenue
Maywood, Illinois 60153
(312) 345-9780
Region 3
Mr. Jim Karnnueller
5415 North University Av.
Peori.i, Illinois 61614
(309) 091-2200
Re g l o n 4
Mr. Kenneth Baumann, Manager
2125 South First Street
Champaign, Illinois 61820
(217) 333-8361
Region 5
Mr. John Forneris, Manager
* 500 South 6th Street
Springfield, Illinois 62706
(217) 786-6892
R e g i o r 6
Mr. Robert Schleuger, Manager
117 West Main Street
Collinsville, Illinois 62234
(618) 345-6220
Region 7
Mr. Larry Ziemba, Manager
2209 Jest Main Street
Marion, Illinois 62959
(618) 997-4371
42
-------
CITIZENS FOR A BETTER ENVIRONMENT (CBE) is
one of the oldest and largest public interest environmental
groups in the midwest. CBE has been involved in
environmental problem-solving since pollution first
became a public policy issue in the early 1970's.
CBE is committed to the belief that citizen
involvement is essential to achieving a clean and healthy
environment. However, we know that effective
participation depends on an informed public; so, CBE has
served as a source of information and assistance to
citizens throughout the last decade. Our full-time
professional staff has done research, written and
distributed reports, answered questions, spoken before
numerous groups, and even taught classes on environment
and energy. CBE publishes a bi-monthly magazine, the
CBE Environmental Review, which provides in-depth
discussions on current environmental issues.
Written By: Bill Forcade
Graphic Preparation By: Cymbria Thompson
This publication was produced with funds from the U.S.
Environmental Protection Agency under Grant Number T-
901014-01. The contents do not necessarily reflect the
views and policies of the EPA.
For additional copies of this booklet or for more
information, contact:
TOXICS WATERWATCH
Citizens for a Better Environment
59 E. Van Buren Street, Suite 1600
Chicago, niinois 60605
(312) 939-1530
43
-------
Appendix D
Frequently Used Calculations
M = cubic meters
MGD = Million Gallons per Day
mg/1 = milligrams per liter = ppm
ug/1 = micrograms per liter = ppb
ppm = parts per million
ppb = parts per billion
ppt = parts per trillion
Ibs/day = pounds per day
cfs = cubic feet per second
To convert concentrations to loading :
Effluent Concentration x Outfall Flow x Conversion
Factor = loading to body of water
mg/1 x MGD x 8.34 = Ibs/day
ug/1 x MGD x 0.00834 = Ibs/day
MVday x 0.000264 = MGD
Kg/day x 2.205 = Ibs/day
MGD x 1.54723 = cfs
cfs x 0.646317 = MGD
mg/1 x 1000 = ug/1
ug/1 x 0.001 = mg/1
44
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