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develop before we act? All the emissions from the plant should be
treated so that they are rendered harmless for those who inhale them.
Response: Dr. Slade raised many good points in his presentation and
we are generally in agreement. He pointed out that there is still no
evidence in the scientific literature that would indicate the likelihood
of a public health problem due to aerosols generated from a sewage
treatment plant. We are in agreement with this and the fact that a
possible health hazard could exist due to the operation of the proposed
WRP. Consequently, we have made a decision to require MSDGC to provide
adequate aerosol suppression facilities to minimize the movement of
aerosols from Site 1. This decision is discussed in more detail in
Chapter 3 and 5.
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2. Richard V. Ward
City of Des Plaines
Slide #1 (City of Des Plaines Testimony by R. F. Ward)
I would like to direct my initial comments to
our audience this afternoon (evening). My previous
slide presentations have been very broad in scope and
contained many aerial views of alternate sites and
other sewage treatment plants. I would then follow
up with a very detailed written input containing the
volumes of information we felt should be considered
in any decision. On March 28, 197^- we submitted a
250 page report, After the December public hearing,
I updated my March report on December 27, 197^ and
the resultant document contained some 400 pages. The
vast majority of our questions and comments have never
been answered by either the MSD or any reviewing agency
and I will incorporate our previous inputs into our
written comments prior to the April 21, 1975 deadline.
During this presentation, I will concentrate on 4 topics;
F. Cost-effective
Tl. Site
T2. Health
T3. Isolation
Although we disagree with their conclusions, the
last three topics have at least been addressed in the
draft Environmental Impact Statement. The first topic
of a cost-effective system has been avoided by the USEPA,
The first topic I would like to refer to as the
forest and the remaining topics as tree 1, tree 2 and
tree 3. And I roust offer the observation that the
reviewing agencies have been examining the trees and
have overlooked the forest. As a further word of expla-
nation to the audience, there are very few interesting
photographs in this presentation and many of the details
I will offer may be difficult to place in context but
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the hearing officer and the USEPA staff will know exactly
what I mean. We will be examining the adequacy of their
draft of the Environmental Impact Statement, We will
be detailing omissions, contradictions, unsubstantiated
and incorrect statements in this draft.
Slide §2 (Aug. 72 and Nov. 73 TARP)
The Federal Regulations require that only the most
cost-effective and environmentally sound projects be
funded. Here we see the August, 1972 and November, 1973
Tunnel and Reservoir Plan that was the result of 20 years
of engineering research and the study of many agencies
of local and state government. This plan has been sub-
jected to a 58$ change during the past several months
,that the MSD has described as quote "minor variations"
in their January, 1975 Facility Plan. The dashed line
under O'Hare Airport is described as a "possible inter-
connection" between the Des Plaines River Tunnel and the
Northwest Tunnel.
Slide #3 (Cross-section of TARP)
Here in this cross-section view, we can see the slope
of tha tunnel that would allow gravity flow down to the
main McCook-Summit reservoir. Again the interconnection
is shown as a dashed segment. Note the comparatively
small O'Hare reservoir that is equal to only J% of the
total retention capacity. During several presentations
and written communications during the last 18 months,
Mr. Donald Dvorak and I have each concluded that this
connection was the most cost-effective and could save
the taxpayers of this Nation over $100 million. The USEPA
has acknowledged not considering this option in their
draft Impact Statement. Unfortunately their own regula-
tions require the USEPA to analyze this option that would
eliminate the need for the O'Hare plant. But it obviously
should have been done before examining the environmental
impact of the O'Hare Plant.
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Slide #b (Novs 73, TARP EIS, p.35)
Here we see that the Tunnel and Reservoir Plan
evolved from over 55 plans developed during the past
20 years. Please note that it was a combination of
alternatives G, H, J and S. Also please note the ex-
tremely important n ..atement concerning the "possible
0'Hare-Northwest connection. This would allow the
entire system to operate as a unit with considerable
advantages for storms having great variable areal dis-
tribution over the 375 square mile service area."
I submit that one reason this connection was eliminated
from the current plan is because the MSD could not
justify the expenditure of over $150 million for the
O'Hare plant and reservoir if this connection was re-
tained in the plans. The MSD contends that building
the plant locally would return the purified water to
our local streams and help recharge the aquifier and
increase the recreational advantage of Higgins Creek.
A geologist has informed me that because of 2 imper-
vious layers of rock and clay only a few percent of the
water would get down to the depth of our municipal wells
and regarding the recreation claim, we all realize that
Higgins Creek flows through primarily industrial and
airport land and would be of little use to our citizens
for its recreational value.
Slide #5 (Nov. 73 TARP EA, Table 3)
Here we see that of the 4 alternatives that formed
the original Tunnel and Reservoir Plan, only alternative
"S" contained the O'Hare reservoir and therefore the
other three had to contain the interconnection.
Slide #6 (Ward letter to MSD, 10-7-7^, p. 1)
In this letter to the MSD last October, we are
reminding them of their obligation to answer our March 28,
questions. As I mentioned earlier, the MSD just
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avoided addressing the vast majority of our comments
and questions, And the USEPA gave the MSD their bless-
ing and likewise avoided many of our comments and questions
in their current draft. In the last paragraph, we again
offer the opinion that it would be more cost-effective
to make the "connection" and eliminate the O'Hare plant
and reservoir.
Slide #7. (3/75 draft EIS p. 1-10)
In their rough draft of the Environmental Impact
Statement, the USEPA also anticipated the MSD's "cost-
effective calculations". But the USEPA had to edit out
any reference to the "cost-effective calculations" in
this published draft because the MSD failed to furnish
them and the USEPA apparently could not or just did not
make a cost-effective analysis themselves. In this
instance the considerable political power of the MSD
may have been influential in the USEPA not following
their own regulations by overlooking the requirement
for the cost-effective analysis.
Slide #8 (3/75 draft EIS p.c-3)
The USEPA must have reluctantly accepted this MSD
reference to their planning history as the cost-effective
justification for creating the O'Hare plant and reservoir.
It is absolutely amazing that the recitation of a history
is allowed to be substituted for a factual cost evalua-
tion. We must severely critize the USEPA for allowing
their regulations to be broken by the MSD.
Slide #9 (3/75 draft EIS pp. 3-6 and 2-29)
While we are on this cost-effective topic, let us
look at the size of the proposed O'Hare plant that the
USEPA mentions they are still studying. It should be
apparent to a casual observer that before you examine
the trees, you must first find the forest. The USEPA
somehow found themselves in the middle of this forest
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and admit that they are not quite sure how much sewage
this forest will produce and how this relates to other
service areas. Here we see a very vivid discrepancy
on 2 separate pages of the draft EIS, On pag- ' T:9
the USEPA is citing the NIPC employment f >•• e. .3 will
be up 37f° by the year 2000. And on page 3-6 the USEPA
is citing the MSD forecast of industrial acres will
increase by 26$% by the year 2000; I have inserted
the NIPC population projections that have been accepted
by both Illinois and reluctantly by the MSD that show
the population will increase 35f° by the year 2000,
Incidentally the proposed O'Hare plant has been designed
by the MSD using their own population projections of
439,000 in the year 2000 which is up 98^ compared to
the NIPC increase of 35$. It is amazing what the MSD
can get away with.1
Slide //10 (MSD Fac. Plan Overview Jan. '75 app F pp.5-8)
Here we see in the O'Hare service area the dis-
crepancy in population projections of 300,000 versus
439*000 times 150 gallon per day per capita results
in a 21 million gallon per day discrepancy in the design
year 2000, Also we see similar discrepancies in adjacent
service areas that have historically handled the sewage
since Des Plaines was annexed to the district in 1921.
Salt Creek will have an excess design capacity of 23 MGD,
Northside will have an excess design capacity of 20 MGD
and Stickney an excess design capacity of 28 MGD. The
estimated 40 MGD from our 300,000 people in the year
2000 can very easily be handled with just the excess
design capacity of Salt Creek, Northside and Stickney.
Slide #11 (3/75 draft EIS p. 3-2)
While we are on the subject of erroneous assumptions
leading to inaccurate design capacities, this is an
example of one of the factors that the USEPA either
developed themselves or just certified someone elses
.6-11
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work as correct. This set of data lead them to the
conclusion that the rate of per capita water consumption
is increasing in the O'Hare service area 2.667 gallons
per day each year. Note in cheir search for accuracy,
they give the conclusion in four significant figures,
But now let's see where this very accurate conclusion
came from. Note that the people in Arlington Heights
each used 69 gallon per day in 1966. And that "by 1970
they were each using 98 gallon very day, an increase
of 42$. That's quite a change in life style. In the
meantime the people in Elk Grove were each using 148
gallons per day in 1966 where apparently the lack of rain
required more lawn watering than further north in Arling-
ton Heights. But by 1970 the Elk Grove consumption had
dropped 12% to 131 gallonsper day. Have I made my point?
Apparently someone got too close to the trees again
and mixed population and water usage figures from dif-
ferent sources, I offer the opinion that the USEPA
•staff was being rushed to meet the June 30, 1975 dead-
line and they were receiving little help from the inade-
quate MSD Facility Plan and Environmental Assessment,
Slide #12 (3/75 draft EIS p. 2-18)
Here we are told by the USEPA that the capacity of
the interceptor to the Northside plant is 40 MGD and that
we are approaching that limit. I concur that the present
flow from "the Basin" is approaching that limit. It
makes no mention that about 10 MGD flow into the O'Hare
Basin will soon be directed to the new Salt Creek plant.
We will refer to the 10 and 40 a little later.
Slide #13 (Jan. 1968 Warren-Van Praag report on Northeast Area)
Rather than the 40 MGD capacity we saw in the last
slide, in January of 1968 the sewer capacity of the Rand
interceptor was 49.7 MGD. I asked for more recent data
in my 12/27/74 written testimony but the MSD again failed
to respond.
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Slide #1A ("Northside Service Area" graph Ward 2/19/75)
For simplification in this presentation we will
only talk about the red design capacity line and the
blue and green flow lines and will not discuss ,.
dashed lines. The USEPA received a copy of ^1.^ graph
attached to my letter dated February 22, 1975. However,
this was after the writing of the draft was concluded.
We can see that with the planned expansion of the North-
side Plant in Skokie from 332 MOD to 436 MGD, there will
be sufficient capacity available to handle the flows
without creating the O'Hare area. This excess capacity
will be sufficient to dewater the flow equalization
tunnel in 52 hours. The addition of the O'Hare plant
would only lower this dewatering time to 42 hours, which
is certainly not a cost-effective justification for
building the $95 million O'Hare plant.
Slide #15 (Cover of EPA Tech. Transfer on Flow Equalization)
The old concept of sizing a sewage treatment plant
one and one -half times the average dry weather flow is
no longer necessary with the concept of flow equaliza-
tion. This is simply including a retention structure
in the collection system to store the flows during peak
periods and then feed the stored flows to the plant during
off peak hours. This results in a more efficient constant
flow through the plant and eliminates some of the over-
building of plant capacity that has taken place in the
past, And the Northside Plant will have this capability
with the 600 acre-foot storage capacity of the Wilmette
to Addison Tunnel segment.
Slide #16 (3/75 draft Eis p. 3-
Now after the USEPA had reviewed the same informa-
tion that I have just partially shown, they came to
the conclusion that "the reported loadings and assump-
tions are not totally consistant with the final design
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criteria". In their merciful way this is certainly
an understatement,'
SITE
Slide #17 (USEPA questions to MSD, 12-23-7^ p. 1)
Now let's turn to the next topic of the reason-
ableness of the site selected by the MSD for the O'Hare
plant. Here we see the USEPA stating that the MSD
site selection focused on economic concerns. And the
USEPA is asking for an environmental evaluation utili-
zing a matrix of impacts on each of the sites con-
sidered.
Slide #18 (MSD 1-20-75 Matrix)
One month later the USEPA received this very simple
matrix that, with the exception of the fl's for water,
makes no sense whatsoever, Because the airport was
not zoned industrial, the MSD gave that site a -1 for
a negative visual impact. And they intentionally mis-
interpreted the flood potential question and related
it to the USEPA reference to the reservoir site. But
for this presentation, I will concentrate on the air
pollution impact of -1 on sites 4 and 5.
Slide #19 (MSD 1-20-75 MAP)
I have outlined the population areas on the MSD's
map in red. Note sites ^ and 5. Site 4 is the mobile
home area that was one of MSD's unfeasible alternatives
in 1966, Obviously if that site was selected -- and
it should not be selected -- there would be no people
left in that area. Now look at site 5 just southwest
of Oakton and Busse. No one lives within a half mile
of this site.
Slide #20 (MSD 1-20-75t para. B, Air Quality)
Here in the explanation of why ^ and 5 were down-
graded from an air quality standpoint, we see that
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sites 1, 2, 3 and 6 are all relatively isolated from
residential development. For sites 1 and 3 that is
ridiculous. The MSD says that site ^ adjoins a trailer
park when we have just seen that site k is the trailer
park. And they claim that site 5 is surrounaed by
residential houses.
Slide #21 (USEPA 1-29-75 follow-up para
The USEPA quickly detected this very bold error
by the MSD and in kind words told the MSD "it is un-
clear why sites 4 and 5 would have a negative impact
on air quality -- while the same reasoning would not
be true of site 1 which is directly south of a resi-
dential area. H
Slide #22 (MSD follow-up answer 2-3-75)
A few days later MSD's follow-up answer arrived
•in the USEPA offices and just repeated the "adjacent
to" and "surrounded by" statements again. But the
MSD was compelled to say something about the USEPA
question so they replied, "site 1, though adjacent
to a residential area, appears to be environmentally
more favorable because the effect of negative impact
would be experienced by fewer number of people."
That is totally amazing because 8,000 people live
within the 1 square mile north of site 1 and 3,000
people live within the square mile south of site 1.
Please note the comment on the USEPA file copy —
just the simple "What?". And the USEPA is allowing
the MSD to get away with these bold responses. Does
the USEPA really believe that a federal judge will
rule that these responses are acceptable elements to
an adequate Environmental Impact Statement? Will the
Region V management be proud of a work product that
contains these inputs when they are brought to the
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attention of the Council on Environmental Quality?
We predict that the answer will be "no" in both instances,
Slide #23 (Council on Environmental Quality to Ward
3-21-7^)
Anticipating possible local political problems
or over-emphasis on funding deadlines, we established
contact over a year ago with the Executive Office of
the President — his Council on Environmental Quality.
We will use this established line of communication as
the need arises.
Slide #24 (3/75 draft EIS p. 3-15)
The USEPA's examination of alternative sites was
so cursory that even the number of acres are not given.
Here they mention that the site next to Flick-Reedy
is in DuPage County where the MSD does not have the
power of eminent domain.
Slide #25 (aerial of Ward's sites 2 and 3)
Here we see this ideal location next to Flick-
Reedy which is marked site 3 on this aerial view. It
is on a receiving stream highlighted in yellow and
remote from any residential area.
Slide #26 (3/75 draft EIS p. 3-17)
In a very quick fashion on this page, the USEPA
eliminated 7 of the 9 sites that were under consideration.
All sites not owned by the MSD were eliminated apparently
in an effort to meet the June 30, 1975 funding deadline
for this fiscal year. But look at the reasons —
sites 5 and 9 were eliminated because of one building
on a portion of each site — one built last year and
the other under construction. Site 7 is in the clear
zone of runway 9L — did the airport state that this
would be a problem? Sites 3 and 8 were eliminated because
of unknown availability and undetermined acceptance.
Did the USEPA staff attempt to make a phone call or
write a letter? Did the USEPA Regional management think
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of exercising their leadership potential in pursuing
these obviously more environmentally sound sites?
Why did the citizens of this Nation create an environ-
mental protection agency?
As one final note on this slide, that t... it 8 is
vacant and for sale so the lack of the power of
eminent domain is no factor at this site next to Flick-
Reedy.
Slide #27 (3/75 draft EIS p. 3-20)
Here is the USEPA's attempt to relate the 2 MSD
owned sites to the residential areas. Even without
considering the relative magnitudes of the populations
in these residential areas, the USEPA should have con-
cluded that site 2 was approximately 900 feet more
distant than site 1 when measured from the center
of the aeration tanks. I have added the relative popu-
lation densities as a frame of reference. There is
a difference in the relative magnitude of 150 versus
10,000.
Slide #28 (3/75 draft EIS, p. 3-21)
Based on the USEPA conclusions that there will be
no health or odor problems, they concluded that there-
fore there is no advantage on the basis of distances
from residences. Let me make this point very clear —•
this entire site selection process is totally unacceptab"
to the people of this community that I represent,
Slide #29 (3/?5 draft EIS p. 5-32)
The USEPA concluded that #1) Funding the proposed
Water Reclamation Plant on site 1 is acceptable to the
USEPA, Again let me emphasize that their very shallow
method of site evaluation is not acceptable to this
community.
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Slide #30 (Ency. Brit, excerpts on "aesthetics")
I have never criticized a method or an alternative
without offering another method or alternative for
consideration, Here we see our Nation's guarantee that
assures for all Americans esthetically pleasing surround-
ings. Let me emphasize the word assure. Encyclopaedia
Britannica states that "in the broadest sense aesthetic
value is taken as intrinsic pleasure or the liking of
a thing for itself". "Aesthetics is the study of imme-
diate pleasure". The immediate response of 9 out of 10
people is that they would rather not live next to a
sewage plant.
Slide #31 (Ward's 2/13/75 site selection matrix)
Here we offered a constructive alternative method
of evaluating sites for a sewage plant. It considers
the threee primary factors in site selectioni aesthetic-
ally remote, emission control and cost. It also gives
an opportunity for assigning weights to each factor.
As we can see comparing the 3 uncovered sites that are
highlighted, the Oakton-Elmhurst site rated 24 points,
the site southwest of the Tollway and Elmhurst, 34 points
and the airport site, 44 points. I asked our Regional
Administrator, Mr. Mayo to have his staff evaluate this
site selection method. It was apparently received after
their draft was already written so we will expect it to
be reviewed in the final EIS next month.
Slide #32 (10001 distances from sites 1 and 2)
Here we see a more indepth evaluation of the rela-
tionship between sites 1 and 2 taking into account the
relative magnitude of each of the residential areas,
These are 1000 foot circles from the center of the aera-
tion tank area at each site. Note that the 2000 foot
green circle does not touch any of the 4 residential
areas.
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Slide #33 (graph of population affected 3/12/75)
Again note on this graph that the yellow area
reflects what we saw on the last slide that no popula-
tion is affected by the aeration tanks on site 2 until
after 2000 feet. And we can see that by this distance,
already 1200 people are affected by site 1. And the
relative isolation advantage of site 2 continues beyond
the 5000 foot limit of this graph.
Slide #3fr (IEPA letter of 2-10-75 para. 2)
v
* This letter from the Illinois Environmental Pro-
tection Agency to the USEPA gives their conclusions!
"We share with you and your staff considerable reserva-
tions about the District's choice of a site for the
facility, in view of the proximity of the site to an
-established residential neighborhood. We will approw
the site currently proposed by the District only if the
following conditions are agreed to and incorporated
into the Facilities Plan for the areai
a) Maximum visual screening.
b) Those process units that are sources of odor
during periods of process upset, or which may
produce aerosols capable of transmitting path-
ogens must be covered, and suitable additional
controls provided to eliminate these potential
hazards to the nearby residential areas."
"If in the alternative the District wished to pursue
relocation of the facility to a site further removed
from permanent residential areas -- for example the site
presently owned by the District which lies southwest
of the proposed site on the opposite side of the North-
'« west Tollway, it is conceivable that these requirements
can be relaxed somewhat, and perhaps eliminated."
I personally agree with these options and recommend
to the people that I represent that they, too, should
support these options with the following reservations i
1) that it is still not the most cost-effective
option to create the O'Hare Service Area
now that the tunnel system is receiving approval.
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and 2) that before the covered tanks and air purifica-
tion systems at Oakton-Elmhurst are certified
— some agency positively determine the current
cause of the eye-irritation problems at the
covered Clavey Road plant.
HEALTH
S?.ide #35 (3/75 draft EIS p. 5-19)
Now let's turn to the second tree in the forest
« the topic of health. We agree with the USEPA con-
clusion that "the fact that aerosols are generated
cannot be disputed".
Slide #36 (3/75 draft EIS p. 5-23)
To conclude that the presence of these aerosols
will positively result in a public health hazard is
not supported by scientific evidence. Conversely, it
has not been proven that there is no possibility that
such aerosols have any public health impact, Let's stop
there and ask if this constitutes the assurance required
in the National Environmental Policy Act of 1969t The
USEPA have not and cannot assure a healthful environ-
ment to our people adjacent to an uncovered sewage plant.
Let's continue — "There is simply no epideiniological
data available, of which we are aware, that would indicate
any public health impacts whatsoever." That is a very
positive statement — unfortunately as we will see in
the next slide it is not true.
Slide #37 (Ward's 12-27-7** Comments para. 3.11B)
Based on the advice of Dr. William Budge of the
Illinois Department of Publich Health that the eye is
a true indicator of air pollution, Mrs. Gail Winston
and Dr, Mark Levine designed the study. Dr. Gordon Hilton
and Dr. Leonard Sornat also were consulted regarding
the study. As we can see, the eye-related problem occured
from 6.8 to 9 times more frequently next to the Clavey
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sewage plant. Statistically this was a near exhaustive
survey with the chance for error determined to be 1 in
1 million. This study was given to the USEPA and they
have failed to even mention it in the draft BIT r-ven
though it was discussed at their January 28, }/"5 Air
Strategy Meeting,
Slide #38 (3/75 draft EIS p. 2-26)
The USEPA concluded that the air quality in the
vicinity of the project sites is already severely de-
graded because of the proximity to O'Hare airport,
Several scientists including Dr. Carnow and Dr. Rogoff
have concluded that the presence of chemical air pollu-
tion lowers the resistance of an individual to infection
by airborne viruses and bacteria transmitted in the
aerosols. The USEPA presented no discussion or con-
clusions on this subject.
Slide #39 (3/75 draft EIS p. 5-15)
The Public Health Service and many medical groups
have been carefully scrutinizing these individual problems
for years but they have conducted no studies to get an
answer to the question,
Slide #bO (IEPA 2-10-75 para. 3)
In regard to the public health risks the Illinois
Environmental Protection Agency concluded thati "In
our view, the evidence that such risks are significant
is very weak, but neither can it be stated with total
confidence that such risks are inconsequentially small".
They further stated that "Hopefully, the Environmental
Impact Statements will shed additional light but we are
not optimistic that this will be the case". The EIS
gave no additional information only USEPA regional
opinions, so we can expect that the certification con-
ditions of covering or relocating will not change.
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Slide #41 (3/75 draft.EIS p. 5-21)
Here is another statement that is contrary to
assuring our citizens a healthful environment» Even
more uncertain are the processes of the infection mecha-
nism once contaminated aerosols are inhaled by humans.
Because little is known of the minimum infecting dose
of most organisms, little can be concluded from a public
health standpoint. A range of from one to many thousands
of infectious organisms may be required to produce a
disease state. Let me repeat the USEPA statement that
little can be concluded.
Slide #42 (3/75 draft EIS p, 5-32)
However, here we see the second USEPA conclusion
that "present knowledge on the potential health hazard
'of aerosol generation indicates that covering of the
proposed Water Reclamation Plant is unnecessary.' We
simply cannot afford to accept such an unsubstantiated
conclusion and rely on the MSD promise to correct any
demonstrated problem,
Slide #43 (3/75 draft EIS p, 5-15)
We certainly cannot rely on the MSD to correct
future problems if they do not even acknowledge current
problems. Here the USEPA is stating that it cannot be
assumed that this plant will experience the odor problems
associated with other MSD facilities. The MSD flatly
refuses to admit that they cause odor problems so this
leaves us with no future assurance whatsoever for either
the potential aerosol or the odor problems.
Slide #44 (3/75 draft EIS p. 5-14)
USEPA observes that odor problems are usually
associated with over-loading, by-passing or indifferent
maintenance and that all the plants cited at the last
public hearing have experienced at least one of the above
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difficulties. Ok, "but it cannot logically be concluded
that even if the MSD could fix those three items, we
would have an odor-free plant. And historically, they
have not been able to fix them in their 86 vear? >f
existence, Also, there are other recognized sources
of odors.
Slide #45 (Tech-Transfer, Upgrading STP, p. 9-11)
The USEPA research staff indicates that "It is
also possible that a properly sized air supply system
can strip odorous gases from septic wastewater". It
should be expected that under certain conditions the
delayed arrival of wastewater from the 66 square mile
service area will result in septic conditions where the
gases will be stripped off in the first stage aeration
immediately after the grit chamber.
Slide #46 (Metcalf and Eddy - V/astewater Engineering p. 4?;
In their very accepted book on Wastewater Engineer-
ing, Metcalf and Eddy concur that odors can occur in
the air emanating from aeration tanks.
Slide #4? (3/75 draft EIS p. 3-60)
Sometimes the USEPA makes very positive statements
that are quickly proven incorrect. Here the USEPA is
stating that the practice of land application of sewage
solids does not contribute to any environmental pollution
— either air or water. Within days after I received
their draft EIS, the local newspaper reported that the
Illinois Environmental Protection Agency ordered the
MSD to stop shipping its treated sewage to Fulton County
because the stuff smells so bad. We admit that even
Des Plaines makes mistakes,
Slide #48 (3/75 draft EIS p. ii)
But we will not allow this mistake to be made in
Des Plaines — the USEPA conclusion that occasional odors
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may be detected from the proposed Wastewater Reclama-
tion Plant. For many, many years our local ordinances
have not allowed odors beyond the threshold level and
we have no intention of lowering our standards for the
sanitary district.
ISOLATION
Slide #49 (Ward to Hirt - USEPA 2-13-75)
Now let's shift to the last topic of isolation
distances. I initially informed the USEPA on January 23,
1975 of the U. S, Dept. of Housing and Urban Develop-
ment guidelines for not insuring mortgages on residences
generally within 500 feet of sewage treatment plants,
I followed-up the January 23rd notification with this
letter on February 13, 1975 that called the USEPA's
attention to several recent HUD decisions including
Frankfort Square. At the January 23rd meeting, I even
gave them the name of my HUD contact and his phone number.
Slide #50 (No Loans for Homes....Herald 2/17/75)
This article by Steve Brown, the editor of the
Herald, was the result of his independent research.
He states that the FHA and VA have regulations banning
the issuance of mortgages for houses within 500 feet of
a sewage treatment plant. He goes on further to say
that a survey of savings and loan associations indicated
a reluctance to approving loans near sewage plants.
Slide #51 (Devonshire map outlining 102 homes)
This map of the Devonshire Area indicates the
extent of the possible loan problems within 500 feet
of the proposed plant boundary. The 500 foot line
takes into account the 100 foot width of Oakton. 102
homes are included within this 500 line. This could
be solved by the MSD selling off a 400 foot strip south
of Oakton but that would only leave a 41 acre parcel
north of Wille Road which is too small for the plant.
6-24
-------
So obviously v.*=> have a 'problem that neither the MS')
or the USEPA had anticipated,
Slide 15_2 (3/75 draft EIS p. 5-25)
The USEP/ singly concluded that the f^, ..„ ,:,3gu-
lations did -not provide :;-:-ecific regulations that wusx
be followed fvj distance requirements,
Slide J51 (3/75 draft EIS p. 5-32)
The third and final conclusion of the USEPA is
that "while th*: ".r-r^nt l;.:'">r *,one is adequate, a
larger ouffor '? ,.\jt,;.L.d bs d-.<;-irable for aesthetic
purposes and •: : ' ' uf e^-a.Lned if W.ille Road were volun-
tarily abandcr r - ":he USEPA fails to mention that Des
Plaine-c pler.-fh?n . : * ft the --. ^ "rom $00 feet to one-
half milet pa>"'h depending, on vr.c nature of the proje
ar d upon the advice furruohed by environmental speci-
1 forwarded this letter to the USEPA on February 2ax.-
i (P'Trxnkfort Square field report)
If the USEPA had called the number I gave their*
followed -up on the Frankfort Square advice I gave t.
they would .^ave found this memo in the HUD files, P
the greciu Tr.erco dated 3/10/75 indicates Mr. Goldfarb
obtained -he information verbally from Mr. Brownyer
6-25
-------
is John Waner's assistant. He used this information to
compile his field report on the proposed Frankfort Square
subdivision. He reported that the sewage plant's boundary
line is 365 feet from the nearest residential lot line.
"This is in violation of this area office's standard of
500'.-
Slide #56 (Ward's 3-11-75 letter to 8? HUD offices)
On March 11, 1975 I sent a letter to all 87 HUD
offices in the United States requesting their local
interpretation of the HUD isolation regulations and any
field reports as examples,
Slide #57 (3-19-75 letter from HUD Grand Rapids)
I received dozens of phone calls by my slide prepa-
ration deadline but only this one letter from the Grand
Rapids, Michigan Insuring Office advising that the "State
of Michigan usually seek a minimum of 800' isolation on
even the smallest plant and a greater isolation with
larger systems". I have since received several additional
letters and these are representative examples!
Cleveland area requires 500 to 1500 feet
Wisconsin requires 1000 feet
Iowa requires 1200 feet
We intend to propose similar regulations to the
Illinois Pollution Control Board that will apply to all
new plants including the proposed O'Hare plant.
Slide #58 (3/75 draft EIS p.3-18)
We get some insight into why the USEPA has been
reluctant to select the most cost-effective and environ-
mentally sound alternatives. Mr, Mayo is concerned that
his federal regional office will be blamed for not spend-
ing this year's money in the Chicago area. As the draft
6-26
-------
states, it would be "an economic stimulus to the local
and national economy".
§i^iL,ii2 (Chicago Tribune 3A3/75)
John Quarles, the EPA Deputy Administrator from
Vi3.e-c.uc:ton confirmed this motivation when he said "getting
this i:!oney into the economy is EPA's No. 1 goal at this
tirn-?".
§IiJfl..li2 (July, 1971 Clavey EIS p. 29)
In the 1971 Clavey Plant situation in Highland Park,
the C:it:PA felt that the project did not fully satisfy
the letter, spirit or intent of the National Environmental
Pol lev Act of 1969. They could not assure an environmentally
s;if.< condition unless both the plant and retention basin
'ware c^/ared and the air purified.
§&&£jt&L. (Ward letter dated 7-3-73)
In 1973* w© cited 4 reasons why the O'Hare plant
should be at least given equal safeguards« the relative
sizr., the combined air pollution, the wind direction
and the established land use.
S"£*'''• P. j.t'A? (HTA 1Q6Q)
"•»' .«#•,. A. \ " v- 7|O <•« \ I Li-* JT J* 9 JL 7 ^ X /
It; this actual copy of the Act itself, the Congress
dec]-.ires that it is the continuing policy of the Federal
u^cr.a.uent, in cooperation with State and local govern-
m-3tv y to coordinate federal plans to the end that the
nay assure for all Americans safe, healthful, pro-
? and esthetically and culturally pleasing surround -
• without degradation, risk to health or safety,
;r undesriable or unintended consequences.
(aerial of sites 1 and 2)
In conclusion we must emphasize that an uncovered
sewage plant on the Oakton-Elmhurst site 1 is unacceptable
6-27
-------
to this community. We will accept a partially uncovered
plant on site 2 with the previously stated reservations.
Slide #6b (Our citizens anticipate!)
Finally — Our citizens anticipate j
1) That the Nation will identify and fund only
the most cost-effective and environmentally
sound alternative within the total MSB area.
2) That the Nation will "assure for all Americans,
safe, healthful, productive, and esthetically
and culturally pleasing surroundings".
6-28
-------
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February 13, 1975
Mr. llarlan D. Hirt
U.S. Environmental Protection Agency
230 South De.-ruorn Street
Chicago, Illinois 6o6(Vt-
Dear Mr. Hirt,
Please devoto a paragraph in the draft EIS to a
discussion of the VA and FHA interpertation of the
attached HUD reflations and the attached MT«n States
Standards."
Several representative opinions concerning sewage
treatment plant1", could possibly be citedi
- Franicford Square
-oBoselle
- Nev/ Lenox
- Hanover
Sincerely,
sewage
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Richard F. Ward
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> by STEVE BROWS SOO-fcXv '",'.,
from U Uiic
Somo home buyers may encounter
mortgage difficulties if their "dren;n Bt'i;' ''•'
house" is near a sewage plant. Sduui.ihi, '
Both the Federal Bousing Adminis-
tration «od tiM Veterans Administration
haw ttfulaUow banning the Issuance of
mortgagw for house* within 600 feet of a
s MM* plant
A mrvqr of tavtafi and loan awcd-
MiMi *tao lodtcMed that white there Is
M ftnud poftjy, tan otflcar* wodd be
idwtot to gnat mortg*g« ftw bomet
buflt nctr swrags pjscu.
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THE LOAN OUTUWK could pose follght to, "•
probleou to borne buyer* in some sec- Sanlta *y U!
aons ot Dos Plaiaa, EUc Grove Village d«ls. "-• c'
and Scbaumburg, wHch have rcstdeaUal than tt-ne • •
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D«B Plainea, lUinoiu
Your letter of 3-11-7& in regards to establishing an isolation factor
between a proposed sewogr. treatment plant ami existing residential use
Is acknowledged.
Our current regulationo and guidelines does not specifically Bp»U out
any given isolation as consideration muat be made to the total proposal
itself.
the proposal should be deaignad to be oompatible with
Ln any instance
adjacent land use.
Conoern IB also given to the size and type of system, health i
air pollution, noise and chemical truok traffic. Actual ait«
Ln respect to climate, trees, undergrowth, topographic condition* is
also part of a total analysis.
The attachment contained with your cornspondencs are the riHtHnsi
this office follow* and isolation eralaation is Bade en th» proposed
sewage plan as indicated in the penultlatte paragraph.
Sincerely,
Chltf 1bdtxwrlt«£
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Response: In order to address the above testimony by Mr. Ward, we will
indicate either the specific question on slide numbers to which
we are responding.
The commentary related to slides #2,3,4,5 and 6 deals with the
cost-effectiveness of the O'Hare WRP and the alternative of
interconnection with the main TARP system. We have reviewed
all the material pertinent to these comments and have com-
pletely revised the text dealing with these alternatives.
A complete discussion can be found in Chapter 3, section A.
The cost-effective information referred to in slides #7 and 8
has been included in Chapter 3, section A. A determination
has been made that the proposed combined sewer overflow
reservoir is separable from the proposed tunnel conveyance
system and water reclamation plant. This discussion can be
found in Chapter 1, section E.
In reference to the comments on slides #9, and 10, we have completed
our examiniation of the capacity of the proposed WRP. Our
evaluation and conclusion is found in Chapter 3, section B.
In addition to the above discussion, it should be pointed out
that a preliminary agreement has been reached between MSDGC,
IEPA and USEPA not to proceed with expansion plans for the
Northside sewage treatment facility. The flow projections
discussed in the commentary to slide 11 have also been examined
in the above referenced portion of the EIS text.
Our response to slides 12,13,14 and 15 is discussed in the
revised parts of Chapter 3, sections A&B and slide 16. This
statement refers to the many documents and projections that
have been made over time for the O'Hare service area. Over
a period of 10 years (1965-1975) many things have changed and
all documents are not updated to reflect specific parameter
modifications. The statement of inconsistency was not a
criticism but a statement of fact.
Slides # 17,18,19,20,21,22, MSD has re-evaluated all nine sites
and redone the environmental matrix; this is found in appendix Q.
Mr. Ward's graphic analysis of population patterns around site
2 are in appendix R . And is discussed in Chapter 3 section C.
Slide #23 No comment necessary
Slide 24,25,26 Appendix Q by MSD provides more detail on all
nine sites including engineering, environmental, economic and
energy analyses. This material supplements the revised dis-
cussion in Chapter 3 section C on site selection. Slide #27
Mr. Ward's relative population density data is an appendix R and
is discussed in Chapter 3 section C.
6-45
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Slides # 28 and 29
The odor and health question are discussed in Chapter 3 section C
and Chapter 5 sections I and L.
Slides # 30 and 31
We have reviewed Mr. Ward's site selection matrix prior to revising
our analysis of alternatives. (This matrix is found in appendix R)
the purpose of this matrix is to present an evaluation of site
alternatives based on 3 categories. We have recommended this matrix
as suggested realing prior to following own evaluation of the site
alternatives including the 3 categories identified by Mr. Ward. Our
review of Mr. Ward's matrix results in the following conclusions.
We disagree with the position that the WRP cannot be designed to be
aesthetically pleasing at all sites. (see Chapter 3 section C).
With respect to emission control USEPA has found no evidence that
indicates there is a demonstrable health hazard, however, we have
decided that a conservative approach would be in the best interest
of the public. We therefore are requiring that aerosol suppressive
facilities be installed for the aeration tanks as discussed in Chapter
3 section C and Chapter 5 sections I and L. With respect to cost-
effectiveness this has been addressed in Chapter 3 sections A and B.
Slide # 32 and # 33
This relative population analysis is in Appendix R and is addressed
in Chapter 3 section C.
Slide # 34
This is not the complete text of the letter. The last part of the
letter indicates that the IEPA retains the option of modifying any
of the above grant conditions stated in this letter following receipt
of the draft or final environmental impact statements.
Slide # 35
No comment necessary
Slide # 36 and # 37
The Clavey Road study referred to was not an epidemiological study
but rather a general health survey based on one health questionnaire.
Although the survey is statiscally significant there is no causal
relationship established between emissions from wastewater processing
equipment at Clavey Road and the eye problems reported in the survey
questionnaire that asked health questions about a period of several
years. To establish a causal relationship a carefully designed
epidemiological study must be conducted (such as the one ongoing
at MSB's Salt Creek Plant by Southwest Research Institute under
6-46
-------
sponsorship of USEPA) and coordinated with extensive monitoring
(both upwind & downwind) of pathogenic aerosol content. USEPA
is hopeful that this epidemiological study will provide more in-
formation relating to the potential health hazards of activated
sludge wastewater treatment plants.
Slide # 38
The comment made by Mr. Ward is valid. However the question is
not as clear cut as it seems. Other scientific evidence indicates
that the presence of chemical pollutants in the atmosphere also
may have a inhibiting effect on the bacteria and viruses trans-
mitted with aerosols. This is discussed further in Appendix S.
Slide # 39
No comment necessary
Slide # 40
See response to slide # 34
Slide #41, #42
See response to slide # 30 and #31
Slide # 43
USEPA believes that the odor control measures proposed for the
O'Hare WRP will prevent odor problems from occurring. However
should any odor problem develop the IEPA IPCB and the Illinois
Attorney General can take appropriate action to mitigate the
problem (see Chapter 5 section L.)
Slide #44
The proposed O'Hare WRP is not comparable to other existing MSB
facilities because of the planned odor control measures and the
lack of sludge processing facilities. See Chapter 5 section B and
appendix J.
Slide # 45
The 24MGD dewatering capacity of the proposed O'Hare WRP should
minimize any septic conditions in the tunnels and the odor control
measures should prevent any odor problems.
Slide # 46
No comment necessary
6-47
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Slide #47
This statement has been revised as follows: the practice of land
application of sewage solids minimizes pollution of air and water
and can be (when property done) most compatible way to recycle a
resource.
Slide # 48
No odors are anticipated under normal operating conditions, however,
any biological process can be upset e.g. should heavy metals get
in the sewage the activated sludge process could be upset with the
possibility of odors being produced while the MSDGC has ordinances
which prevent the discharging beyond concentrations of heavy
materials into sewers which could cause biological upset, the
possibility of this occurring cannot be totally ruled out.
Slides # 49-50-51-52
Applicable HUD guidelines do not specify isolation distances required
between residences and treatment plants; however, HUD recommends
the protection against possible odors by providing space between
residential properties and the plant. The generally recommended
isolation distance in this HUD region is 500 feet; however, both
HUD (FHA) and VA have indicated that this is by no means a re-
quirement. The isolation distance chosen is based on conditions
of each specific case; since no significant odor problems are
anticipated, USEPA does not foresee a conflict with the HUD general
guideline of 500 feet, considering the planned odor control measures
designed for the WRP.
Slides # 55-56-57
USEPA recognizes that the HUD Chicago Area Office generally accepts
a buffer zone of 500 feet for mortgage insurance approval of homes
near treatment plants. The"Frankfort Square" project was approved
by HUD in that all homes which were part of the application for
mortgage insurance to HUD were beyond 500'. Residences closer
to the plant were not part of the HUD application. A chart in-
dicating distances recommended by the 46 HUD responses received
by Des Plaines in regard to their letter of 3-11-75 is included
in this statement.
Slide # 58
USEPA has selected the most environmentally sound and cost-effective
alternatives possible considering the critical need to implement the
project so that combined sewage overflows are eliminated and that
redesign delays do not excessively inflate the cost of the project.
(see Chapter 3 section A,B,C, Chapter 5 section I & L and Appendix Q).
6-48
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Slide * 59
No comment necessary
Slide I 60,61,62,63,64
The Clavey Road Sewage Treatment plant project was an expansion
of an existing overloaded plant from 6 MGD to 18 MGD. Prior to
new construction it had a history of odor problems associated with
the operation of the 6 MGD facility. A comparsion between the
O'Hare WRP and the Clavey Road STP cannot be made because of the
many differences in design and process facilities. We believe
that we have fully investigated all concerns raised by Mr, Ward
resulting from siting the O'Hare WRP at all nine locations and
that the recommended action of this agency does meet the letter,
spirit, and intent of NEPA.
6-49
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THE CITY OF DBS PLAINES
COOK COUNTY, ILLINOIS
ALAN M. ABRAMB
• • •
Alderman Eighth Ward
514 WESTMERE MEMBER ILLINOIS
DES PLAINES. ILLINOIS uiiMiriDii icAfiic
6OO16 MUNICIPAL LEAGUE
RES. 437-0079
• US. 297-3370
March 31, 1975
2. Alan M. Abrams
City of Des Plaines
STATEMENT PERTAINING TO
DRAFT ENVIRONMENTAL IMPACT STATEMENT
OF THE METROPOLITAN SANITARY DISTRICT
CHICAGO-DES PLAINES 0'HARE RECLAMATION PLANT
By: Alan M. Abrams
Alderman 8th Ward
City of Des Plaines
51^ Westmere Road
Des Plaines, Illinois
The City of Des Plaines has authorized us to comment on
the draft environmental Impact statement.
The basic position of the City may be summarized as
follows:
1. The plant is not ecologically or socially acceptable
as now proposed.
2. The draft environmental impact statement is not adequate
in evaluating the environmental effects of the proposed
plant in that it fails to adequately consider and propel
ly evaluate the following:
a. The public health risks associated with pathogenic
air-borne emissions from such plant;
b. the combined effect of such emissions upon a large
human population now presently subject to extremely
poor ambient air quality due to pollution from
O'Hare International Airport;
6-50
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c. alternatives to the proposed plant in terms of
(1) alternate plant sites; and/or
(2) treatment of emissions from the plant to
eliminate odor and pathogenic emissions.
3. If such factors had been adequately evaluated and con-
sidered, the EPA, of necessity, would have concluded
that the proposed plant is environmentally unsound.
II. PERSPECTIVE
To bring this hearing into perspective, we are commenting
here effectively under the auspices of the National Environmental
Policy Act of 1969. Under that Act, when a Federal agency pro-
poses any project which has a major effect upon the environment,
such agency must prepare an environmental impact statement.
A basic mandate of such Act is the recognition by Congress that
"each person should enjoy a healthful environment", and further
that any Federal Action must "attain the widest range of bene-
ficial uses of the environment without degradation, risk to
health or safety or other undesirable and unintended consequenses."
Under the regulations promulgated pursuant to that Act by the
Council on Environmental Quality the agency involved should con-
duct a "rigorous" exploration of all environmental matters in-
cluding threats to health by the proposed action.
We submit that the draft environmental impact statement as
now proposed by the EPA totally fails to meet the mandate and
the objectives of the National Environmental Policy Act as well
as the regulations promulgated thereunder by the Council on
Environmental Quality.
As indicated in our prior testimony, the Metropolitan Sanitary
District in preparing its environmental assessment totally failed
to adequately evaluate the environmental impact of the proposed
plant in respect to:
1. The ambient air quality in the proposed plant site area;
2. The dangers to public health resulting from air-borne
pathogenic emissions and bacteria from the plant;
3. The combined effect of such pathogenic emissions and
the already existing seriously deteriorated ambient
air quality at the proposed plant site.
6-51
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During the hearings on the environmental assessment prepared
by the Metropolitan Sanitary District, various citizens, micro-
biological experts and the City of Des Plaines did present evidence
on these critical issues. Such testimony, moreover, did clearly
establish that:
1. There are serious potential dangers to the public health
due to pathogenic emissions from sanitary treatment plants;
2. The present ambient air quality at the proposed plant
site is adversely and seriously affected by aircraft
emissions from O'Hare Airport; and
3. There are reasonable alternatives readily available for
the plant in terms of
a. alternate plant sites; and/or
b. treatment of emissions from the plant to control
odors and pathogenic emissions.
Notwithstanding this clear and convincing evidence presented
on these critical environmental issues, the Environmental Protec-
tion Agency has basically chosen to either ignore this evidence
or, when considered in part,to conclude that such evidence does
not conclusively show the existence of any serious public health
hazards.
We submit that this is in conflict with both the letter
and spirit of the National Environmental Policy Act of 1969.
III. REVIEW OF POSITION OF EPA ON CRITICAL ENVIRONMENTAL FACTORS
A. Ambient Air Quality at Proposed Plant Site
The Metropolitan Sanitary District in its Environmental
Assessment, as we previously testified, grossly misrepresented
the quality of air at the proposed plant site.
In contrast, we presented data from a study conducted by
the Argonne National Laboratories which clearly indicated that
the ambient air quality at the proposed plant site was already
under an extreme environmental impact primarily due to aircraft
emissions from O'Hare Airport.
The Environmental Protection Agency apparently agrees with
this position but then chooses simply to ignore the data and
generally dismisses it as of absolutely no consequence. For
example, the Argonne data as presented by us and the EPA comments
relative thereto are as follows:
6-52
-------
1. Particuiate Matter
The Argonne study indicated levels outside O'Hare
as high as 180 micrograms per cubic meter and inside as
high as 240 micrograms per cubic meter and further that
"if such levels persist throughout the year then the level
would exceed the National Ambient Air Quality Standards
promulgated under the Clean Air Act of 196? as amended."
The EPA agrees and indicated "It does appear, however,
that samples taken close to airport sources generally
violate standards but that concentrations of particulate
matter decrease with increasing distance from the airport."
2. Nitrogen Oxides
The Argonne study indicated nitrogen oxide levels as
high as 209 and 440 micrograms per cubic meter at posi-
tions near the proposed plant site. In respect to
nitrogen oxides the EPA concluded that "It Is very common
In certain areas spot samples will result in readings
which greatly exceed the hourly standards," that is the
Federal Ambient Air Quality Standards.
3. Total Hydrocarbons
The Argonne study indicated that total hydrocarbon
levels were as high as 1970 micrograms per cubic meter
and as high as 2130 micrograms per cubic meter in areas
near the proposed plant site. As further indicated by
the EPA in reference to the Argonne Study, the hydro-
carbons from the aircraft emissions may contain a sub-
stantial portion of reactive hydrocarbons which are
known contributors of photochemical smog.
These levels of pollutants range from 3 to 14 times the
National Ambient Air Quality Standards and clearly demonstrate
that the quality of the air at the proposed plant site is extremely
contaminated. Moreover, these standards were established at
levels necessary to protect the public health. Ironically, it
is the EPA which has the primary jurisdiction to establish these
national air quality standards. Apparently In considering the
proposed plant the EPA is simply ignoring the standards which the
Agency itself has set as being necessary to protect the public
health. In conclusion, the EPA states:
"In general, it appears that air quality in the
vicinity of the project site is severely degraded because
of the proximity to O'Hare Airport. While comprehensive
sampling indicates that the standards for some pollutants
are not violated, spot sampling would certainly indicate
a noticeable degradation of the air quality in the area."
6-53
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We are, of course, vitally interested in the plant vicinity.
Moreover, we submit again that such site is under an extreme
environmental impact due to pollutants from O'Hare aircraft.
As we previously testified, the proposed plant site is directly
under the approach path to runway 32R-14L, one of the airport's
busiest runways. Further, as discussed by the Argonne personnel,
the exhaust plume trailing a landing jet aircraft is visible at
ground level over a distance of one to two miles from the end of
the runway. Thus aircraft landing on runway 14L will leave a jet
engine exhaust plume of high pollution levels extending from one
to two miles from the end of runway l^L and therefore directly
into and onto the area of the proposed plant site. The EPA also
recognizes this fact in the draft statement and indicates that
the exhaust plumes increase the atmospheric pall in the airport
vicinity. These exhaust plumes, however, do more than simply
create an atmospheric pall. They contain high levels of pollutants
such as unburned jet engine fuel, nitrogen oxides, hydrocarbons
and particulate matter. It is these contaminates in these ex-
tremely high levels which settle directly upon the proposed plant
site as aircraft arrive and depart from runway 32R-14L.
B. Health Hazards Created by Odors and Air-borne Pathogens
Created by Sanitary Treatment Plants
The EPA generally concluded that there is no specific evidence
indicating that air-borne pathogens created by a sanitary treat-
ment plant will, in fact, cause a serious public health problem.
The EPA does, of course, recognize the opinion of various experts
that there is a potential danger from such air-borne emissions
but simply concluded that in the absence of specific data of
illness or health problems the Agency will take a wait and see
attitude as follows:
"In summary, it can be seen that there are innumer-
able factors which control the viability and infection
potential of micro-organisms commonly found in waste-
water aerosols. To conclude that the presence of these
aerosols will positively result in a public health hazard
is not supported by scientific evidence. Conversely,
it has not been proven that there is no possibility that
such aerosols have any public health impact. There is
simply no epidemiological data available, of which we are
aware, that would indicate any public health impacts
whatsoever. Given this tremendous gap in evidence, we
cannot, at this time, conclude that the aerosols gen-
erated at the O'Hare Water Reclamation Plant will have
any significant adverse impact. This Is by no means a
closed case. Should such evidence become available, we
would find it imperative to require mitigative remedies
necessary to eliminate any public health hazard as well
as implement compliance with any law applicable."
6-54
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In arriving at this position the EPA presumedly based its
conclusion in part upon a survey of several experts. The con-
clusions of these experts are reported in the draft statement.
Our reading of these statements convinces us that a serious
public health hazard does exist. For example, Dr. Hutton D.
Slade, a noted expert in microbiology, indicates that there is
a definite potential health hazard associated with the proposed
O'Hare plant. Dr. G.E. Quan of Northwestern University agrees
that a potential health hazard does exist but, as also indicated
by Dr. Love of the EPA staff, little is known about the extent
of the potential health hazard. Also Robert Brunch of the EPA
further indicated that:
"The literature is replete in documenting the
potential hazards of aerosolized sewage organisms."
In responding to this critical environmental question of
pathogenic aerosol emissions, the Sanitary District presented
a position paper which in effect concludes that there is no
health hazard. The conclusion is mainly based upon the District's
argument that certain studies of sewage treatment workers has
not revealed any increase in health risks associated with
operating such plants. This, of course, is factually untrue.
As indicated by Lelan J. McCabe of the EPA, there are studies
which indicate that sewage treatment plant workers had higher
rates of leptospirois and infectious hepatitis than the general
public. The EPA further indicated in reference to the District's
conclusions that certain medical experts believe that the possible
lower illness rate of sanitary treatment plant workers may be
due to a gradual immunization of such workers over a lengthy
period of time.
In reference to these studies pertaining to sewage treatment
plant workers we submit that quite likely none of these studies
were conducted in an environment such as that which now exists
at the proposed plant site where the ambient air is substantially
polluted and contains levels of pollutants which substantially
exceed the standards now set by the Federal Government to protect
the public health.
Even more significant in this respect is the fact that we
are not here primarily concerned with the potential adverse health
effects upon the average, healthy worker employed at treatment
plants. Rather we are vitally concerned here with the impact of
the pathogenic emissions from the plant upon those most susceptible
to illness, namely the newborn, the aged, asthmatics and the young
and aged with heart and lung diseases. These are the individuals
of our concern. These Individuals unlike sewage treatment plant
workers will be living in the plant environment 24 hours a day,
7 days a week, 30 days a month, 365 days a year. These individuals,
moreover, will be living near the plant in an ambient atmosphere
6-55
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which already, according to Federal Ambient Air Quality Standards,
is not suitable or adequate to protect the public health.
In this respect and as we previously testified in reference
to the statements of Dr. Bernard Carnow, a noted expert in air
pollution, and as reported in the Chicago Tribune on January 10,
1971:
"Death by air pollution doesn't strike like a bullet,
it is slow like poison. It strikes the weakest people -
babies, infants, asthmatics, the aged with heart and
lung disease."
This is the same Dr. Carnow who previously testified for the
final environmental impact statement pertaining to the North
Shore Sanitary District, Clavy Road Plant, that the combination
of air-borne viruses and bacteria generated by sanitary treatment
plants together with atmospheric pollutions and irritations such
as nitrogen oxide, sulfur oxide and particulants will likely
reduce the resistance of humans to illness.
It is readily apparent that no one can predict with total
and absolute certainty that if the plant is constructed whether
the substantial quantities of air-borne pathogens emitted into
the heavily polluted atmosphere near the plant will result in
serious illness or death. However, a total certainty of serious
health problems has never been an essential prerequisite in
formulating public health or environmental policies. Rather
governmental action has always and correctly been predicated
upon the existence of potential dangers. For example, the
Eighth Circuit Court of Appeals, in the recent case Involving
Reserve Mining pertaining to the generation of abestos fibers
into Lake Superior and into the air, stated in summing up the health
issues:
"It cannot be forecast that the rates of cancer
will increase when drinking Lake Superior water or breath-
ing Silver Bay air. The best that can be said is that
the existence of this abestos contaminant in the air
and water gives rise to a reasonable medical concern for
the public health. The public's exposure to abestos
fibers in the air and water creates some health risks.
Such a contaminant should be removed."
Thus our environmental laws and their implementation have
universally recognized this basic principle in public health
matters that there need not be absolute and predictable results,
only that there be recognized risks. The record here clearly
shows such risk. There is a serious and recognised potential
health problem associated with air-borne pathogens from treatment
6-56
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plants and when emitted Into an atmosphere already under severe
environmental pollution the risk for the humans in this area
is manifestly clear. The imposition of such risk upon the people
living in this area is, moreover, contrary to the mandates of
the Environmental Policy Act of 1969 which insure for every
American a healthful environment free of risks to health;
The EPA should, therefore, reconsider its conclusions In
reference to the proposed plant and direct the Metropolitan
Sanitary District either to relocate the plant to a site more
remote to a large human population or more appropriately to
redesign the plant so that all emissions are collected and
treated prior to atmospheric release so as to eliminate odors
and pathogenic bacteria.
Alan
Abrams
6-57
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Response: Several comments were made by Alderman Abrams about our
interpretation of the Argonne air quality data. He believe
we have made a fair interpretation of the data and will
respond to each area of concern.
With respect to participate matter, we do not agree with
Mr. Abrams interpretation of the Argonne Study. The data
presented in the Argonne Study cannot be directly compared
to the National Ambient Air Quality Standards since the
sampling periods are not identical. First of all the
primary national ambient air quality standard, is an annual
average no greater than 75 mg/m . No annual average data
was presented in the Argonne Study. Data from other sources
did indicate that the primary standard was not violated.
The standards also require a 24-hour maximum no greater than
260 mg/m . Samples on airport property indicate that 100%
of the 24-hour values obtained were 240 mg/m^ or less while
100% of the 24-hour samples outside the airport were 180 mg/m^
or less.
We do agree that the hourly standard is violated with some
spot samples, but the great variability in data also indicates
that these levels are found only in very isolated areas of the
airport grounds where there is the greatest vehicle concentration.
It should be pointed out that annual average are well within
the standards. •
Our conclusion indicated that while the air was noticeably de-
graded in the project area, standards were not always violated.
It is not necessarily valid to assume' that the air quality
present on the airport site itself is identical to that at
the site of the proposed WRP. Furthermore, we do not feel
sufficient data exists to draw any conclusions about synergistic
effects of air pollutants and any aerosols generated from the
WRP. There have been some studies in this area and these were
discussed in Chapter 5 of the Draft E1S and in Appendix S of this
EIS.
6-58
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Mr. Abrams also contends that we failed to recognize the
input we received which indicated that there was a potential
public health hazard from aerosol-transmitted organisms.
Although there is no demostrable evidence that indicates
any health hazard exists from aerosol transmission USEPA has
decided a conservative approach would be in the best interest
of the public. We therefore are requiring that aerosol
suppressive facilities be installed for the aeration tanks
as discussed in Chapter 3, Section C, and Chapter 5 sections
I and L,
6-59
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3. Charles Willis, Village Manager
Village of Elk Grove Village
Mr. Willis presented a chronology of interest by Elk Grove Village
in the O'Hare water reclamation plant. A copy of this chronology
is included in section D of this chapter.
4. Bernard Hemmeter, Director of Engineering
Village of Mount Prospect
Mr. Hemmeter presented a resolution urging the MSDGC to proceed
with the tunnel conveyance system and water reclamation plant.
It is reporduced in Section D of this Chapter.
5. Edward Edgenlerg, Jr.
(appearing for the MSDGC)
Mr. Edgenlerg indicated that the proposed odor control measures
proposed for the O'Hare WRP are over and above those generally
included in treatment plant design.
6. Otis J. Sproul
(appearing for the MSDGC)
Mr. Sproul stated that on the basis of his experience in viral
research, review of the MSDGC plans, and review of pertinent
literature on the subject, it is his conclusion that there
has been no receorded instance of infection or disease resulting
from people being in the general proximity of wastewater treatment
plants.
7. Heinz P. Zupke
Comments: (See following page)
6-60
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Gentlemen!
Over the past years testimony has been given by experts who contended
that the proposed treatment facility should not be built at it's
present location, but if no other site was availble that the design
should be changed. As a lay person and homeowner I can only judge
through things presented by the news media. Recent articles indicate
that the prime concern of the MSD is allocation of available federal
funds without regard to the health and welfare of the residents of
the neighborhood affected by the proposed treatment plant.
On March 11, 1975 in the 9AM newscast on WGN Radio it was announced
that no more treated and deodorized sludge should be shipped to Fulton
County because it smells. This statement was made by the Illinois EPA.
My question is this: If treated and deodorized sludge gets to be
objectionable why cant't precautions be taken that the untreated sewage
does not develop into not only something objectionble. In addition not
only should objectionable odors concern you, but also the potential
hazard for the residents of our area.
Either move the facility or cover it. Most of all restore some of our
faith in government by proving to us that our testimony means something
and that our concerns are really listened to.
Heinz P. Zupke
670 West Elizabeth Lane
Des Plaines, Illinois
6-61
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Response: Our discussion of the potential odor problems at the O'Hare
WRP can be found in Chapter 5. Many of the odor producing
processes at the proposed facility will be enclosed and the
ventilated air treated through ozonization before release
to the atmosphere. All sludge handling processes will occur
at the John E. Egan WRP.
8. Hugh McMillan
MSDGC
Mr. McMillan referenced our concern regarding the cost-effective-
ness of constructing a 72 MGD facility. He directed our
attention to attachment C for the final environmental assessment
documents. Our discussion of this issue can be found in Chapter
3, section B.
9. Alan M. Abrams, Alderman
City of Des Plaines
The following statement was made by Alderman Abrams at the
March 31, 1975 public hearing.
10. Charles Bolek, Alderman
City of Des Plaines
Mr. Bolek presented a brief summary of the events which led
to the MSDGC1s purchase of site 1 in 1966. The acquisition
of site 1 occurred shortly after MSDGC officials met with
officials from the City of Des Plaines to look at alternative
sites and discussion the City's objections to site 1.
11. Spencer Chase, Alderman
City of Des Plaines
Mr. Chase acknowledged the amount and quality of work performed
by Alderman Ward and Alderman Abrams on the project. He
reiterated the consistent and unanimous support from the City
Council over the years.
12. Frank Palmatier
Village of Arlington Heights
Mr. Palmatier presented a statement on behalf of the Village
supporting the tunnel conveyance system and water reclamation
plant. This statement is reproduced in section D of this Chapter.
13. Howard DiDoMenico
Mr. DiDoMenico indicated that Mr. Vinton Bacon (former General
Superintendent of the MSDGC) was opposed to site 1. He expressed
his concern for the health of his family and his opposition to
the construction of the WRP at site 1.
6-62
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14.
Response:
15.
Response:
16.
Response:
17.
18.
Response:
Donald Dvorak
Mr. Dvorak's statement concerned the need for the construction
of the O'Hare water reclamation plant. He feels that the
North Side Plant can adequately handle day weather flows in-
definitely and that the only problem would occur in wet
weather. He suggests that this could be resolved by inter-
connecting the Des Plaines - O'Hare tunnel conveyance system
with the main TARP system.
Sections A and B of Chapter 3 have been revised to reflect
the concerns expressed above.
Daniel Dudych
Mr. Dudych indicated his concern for the air quality of the
area and, in particular the effect of the combined impact of
the WRP and the already degraded air quality.
These concerns, as well as recommended mitigative measures,
are discussed in Section B of Chapter 5.
Ed Zych
Mr. Zych inquired about the impact of the
on his family and property value.
proposed project
Chapter 5, Section B and C, discuss the impacts of the pro-
posed project on air quality and land use, including a specific
discussion of the effect on property values.
Richard Harwood
Home Builders Association of Chicago
Mr. Harwood read a statement supporting the construction of the
O'Hare Water Reclamation Plant and the tunnel conveyance system.
Jeff Ketelsen
Mr. Ketelsen expressed the concern of his school for the wildlife
present on the proposed WRP site.
USEPA contacted the Cook County Forest Preserve District con-
cerning the possibility of relocating some of the rabbit pop-
ulation on the proposed site to the Ned Brown Forest Preserve.
They indicated that this would probably be unnecessary as they
could easily adapt to urban situations and because other suitable
habitat was available in the area.
6-63
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19.
Response:
Raymond Miller
Mr. Miller emphasized the need for the proposed projects,
because of the basements In the area being flooded, but
suggested that another site be found for the proposed
treatment facility.
There are many factors vhlch need to be considered In the
selection of alternate sites Including the critical need
to proceed with a project. This discussion Is found In
Section C of Chapter 3.
6-64
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B. Written Statements
1. Richard F. Ward
Commenting for the City of Des Plaines
Mr. Ward submitted his comments on April 21, 1975. His submittal
consisted of six sections and we will address each of these indi-
vidually.
a. December 19, 1974 Public Hearing Testimony
This section is actually a resubmittal of the testimony
Mr. Ward presented at a public hearing held by the MSDGC
on the Environmental Assessment for the proposed Des
Plaines - O'Hare projects. The MSDGC has responded to
this testimony in three public hearing documents submitted
to this Agency on February 5, 1975. They have also advised
us that these documents are available in the Des Plaines
Public Library. Mr. Ward feels that the MSDGC has not
responded to all his comments made at the hearing. While
we do not agree that their response was incomplete, we
must also point out that many of his issues are repeated
in later testimony and therefore have been addressed by
this Agency either in the EIS itself or in the following
comments.
b. December 27, 1974 Written Comments
As we indicated above these issues have been addressed
by the MSDGC. Again we must point out that the major
issues raised by Mr. Ward have been dealt with in the
text of this EIS and in this Chapter.
c. January 1975 to March 1975 Correspondence
The above correspondence was reviewed in the preparation
of the Draft and Final EIS. Wherever necessary we
responded directly to Mr. Ward or have taken his submitted
materials into consideration in the formulation of our
decision.
d. March 31, 1975 Public Hearing Testimony
Our response to Mr. Ward's testimony can be found in
Section A of this Chapter.
6-65
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e. April 21, 1975 Written Comments
The additional comments submitted by Mr. Ward are repro-
duced on the following pages. We have numbered his comments
and our responses will be numbered to correspond with
his individual comments.
6-66
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1 THE CITY OF DBS PLAINES
•i* . COOK COUNTY. ILLINOIS
f RICHArtO ^ WARD
* Alderman 8th Word . •••
0«i ptineT7mno,s60018 MEMBER ILLINOIS
m
-------
fcl
«, estimate of the maximum number of viable particles that
JJ will be emitted to the Des Plaines atmosphere under the
most adverse conditions? Under these adverse conditions,
|j how many particles per breath will our children inhale at
the fence line of the plant? What percent degradation from
[ the upwind ambient air quality will be caused.by the aerosols
from the proposed sewage plant under the average and most
F adverse conditions?
L : .
F 3. page ii (Bib conf,) "There is no demonstratable health
*• hazard associated with these aerosols." Why was the Clavey
CEye Irritation Study omitted from consideration in the
draft EIS after it had been submitted to the Illinois Pollu-
tion Control Board on December 9, 1974 and the USEPA on
!P
1^ December 19 and 27, 1974? ^e must assume that .the Clavey
Study was omitted to justify the USEPA draft conclusions.
4. page iii (2a) "The effluent flow in the design year is
f* projected to be 72 MGD." By whom? Other projections have
• been given as low as 40 MGD by various reviewers including
§Des Plaines starting with the actual flow of 30 MGD in
1970 from a population of 223,000. There is more discussion
t
m of this subject in the Section III letters as well as later
m
I* in this section.
W
|wt 5. -page iii (4A) "Alternatives Considered - Nine site locations
for the WRP." The USEPA omitted considering the 3 sites
f. that were the first choice of the MSD in their June, 1964
ii*.
study. The USEPA was made aware of these sites in Attach-
T ment #11 to Des Plaines 12/27/74 Comments. All three sites
' are still undeveloped and partially owned by the.MSD or
r Chicago. Why were they omitted from consideration?
fe
p 6- Page iii The most significant alternative that was omitted
L from MSD or USEPA consideration is the most cost-effective
and environmentally sound option of utilizing the increased
•^ collection capacity and flow equalization capabilities
of the proposed Tunnel and Keservior Plan. Possibly there
I is a message in the March 12, 1975 statement by USEPA
-------
Deputy Administrator John Quarles that "getting this money
into the economy is EPA's No. 1 goal at this time." (Chicago
Tribune, 3-13-75). Des Plaines officials and others have
contended that this Nation could save over $100 million by
examining the "cost-effective calculations" that were edited
out of the rough draft of the EIS. It seems reasonable to
expect that getting the money into the economy in a cost-
effective and environmentally acceptable manner should be
EPA's No. 1 goal.
7- page iv • USEPA acknowledges that portions of the draft EIS
were taken directly from the November, 197^ Environmental
Assessment prepared by the MSD. The USEPA should state that
it accepts the responsibility for the accuracy of those por-
tions taken from the EA. i
8-. Page 1-1 Does the USEPA accept the .responsibility for the
accuracy of the draft EIS statement, "The projected average
dry weather flow by the year 2000 is 72 MGD"? |
9. figure 1-1 The outlined area is inaccurately described as ,
the "Upper Des .Plaines Drainage Basin". This is a proposed
service area that the MSD desires to create without the justi-
fication of cost-effective, calculations..
10' page.1-6 "During wet weather, the North Side sewage treatment
plant is presently overloaded and existing interceptors are
approaching capacity." This is an unsubstantiated statement
that may not be considering the capacity of the Salt .Creek
plant or the planned 104- MGD expansion of the Northside plant.
11. page 1-9 "Prior to the issuance of a draft EIS in November
1972 an Environmental Assessment (EA) on the TARP program was
prepared," The draft EIS was issued in 1973, not 1972 and by
the applicant (MSD) and not by a federal agency — therefore,
it may be misleading to call it a draft EIS. Does the USEPA
concur? Also, why has a draft and/or final EIS not been *
published on the TARP system as of now? It is impossible to
examine the O'Hare "Service Area" until the reviewing agencies
6-69
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have examined the interrelationship with the total Facility
Plan. Quite obviously thin has not been accomplished and
this may be the reason why the cost-effective calculations
that justify creating the O'Hare service area have been
omitted.
12. page 1-9 "A public hearing on the TARP EA was held July 26,
1973, and discussion was presented. " The records indicate
that this was called as a meeting and not a hearing. Also
the required 30 days notice for a "hearing" was not given
to the public. The purpose of the meeting was to present
TARP alternatives and several speakers were invited in addi-
tion to the MSD staff. The testimony that this reviewer
offered was .uninvited and unexpected.
13. page 1-10 This is one of the most important pages in the
entire draft EIS. It reveals that "other engineering studies"
(not referenced) justify the creation of the O'Hare service
area and plant. This is the section where the References to
"cost-effective calculations" were eliminated from the pub-
lished draft EIS either because they did not exist or because
they did not justify creating the service area. A logical
and factual discussion in the final EIS is absolutely essen-
tial for the public trust to be restored in the environmental
review process, The second paragraph on page 1-10 is equally
revealing — "The O'Hare Service Area can be separated from
TARP"." — but should it be? The last sentence reveals that
the USEPA really does not know what should be done in relation
to the $3.3 billion TARP system. That is a very honest but
sad admission. Unfortunately the federal courts and the Presi-
dent's Council on Environmental Quality may not be sympa-
thetic to the regional draft findings.
14. Page 1-12 Reference to January 20, 1975 MSB answer to USEPA
December 23, .197^ questions is missing. Also, January 29»
1975 follow-up questions from USEPA to WSD is missing. Also
February 3* 1975 follow-up answers by MSB to USEPA is missing.
Why? Besides dealing with a number of relatively important subjects
-------
this series of letters contain the core of the 10 year con-
trpversyi the MSD's environmental justification for the
Oakton-Elmhurst site. This exchange between the applicant
(MSB) and the USEPA is a classic example of the political
arrogance and moral integrity of the MSD and the utter frus-
tration of the USEPA staff. The USEPA staff caved in under
this historical MSD tactic possibly because the staff may
not have had the backing of their superiors,
For those of you reading these comments that have been
denied the MSD's January 20, 1975 site evaluation, copies
have been included on the following pages for your reference.
Using the same MSD sites and environmental factors, we will
. reconstruct the matrix and the USEPA is requested to comment
on both versions in the final EIS. We agree that the water
quali-ty will be the same at all six sites. Regarding, air
quality, sites 1 and 3 are both upwind from substantial resi-
dential populations. Sites kt 5 and 6 would be relatively
isolated (3,000 people now live on site 4 but would have to
be relocated, which of course should not even be considered).
Site 2 falls between 1 and 3 and bt 5 and 6 in terms of rela-
tive isolation. The noise and visual effect would be the
same on all sites. The flood potential of each site is seen
on page 2-22 of the draft EIS. Sites 1 and 2 are in the 100
year flood area. Site 6 would partially be flooded and sites
3, b and 5 are not flood prone. Please note the different
. site numbering system by the MSD and USEPA. Using the same
. sites and factors the matrix should look like thisi
MSD Site # I 2' 2 4 £ 6 •
Water tl +1 fl +1 fl fl
Air -1 0 -1 fl fl . fl
'Noise 0 0 00 0 0
Visual Effect 000000
Flood Potential -1 -1 fl fl fl 0
-i o fi f3 f3 f2
Can anyone reading this imagine what would have been
the USEPA "findings" if the MSD had honestly prepared the
environmental site matrix. The USEPA staff was on the right
track in requesting the matrix but they lacked the fortitufle
and the time and the support to insist on honesty. However,
6-71
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this reviewer has the fortitude, the time and the support
and as wo have insisted on honesty for the last 10 years,
we will continue to demand honesty into the future,
15. page 1-12 "February 6, 1975 USEPA received Revised Environ-
mental Assessment and Responses of the MSDGC to Public com-
ments". Another tactic frequently used by the MSD is deny-
ing requests for documents during the environmental review
process because of pending litigation. The-federal authori-
ties are responsible for finding a solution to this tactic
which short-circuits the review process. Even though the
Facility Plan Documents were requested early in January when
no litigation was pending, the City of Des Plaines did not
obtain these documents until the end of March. Even the
Illinois EPA did not receive the Revised EA as of the public
hearing March 31, 1975. As this review is being written on
April 11, 1975 I have, still not received a copy of the Revised
EA, If there was not so much at stake for our community, we
too might have become utterly frustrated as the MSD desires.
16. page 2-1 "The area is 60% developed...The 1970 population
for the area was 223,000." As page 1-5 indicated 5,000 acres
(13#) of the 37,250 acres are expected to remain undeveloped.
If the Wo = 223,000 ~ 30 MGD = 1970 then the remaining 7.1%
development will result in 13.5 MOD additional flow in the service
• area or an ultimate average dry weather flow of 43.5 MGD,
. The ultimate development of the area will occur sometime after
the year 2030. Therefore this is a further correlation that
our 40' MGD estimate for the design year 2000 is reasonable.
17. page 2-4 This figure confirms that the Devonshire/Waycinden
area is downwind from both sites. 1 and 2.
is. page 2-23 Note the location of the "combined overflow reser-
voir". Federal Regulations require the combined impact of
related components to be considered. If the reservoir is
to be retained in this EIS, then the plant cannot be con- <•
sidered alone. The USEPA is requested to address this aspect
of their regulations in the final EIS,
-------
19. T?aqe 2-25 Particulate matter standards are currently being
5*| violated.
fcei
if? 20. page 2-25 The highest nitrogen oxide levels were obtained...
^ near the ends of runways l^R and I**-!*.
M 21. page 2-26 "Total hydrocarbon levels...(west Of site 1)
ranged from 1535 ^g/m^ to 2100 /ig/m^." "The maximum standard
H rf for a 3 hour period, which is not to be exceeded more than
once per year is .160 /ag/m3. "
™
* 22. page 2-26 "In general, it appears that air quality in the
H vicinity of the project sites is severely degraded because
of the proximity to O'Hare Airport." The draft EIS discus-
H sion stops at that point. Again the omission of inputs by
** Dr. Carnow and Dr. Rogoff were necessary in order to justify .
H the site i favorable findings. In the final EIS, we expect
1 that the USEPA will discuss the effect chemically polluted
air has on the probability of infection from microbial con-
j| tamination.
1 23. page 2-29 "Other Programs in the Area" possibly should
include the combined sewage reservoir.
24. page 3-10 Why is the word contiguous omitted from the refer-
H ence to the MSD 1965-66 site criteria of 100 acres?
m 25. page 3-11 The plant can be accommodated on a ^-0 acre rectan-
m • gular plot — not 65 acres as the draft EIS .states.
H 26. page 3-11 Why is an "adequate buffer zone for aesthetic
reasons" needed if 'the USEPA has found that the plant will
y * • be attractive and there will be no odor or health related
problems? This is an apparent contradiction.
» .
I • • " •
27• Page 3-11 In addition to "the tpllway on the south", 3000
r people also live there (on site 4). *
y • '
f 28. Page 3-13 Why would site 2 require 500 to 1500 feet of
^ 7 foot diameter influent sewer to dewater the 20 foot tunnel
6-73
-------
that ends on that site? Also why should site 1 only require
600 - 700 feet of influent sewer? How large is site 2?
29. Page 3-13 In 1966 the airport authority said 3 other sites
were not available, not site 3. Please refer to Des Plaines
12/27/7** Attachment #11. Also site 3 was not recently con-
sidered for a stormwater retention reservoir as the draft
EIS incorrectly states.
X
3Q ,i5age 3-1** What i's the current value of the industrial build-
,/' ing under construction on site 5? Is that sufficient reason
/ for the site being eliminated? How large is site'5?
' 31. page 3-1** How large is site 6 and what is the value of the
buildings on that site?
32. Page 3-lft Please state reference to draft EIS conclusion
that "WRP on Site #7 may cause a safety hazard to aircraft".
33. Page 3-15 If site 8 is for sale as the letter in the USEPA
files indicates, why was the site downgraded because the
"MSDGC does not have the powers of eminent domain?"
/
34. page 3.-16 "Since all of the sites considered, except site 3
are within areas zoned for light industry, the plant is
visually well suited for placement in any of the sites con-
sidered. " Sites 4 and 7 are also not zoned for light industry.
35. Page 3*17 Sites 3 and 8 were eliminated because of unknown
availability and/or undetermined acceptance. These are not
reasons, they are excuses, Because the site question has been
the central issue for 10 years the USEPA could have at least
solicited letters from Chicago and DuPage stating they were
opposed to a sewage plant on those sites. Of course, possibly
DuPage may not have been able to find a reason to refuse the
plant and then the June 30, 1975 deadline may have been exceeded.
*
36. page 3-18 "The proposed Water Reclamation Plant appears
to be adequately designed." We desire a stronger assurance
-------
Pi
J
that the plant has been designed to'the highest standards.
37. page 3-20 The responses to the questionnaire in Appendix D
are referred to but there is no discussion that indicates
that 5 of the 8 responses indicated a potential health hazard
would exist. A composite of the responses would be desirable.
38. page 3-21 If the USEPA really believes that there is no
health hazard and no odor problem then the location is irre-
levant and the alternate sits question should not have even
been discussed in the draft EIS. USEPA please comment.
39. -page 3-21 The present 150 foot buffer zone would have been 300
feet if V/ille Road had been vacated. The 300 foot number from
the 1968 Brown and Caldwell report should be incorporated into
the final EIS. !
40. page 3-29 The MSD 1990 assumption of a total flow of 2118 MOD
and a service population of 5,770,000 equals 367 gallons
per day per capita which deserves some USEPA comment.
• . • ' • • l
41. page 3-^-1 Colonel Miller of the Army COE is quoted regarding
the Land Treatment Alternative as being not "socially accept-*
able". Has the USEPA made a determination that the uncovered
t '
O'Hare plant on site 1 is socially acceptable?
42. page. 3-^3 The draft EIS notes that, the plant design capacity-
may be excessive but that has no effect on considering alter-
natives. That is not accurate because it is difficult to
justify creating a separate service area to process ^0 MGD
(12%) of the projected 329 MOD Northside flow in 1990. See
."Northside Service Area" graph in Section in letter dated
2-22-75.
43. page 3-^7 The "No Action" discussion overlooks the Tunnel
and Reservoir Plan with the Northwest Tunnel connected to
the Des Plaines River Tunnel. . ,
6-75
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44. page 5-5 It mentions that occasional odors can usually be
traced to 5 sources. What are the other possible sources of
odors?
45. paffe 5-11 "The only potential sources of odor at O'Hare"
will be covered. Certainly the aeration tanks and settling
tanks can also be sources of odors as the testimony and refer-
ences in the previous Section IV has indicated,
46. page 5-12 During the pre-chlorination process, what per-
cent of the H2S that may be generated during low flow con-
ditions in the 66 square mile collection system will be reduced
to chemical compounds devoid of any. unpleasant odor through
•oxidation? Whatever percent is left will very effectively be '
stripped from the raw sewage in the next process — the first
stage open aeration tanks.
47. page 5-13 What is the distance from the ozonated exhaust air
stack to the fence line? V/hat is the maximum height allowed
by the PAA under the approach path of runway l^L at the pro-
posed stack location. Does the comprehensive plan of the City
of Des Plaines allow a stack of 115 feet in this location
across the street from an established residential area?
The USEPA is requested to discuss the aesthetic qualities of
the proposed stack as related to the visual qualities a resi-
dential area should expect from an adjacent typical suburban
light industrial facility.
48 page 5-13 The exhaust ozone concentration will be kept below
an average of 0.015 ppm which is double the "ozone watch"
level of 0.00? ppm. What has the MSD experience been at their
other plants that use ozone systems to control odors?
49. page 5-1^ We concur that the plants cited at the December 19 »
197^ public hearing have experienced either over-loading or
by-passing or indifferent maintenance. But the odors were not
always associated with one of those three situations and it-
does not logically follow that the O'Hare Plant will somehow
6-76
-------
,
& be a shining exception in the MSD system. Why has the MSD
not taken the initiative to improve its odor image at its
'\ *'*
y| existing plants?
"i 50. page 5-15 "....it cannot be assumed that this plant
oi
will experience the odor problems associated with other MSIV-C
[ft facilities. If significant odor problems result from the
Lil
operation of the proposed plant, it would be possible to
|U take necessary mitigative measures at that time." Would
. these measures be similar ,o the actions that have not been
ei taken at the existing plants? Des Plaines is certainly not
H* ready to accept an empty promise and that is exactly why we
have adopted the odor threshold lim.it in our health ordinance.
j| It would be greatly appreciated if the USEPA would read and
comment on the internal KSD memo dated September 11, 1973
H regarding their inability to meet a standard 8 times the odor
threshold concentration (12/2?/?^ Attachment #10).
51. page 5-15 If any one of the aerosol generation studies taken
g as a separate isolated situation could be interpreted as a
•" potentially alarming problem by a non-expert, then what does
•a the composite of all the studies mean to the experts? In
H' Appendix D, they either say "We don't know" or "Because of
m ' the potential hazard we should be cautious." None of them
H concluded that "a good location for a 96 MGD sewage plant is
adjacent to a. residential area". Somehow the USEPA picked
jl ' an ear of corn out of a basket of apples and oranges. The
•USEPA should explain what conclusions they drew from Appen-
I ' dix D. '
"*•
H 52. Page 5-15 If the "Public Health Service and many medical
, groups have been carefully scrutinizing these individual
§ problems for many years" —then'why are there no published
studies to document this USEPA statement? Also we are not
predicting "epidemics or similar catstrophic problems" —
j§ we are concerned about the more subtle 5% or 10$ increase
of respiratory problems that may not even qualify as "statis-
H tically significant". We are also concerned about the
ff 6-77
-------
doubts and fear that we have indirectly helped to create
in the minds of our citizens. We are not willing to accept
the hope of a possible future answer. We are not ready to
allow the plant as proposed to be built next to us while
waiting for the probably useless $278,000 Salt Creek Health
Study on persons living beyond a half-mile from that sewage
plant. Incidentally, the Salt Creak plant may have been
selected for the study because there possibly were no situa-
tions in the United States whero a sewage plant of the size
desired was being built next to a substantial existing popu-
lation. The USEPA is requested to verify or deny this obser-
vation with specific details. . ' ^
53. page 5-16 USEPA Region V is "recommending diligence in the
pursuit of this missing information". This is nearly a
duplicate of the statement that Region V made in July, 1971
and during those last ^ years the federal authorities
have produced nothing. And we are concerned that when the
Salt Creek results are available in 1976, we will still have
no answer. The Clavey Eye Irritation Study offers some insight
into the scope of the hazard, but the USEPA failed to address
that study in the March, 1975 draft EIS. We can only question
"why" .and will offer no opinion at this time.
54 page 5-16 "Much of the reported work with biological aerosols
has centered on the study of coliform bacteria that have been
the traditional indicators of domestic fecal pollution." Why
have the coliform bacteria been excluded from the Salt Creek
study? Including them would offer an opportunity to relate
the current results to previous studies.
55. page 5-17 "This differentiation demonstrates the need for
specific testing of Klebsiella and other specific pathogens
in biological aerosols from wastewater studies in lieu of
the more traditional general coliform group". Des Plaines
co'ncurs and has set standards that will limit the respiratory
intake to similar levels prescribed in the USPHS Water Quality
Standards for average daily digestive intake. While the legal
aspects of interpreting the federal regulations are being
-------
argued in U. S. District Court;the reasonableness of the 42
E. Coli and t^ Klebsiella standards should be discussed in
the final EIS. If the USEPA desires to propose air quality
"*; - standards to fill the current federal and state void, the
*** Des Plaines officials would be most willing to participate.
"•»,
;"•'
*^ 56 page 5-17 It is good to know that the "activated sludge
pj process liberates ten times as many airborne coliforms as
& the trickling filter." But no whers in the 362 pages of the
* draft EIS can we -find an estimation of the aerosol microbial
^ *
•'•'.• concentrations that the proposed 96 MOD O'Hare plant will
emit under average and most adverse conditions. How can the
fi^Q
g - USEPA approve any facility before estimating the pollution?
n 57. page 5-18 Kenline's dispersion model that predicted the con-
i *
centration downwind from an aeration tank with an emission
i|i rate, of 440 bacteria/sq. m,/sec does not make a correction
W for plant size. Even though the emission rates are the same
p, per square meter of surface, the concentration 500 feet down-
H wind from the proposed 8 acres or O'Hare tanks will be greater
than 500 feet downwind from a 80 square meter aeration tank.
?3
H The USEPA is requested to comment in the final EIS on the
estimated concentration 500 feet downwind from the proposed
Si O'Hare- aeration tanks.
m . • . • • .
H 58. page 5-1.9 "The fact that aerosols are generated cannot be
23 ' •
** disputed". Des Plaines concurs,
S- •' •
^* 59 page 5-20 Des Plaines also concurs that at 20 feet downwind
m from the proposed aeration tanks, 60$ of the bacteria remain-
F*^
£'* ing are small enough to penetrate the lungs. This percentage
of the remaining bacteria inr^eases as the bacterial cloud
•m, '• • '
passes into our residential area. What is the USEPA estimate
aU
of this percentage at the MSD fence line and nearest residen-
H tial lot line? Also what is the USEPA estimate of the quan-
$s
tity (average and adverse) and percent of viruses that will
f- allow lung penetration? f
u,'-
w • 6-79
-------
60. page 5-21 The USEPA should further explain the statement,
"Because little is known of the minimum infecting dose of
most organisms, little can be concluded from a public health
standpoint." Please relate this to the recent U. S. Supreme
Court decision on the Reserve Mining Case in Minnesota that
recognized that potential hazards, as well as after-the-fact
evidence, must be taken into account. As the Chicago Tribune
editorial on April 8, 1975 stated, "Water pollutants that
require up to 20 years to kill need not be tolerated until
dead victims can .be cited in court. All branches of govern-
ment, with public support, are saying ever more clearly that
a technically complicated society requires sophisticated safe-
guards of its water. The days when it was all right to dump
any amount of anything anywhere are over. They have to be."
Again Des Plaines simply desires the air we breathe to be as
pure as the water we drink.
61. page 5-22 We concur with the USEPA conclusion that, "it is
not adequate to compare 'sewage workers' to individuals-in
the general population who may come into sporadic contact
with infectious agents in sewage aerosols or on vegetation
and soil". Does the USEPA concur that this statement is a
contradiction to the primary MSD argument in "Health" position
paper on page I-2,"The purpose of this survey is to review
what is known about aerosols generated by sewage treatment
plants for two points of viewi
1. The aerosols themselves, their persistance and
composition
2. Public health implications associated with sewage
treatment facilities.
The second topic will be discussed primarily with respect to
wastewater treatment personnel,"
62 page 5-23 "There is simply no epidemi©logical data available,
of which we are aware. that would indicate any public health
impacts whatsoever."(emphasis added) Please explain this
Statement in relation to the Clavey Eye Irritation Study tHat
was presented to the USEPA on December 27, 1975.
-------
Li
63• page 5-23 The reference to "implement compliance with any
?- law applicable" is an apparent contradiction to Mr. Mayo's
statement of August 21, 1974, "To the extent that your ordi-
TI nances would not be in conflict with Federal law and con-
struction grant regulations, it would be an implied condition
te of any grant." The U. S. District Court of Appeals recently
^* ruled against the AEG for violating their own regulations
tw; f at Portage, Indiana. This decision also cited that the AEG
la overlooked their own staff recommendations. A similar situa-
m tion may exist wi-thin the USEPA where possibly contrary
jj, * recommendations may be contained in "3 memoranda, dated
1/7/75, 2/4/75 and 3/5/75, concerning first the drafters'
|r conclusions and thoughts regarding site and size alternatives."
This is a statement from a letter dated April 7, 1975 from
H Robert B. Schaefer, the USEPA Regional Counsel in which he
denies our request for examination of these documents. Be-
E cause the site question has been the core of the controversy,
we feel it is improper for the drafters * conclusions and
P thoughts regarding site alternatives to remain legally hidden.
&t We pray that the USEPA will reconsider this denial and incor-
porate these memos in the final EIS or at least make them
^ available for evaluation to a neutral third party such as
Congressman Crane.
64. Paf^e 5-23 "Because of the interest in this particular subject,
P we have also included MSDGC's position paper with respect to
health aspects in Appendix I." The draft EIS contained only
ip ' the USEPA and MSB's ideas. Any contrary ideas were excluded
"•~" with the exception of 3 respondents in Appendix D. This does
«• not improve the reputation of the USEPA for being objective.
L. . Will someone reviewing the draft EIS be aware of our imputs
of 12/19M, 12/27/74, 1/21/75, 1/25/75, 2/13/75, 2/14/75,
£ . 2/21/75, 2/22/75, 2/26/75? How do we know they were even
considered if they were not discussed in the draft EIS? We
P assume they will each be included and discussed in detail in
the final EIS.
r
65. Page 5-24 The "Village" of Des Plaines is a City.
r
L 6-81
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66. gftpe 5-25 "The (HUD) Handbooks do not provide specific regu-
lations which must be followed (for example, distance require-
ments)." The USEPA should agree that it would be impossible
for the HUD handbooks .to provide specific isolation minimums
for every conceivable situation. But the USEPA is remiss for
not attempting to determine how the non-specific guidelines
are specifically interpreted by local and regional HUD offices.
Again, this information had to be omitted by the USEPA to
justify their approval of Site 1. The Des Plaines officials
did the work for .the USEPA and requested inputs from all 8?
HUD offices in the United States. As of this writing we have
received a total of 46 ret lies that contain substantial and
detailed information that very clearly proves that site 1
could not be approved by the agency of our federal government
that is concerned with the homes of our citizens. These HUD
replies also revealed the existence of State Isolation Standards
in b out of the 6 states within our own USEPA Region V. All
^6 replies are reproduced in the following Section VI.- No
additional replies have been received as of this writing
(4/l^/75)(and therefore none have been withheld because they
did not support our position). The USEPA is requested to <
study these federally required isolation distances and comment
in the final EIS. They will find for an average sized plant
an average required isolation distance of 1000 feet between
the plant boundary and the residential boundary. The half mile
long 100 foot width of Oakton would be totally unacceptable.
67 "Page 5-25 Concerning the homes adjacent to the sewage plant
the draft EIS concludes "any long-term decrease will be
negligible." Please relate this conclusion to the HUD regula-
tions included in the draft EIS Appendix 0. Apparently HUD
does not concur. We suggest the United States Environmental
Protection Agency and the United States Department of Housing .
and Urban Development should begin a dialog before the final
EIS is written. Their local phone number is Area Code 312,
353-7660. The phone numbers of the other *f5 HUD offices that
responded to our request for information are included in their
letters reproduced in the following Sectior, VI.
6-82
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V:
H, \
68. p&fte 5-25 "Onco constructed and landscaped, the site should
be aesthetically pleasing in the context of its surroundings.
This is not accurate either considering the broadest meaning
of the word (see Itr, to Mayo dated 2/14/75 in Section III)
or considering the proposed 115 foot stack.
69. page 5-2? 'Vhy is it important "to maximize the ground level
visual screening" if the plant should he such an attractive
and socially accepted addit-.on to our community.. This is
an apparent contradiction that the USEPA is requested to
explain,
• **'
70. page 5-28 The draft EIS states that "Extensive provisions
y
have been made in this project for odor control at key
!i| odor generating points." This is an apparent contradiction
KJ
™ to the statement on page 5-11 that is worded VThe only
«Hi potential sources of odors " We agree with Ketcalf &
|;?|
li Eddy and the USEPA Technology Transfer Series that the aera-
tion and settling tanks are also' potential sources of odor
n
H release. Uncovered tanks on site 1 are not acceptable to
Des Plaines. Uncovered tanks on sites 2 through 9 are con-
§ ditionally acceptable.
/
|i . 71> page 5-31 The draft EIS states that "The use of sludge as
a landfill will not have any detrimental effects on the sur-
f rounding area," This is an apparent contradiction to the
$<*& . • , •
* Illinois Pollution Board Case #75-112 which is the "Illinois
•& EPA vs. KSDGC — Complaint charging respondent with the dis-
&..i
charge of contaminates so as to cause air pollution in vio-
lation of the Environmental Protection Act in the operation
j| of its sludge utilization and disposal facilities in Fulton
A
County. A hearing is mandatory." (IPCB Environmental Pvegis-
1 , ter #100 dated March 28, 1975 - New Cases). The USEPA is
a
requested to clarify their draft EIS statement,
3»
Jjj •••'''
72. "Page 5-32 (Finding #1) Funding is not permitted until all
jf conditions are met including state certification and compliance
I. - • '
y. 6-83
j
It
-------
with local environmental laws and regulations (40 CFR 35.925-1^)
Site 1 is not permitted under federal interpretations of mini-
mum isolation distances from residential areas,
73 Pages 5-32 (Finding #2) Covering of tanks at site 1 is man-
datory to meet local emission standards and to "assure for
all Americans, safe, healthful, productive, and esthetically
and culturally pleasing surroundings — without degradation,
risk to health or safety.... "(National Environmental Policy
Act of 1969). The MSD has demonstrated that they will, not even
acknowledge the U5EPA recognized odor problems at their existing
facilities,
74. "pages 5-32 (Finding #3) The present buffer zone of 100 feet
(width of Oakton) is not adequate based on federal decisions
made by sanitary engineers from the housing viewpoint. The
status of v/ille Road will not change the 100 foot boundary
distance which is the federal measurement practice. Also the
USEPA should explain why a "larger buffer would!be desirable
for aesthetic reasons." This is an apparent contradiction to
the USEPA conclusion that a sewage plant is an attractive and
socially acceptable neighbor similar to an attractive suburban
light industrial facility.
75. .page 6-rl This chapter should not have" been left blank if. the
USEPA desired to present contrary opinions in the draft EIS
for 'circulation, examination and comment. If the USEPA intended
to limit the circulation of opposing ideas, opinions, facts
and conclusions, then the objective was accomplished. ,ve will
predict the USEPA explanation that because of the voluminous
nature of the input, it was all excluded. If limited to state
and municipal comments without attachments, it would have
added approximately 70 pages to the 362 page draft EIS.
76. page 7-1 What is the status of the draft EIS on the Tunnel
and Reservoir Plan? The USEPA is requested to comment on the
Des Plaines opinion that the entire TARP system concept should
6-84,
-------
'-*!>> #
have been studied before the O'Hare facilities (which are an
element of TARP)are approved for funding. Also please comment
on the decree of federal involvement in the preparation of
the TARP draft EIS. Does the responsible federal agency
accept responsibility for the accuracy of statements made by
the MSD and Bauer in their preliminary draft EIS?
77. page 7-7 The City of Des Plaines M-23-74 Health Ordinance
is referenced but is not discussed anywhere in the draft EIS.
• Can the environmental review process be completed without
addressing the reasonableness of the air pollution limitations
for bacteria and odors ' Will funding be approved before the
legal aspects are resolved? Will funding for the northwest
porti-on of TARP be approved before TARP is evaluated to deter-
mine the cost-effective interrelation?
ft*
78. page A -12 "population equivalent of 439,000" should be
revised downward to 300,000 in the design year 2000 to agree
If with NIPC projections adopted by Illinois and MSD.
L '
1? 79. Page A-13 Note use of "land located in the clear zones for
^ t additional public benefit." Please relate this in the USEPA
* draft EIS statement on page 3-17 i "Site 7 is being elimina-
& ted because it lies in the 'clear zone' approach to runway 9L
^ . on O'Hare International Airport." Of course an effort would
\ '
a* • have to be made to keep all structures low or flush with the
surface but this would be less expensive than the $30 million
^•^ tank covers on the Oakton-Elmhurst site plus another $15
million for air purification equipment and the annualized
F " operating costs. USEPA please comment.
iL *. .
^ 80. page A -15 Has a cost-effective analysis been calculated on
*" utilizing the 850 acre-feet combined sewage retention capacity
••.«i of the Mount Prospect reservoir as a flow equalization on-line
it reservoir in conjunction with the. connection of the proposed
,r northwest tunnel to the Des Plaines River Tunnel. Our calcu-
i^ lations indicate this would be more cost-effective and elimi-
nate the need for the O'Hare plant and reservoir. The USEPA
in
I is requested to evaluate this option in the final EIS. Please
-------
considert 1) the start-up of the Salt Creek plant 2) the
1968 capacity of ^9.7 MOD in the Rand interceptor 3) the
planned 10^ MGD expansion of the Northside Plant and 4) the
planned expansion of the Stickney plant. .
81. page B-l Please examine the cost-effective calculations of
TARP Alternatives G, H, and J that do not include the O'Hare
reservoir and relate these calculations to the need for the
O'Hare plant based on the revised service area flow estimate
of ^1 MGD (including industries and infiltration) from an
effective population of 300,000 in the year 2000.
82. Page B-2 Has a delay beer approved by the Illinois Pollution
Board to allow the estimated 6 overflows per year into Weller
Creek after the December 31, 1977 deadline? This will be
necessary if the 1800 foot O'Hare combined sewage reservoir
is no longer actively being considered. Of course, if the
reservoir is still a vital part of the plans, then the com-
bined pollution impact must be considered in the final EIS.
83. pape B-2 The Stearns Reservoir has been dropped from the
1975 major revision of TARP based on a request from Chicago
that said "it would become a lar^e open-pit during dry weather"
periods and a pool of combined sewer overflows during and
after storm periods." Such use "is in conflict with city
requirements and planning. " In an MSD report dated September A
197^ the Stearns Quarry was dropped from the TARP system.
The Stearns Quarry is in Mayor Daley's home llth Ward. The
location of the O'Hare plant and reservoir are in conflict
with our planning and we have requested consideration of more
environmentally sound'sites for 10 years. The USEPA is
requested to comment on the possible relationship between the
disposition of these two requestr regarding the engineering,
environmental and cost-effective principles used in each MSD
decision. . .
84. -page B-12 Without the Stearns Quarry reservoir the mainstream
•
tunnel would have to be increased in size from ^2 foot to
55 foot diameter. This will raise the system cost from $25
-------
to
to $50 million dollars according to MSD district superintendent
f; Bart Lynam (Sun Times, 3/7/75). USEPA please comment.
K, oc page B-13 The MSB statements on this page leave the impres-
ts
sion that a 2700 acre-foot O'Hare reservoir is still being
H considered. Again let us repeat that federal regulations
^ require the consideration of the combined environmental impacts
fjs* and combined cost-effective calculations. Is the USEPA read-
is ing their regulations differently than Des Plaines? USEPA
please comment. •
86 page B-lfr- Increasing the diameter of the Des Plaines River
f| •c—a ~
y Tunnel should allow sufficient capacity for the connection
to the northwest tunnel system. Has the USEPA scheduled a
i] draft EIS for the Des Plaines River Tunnel and the McCook-
Summit Reservoir?
87. page B-20 The ?/!SD describes the 58$ changes in the November
m '74 TARP system as "minor variations". The "possible inter-
Hi . connection" under O'Hare Airport has been eliminated. USEPA
m please comment if this is cost-effective. Also please comment
|f if public hearings will be required on the 58$ "minor varia-
tions" of the TARP system.
88. Page C-3 There are no cost-effective calculations or even
3 a comparison of the total costs of .various alternatives in
Appendix C or any of the References. Citing the "review of
1 the planning history" as the cost-effective justification for
** creating the service areas should not.be acceptable to the
t USEPA because a history does not fulfill the requirements in
the federal regulations. The various policies and plans that
m . were revised over the past 15 years should be updated to reflect
J the adoption of the TARP system. No federal funds can be
approved for the O'Hare plant until the creation of the service
H , area is justified.
fl 89. page D-16 & D 17 When our windows are open during July and
August and our backyards are used most frequently, the
ll 6-87
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predominate wind will be out of the S-SW 32# of the time.
Subtracting the calm conditions from 100# and multiplying
by 3/16 would sive an evenly distributed wind from this direction
of 18$ of the time.
90 pape D-36 Dr. Bunch (USEPA research) states that "the actual
data available would indicate that the risk is very small."
But no data is provided to justify that conclusion.
91. page D-36 "Primary settling basins may need covers if the
sewers coming into the plant are septic or contain offensive
organic compounds." Should this be classified as a potential
source of odor in the final EIS?
i
92. page D-36 Why are "scientifically placed wind baffles"
. suggested if the "risk is very small"'from "the drift of
bacteria from the aeration tanks'? f
I
%
-93. Page D-39 Dr. Wellings (State of Florida) "These data indicate
that there is a possible health hazard in siting a waste
treatment facility of this size and type in this location".
USEPA please comment.
94 Page D'-40 "There are odor problems in- a half to one mile
radium of a 5 MOD activated sludge treatment plant in northwest
St. Petersburg. The odors are augmented by humidity and wind
direction. I would anticipate that the proposed plant would
pose similar problems."
95. "Page D-**-5 Dr. Love (USEPA Research) "There is some potential
health hazard but too little is known to define the extent
of the hazard". Does this constixute the "assurance" and
"without degradation, risk to health or safety" that is pro-
vided by the National Environmental Policy Act of 1969?
96. page D-^6 Why was Clifford Risley of USEPA Region V not aware
of the minimun isolation distance requirements in 4 out of
the 6 States in Region V?
-------
Ml
97. Pa^e D-^7 Why did Clifford Risley of USEPA Region V not
recall the Clavey situation when answering question #7?
USEPA please comment on paragraph ^.13 of our 12/27/75 comments.
98. page 1-4 "up to JQ% reduction in coliform counts per
meter distances from 1320 to 4-224 feet.". What was the bottom
U-limiJl™. V..O-U1L-™-
end of this range up to
^ 99. Page 1-9 "It is recognized that as little as one tissue
culture infective dose (TCID) of certain viruses may initiate
$*
jk infection in man." .Des Plaines concurs with this MSB state-
ment based on the literature reviewed. What levels of micro-
1^ bial contamination does the MSB and/or USEPA estimate that
ggjg
will be generated by the proposed plant? And what levels are
j?. considered "without degradation or risk free" by the ffSD and/or
m
USEPA? '//hat percent increase in respiratory infections is
p considered acceptable by the MSB and/or USEPA?
fe
«pj! 10o. page I -11 "The fact is that the combination of factors necessary
& to produce an illness is not known." This MSB statement cannot
be considered as any assurance to the people living next to
k the proposed plant.
/
f! 101. page 1-12 What is the reference to "lower property values"
doing in the MSB's position paper on the Health Aspects of
jf ' Sewage Treatment Facilities?
m ' 102. page 1-13 Where in the United States is a plant of this
I. • — . ^ •
*i** magnitude being "sited in close proximity to populated areas"?
103. 2*ge 1-13 Please provide a population versus distance bar
graph on the population "near" the Egan plant that are par-
ticipating in the health study. Also relate this bar graph
to the survival distance of microbial air pollution.
Page J -2 Sewage plants are not "causing vehment opposition
from the public, notably because of an apparent odor potential
•
but because they smell.
! 6-89
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105. pafte J-8 Considering the MSB's "prime obligation to promote
a healthful environment within its jurisdiction" why has
the MSD been so insensitive to the odor problems at Northside
revealed in the 1968 and 1973 surveys?
106 page K-2 Why is the f'SD "evaluating methodology for reducing
aerosol transmission from the plant proper1?
107. Page K-4 If the MSD "has chosen" not to attempt to answer
each individual question, will the USEPA address each of our
questions and comments in the final EIS? This, of course
should have been done in tne draft EIS.
108. Page N-l*t- Why is the "Chicago Building Code" being used
for a plant proposed for the City of Des Plaines? USEPA
please relate this to the federal regulation ^0 CFR 35.935-^
which states in part "each treatment works grant shall be
subject to the following conditionst State and local laws
—The construction of the project shall conform to.,.local
laws and ordinances,"
ing, page 0-1 Federal HUD Regulations state "the best means of
assuring protection against possible odors is to provide
adequate space between the residential properties and the
sewage treatment plant." Without even being aware of the
HUD interpretations in the following section and just relying
on simple common sense — does the USEPA Region V really
believe that the 100 foot width of Oakton Street between
the one-half mile long common boundaries constitutes an
. adequate and reasonable "isolation" strip?
.Respectfully submitted,
Richard F. Ward
Commenting for the City of Des Plaines
6-90
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Response:
1. Odors may occur if the biological processes are upset for some
reason. Under normal operating conditions we have concluded
that no significant odors will develop. We.likewise do not
believe the aeration tanks or settling tanks will be sources
of odor.
2. A discussion of the aerosol suppression facilities which we
are requiring MSDGC to provide is found in Chapter 3, "Section C.
3. See our response in Section A of this Chapter! to Slides
36 and 37.
4. Our analysis of projected flows to the proposed WRP is discussed
in Chapter 3, Section B.
5. The status of sites identified as 1, 2, 3 in the June 25, 1964
report is as follows: •..
Site 1 - Ravenswood Airport - MSD owns 22 acres at the north
end of the property and the City of Chicago owns the remainder
of the parcel. MSD hopes to acquire the remainder of the
parcel to construct a storm water reservoir., on the site as
part of the Higgins Creek Watershed Plan. See Appendix A.
Site 2 is at the end of one of the O'Hare runways.
Site 3 is the same as site #10 in Appendix Q, Attachement A.
These three sites referred to by Mr. Ward were not part of
the nine possible sites that were identified by Mr. Ward
when he met and visited each site with USEPA staff on January
.23, 1975.
6. The option of utilizing the increased collection capacity
and flow equalization capabilities of TARP identified by
Mr. Ward was evaluated by USEPA (See Chapter 3, Section A, B)
and found not to be the most cost-effective alternative.
6-91
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7. USEPA accepts full responsibility for the content of the body
of the Final EIS statement and those appendices written by
USEPA. The appendices by MSDGC have been reviewed by USEPA
Other appendices represent the positions of the authors.
8. The 72 MGD projection includes a dewatering capacity of 24 MGD.
(See Chapter 3, Section B)
9. The area is now referred to as the Upper Des Plaines Service Area.
10. See response to slides #9 and #10.
11. We do not concur with At. Ward's statement that MSB issued
a Draft EIS on TARP. It is our understanding that the Army
Corps of Engineers issued the Draft EIS. The question about
when the Corps will issue a Final EIS on TARP should be
directed to the COE. Chapter 3, Section A of the O'Hare WRP
EIS determined that the O'Hare Service Area should be formed
and the WRP constructed.
12. Since MSD stated that the July 26, 1973 was a meeting and not a
hearing, the requirements for a public hearing are not applicable.
13. Chapter 1, Section E and Chapter 3, Section A have been revised
to address these questions.
14. All correspondence relating to the proposed project is not
referenced. USEPA does not feel it necessary to list each
letter related to the proposed projects. The MSD environmental
matrix has been revised by MSD and is found in appendix Q.
15. Copies of the Revised Environment Assessment and Responses
of the MSDGC to Public Comments were transmitted to the City
of Des Plaines and the Des Plaines Public Library by MSD.
16. Chapter 3, Section B address these questions.
17. No comment necessary
18. The impacts of the possible combined overflow reservoir have
not been addressed in this EIS since it is not part of the
proposed project. Constructing the proposed WRP and tunnel
conveyance system does not makf a commitment to constructing
the combined overflow reservoir. (See Chapter 1, Section E)
19. No comment necessary.
6-92
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20. No comment necessary.
21. No comment necessary.
22. See response to slide #38.
23. See response to question //18.
24. The word contiguous was not a word used by MSD in their criteria
for selecting a plant site in their November 1974 Environmental
Assessment.
25. The statement on Page 3-11 is that the WRP has been designed so
that it can be accomodated on a rectangular plot of land of
approximately 65 icres.
26. USEPA believed that greater flexibility in the architectural
landscaping could be achieved with a larger buffer zone.
27. The trailer home on site #4 is identified when site #4 is
discussed and the population density surrounding site 1 and site 2
are reflected in Mr. Ward's relative population density
analysis found in appendix R.
28. Chapter 3, Section C and appendix Q identify the approximate
distances of the 10 foot diameter influent sewer necessary to
dewater the 20 foot diameter tunnel.
29. The status of site 3 is discussed in Chapter 3, Section C.
30. See Chapter 3, Section C and appendix Q.
31. See Chapter 3, Section C and appendix Q.
f
32. Site #7 was eliminated because the land was said to be unavail- ^
able by the Chicago Airport Authority. The statement that
site #7 may cause a safety hazard to aircraft has not been
confirmed or denied by the Airport Authority and is a moot
point since the site is not available.
33. See Chapter 3, Section C and appendices Q and V.
34. See Chapter 3, Section C and appendices Q and V.
35. See Chapter 3, Section C and appendices Q and V.
36. Prior to constructing the O'Hare WRP the State and USEPA will
certify that the WRP design plans meet all required engineering
and environmental standards.
6-93
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37. The responses are available for review. Chapter 3, Section C
and Chapter 5, Section I and L address USEPA evaluation of
the potential health hazard question.
38. USEPA regulations require that alternative sites be evaluated
for all wastewater treatment plants funded under PL 92-500.
39. This could only have been incorporated if the City of Des Plaines
had vacated Wille Road.
40. See Chapter 3, Section B.
41. USEPA considered social acceptability as one of the factors
in evaluating sites for the location of the WRP. We feel that
the proposed WRP as designed with aerosol suppressive facilities
is socially acceptable.
42. See Chapter 3, Sections A and B.
43. Building and interconnecting tunnels is not a no action
alternative; it is an action alternative and was evaluated.
(Chapter 1, Section E and Chapter 3, Section A)
44. Other sources of odor could occur if the biological processes
of the treatment plant were upset.
45. Other sources of odor could occur if the biological processes
of the treatment plant were upset.
46. The dewatering capacity (24 MGD) of the tunnels should preclude
the sewage from becoming septic. Pre-chlorination is included
as a precaution to handle any sewage which might become septic.
It is not possible to predict exact quantities of H^S that
might be generated.
47. The stack is 200 feet from the North property line and
130.5 feet CCD. The site elevation is 80.5 feet, so the stack
height is 50 feet. The site is zoned for light industry and
this 50 foot stack will not be aesthetically incompatible
with the surroundings.
48. Page 5-14 of the Draft EIS is in error. IPCB rules state
that an "ozone watch" must be crlled when the average ozone
concentration exceeds .07 ppm for two hours and the official
weather forecast indicates no substantial improvement in
stagnation conditions. The emission concentration at the
stack discharge point will average less than .015 ppm and
6-94
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this concentration is diluted as mixing with the air occurs.
49. The MSDGC has addressed the odor issue raised at the North
Side Plant. (See appendix Q )
50. It is our conclusion that the proposed odor control measures
will be sufficient to avoid any significant odor problem
at the O'Hare WRP. We r"o not feel this plant can be compared
to other MSDGC facilities. Should a significant odor problem
develop, the State of Illinois has an established enforcement
mechanism for addressing these problems.
51. The ability to isolate and replicate on nutrient media pathogenic
organisms does nr t indicate if the organisms are virulent
enough to infect man. Therefore, studies that isolate and
replicate pathogenic organisms from a sewage treatment plant
do not determine infection potential or a health hazard. See
Chapter 3, Section C and Chapter 5, Section I and L for
further discussion on the potential health hazard question.
52. We believe that the mitigative measures we have proposed in
Chapter 3 will be sufficient to preclude the possibility of
a health hazard to the residents in close proximity to Site 1.
53. See response to slide #38.
54. Coliform bacteria are not generally considered to be pathogens
but rather indicators of pathogens.
55. The proposed WRP shall meet all applicable Federal, State and
local laws.
56. While we could make estimates of the concentration to be at
a certain distance downwind, it would be impossible to judge
the accuracy of these estimates. The concentration would
also never be static, but would fluctuate considerably under
various atmospheric conditions. As pointed out in the literature,
the bacteria and viruses are subject to factors such as wind
speed, humidity and temperature, which result in a particular
die-off rate. This rate would also be specific for various
species of bacteria and viruses. We are requesting the MSDGC
to demonstrate to us the effectiveness of the aerosol suppression
facilities which they are being required to install. This will
provide us with further information on possible aerosol movement
from the site.
6-95
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57. See previous response.
58. No comment necessary.
59. See response to comment 56.
60. See Chapter 3, Section C and Chapter 5, Sections I and L.
61. Since sewage plant workers gererally represent an age group
from 18 to 65 years of age and most often are males, they do
not reflect statistically a general community population.
62. See response to slide #38.
63. There is no conflict between the language of August 21, 1974
and the statement "implement compliance with any law applicable"
on Page 5-23 of the draft. With respect to the 3 memoranda,
they come precisely within the exemptions defined in the
Freedom of Information Act of the Congress, as recently amended
by Public Law 93-502. The freedom of staff to set forth and
exchange thought processes, free from thought of censure or
disturbance, is thereby determined to be important even as the
importance of the right of the public to have access to the
factual information contained in our files is parallelly assured.
This viewpoint was expressed to Congressman Crane in a May 6, 1975
letter from Mr. Francis Mayo.
64. The letters submitted from all agencies of the City of Des Plaines
and the general public have been reviewed by USEPA staff as to
their applicability and content and have been given consideration
in reaching the conclusion in the final EIS.
65. The word Village has been changed to City in the final EIS.
66. See response to slides #'s 49, 50, 51, 55, 56 and 57.
67. Same as above.
68. The stack will be 50 feet tall. The site will be designed to be
aesthetically pleasing.
69. Processing equipment by itself is not known for its inherent
aesthetic beauty.
70. The two statements quoted are not at all contradictory. The
statement on Page 5-11 recognizes that some units in the
treatment process are much more likely to be a source of odors
than others. The statement on Page 5-28 recognizes that
6-96
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certain precautions should be taken at these particular potential
odor sources.
71. There is a fundamental difference between the use of sludge in
a landfill and its use for application on land, such as in
Fulton County. In order to be used in a landfill the sludge
must be dewatered considerably before being disposed of. It is
then covered by other material in a properly operated landfill.
In a land application project, the sludge is sometimes simply
sprayed on the land, thereby it could more easily be a source
of odor.
72. Construction grant regulations do require compliance with
applicable state and local laws. The applicability of the
Des Plaines ordinance is being determined by the courts. The
500 foot HUD guideline cannot be applied to all cases, since
each case must be judged on its own merits.
73. We are requiring mitigative measures to comply with the cited
intent of the National Environmental Policy Act. (See Chapter
3, Section C and Chapter 5, Section I and L)
74. See responses #26 and #72 as well as Chapter 5, Section C.
75. Chapter 6 is to express public comment in the final EIS, not the
draft. Public comments were reviewed and considered by USEPA
prior to writing the draft EIS.
76. See response to question #11, Chapter 1, Section E and Chapter
3, Section A of the final EIS on the O'Hare WRP.
77. The legality and validity of the City of Des Plaines, M-23-74
Health Ordinance will be resolved in the courts. A grant
condition of funding the WRP is that it meet all applicable
Federal, State and local laws.
78. See Chapter 3, Section B.
79. See response to question #32.
80. Constructing a single 850 acre foot combined overflow reservoir
is not a solution to the problem defined for the O'Hare Service
Area. The formation of the O'Hare Service Area and decision to
build the WRP is discussed in Chapter 1, Section E and Chapter 3,
Sections A, B and C.
81. See Chapter 3, Section A.
6-97
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82. See Chapter 1, Section E.
83. See response to question #18, Chapter 1, Section E and Chapter
3, Section A.
84. This statement is relevant to the projects being evaluated in
this impact statement.
85. See response to question
86. As of this date, we are examining the need to do an EIS on TARP.
87. See Chapter 1, Section E and Chapter 3, Section A. At the
present time, we have not determined whether any additional
public hearings will be necessary.
88. See response to question #83, Chapter 3, Sections B and C
and appendix Q.
89. No comment necessary.
90. Dr. Bunch is referring to the fact that there has been no
documentation of a health problem resulting directly from
the aerosols generated by a sewage treatment plant. He
therefore concludes that the risk would be very small. Very
little actual study has actually been done to conclusively
define the risk involved.
91. The O'Hare water reclamation plant is designed without primary
settling basins, since it will generally be operated as a
two-stage aeration facility.
92. They were suggested simply as a means of decreasing any risk
that does exist, however small.
93. We are in complete agreement with Dr. Wellings statement. This
was one of the many factors considered in our conclusion to
require adequate aerosol suppression facilities.
94. It is not clear that the St. Peterburg plant cited has sludge
handling facilities on site, although this is likely to be the
case. It would not be valid to compare a plant without
sludge handling facility and with its proposed odor control
measures to another activated sludge plant unless they have
similar process facilities. Furthermore, many other factors
relating to composition of raw sewage, type of processing
equipment and operation and maintenance procedures must be
similar to make a comparison.
6-98
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95. Our proposed mitigative measures will be sufficient, we feel,
to provide the assurance prescribed in the National Environmental
Policy Act.
96. The distance requirements cited are applied to forestall any
odor problems and not to protect adjacent residential com-
munities from a potential health hazard, which was the
subject of question 5.
97. Apparently, Mr. Clifford Risley does not feel that Clavey
Road and the proposed O'Hare WRP are comparable situations. We
have considered paragraph 4.13 in evaluating the proposed
project as discussed in the final EIS on the WRP.
98. The cited reference shows that from 1800 feet to 4224 feet
there was only a 58% reduction. It should be pointed out,
however, that this was only one sample and before any generali-
zations or conclusions are made, all the data given in Table I
of the Adams and Spendlove article must be considered.
99. See response to #56. It is impossible to state explicitly
what is risk-free.
100. No comment necessary.
101. MSD was relating their experience at the Hanover treatment
plant with respect to effect on property values and the
acceptance of a sewage treatment plant adjacent to their
residences.
102. One instance of which we are aware is the Coney Island Water
Pollution Control Plant operated by the City of New York.
The capacity of the plant is approximately 100-110 MGD. There
are apartment buildings and two-family dwellings immediately
adjacent to the plant site.
103. The Salt Creek Plant does not have a high population density
around it. Much of the area adjacent to the plant is
undeveloped. We anticipate that microbial survival data will
be available when the Salt Creek Study is completed.
104. No comment necessary.
105. See appendix Q, attachment D for MSB's position on this question.
6-99
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106. Possibly, they anticipated our concern for aerosol suppression.
107. USEPA has tried to answer all relevant questions raised by all
groups and individuals related to the proposed O'Hare projects.
108. With respect to 12.2 in Appendix N, beginning on N-13, the
listed items are points of reference to be applied consistent
with 40 CFR 35.935.4.
109. See response to slides #49-52 and #55-57 and see Chapter 3,
Section C and Chapter 5, Sections C, I and L.
6-100
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f. HUD Isolation Interpretations
The City of Des Plaines sent the letter on the following
page to 87 HUD offices in the United States. The responses
they received are summarized in the following table. Our
response to this issue is discussed in Ahapter 5, Section
C and in our response to Slides 49-52 and 55-57.
Summary of HUD responses to Des Plaines letter dated 3/11/75.
Name of Office Isolation Distances Recommended
Anchorage, Alaska FHA Insuring Office 1000 feet
Atlanta,Georgia Area Office 500 feet
Charleston, West Virginia FHA Insuring Office 500-1000 feet
Chicago, Illinois Area Office 500 feet
Cleveland, Ohio FHA Insuring Office 500-1500 feet
Columbia,South Carolina Area Office 300 feet
Coral Gable, Florida FHA Insuring Office 400 feet
Houston, Texas FHA Insuring Office 300 feet
Indianapolis, Indiana Area Office 250-500 feet
Des Moines, Iowa FHA Insuring Office 1000 feet
Jackson, Mississippi Area Office 200 feet
Jacksonville, Florida Area Office 400 feet
Louisville, Kentucky Area Office 250-600 feet
Lubbock, Texas FHA Insuring Office 1600 feet
Grand Rapids, Michigan FHA Insuring Office 800 feet
6-101
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Name of Office Isolation Distances Recommended
Milwaukee, Wisconsin Area Office 750-1000 feet
Minneapolis, Minnesota-St. Paul Area Office 1000 feet
Phoenix, Arizona FHA Insuring Office 500 feet
San Francisco, California Area Office 300 feet
San Juan, Puerto Rico Commonwealth Area Office 330 feet
Shreveport, Louisiana FHA Insuring Office 500 feet
Washington, D. C. Area Office 1000 feet
San Diego, California FHA Insuring Office 500 feet
6-102
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RICHARD f. WARD
Ald«rm»n 8th Word
THE CITY OF DBS PLAINES
COOK COUNTY. ILLINOIS
•••
MEMBER ILLINOIS
(AC 312) 827 8715 MUNICIPAL LEAGUE
March 11, 1975
SEtslT "To ALL 87 MuD Off(t£$ liJ
ANSWERS WERE
We are attempting to determine a reasonable isolation
distance "between the boundary line of our proposed ?2 MGD
activated sludge sewage treatment plant and existing
residential boundary lines.
As the attached excerpts from several HUD Regulations
indicate, local interpertation is necessary and each
situation is carefully examined for mortgage insurance
purposes. It is our understanding that the advice of
qualified sanitary engineers and local health authorities
is solicited and considered to determine the eligibility
of a property for mortgage risk insurance.
We would appreciate copies of your local guidelines and
2 or 3 representative field reports or appraisals that
cite distances from sewage plants. We are aware that
the outdated Neighborhood Standards #6 specified a
minimum isolation distance of 750 feet and we have already
received a few examples that cite distances of 500 feet
to one-half mile. We need your input so that we will have
a broader base of information. We would appreciate your
reply before March 21st so that it can be incorporated
in our presentation at the USEPA public hearing on March
31, 1975. Thank you.
Sincerely,
Richard F. Ward
Attachment
6-103
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2. William H. Radcliffe 136 W. Dover Dr.
DCS Ploiries, Illinois bOOxo
April 18, 1975
hr. liar Ian D. Hirt
Phi t-.f " f- I ]f c'l^^ivr
o IA.LOJL. £ py '*c^
Planning Branch . v
United States TSnvironmental Protection Agency
236 South Dearborn Street
Chicago, Illinois 6060!+
Subject: Environmental Impact Statement for the O'Hare Sewage
Treatment Plant and Its Associated Projects.
Dear Mr. .Hirt:
When the Metropolitan Sanitary District of Greater Chicago had
their hearing on the O'Karo T.rt-;atrnonc Plant on December 19, 1971;,
I submitted a report. Because of the l^ck of good technical process
flow data in the MSDGC EIS, ths report was aimed at pointing out
potential areas of concern. A copy of this report was sent to your
branch. Unfortunately, I find myself in a similar situation after
studying the US3PA SIS on the O'Hare projects. It is therefore my
intent in this letter to address a few of those concerns.
I. Site Location
It is my opinion that the site at Oakton and Slmhurst Roads does
not correspond to 'good engineering practice1 and does not comply
vith thf3 guidelines for the locations of sewage treatment plants
within the State of Illinois as outlined in the 'Ten State Standards
for Sewage Treatment Plants'. There/ are three key factors factors
which negate the selection of this site; bordering residential
area, major prevailing wind and size of the plant. The plant to be
constructed is a large treatment plar.t. It is to be built down wind
6-104
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2
0'1-are WTP
4
and across the utroet from an existing; residential area. I do not,
believe that a 100 foot or a 1+00 feet buffer zone is justified when
considering these facts. It is my opinion that a plant of this s^e
should be at least £ mile away froir existing residential areas,
especially when it is to be built down wind of the residential area
in the direction of the major prevailing wind.
II. Sewer Detention Time
In one of the USEPA technology transfer bulletins prepared by Roy
E, Western Inc., one of the problems presented was the receipt of
septic sewage at the Washington D. C. sewage treatment plant. It
occurred primarily during the hotter months and was attributed -co
low flow in the complex sewer system. The toxic, flammable, highly
odorous gasses associated with such septic sewage would be stripped
out into the atmosphere by aeration. A solution to this is to add
sodium hypochlorite up stream of the plant. This will inhibit the
generation of lipS, but it also increases the load on the aeration
tanks since it is a bacterielde for the bacteria required for
BOD reduction. I question the design of the tunnel and reservoir
system. Will this generate septic conditions? Further with the
tunnel and reservoir system and potential varying septic conditions,
will the sodium hypochlorite system truly control odor problems or
tend to minimize them at best? I believe the latter is true.
6-105
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3
O'Hare WTP
4
HI. Or, one for Odor Control
A building will be built to contain the incoming. odorous screenings.
To control the odors ozone will "be employed to treat the exist
gassfts. The system as described leaves m* very skeptical. I believe
that an excess of ozone will have to be employed with this system
to effectively control the odor. This is not a desirable condition.
As the system is to theoretically work, I again perceive a unit which
will minimize odors but not control them0
IV. Potential Health Hazard from Air Borne Bacteria.
Here we are dealing in true speculation. The USSPA EIS speculates
i
IS
that there mostlikely^no major health hazard and in the future if
this proves to be wrong then they will try to correct the problem.
I have a lot of respect for the U33PA. I consider this concept to
be well below their usual policy.
It is a known fact that there are many different viruses and bacteria
in waste water. We are concerned only with those that are pathogens.
As the EIS states those pathogens will have a air borne life in a
generated aerosol directly dependent of the particular pathogen and
the climatic conditions present. Farther in publications of the
American Water Works Association^, it is pointed that such pathogens
borne in water have their greatest effect on the young. As individuals
grow older they develop a greater irr.ranity to the pathogens found in
waste water,
Kow I run Into a problom. It was my understanding that in
standards were to be adopted on just such emissions as what is
being considered here. But, I find very little and for the most
-------
page I;
0«Hare WTP
t
very Inadequate work being done on this subject. One apparent
standard is to use E. Coli as the guideline for concentrations
of pathogens present. It is assumed that the various pathogens
are present in some concentration proportional to the known
concentration of E. Coli. Although this is true, the proportion
will vary with the incidence rod the type of illnesses prevalent
in the area. The only documentation whichAstudied"«, Coli aerosol
emissions from equipment processing sewage is reported in the
American Institute of Chemical Engineers', Recent Advances in Air
Folution Cpntrol, Volume 70, 197l|. In this publication data is
accumulated from which estimates of S. Coli emissions can be made.
further in this publication, Ic is recommended that aerosol S. Coli
emissions be the same as those for water when related to human
intake. This would limiz E. Coli emissions to e maximum of 3.5 S.
Coli per cubic meter.
Based on the above article and a flow of \tfy KGD, the S. Coli
emissions from the plant would be as low as one million S. Coli
per hour to more than several billion E. Coli per hour. The source
concentration could range from, about 3H-0 3. Coli per cubic meter
to above 10,000 E. Coli per cubic laeber. No known relationships
between these concentrst j ons to other pathogens were found. V.'ith
the possibility of generation of such high quantities of pathoger.s
in aerosols, it is hard for me ,,^ lightly dismiss the potential
problem.
»
and
Now for an aside some speculation on my part. In the Chicago Tribu:
anted Friday, April [j., 197£ two items x^ere reported on page p,
6-107
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page
p'Hare WTP
i
The first article wns the fact that Chicago had double the national
average of known cases of infectious hepatitis. Is this a problem
in this area? Such reports make mo curious about the location of
a large treatment plant in relation to residences.
The second article dealt with the study of cancer causing viruses in
the Fox River, In this article thero was a map of Aurora with symbols
identifying leukemia and lymphoma victims. I noted that there appeared
to be a heavier cluster ec^t of the Fox River and towards the middle
to south end of Aurora. This cluster is located down wind from a
treatment plant which I believe might be within one mile of the
cluster. This particular plant is located at the south end of Aurora
on the west bank of the Fox River. It employs extensive spray systems
and costantly seems to have a heavy mist generated. Is there a
relationship? j am not qualified to address such a question, and for
me to"speculate is just as bad as the speculation in the EIS.
V. Combined Reservoir
In the USKPA EIS there is a map which shows a combined reservoir
southwest of MSD site. This is the reservoir that the KSD would
not admit to on December 19, 197I)-* This reservoir, depending on
design, with the proposed treatment plant at Oakton and Elmhurst
Roads would compound the problems. One known proposed design for
this reservoir at £0 acre surface and an annual potential evaporation
rate of 32.66 inches per year, will have an average evaporation rate
of about 14-0,000 pounds of water per hour. A southwest wind across
such a reservoir then crossing the treatment plant would hp.ve to
increase the life span of the air borne bacteria because of the
' fi-ino
-------
pCRO 6
0' Hnre WTf
incivased humidity. If such a plan is a possibility, I cannot see
how tho current EIS can be valid since a reservoir could drastically
effect the overall environmental impact .
It is my opinion that a plant built at Oakton and Elmhurst Roads
should be inclosed because of the previously stated reasons. Also,
from the information presented in the EIS on odor control and
considering this location, I believe such a plant should employ
incineration of exit gas streams. The cost penalties that are
incurred in building such an inclosed plant contradicts my engineerinc
economic principles,
I believe the plant should be built as proposed in the EIS, but wi~ch
the proper site selected. This site should be remote to existing
residential areas; thus, allowing for the natural decay and dilution
of the pathogen containing aerosols. It is my opinion that a minimum
of % a mile should be adequate for most normal conditions.
It is my opinion that it is wrong to build a treatment plant on t,he
basis that we don't know ii" there is a problem, but in the future
if there is a problem, we will try to correct it. .
Yours truly,
William H. Radcliffe/ P.;
State of Iliionis
6-109 Number
Dat«
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Bibliography:
i
1. Metropolitan Sanatary District of Creator Chicago, gnv i ronment _al_
Assessment. Statements for Proposed Projects for the Upper
Dos Plainos Service" Basin: O'Hare Tunnel Project, O'Haro
Water Reclamation Plant, and O'Hare Solids Pipeline,
November, 197ij..
2, Climates of th« TJnitud States, Volumo 1, by the Officials
of the National Oceanic and Atmospheric Administration,
U.S. Department of Commerce, 197lj.* v
3» U.S. Department of Commerce, National Weather Service, Chicago
Euro au * ,
>
ij., Lako Evaporation in Illinois by W. J. Roberts & J. B. Stall,
Illinois State Water Survey, Report Investigation No. 57 •
5>. C horn i c al En g i ne e r s ' H s ndb o ok , Fifth Edition, Robert H. Perry and
Cocil H. Chilton, editors, McGraw-Hill, 1973.
6, Standard Kathods for tho ExaminaTCion of Water and Wastewatar,
Thirteenth Edition, Prepared and published by : American
Public Hop.lth Association,, American Water Works Association,
Water Pollution Control Federation.
7. Summary Roport of Wastewator Kcxnagcmont Study for Chicago
' -.-.T South Hind of Lake Michigan^ Dapartment of the Army,
Chicago District, Corps of Engineers, April, 19?i{..
8, ASHRAK Handbook of Fundamental.- ^American Society of Hofflting,
Refrigerating, and Air- Condition ing Engineers, Inc. ,197i|.
9. Wastowater Engineering, by Mctcalf & Eddy, Inc., McGraw-Hill,- ;1 972.
10. Coliforrn Emissions from Air/Wator Contactorsj A Preliminary
Attempt to Establish Maximum Concentrations by L. J.
Thibodenux and N. J. Carter, Rocgnt Advances in A_ir
Pollution Control, American Institute of Chemical
Engineers, Voluinc 70, 197^.
11, Air Pollution, by Virginia Brodino, Harcourt Brae© Jovanovich Inc. -
12, Operation of Wastawator Troatmont Plants, V/PCP Manual of
Practice No. 11. Water "Pollution Control Federation, 1970,
i
13. Wat ft r Quality Network, 1971, Summary of Data, Volume 2, State
of Illinois' Environmental Protection Agftncy,
.. Process Posign Kanusl f or .JTprrri.d.l.ng J^yl stinp; w
- treatment Plants , for "Environmental Protection Agency,
by Roy F. Woston, Inc., October, 1971*.
»
^. Rocormnondod Standards for Sewage Works, 1971 Revised Edition,
Member States: Illinois, Indiana, Iowa, Michigan, Minnesota,
Missouri, New York, Ohio, Pennsylvania, Wisconsin;
Health Education Service.
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16, Do a j p;n C r IT. o r 1 n f o r S o wo rap; o Sy_a tjrmg^y Division of Wustowatcr
Technology and Surveillance, Section of Environmental
Health Sorvico3s Texas State Department of Health, 1970.
17. Supreme Cour-c Affirms I\Ton- Do gradation Ruling, Journal of tho
;.lr Pollution Control A^s-jociation, Volumo 23, p. 720
August 1973.
18. Air Pollution Control,, Chemical Engine a ring, Doakbook Issue,
19- Technology Gear Up to Control 7ino Particles, Chemical
Enpanooring, p. 50^ Augj^rc 21, 1972.
20» Controlling Pino Particlos, Chemical Engineering, Deskbook
lo^uo, pa 107 ) tlun« 16, 1973.
21. .lir Pollution second ..clioxon by Arthur C. Stern, Volume 1,
Academic Press, 1 /66«
22« Nitrification and Dc-nitr-if Ication Facilities , Wastewatcr
j U.S, "shvironmoii-cdl Protection Agency, August, 1973.
23* Dosi^n. Crltoria OUIaro VJatcr Reclamation Plant, Metropolitan
Sanitary District of Greater Chicago, March 15, 1972.
6-111
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2. Response to Mr. William H. Radcliffe
I. Site Location - See Chapter 3 Section C, and Chapter 5
Section B, C, K and L.
II. Sewer Detention Time
It is theoretically possible that low flow conditions could
prevent adequate scouring of the proposed tunnels and thereby
allow some deposition to occur. We believe, however, that low
flow conditions will not cause odor problems at the WRP given
the odor control planned.
III. Ozone for Odor Control - No comment necessary.
IV. See response to I.
V. Combined Reservoir - See Chapter 1, Section E.
6-112
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Richard J.
Registered Professional Engineer
'State of Illinois
1270 Leslie Lane
Des Plaines, Illinois 60018
3. Richard J. Maggio
April 19,1975
iNG bKAiNUi - Kegion V c
FIL£ NO
ENVIRONMENTAL PROTECTION AGENCY
Mr. Kent Puller RECEIVED
Plannin g Branch
United States Environmental
Protection Agency
Region V
230 South Dearborn St.
Chicago, Illinois 6060U
Dear Mr. Fuller«
I have reviewed the Draft of the Environmental Impact Statement dated
March, 1975 for the MSDGC O'Hare Water Reclamation Plant And Solids
Pipeline and my comments, which I would like incorporated into the
notes of the March 31, 1975 meeting, are as follows*
1. In the operational Impact - air quality section (page ii) the use
of the words "occasional odors", "expected to be infrequent" and
"aeration tanks will generate a 'limited quantity of aerosals' containing
bacteria and virus particles" brines to mind an old engineering slogan.
If something can happen, it will happen. In my experiences, I have found
that this slogan can be extrapolated to say, If something 6annot happen,
it probably will happen infrequently; If something is expected to happen
infrequently, it .just may happen fairly often, too often.
5^ Pages l-r> and 1-7 address the present problem of overload of the
ftenth Side Sewage Plant during wet weather and resultant discharge of
raw sewage into streams and backup into basements^ I would certainly wel-
come a permanent solution to thi
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2.
cost figures generated for these alternatives. Appendix A and C dcas not
provide adequate coverage. I wpuld certainly expect the MSD to prove be-
yond a shadow of a doubt that their proposed WRP will at least handle a
maximum credible rain storw with no discharge or backup of raw sewage into
streams or homes,
3. On page 2-1, It is shown that Des Plainec has the 2nd hierhest population
of the entire 58.2 square mile service area. I certainly do not object
to a WRP in Des Plaines. What I do object to is the frequent and non-
justified statement made throughout the ri- aft report that "WRP*s must be
located in high population zones." I wjuld like this statement to be
justified and have adequate cost and operational effectiveness data and
analysespresented qualifying this philosophy. I refer you to the nuclear power
plant -i which was recently disallowed on the Indiana Dunes portion of Laka
Michigan because of the esthetic ard health aspects. I also refer you to the
similar claims made by the nuclear industry in regard to their perfect
record of never having had an incident in which a life was lost or d isease
inflicated upon a human being duo to the operational malfunction or accident
in a nuclear plant. Nuclear plants, even with their excellent safety record are.
forced to be placed in low population zones andwith a very large buffer
zone between the plant boundary and residential areas. Why so much attention
is given to the location, design, and operation of nuclear power plants
and such .little attention to sewage plants is beyond me. Unlike the nuclear industry,
the sewage treatment industryappears to take the attitude that precautions will not
be taken until a major incident occurs and many people are seriously affected by a
plant malfunction or accident. These occurences should be anticipated andthe site
and plant design fixed accordingly. .* •
-, f
I*. On page 2-21, It is mentioned that *no endangered or rare species —•
are known to be present in this area," I wholeheartedly disagree with this
statement. My son and daughter are the only ones I havei how rare can jrou
get. Let's give as much attention to people, particularly children and
infants who are* fci&hly susceptible to disease. Although I do not know
much of physiology, medicine, and health, I must ask how many" people will
contract disease due to the WRP which are not publicized as related to or
caused by the WRP. It seems that although nobody dies from "sewage-itis",
many people contract deseases due to the complicated physiology between
germ (sewage) and man. I would certainly not want to feel the MSD com-
promised an unknown quantity of childrens lives for a few dollars,
5. Page 2-26 states that "air quality in the vicinity of the project sites
is severely degraded because of the proximity to O'Hare Airport." I Bust
say that the proposed area is particularly plagued by air pollution from the
airport, too many restaurants, shopping areas and resultant pollution from
auto traffic and noise. Mr. B. T. Lyman of KSDGC states in his letter
dated Feb.'^l, 1975 that " it is somewhat incongruous that the district
must respond to concerns associated with e'.:i.ssions from aircraft operations."
•JMr. Lyman should be informed that we are not dealing here with life-in-a-
goldfish-bowl. The total health aspect picture must be analyzed, not the
adequacy of one piece of equipment, one process, or even one WRP,
6e In regard to chapter 3f section A on capacity of the proposed WRP,
insufficient data concerning plant design vs. capacity of various sewage
treatment plants throughout the country is presented. The plant is a very
large capacity plant and most research, both pro and con has been conducted on plants
much smaller in size . We can certainly expect the health
/
6-114
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hazards and odor problems to crrow at least in direct proportion to size
unless a great deal more air confining and purification features are de-
signed into the plant oar larger buffer zones employed between Ihe plant
boundary and residential areas (or preferably both).
7. On page 3-10 and 3-H» site selection criteria are presented. It is
very striking that the health aspects of an adequate buffer zone are not
mentioned. I would think this should be tl,e most fundamental criterion
in selecting a site. I would certainly chink an organization such as the
EPA (if not the MSDGC) would agree. I m fully aware that sewage treatment
plants have, in the past, been locate-! in high population zones and with
little or no buffer zone. However, 1 believe this lack of consideration for
people near the sewage plants by t'oe plant owners was0ne of the reasons the EPA
was formed| to protect us from such negligence and lack of concern. The
faot that the applicant owns &Lpiece of property should not affect the
decision of the EPA, The XSDGC should be made to reevaluate each of the
9 sites objectively* Answers such as "the availability of sites is
unkhown" or "The airport authority appears to be opposed to the construction
of a sewage treatment facility on its land" as stated on page 3-17, are
strictly inadequate, The airport would benefit from the WRP, the plant
will be low profile and. in no way can interfere with flight operations, and
if it is as esthetically pleasing as the draft statement claims, it
should actually improve the ugly terrain around the airport. The area
presently looks like a slum, and I can't think of a better site for tfcis
WRP.
gB I'm not very impressed with the statement on pages 3-17 that the
"construction of the WRP should occur as soon as practical"t since for
the past 10 years the people of Des Plaines have resisted construction on
the proposed site 1. The MSDGC has stubbornly insisted on this site and
•gainst the wishes of the City, went ahead and purchased the site. If
they had given at least a. little consideration to the people living near
to the site, they could have had their plant built already.
9» If sewage treatment plants are necessary "as an economic stimulus to
the local and national economy", why is the MSDGC so intent on building a
"minimum feature" treatwent plant on a most convenient and ecologically
inadequate plant siteT I admit that a better design on a better site
would cost more, but all the better for our economy.
10. The inadequacy in the Environmental Inpacts of chapter 5 on Air
Quality are apparent. All sorts of problems concerning odors and aerosel
generation are discus see* and several techniques presented which could
mitigate their effects. Then the EPA states that although there is much
scientific evidence indicating health hazards generated by sewage treat-
ment plants, the evidence must be put "into perspective in terns of public
need". Now, I ask you, why should research be performed if regulatory
agencies totally ignore the evidence. The EPA is essentially saying,
don't confuse me with the facts, my mind is already made up. True, an
"interpretation at this time is not in the interest of everyone concerned"
but an interpretation by the EPA shoulu be made in performing the duties
made law under the Environmental Protection Act since no-interpretation
is certainly not in the interest of anyone living near the WRP.
11. The EPA has no right to state (pages 5-22) that "Immunization by
inhalation of small quantities of pathogens may protect us from disease1?.
I wonder what the Surgion General would say about the MSD appearing to practice lief
medicine on a mass scale with vaccines unknown in nature.
6-115
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12. In the EPA findings on pages 5-32, how can the "present buffer zone be
adequate" when there is literally no buffer zone at all? In addition,
stating that covering of the plant is unnecessary for "plants of tH s size1*, |
I aga-l.n remind the EPA that this is not a small plant. Allowing an un-
covered plant of this size is certainly not "protecting" anyone.
13. Appendix D questionnaires certainly present a great deal of evidence
on the O'Hare WRP, pro and con. It anpears that the EPA dismissed all of the j
con in their evaluation and preliminary approval of the plant, I feel more
interpretati on of these questionnaires should be performed by the EPA. .
P.. In appendix I, page 1-7, the MSDGC admits that buffer distance is very f
important in site location by dismissing 1 r.j Randall and Ledbetter findings
on the basis that only a 100 ft. distant was employed in the research.
What was the capacity of the plants studied? Why have they totally dis- i
regarded buffer distance in the site location of this WRP? *
15. In regard to the Plotkin and Katz findings that "the virus particle j
ntust come in contact with a susceptible cell", I am sure that a certain j
percentage of virus particles will eo^e in contact with a certain percentage |
of susceptible cells (people). We can't change the quantity of susceptible !
cells but we certainly can minimize the quantity of virus particles through j
proper site location and plant design.
16. On pa.ge 1-13, the MSDGC claims that "sewage treatment plant workers are
healthier than workers in other industries". I am sure the MSB has very |
stringent health requirements for employment and that their claims are i
probably true. I wonder what percentage of sewage plant workers are infants,
young children, and senior citizens who are less immune to WRP plant aerosols?
17. In appendix N covering Plant Design Criteria, it appears that certain
plant deficiencies such as inadequate buffer zone, location of plant in
high population area, and design of plant with no confining of aerosols and
minimal treatment of aerosols with ozone is to be compensated for by the
chlorination of raw sewagB. I would like to point out, that analytical instru- '
mentation such as residual chlorine analyzers are not highly reliable and !
I would expect frequent over-chlorination and under-chlorination of the j
raw sewage in this plant. Over-chlorination would tend to produce a i
chlorinated aerosol from the aeration tanks and resultant eye irritation
to nearby residents, Under-chlorlnation in turn would increase pathogen
levels in the aerosols. I believe simply relying on chemical treatment
of raw sewage and aerosols is inadequate and further that all possible aerosol
generators in the plant are not handled by the ozone units supplied. In
addition, I would like to see further proof that ozone will not only mask
odors but will reduce the amount of pathogens in the primary plant aerosols,
I believe we should remove, not cover up, all plant emitted pathogens. H
18. In regard to on-site power generators, I would like to know whether
sufficient power is available, on loss of off site power, to operate plant
at sufficient capacity to handle the influent from a severe rain stor**. If
the on-site power system is not adequately sized for severe rain storm cap-
acities, we can certainly expect that the flooding, discharge and sewage
backup problems have not been completely re:, /Ived even assuming the storm water
reaches the plant intake at sufficient rate to avoid flooding and backup,
19» The limiting factor in flood control may not be WRP plant capacity
but the capacity of all main and branch conduits leading to the WRP. Before
flooding can be effectively controlled, a thorough study of all sewer mains
in the entire service area must be made, if this is not done, the flooding of
homes can be expected to continue. I feel the entire service area population
is possibly being deceived that this WRP is a cure-all. The problem is certainly not
that simple.
20. I»m not satisfied with the MSDGC claim that the HUD-FHA will lower their
standards, In regard to isolation distances, to comply with MSDGC design.
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5.
Tha MSDGC should be forced to comply wit.hHUD-FHArequiremen^s, not have the
KUD-PHA lower it's standards. These standards were established for certain
reasons and if these standards are to be violated, the MSDGC should be made
to provide detailed .justification and adequate proof that the basis for the
standards are erroneous. The MSDGC certainly has not adequately addressed
HtJD-FHA isolation distance standards.
In conclusion, I would like to add that the 3 year construction period
could easily be extended if certain prcble-ns arize. The service area is in
bad need of flood control measures anH I don't feel we can wait 3 years or
longer for this flood relief. Other "lore expedient alternatives need to be
studied.
In addition, any facility that is provided sVould be designed to give max-
imum environmental protection tc neighboring residential areas. Later
backfitting of more effective environmental control features is totally
inadequate for 2 reasons. First, the plant (unlike other types of industrial
facilities) cannot be shutdown until remedial measures are taken. People
will be forced to suffer unt .1 the measures are completed. Secondly, the
remedial measures will take a considerable amount of time for completion.
I believe if there is any possibility of the need for more environmental
controls, they should be incorporated into the initial plant design and I
might add that confining and removal of dangerous pathogens from plant
aerosols appears called for en the basis of fcther plants in existence.
There incorporation now would certainly be more nays* effective than backfit«
ting at a later date.
Lastly, if the MSDGC plant design and location is suspect, one might also
lack confidence that the plant would be operated with any greater degree of
conscientiou sness and concern.
Based upon the above, it is apparent that although the plant may be de-
signed and plant site land purchased, the MSDGC has grossly failed, by their
own admission, to consider the total "environmental picture11 into their
design criteria.
I believe the EPA should favor a conservative plant design and site lo-
cation where a great deal of environmental unknowns are present rather than
favoring the proposed design and site location. I believe an. organization
sticks its neck out when they make a decision in favor of economy and con^
venience where a great deal of public health and welfare implications exist.
A decision by the EPA in favor of a more conservative design and site
location would certainly remove much 6f the fear and doubt of nearby re-
sidents and maintain the creditable reputation the EPA presently has.
With confidence that the EPA will make a decision, on this matter, in
favor of our environment, I remain,
Very truly yours,
<&> sj* ^
Richard J.Tfeggio
RJM/CMM
co» Francis T. Mayo
Harlan .. Hirt
Valdas 7'. Adamkus
Richard F. Ward
Alan M, Abrams
Philip M, Crane 6-117
William J. Scott
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3. Response to Richard J. Maggio
1. Any biological process is capable of being upset. With respect
to the operation of a WRP, excessive concentrations of heavy
metal could cause a biological upset and a temporary odor.
Since the influent sewage is primarily municipal and ordinances
control influent concentrations of industrial wastes, biological
upsets are not expected but cannot be completely ruled out during
the life of the facility.
2. See Chapter 1, Section E and Chapter 3, Sections A and B.
3. In the site selection and EIS process, we have followed the
requirements of PL 92-500 (funding of wastewater treatment
plants), NEPA (PL 91-190) and USEPA regulations.
4. We agree that one's children are most precious and have considered
the potential health problem question. (See Chapter 3, Section C
and Chapter 5, Sections A, B, K and L.
5. No comment necessary.
6. See Chapter 5, Section B.
7. See response to question #4.
8. No comment necessary
9. See response to question #4.
10. See response to question #4.
11. No comment necessary.
12. There is a buffer zone.
13. USEPA is requiring facilities to suppress aerosol movement
from the site as a precautionary measure.
14. MSD would have had a larger buffer zone if the City of Des Plaines
had abandoned Wille Road.
15. See response to question #4.
16. No comment necessary.
17. Prechlorination is being provided for the purpose of mitigating
any potential odor problem and not to prevent pathogens from
being aerosolized. The mitigative aerosol suppression facilities
will be sufficient to avoid any potential health hazard.
6-118
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18. Sufficient backup power shall be provided .
19. USEPA is not building the WRP and conveyance system to control
flooding, but for water pollution abatement.
20. See Chapter 5, Section C for HUD - VA discussion.
The summary comments of Mr. Maggio have been addressed in
the Final EIS.
6-119
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C. Letter Comments
6-120
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Office of Water Program Operations
Comments on
Pre-Draft Environmental Statement
O'Hare Water Reclamation Plant
Des Plaines, Illinois
1. The statement contains much v; luable data on the project. As presented
in the statement, however, it is difficult to locate specific items of
required information. Section 1500. 8(a) of the CEQ Guidelines (40 CFR
1500) defines the topics that must be included in an EIS. Although these
may be discussed in different order; the discussion of each topic must
be easily identifiable. Th3 EPA regulations for EIS preparation (40 CFR
6) contain the same requirements, but are more specific with regard
to EPA related subjects.
2. It is stated (pg. 7) that approximately 5000 acres of the 37, 250 acres
in the Upper Des Plaines Basin are expected to remain unsewered
and are not included in the project. The statement should more
clearly state the reasons why these lands are expected to remain
undeveloped.
3. In the discussion of the flood prone areas, explanation should be
provided indicating the flood protection measures for the plant
which is situated in these flood areas.
4. It is indicated that the water quality in Higgins Creek is "probably"
below state water quality standards (pg. 28). This indicates that we
are in doubt about the quality (which could easily be measured). The
statement should be reworded to indicate that during storm bypass
conditions the runoff pollutes the stream to a point where the standards
are violated.
5. On page 66, it is stated that 15 GPCPD is considered excessive
infiltration. No information is given, however, whether MSDGC
has a program to relieve this flow or whether it has been
determined that it is more economical to treat these flows
rather than remedy them. This should be discussed.
6. The discussion of site selection mentions the closing of Wille
Road which crossed the site (pg. 81). Since this seriously
impacts the usable portion of Site 1, further discussion of the
disposition of this road should be provided.
7. The statement indicates (pgs. 2
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Some ambiguity exists in the discussion of the Higgiris Creek
modifications (pg. 129). The discussion should more clearly
differentiate between existing and proposed conditions and
should give a more detailed description of the proposed
storage and channel facilities.
The proposed plant will divert flows from Weller Creek and
Feehanville Ditch to Higgins Creek. A. discussion should be
provided concerning the expected impacts on Weller Creek and
Feehanville Ditch when this flow is removed and upon Higgins
Creek when the flow is increased. The discussion should
include conditions of low flow as veil as peak flows.
10. It is noted that ozone is to be used for odor control (pg. 141).
The impacts of this ozone on the plant operators were not
discussed. No discussion • /as provided concerning the noise
levels within the plant and the impacts upon the workers.
11. The conveyance system and the storm water storage facilities
are discussed in a separate EIS. The odor problems from the
storage pond may have significant influence upon the site
selection for the treatment plant, particularly with respect to
both sites owned by the MSDGC. Therefore, a further discussion
of the interrelations between these sites and the impacts from
the storage facilities should be provided.
6-122
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Responses:
1. The specific sections referenced in the regulations have been
included as Section I,J, and K of Chapter 5.
2. There are actually 41,382 acres in the service area. The 5000
acres which will remain uusewered consist of land uses as
forest preserves, cemetpries, military reservations and
designated open space areas.
3. This discussion is included in Chapter 4.
4. Higgins Creek is not subject to combined sewer overflows.
Additional water quality data is contained in Appendix T.
5. The MSDGC will uake any necessary action to relieve excessive
infiltration.
6. The proposed project has been designed with the assumption of
Wille Road remaining in place. If the City of Des Plaines had
vacated Wille Road it might have been possible to locate the
water reclamation plant further south on Site 1.
7. The discussion of plant capacity (Section B, Chapter 3) has
been revised.
8. These changes have been reflected in Chapter 4.
9. While the combined sewer overflows will be reduced from over
80 to 6 per year, this will not have an adverse effect on
Weller's Creek or Feehanville Ditch. The increased flow in
Higgins Creek will be easily accomodated since the channel
is being modified to handle 100-year storm events. The plant
effleunt would only be a small portion of such a flow in wet
weather.
10. Ozone will not have any impacts on the plant workers since the
only exhaust from the ozonation system is to the atmosphere.
This will be monitored and controlled so that the exhaust
concentration of ozone will not exceed the detectable level.
The noise levels in the plant will be maintained below OHSA
standards.
11. Chapter 1, Section E contains a discussion of why we believe
the combined sewer overflow reservoir can be separated from
the projects presently under consideration.
6-123
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
P.O. Box 678, Champaign, Illinois 61820
April 9, 1975
Mr. J^rancis T. Mayo
Regional Administrator
U. S0 Environmental Protection Agency
Region V ENVIRONMENTAL PROTECTION AGENCY
230 South Dearborn Street RECEIVED
Chicago. Illinois 60604
APR 111975
Attention: Planning Branch - EIS Unit
PiANMiMi; BRANCH - Regio. V
'Dear Mr. Mayo: HI* wo. __
Ihe draft environmental impact statement for the proposed
Metropolitan Sanitary District of Greater Chicago O'Hare
Water Reclamation Plant and Solids Pipeline in Cook County,
Illinois, was forwarded to the Soil Conservation Service
on March 4, 1975 for review and comment.
Ihe proposal refers to levee and berm construction,, The
Soil Conservation .Service has standards and specifications
for establishing vegetative and woody plantings which may
be useful in contracting.
If land application is selected for disposal of solids, a
conservation plan for the site is extremely Important. Such
items as the soil type, .slope, erosion, cropping system,
conservation practices and other such items must be con-
sidered in planning such an operation.
Ihe local Soil and Water Conservation District, with assistance
of the U. S.. Soil Conservation Service and'other cooperating
agencies, provide this type of conservation planning assistance.
Contracts for construction of the proposed facilities and
spoil deposition should'include erosion and sediment control
as a requirement.
If
there are questions concerning the soils, fertilization,
herbaceous and woody 'plantings, or any soil and water con-
servation practice, don't hesitate to contact the U. S. Soil
Conservation Service District Conservationist.
We appreciate the opportunity to review and comment on the
proposed project.
Sincerely,
Daniel E8 Holmes A
State Conservationist
6-124
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Response:
Land application of sludge will be practiced. At the present
time, the MSDGC is applying sludge on strip-mined land in
Fulton County, Illinois. A comprehensive land use and water
quality control plan is prepared for each site used in the
Fulton County area.
MSDGC contracts routinely contain erosion and sedimentation
control measures.
6-125
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DEPARTMENT OF THE ARMY
CHICAGO DISTRICT. CORPS OF ENGINEERS
219 SOUTH DKARBORN STREET
CHICAGO. ILLINOIS 6O6O4
NCCPD 22 April 1975
Mr. Francis T. Mayo
Regional Administrator
Region V
U. S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Mayo:
This is in response to your letter of M March 1975 requesting
comments on the Draft Environmental Impact Statement (EIS) for
the proposed Des Plaines - O'Hare Water Reclamation Plant (WRP)
and Solids Pipeline.
Our comments have been restricted to only those items which
we feel will clarify or add to the understanding of the proposed
action. The adequacy of the treatment process design is con-
sidered a matter outside the purview of the Corps. It is
assumed, however, from the statement on page 4-2 of the draft
EIS that the discharge from the O'Hare WRP will comply with the
water pollution regulations adopted by the Illinois Pollution
Control Board in July 1973 and approved by your office.
Chapter A, Description of the Proposed Action, should be
expanded to include a discussion of the restrictions on the type
and concentrations of pollutant loadings discharged into the
sewer system. It is our understanding that the treatment plant
is designed to achieve an effective control of only three
pollution constituents; namely, the biochemical oxygen demand,
suspended solids and ammonia nitrogen. The regulatory control
of discharge to the sewers is needed to comply with the
effluent and stream standards for all other polluting constituents.
This type regulatory control is particularly important in view of
the projected industrial developmer-1- within the service area.
Moreover, it is not clear whether or not provisions for in-stream
aeration are included as part of the plant design in order to insure
6-126
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NCCPD r';1 /U'i'i i 19Y1)
Mr. Kraru: In T. Mayo
coinp iianoe with the water- quality :;taridardr> for dissolved oxygen.
A statement should be included in the discussion on projected
design flows to clarify If the population projections are in
consonance with the official Ltate estimates prepared by the
Illinois Bureau of the Budget as the basis for resource planning.
In evaluating the cost-effective tradeoffs in sizing the plant,
consideration should be given to the dewatering rate and the
duration of the period when the water level in the tunnel
would be higher than the surrounding ground water (See page
5-12 of the draft EIS lor the proposed tunnel conveyance system
in the Des Plaines - O'Hare Service Area). This could be a major
problem with construction of the main reservoir deferred,
The disposal alternatives for the sludge from the John E. Egan
WRP should be discussed in greater detail in the EIS. The
discussion should cover the availability of possible disposal
sites, the cost of shipping the sludge and public acceptance
of the individual alternatives. The potential for incorporating
the sludge into the existing MSDGC Fulton County Reclamation
Program should also be assessed and the comparative (to the
other alternatives) beneficial as well as adverse impacts
identified along with the reasons for eliminating such an
alternative.
No Information is provided on the environmental impact of
the project relative to the affected aquatic ecosystems. The
EIS should discuss the existing aquatic ecosystems and describe
any expected changes in both Higgins and Willow Creeks and the
Des Plaines River. Such discussion should include not only
the type and quality of future fisheries but also the change
in flow regimen and the potential for both in-stream and bank
erosion.
The opportunity to review the draft EIS is appreciated.
Sincerely yours,
/te--
f / JAMES M. MILLER
^ Colonel, Corps of Engineers
District Engineer
6-127
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Response:
The MSDGC has ordinances prohibiting or limiting the discharge
of certain materials, which could upset the treatment process,
to their system.
Instream aeration is not needed in this project to maintain
compliance with water quality standards.
The population projections are in consonance with the projections
of the A-95 clearinghouse, the Northeastern Illinois Planning
Commission.
Discussion of the plant size has been revised (Chapter 3, Section
B).
The sludge from the John E. Egan Plant will eventually be land
applied in Fulton County, Illinois. We agree that the environ-
mental impact of this proposed sludge disposal method should
be addressed. We intend to prepare an EIS, specifically on the
land application project in Fulton County.
No biological sampling has been conducted on the streams in
the project area. The IEPA will begin some biological survey
work on Higgins Creek this summer.
6-128
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
CHICAGO AREA OFFICE
17 NORTH DEARBORN STREET
CHICAGO, ILLINOIS 60602
May 6, 1975
MKIilON V
100 flmilli W«< km Drive-
fill. *«.., llll.uil. f)l)000
INKF. PLY HI-F-K.N IO-
5.2PP (Goldfarb)
< . i
Mr. F. T. Mayo, Regional Administrator
U. S. Environmental Protection Agency r
Region V ^ <-
230 South Dearborn
Chicago, Illinois 60604 —
C c,
Dear Mr. Mayo: />
C
The Chicago Area Office of -he Department of Housing and Urban development
appreciates the opportunity to review the Metropolitan Sanitary District of
Greater Chicago's EIS for the O'Hare Water Reclamation Plant and thereby
recognize the responsible manner in which the MSD is planning to meet the
needs of Greater Chicago. In reviewing the EIS we were impressed with both
the comprehensive manner in which the MSD is meeting its demands and with the
careful design of this particular plant. We also appreciated the fine work
the USEPA did in preparing this EIS, particularly the sections on process
and solids handling alternatives. The USEPA seemed to identify several
alternatives which might be attractive for future use and it is hoped that
their dissemination in this form will prove to be the first phase of a planning
cycle that will lead to their eventual implementation.
Although the design of the plant seems to have given careful consideration to
the potential for adverse environmental impacts we were struck by the lack of
such consideration in the site selection criteria listed on pages 3-10 and
3-11 of the EIS. Such consideration would seem appropriate as both odor and
aerosol concentrations seem to be inversely proportional to a geometric
function of distance from the plant. The absence of environmental impact
considerations from site selection criteria would be justified if possibili-
ties of both odor and aerosol generation were eliminated. This has not been
demonstrated possible nor claimed in the EIS. It therefore seems inappro-
priate that the site closest to a residential was ultimately chosen.
The EIS prepared by the USEPA seems to indicate that there will be no adverse
impacts from construction of the proposed facility. In the absence of evi-
dence to the contrary we must take this assessment at its face value. We
would, however, 'Jtke to see the alternatives section of the final EIS expanded
to include the following points:
What are the total relative impacts of each site upon residential
communities. This might be evaluated by using a system of concentric
rings around each source of odors and aerosols and tabulating the
number of residential units in each ring. For example, the following
6-129
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2
system might be used
ring 1 = 0 - 250' radius
ring 2 = 250' - 400' radius
ring 3 = 400' - 600' radius
ring 4 = 600' - 900' radius
ring 5 = 900' - 1500' radius
ring 6 = 1500' - 2500' radius
Why is the City of Des Plaines refusing to vacate Willie Road? It
seems as if this action would significantly increase the attractiveness
of this site and therefore merits a full exposition of the relevant
issues.
Thank you again for the opportunity to comment on this EIS. We would
appreciate receiving a copy of it in its final form.
Sincerely,
hnJU Waner
irector
Chicago Area Office
6-130
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Response: Chapter 3, Section C of this EIS addresses the environmental
impact considerations of odor potential and aerosol generation.
This is further expanded upon in Chapter 5 (Environmental
Impacts of the proposed action) Sections B,C,F,I, and L.
Appendix R contains an anaDj-sis of population density from
the center of sites 1 and 2 (based on 1,000 foot concentric
circles) and is part of the site selection discussion in
Chapter 3, Section C.
The City of Des Plaines must answer the question why they
are refusing to abandon Wille Road.
6-131
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ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
2200 Churchill Road j|§C?
-------
s-~- STATE OF ILLINOIS
DEPARTMENT OF CONSERVATION
605 STATE OFHfL bUILDINC)
400 SOUTH SPRING ST
ANTHONY T DEAN SPRINGFIELD 62706 HAROLD l_. ELLSWORTH
DIRECTOR _—— ASSISTANT DIRECTOR
CHICAGO OFFICE ROO"/ 1OO, 1 6O N. LA SALLE ST., 6O6O1
April 4, 1975
Mr. Francis T. Mayo
Regional Administrator
United States Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Mayo:
The Department of Conservation has reviewed the draft EIS's for the
proposed tunnel conveyance system for the Des Plaines-O'Hare Service
Area and the proposed Des Plaines-O'Hare Water Reclamation Plant and
Solids Pipeline.
Both EIS's indicate the project will cause adverse impacts to Higgins
and Weller's Creeks. Since these creeks are presently degraded by
pollution and channelization and do not maintain a significant fishery,
the Illinois Department of Conservation believes the project's projected
improvement in water quality will far outweigh any minor adverse impacts
associated with the projects.
Sincerely yours,
Bruce A. Rogers
Supervisor,
Division of Long-Range Planning
BARraf
cc: Al Lopinot
Harry Wight ENVIRONMENTAL PROTECTION AGENCY
RECEIVED
APR 1 : 1975
6-133 PIANJNUNG bHAJNCH - Region V
Recycled Paper
-------
Village of Mount Prospect
OFFICE OF THE MAYOR
E. Northwest Highway Mount Prospect, Illinois BOO5B
Robert D. Teichert '"/to^Phane 312 / 392-6OOO
Mayor *f
March 31, 1975
United States Environmental
Protection Agency - Region 5
230 South Dearborn Street
Chicago, Illinois 60604
Attention: Harlan D. Hirt, Chief of Planning
Dear Mr. Hirt:
Since I will be unable to attend the public hearings being
held today regarding the Metropolitan Sanitary District O'hare
treatment plant, I should like to use this letter as a means of
placing my comments and observations as the Mayor of the Village
of Mount Prospect before your agency.
While I can be sympathetic with the viewpoint of those who are
objecting to the installation of this facility on the basis that
it will adversely affect the local environment, I do not believe
such sympathy requires that I ignore the existing and known health
hazards in deference to speculations as to what might be. Inade-
quacies of the present MSD facilities for removing sewage from
our community have well been documented over the past ten years ...
it is the same for our sister communities, Elk Grove Village and
Des Plaines. The inability of the MSD interceptors to handle our
accumulated sewage results in raw sewage being overflowed into
our creeks and drainage ditches and backed up into the basements
of our residents.
For seven years the means to resolve this major area problem
has been at hand, but the specter of bad environmental impact
has been used to delay the implementation of this most needed
facility. No one can convince me that untreated raw sewage
stored in the basements of residences and spread across the open
land is preferable to storage of such sewage in controlled
circumstances. Unless your agency can assure our citizens that
the storage of raw sewage in and about our properties is a lesser
health hazard than the storage of such sewage at the O'hare
treatment facility, I would believe it mandatory that you approve
this facility for immediate construction.
6-134
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Ill ri, rMfj,- ;- March 31, 1975
The eit.i/tiiio oi' t,he commun i t, u-.;; in our area have long enjoyed
a dream world existence where by the flick of a handle they
could transport their sewage into Chicago for treatment and
disposal. We have refused to cooperate with each other and the
MSD on sewerage or flood control matters, particularly if it
would cost us our own money. The disposal of sewage and solid
waste materials is of little concern to us so long as we can
dump it in somebody else's b.^kyard ... when it is our own back-
yard, we become quite concerned. If each community was required
to collect and treat its own sewage within its own boundaries, I
wonder if the standards we demand of others would be exacted from
ourselves.
Certainly we should not through undue haste create new problems
when we solve old problems, but the seven years of delay on this
project with the multitude of hearings and court cases can
hardly be considered "hasty". If there is going to be continuing
delays, it would seem that those responsible for such delays
should be required to compensate the citizens of our communities
who suffered damage due to sewage backup.
I do not believe that a project designed via established experts
in the sanitary field can be so patently deficient as to warrant
the attacks being made on this project. If after seven years the
"alleged" deficiencies have escaped the notice of the Federal
experts, I would suspect that political pressure is now replacing
reason. We are not considering a beautification project for the
area, but a much needed reclamation plant to treat our own sewage
in a controlled and healthy manner.
Our citizens will no longer tolerate the stench of putrifying
raw sewage nor will we continue as spectators while the sewage
backs up into our basements and recreation rooms. We have a
present health hazard ... there is a solution at hand ... further
delay is unwarranted unless it can be proved that the proposed
facility will present a greater health hazard.
Please enter these comments in the record of your proceedings.
Very truly yours
Robert D. Teichert
6-135
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CfilCQQO
Qudubon
/oclety
(Chapter of the
National Audubon Society)
6414 N. Ridge
Chicago, Illinois 60626
(312) 262-1716
Founded by
R. Sethuraman
Helen P. Sethuraman
President & Chairman
Board of Directors
R. Sethuraman
Vice President
Dr. Peter L. Ames
Treasurer
William C. Florian
Recording Secretary
"•isan C. Pettinger
Bonding Secretary
--_ ictoria E. Kohlman
Chairmen of Committees
Broadcasts
Marcella Gewirth
Conservation
Marjorie B. Molyneaux
Education
R. Sethuraman
Field Trip
Sonia Florian
Finance
William C. Florian
Indiana Dunes
National Lakeshora
George Bunce
Membership
Helen P. Sethuraman
Nature Study &
Photography
Mildred A. Glueck
Program
Mildred A. Glueck
Publications
Philip Hablutzel
Publicity
Susan C. Pettinger
Scientific Research
Robert Tweit
Board of Directors
Homer C. Bishop
Jack Brickner
Virginia J. Brown
Philip Hablutzel
Bruce Sturzel
" --rge Bunce
Ann Garner
, las J. Jacob
x^_^de Kaplan
Robert Leighton
Sonia Florian
7322 East End Avenue
Chicago, Illinois
April 17, 1975
Franoia T. Mayo
Regional Adainiatrator
United States Envlronaental Proteotioa Agency
Region f
230 South Dearborn Street
Chicago, Illinois 6otO
-------
ENVIRONMENTAL IMPACT STATEMENT
METROPOLITAN SANITARY DISTRICT OF GREATER CHICAGO
0*HARK SERVICE AREA wASTBWATER CONVEYANCE SYSTEM
O'HARE WATER RECLAMATION PLANT AND SOLIDS PIPELINE
la responding to the environmental impact statements for the above projects we
would like to state at tha outset that we support the two plans, in principle,
and we believe that they are a big step forward to improve the total water
quality of the area« However, our review of these projects would be aore
understandable to all if we were asked to first respond to the total project
and then to the remaining seven of its partso ^his plan would give the reviewer
the opportunity to judge the impact on Jae environment of the total program
rather than to respond piecemeal for ex»ch separate part. Without this complete
understanding we will respondto the irdividual projects separately.
O'Hare Service AreaWastewater Conveyance System
We are concerned about the disposition of the rook and debris removed when digging
the tunnels. Mutt is to be done *dlth it, and how long will it remain there?
We would like to see positive t^atements about measures to be taken regarding:
Noise pollution abatement
Heavy drilling effects
Effect on private wells and supplies of water to those property owners
during construction * even though monitoring will be done
Sealing of drop shafts to prevent aerosol release at top of shafts
Reduction of partieulate matter levels from blasting and excavation
Restoration of the habitats for plant and animal life by replacing or
replanting vegetation to its original state
Incorporating ways to increase the retention time in the pond to reduce
siltation into Biggins Creek during construction
As combined sewer overflows to Weller's Creel: and Feehanville Ditch are reduced
from 80 per year to 6, water quality in these streams will improve and will serve
to encourage indigent plants and small animals to reestablish in the area*
O'Hare Water Reclamation Plant and Solids Pipeline
From our review of the proposal we feel there is more concern for the aesthetic
value of the plant and its surroundings than the biological impact on the area.
The fact that so little is known about the effects on public health of bacterial
and viral respiratory pathogens should cause the Metropolitan Sanitary District
to promote or to assure that others will promote increasing research in these
areas in order to solve specific problems. Giving rewards to scientific leaders
for their accomplishments and setting up future rewards for work to be done is
one method which could be used. Innumerable others would be of value so that we
no longer have to say that scientific knowledge hasn't uncovered the answers.
We are concerned with the impact of the plant on Higgins Creek, the nearby
forest preserve and the flood plain - the biological effects on the population
of the area, on the local traffic flow through and the siae of the buffer zone
around the plant.
Marjorie Molyneaux, Chai
Conservation Committee
Chicago Audubon Society
6-137
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Response:
The impacts of the proposed water reclamation plant on Higgins
Creek are discussed in Chapter 5, Section A. The proposed
pipeline through the forest preserve should have little
impact since the proposed route follows an existing pipeline
right-of-way. Discussion of the other concerns mentioned
can be found in Chapter 5.
6-138
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GRFAT LAKES CHAPTER
930-10 E. Shady Waj
Arlington Hts, II 60005
April 18, 1975
cr/
•*
c
Mr. Francis T. Mayo _.
Regional Administrator O <=>
U. S. B P A > c •
230 S. Dearborn Street CC o
Chicago, Illinois 60604
Subject: O'Hare Water Reclamation Plant & Solids Pipeline Project
Bear Mr. Mayo:
We have examined the environmental impact statements concerning the
O'Hare Water Reclamation Plant and associated Solids Pipeline
Project proposed by the Metropolitan Sanitary District of Metro-
politan Chicago. The Sierra Club gives its approval to both of
these projects contingent upon the continued awareness and action
on the part of the MSD8C to eliminate any environmentally hazardous
consequences of the construction and operation of these projects.
The expected growth of the population and industrial activity of the
area serviced by the proposed projects will be accompanied by in-
creasingly larger wastewater loads. This, together with the very
limited assimilative capacity of the receiving waters in the area,
along with the Water Pollution Control Regulations of Illinois
(effective December, 1977) require that some type of wastewater
treatment system be developed for the region. It is the opinion
of the Sierra Club that a reasonable analysis of the problem was
presented in the Environmental Impact Statements, and that fair
and rational judgement was used to decide the best possible alter-
natives to the problem.
While construction and operation of the proposed projects present
some environmentally undesireable consequences, they are far out-
weighed by the potential benefit. . Nevertheless, every possible
thing should be done to limit or eliminate these undesireable
side effects. Areas of special attention include:
1) Potential health hasards of air borne pathogens. The existing
6-139
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(2)
evidence, while very incomplete, implies that airborne pathogens
pose no significant health problem. However, the MSDQC must be
prepared to control the aerosol emissions from the VHP if future
evidence and/or resident complaints show that, indeed, airbom*
pathogens do present a dangerous health problem.
2) Odors - Evidence is given that ;:he odors generally associated
with a sewage treatment plant occ^i- only urder conditions of
overflow or bypass, during sludga treatment, or as the result
of poor maintenance and operation procedures. The O'Hare WRP
is designed with sufficient design capacity and backup facilities
to prevent the overload or bypass situations. The plant does
not have sludge treatment facilities. Attention must be given
by the MSDGC to maintain high standards in the operation and
maintenance of the system so as to not create situations which
will cause odor problems. The MSDGC must be prepared to eliminate
any odorous emissions if such emissions do, in the future, become
a problem*
3) The ultimate site of sludge disposal - while sludge disposal
will be outside the service area of the O'Hare WRP, it must be
considered an integral part of the project. The MSDGC must be
prepared to handle the sludge disposal problem in an environ-*
mentally acceptable manner.
4) Every effort must be made to make the WRP project aesthetically
pleasing.
5) Every effort must be made to eliminate disturbances caused
by the construction of the O'Hare WRP and the associated Solids
Pipeline. Residents should be compensated for any damages or
costs attributable to decreased water quality or any loss of
property resulting from construction of the project.
6) Disposal of excavated material - The MSDGC must, be prepared
to dispose of the material excavated from the Solids Pipeline
Project in an environmentally and economically acceptable manner.
If the MSDGC maintains a constant vigilance over the above environ-
mental concerns, the Sierra Club must then give its approval to
the entire project.
Very truly yours,
L
Ann Fisher
Conservation Chairman
6-140
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Response:
Both the aerosol and odor questions are addressed in Chapter
3 and 5. Mitigative measures are planned to suppress the
movement of aerosols. Odors will not be a problem given the
extensive odor control measures which are proposed. Other
aspects of the submitted comments are discussed in Chapter 5.
6-141
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April 12, 1975
US Environmental Protection Agency
230 S. Dearborn Street
Chicago, Illinois 6060^
To Whoever Will Listen,
As a father who lives in the proposed sewerage treatment
area (within $ mile) and whose fe^ily would be the ones sub-
jected to any health hazard or ill effects of this project,
I wish to voice my protest against the O'Hare Water Reclamation
Plant at the proposed site*
I do so with the persistent feeling that my objections
and those of my neighbors' are only a waste of our time and
energy* I feel the Metropolitan Sanitary District and the USSPA
have already decided what best serves our needs and the Public
Hearings are only window dressing to give the public an
appearance of listening, I write this letter in the hopes that
I am wrong.
I have been following the pros and cons of this proposed
project, depending primarily on my neighborhood paper Cor most
of my information. When I learned the USEPA was holding a Public
Hearing on March 31, 1975, I attended to determine in my own mind
what effect this would have on my home and community.
I felt this was a very complicated project, consisting of
engineering layouts and data, statistical projections, environmental
studies, doctor reports and legal rulings, etc., and felt I was
not qualified in any way to offer an opinion* After attending
the hearing and reading the Environmental Impact Statements,
to my surprise, the more I got involved the less complicated
it appeared.
Instead of getting lost in all that mumbo-jumbo, I was
getting the clear picture, that what this argument boiled down to
was, in essence, a determined effort to reassert authority.
Would the MSD or any other government agency be able to retain
their exclusive right to dictate their pet projects as they saw fit
on an unwilling community?
If that is not the reason, then why won't the MSD consider
alternate sites away from residential homes? Why won't they
sit down with Community Representatives and try to work out
a satisfactory compromise?
Why was Site 2 rejected when it's tanks would be 950*
further away from residential homes, meets all of their own
requirements and is presently owned by the MSD?
Why were Site 3 and 8 rejected because the availability
of these sites are unknown? What action, if any, was taken to
determine their availability?
With the control devises, the MSD claims this facility
will not experience the foul odor problem as they have at ether
treatment plants and then contradict that statement by claiming
it is not possible to judge the exact extent of the potential
odor problem from the proposed WRP project.
6-142
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The NSD states they recognize the infection potential in
wastewater aerosols and claims it would be improper to conclude
that it will positively result in a public health hazard, but why
can't they deny that such aerosols present no potential public
health danger? Is it because th3y can't? They admit they do not
realize the full extent of thin problem and yet are still willing
to jeopardize the health of my children and family to these dangers.
We recognize the need for building proper sanitary facilities,
but we also recognize a need for our families to grow in a healthful,
pleasant, environment.
Were willing to work with you and the Metropolitan Sanitary
District. Are you as willing to work with us?
Bd Verri
760 Devonshire Dr.
Des Plaines, 111.
6-143
-------
Response:
As indicated in previous chapters of this EIS, we have made
a determination that the MSDGC provide adequate aerosol
suppression facilities to restrict the movement of aerosols
from Site 1.
6-144
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HURRY Hff MOODY
933 South Plum Grove Road, Suite 101
- •&*/
Palatine, Illinois 60067
Phone: 312 / 358-5960
ENVIRONMENTAL PROTECTION AGENCY
RECEIVED
MAR 211975
OANNiWfe ttKANCH - Region V
March 27, 1975
Harlan D. Hirt
Chief, Planning Branch
U.S. EPA Region 5
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Hirt:
I wish to express my opinion on the question of the proposed
construction of the O'Hare Treatment Plant by the Metropolitan
Sanitary District to serve the Northwest section of Cook County.
In my professional opinion as a consulting engineer working in
the said section, 1t is no longer a question of \f_ the plant 1s
needed. It 1s merely an urgent question of when. I hope and
trust that permission for construction will be given Immediately
Very truly yours,
MURR'Y AND MOODY
cc: Mr. A.Y. Ta1ham1
Metropolitan Sanitary District
6-145
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION1 V
230 SOUTH DEARBORN STREET
CHICAGO, ILLINOIS 60604
PUBLIC NOTICE
Notice of Extension of Comment Period
On March 4, 1975, we announced the availability of -two Draft
Environmental Impact Statements for several projects proposed
by the Metropolitan Sanitary District of Greater Chicago. One
EIS concerns tVie proposed tunnel conveyance system for the
Des Plaines - O'Hare Service Area, and the other, the proposed
Des Plaines - O'Hare Water Reclamation Plant and Solids Pipeline.
The deadline for comments on these Drafts was given as April 7, 1975,
In view of the public interest surrounding these projects, proposed
EPA regulations and CEQ guidelines,the final date for receipt of
written comments is being extended to April 21, 1975. Because of
the large volume of comments expected however, we would appreciate
receiving comments as early as possible.
?rancis T. Mayo
Regional Administrator
o
"fcJL.
6-146
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION' V
230 SOUTH DEARBORN STREEJ.....^.,...,,,, '
'NVIRONMENTAl PROTECTION AGENCY
CHICAGO, ILLINOIS 60604 RECEIVED
.',''.' . ' APR. 31975
PUBLIC NOTICE etAMSiiMG tfKANCH - Region V
—: fiui NO
i
Notice of Extension of Comment Period
On March 4, 1975, we announced the availability of two Draft
Environmental Impact Statements for several projects proposed
by the Metropolitan Sanitary District of Greater Chicago. . One
EIS concerns the proposed tunnel conveyance system for the
Des Plaines - O'Hare Service Area, and the other, the proposed
Cos Plaines - O'Hare Water Reclamation Plant and Solidsr Pipeline.
The deadline for comments on these Drafts was given as April 7, 1975,
In view of the public interest surrounding these projects, proposed
EPA regulations and CEQ guidelines,the final date for receipt of
written comments is being extended to April 21, 1975. Because of
the large volume of comments expected however, we would appreciate
receiving comments as early as possible.
? rands T. Mayo
Regional Administrator
.6-147
-------
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6-148
-------
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^ Q^ns&^A—- 3te44r ^
*J$) y^L^'t- ^&i&??Cs &v&e^'\ (QZ&^p '^^t^cs.
6-155
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Response: (to 6 previous comments)
As discussed in Chapter 3 and 5, we will require the MSDGC to
provide adequate aerosol suppression facilities to restrict
the movement of aerosols from the site. We believe the odor
control measures proposed by the rtSDGC will be sufficient to
avoid any significant odor problems.
The airport site must be eliminated because of the restriction,
placed on the FAA grant to purchase the land, that it only be
used for facilities of direct benefit to the airport.
A distinction must be made between the literature which concludes
that there is a possibility of a health hazard associated with
aerosol transmission :nd the fact that an actual health hazard
has not been demonstrated. The risk involved however, led us
to the conclusion to require aerosol suppression facilities.
With respect to odor considerations, the proposed O'Hare Water
Reclamation Plant cannot be compared to other MSDGC facilities.
The absence of sludge handling facilities and the proposed odor
control measures will be sufficient to avoid any significant odor
problems.
The statement concerning the decrease in property values being
negligible over the long term means subsequent to the period
of construction.
6-156
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I Food Services Division
INC
2600 Lively Boulevard
Elk Grove Village, Illinois 6000?
April 22, 1975
U. S. Environmental Protection Agency
Region 5
230 South Dearborn Stree;
Chicago, Illinois 6060lj.
SUBJECT: Proposed O'Hare Water Reclamation Plant -
Oakton and Elmhurst Roads
Dear Sir:
The Village of Elk Grove Village has consistently supported the
construction of that facility because it is vital to the long
range development of the Village of Elk Grove and in particular
the industrial community of Elk Grove Village. Without a new
plant location nearby, the Village of Elk Grove could conceivably
be faced with limitations imposed by the Metropolitan Sanitary
District, prohibiting new construction or additions to private
property in the Village. Both residential and industrial
development could be curtailed. The new facility is desperately
needed to relieve the extreme back pressures created in our
sanitary system due to the introduction of both sanitary and
storm water in municipalities located north of the toll road.
Such flows in periods of wet weather in our opinion create back
pressures on the interceptor systems servicing Elk Grove Village
which, in turn, cause sanitary sewer backups in both residential
and industrial properties.
As a business resident of Elk Grove Village, I am concerned that
the future progress and development of our Village not be
curtailed. My second concern is the health factor, which is
faced not only by my business associates, but also by the home-
owners who in periods of wet weather are faced with sewer backups,
I encourage you to support, by all means at your disposal, the
as soon as possible of the new treatment plant.
Ditribution Branch Manager
Elk' Grove Sales and 6-157
Distribution Center
-------
Additional letters, substantially identical to the previous letter, in support
of the proposed O'Hare Water Reclamation Plant project were received from
the following:
James P. Jacobs
Vice President & General Manager
LOEB Corporation
Chicago - 1925 Busse Road
Elk Grove Village, Illinois
Washington - 7301 Roosevelt
Landover, Maryland
W. K. Leutz
President
Gane Brothers & Lane, Inc.
1400 Greenleaf Avenue
Elk Grove Village, Illinois
60007
Jeanne Shaw
General Manager
Easy Travel Service, Inc.
573 Landmeler Road
Elk Grove Village, Illinois
60007
Frederick Roemer
Industrial Relations Manager
Chicago Magnet Wire Corporation
901 Chase Avenue
Elk Grove Village, Illinois 60007
Henry J. Duda
President
Zip Dee, Incorporated
96 Crossen Avenue
Elk Grove Village, Illinois 60007
William Bruce
General Manager
The Voice
1495 Tonne Road
Elk Grove Village, Illinois 60007
Ira A. Eichner
Chairman of the Board, AAR Corp.
2050 Touhy Avenue
Elk Grove Village, Illinois 60007
Robert 0. Kramer
President
Keen Screw Products, Inc.
P.O. Box 34
1535 Brummel Avenue
F.Ik Grove Village, Illinois 60007
Clarence Nowicki
Regional Manager
ZEP Manufacturing Company
1390 Lunt Avenue, P.O. Box 177
Elk Grove Village, Illinois 60007
J. W. Brittingham
Rollex
2001 Lunt Avenue
Elk Grove Village, Illinois 60007
Kenneth A. Dobbs
ABRA Enterprises, Incorporated
360 Kent Street
Elk Grove Village, Illinois
60007
Eli Field
President
Field Container Corporation
1500 Nicholas Boulevard
Elk Grove Village, Illinois 60007
Bruno Diekmann
President
Buss-Condux, Incorporated
2450 Delta Lane
Elk Grove Village, Illinois 60007
R. F. Kowalski
General Manager
J. T. Ryerson & Son, Incorporated
2180 Pratt Boulevard
Elk Grove Village, Illinois 60007
6-158
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John M. Lengyel
Manager
Warner-Lambert Company
1350 Bates Avenue
Elk Grove Village, Illinois 60007
Alvin A. Brzycki
General Manager
Oxy-Dry Sprayer Corporation
2011 Landmeier Road
Elk Grove Village, Illinois 60007
Gayle B. Bantner
President
Elk Grove Drugs, Incorporated
11 Park 'N Shop Lane
Elk Grove Village, Illinois 60007
Frank Di Canio
President
F-D-C Drafting Aides Corporation
85 Gaylord Street
Elk Grove Village, Illinois 60007
Irv Harvey
President
Galaxy Carpet Mills, Incorporated
850 Arthur Avenue
Elk Grove Village, Illinois 60007
Charles R. Wilcox
Vice President
J. F. Helmold & Bro.,
901 Morse Avenue
Elk Grove Village, Illinois 60007
Incorporated
James N. Martin
Traffic Supervisor
AMF Voit, Incorporated
2601 Lively Boulevard
Elk Grove Village, Illinois 60007
Brandt W. Berger
Jet Die Casting Corporation
850 Elmhurst Road
Elk Grove Village, Illinois 60007
William E. Huntsha
Manager, Distribution Center
Amerace Brands Division
Amerace Corporation
1201 Mark Street
Elk Grove Village, Illinois 60007
L. Allen Singer
President
Schwinn Sales Midwest, Incorporated
21C1 Arthur Avenue
Elk Grove Village, Illinois 60007
Joseph E. Turley
Thomas Equipment Corporation
675 Lively Boulevard
Elk Grove Village, Illinois 60007
William Goldman
Vice President
L. Karp & Sons, Incorporated
1301 Estes Avenue
Elk Grove Village, Illinois 60007
Gerald A. Skillicorn
Director of Operations
Lieberman Enterprises
1000 Touhy Avenue
Elk Grove Village, Illinois 60007
James H. Weeks
Secretary Treasurer
Overhead Door Company of Elk Grove
100 Kelly Street
Elk Grove Village, Illinois 60007
J. J. Pawlak
General Superintendent
Lifetime Foam Products, Incorporated
3001 Cullerton Drive
Franklin Park, Illinois 60131
Edward E. Dormal
Panlmatic Company
79 Bond Street
Elk Grove Village, Illinois 60007
6-159
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Glenn E. Ronk
President
Sola Electric
1717 Busse Road
Elk Grove Village, Illinois 60007
James Moyles
President
James Moyles & Associates, Inc.
2680 Coyle Avenue
Elk Grove Village, Illinois 60007
K. H. Sankman
Secretary-Treasurer
Globe Amerada Glass Company
2001 Greenleaf Avenue
Elk Grove Village, Illinois 60C07
District Manager
Ryder Truck Rental, Incorporated
P.O. Box 13
Bensenville, Illinois 60106
Pat Starr
Vice President
Biltmore Tire Company, Inc.
2500 Devon Avenue
Elk Grove Village, Illinois 60007
I. Kacsh
Director of Finance
Eskay Products Corporation
123 Scott Street
Elk Grove Village, Illinois 60007
Wayne A. Hudec
Manager - Midwest Region
Markem Corporation
2082 Estes Avenue
Elk Grove Village, Illinois 60007
E. J. Burke
Central Warehouse Company
2311 2301 West Touhy Avenue
Elk Grove Village, Illinois 60007
G. A. Strehlow
Treasurer
National Material Corporation
2525 Arthur Avenue
Elk Grove Village, Illinois 60007
Joseph A. Hollander, Jr.
President
Hollander Storage & Moving Company
1801 Pratt Boulevard
IJk Grove Village, Illinois 60007
William J. O'Shea
Vice President
Shamrock Electric Company, Incorporated
1281 E. Brummel Avenue
Elk Grove Village, Illinois 60007
Bernard L. Peterson
Executive Vice President
and General Manager
Wayco Foods Corporation
2000 Pratt Boulevard
Elk Grove Village, Illinois 60007
Robert F. Tomalka
District Manager
J. C. Penney Company, Incorporated
851 Devon Avenue
Elk Grove Village, Illinois 60007
Edmund J. Burke
United States Flour Milling Company
2301 West Touhy Avenue
Elk Grove Village, Illinois 60007
Norman G. Jensen
Vice President
Cosmos Shipping Company, Incorporated
1351 Brummel Avenue
Elk Grove Village, Illinois 60007
E. J. Burke
E. J. Burke and Company
2301 West Touhy Avenue
Elk Grove Village, Illinois 60007
6-160
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Richard C. Hoskins
President
Hoskins Chevrolet, Incorporated
175 North Arlington Heights Road
P.O. Box 175
Elk Grove Village, Illinois 60007
George E. Noldan
President
Noldan Steel Fabricators, Inc.
105 Weiler Avenue
Elk Grove Township, Illinois 60JOS
Dan Thomson
Executive Vice President
Halo Lighting
400 Busse Road
Elk Grove Village, Illinois 60007
Louis H. Bennit
Vice President
Wilson Enterprises, Incorporated
2390 United Lane
Elk Grove Village, Illinois 60007
Rob't W. Church
Manager
Ilford, Incorporated
1230 Jarvis Avenue
Elk Grove Village, Illinois 60007
R. C. Atherton
President
Raco Industrial Corporation
2323 Touhy Avenue
Elk Grove Village, Illinois 60007
J. R. Franzen
Vice President
Hanke Company, Incorporated
1001 Fargo AVenue
Elk Grove Village, Illinois 60007
George D. Crawford
Chairman
Northwest Collectors, Incorporated
30 Lively Boulevard
Elk Grove Village, Illinois 60007
Major Lawrence
President
Lawrence Foods, Incorporated
2200 Lunt Avenue
Elk Grove Village, Illinois 60007
Tony Weinhammer
Operations Manager
Curtin Matheson Scientific,
1850 Greenleaf Avenue
Elk Grove Village, Illinois 60007
Incorporated
Thomas J. Chodl
Sales Manager
General Box Division
Southwest Forest Industries
2628 Delta Lane
Elk Grove Village, Illinois 60007
Brother Felix Bettendorf
President/Chief Executive Officer
Alexian Brothers Medical Center
800 West Biesterfield Road
Elk Grove Village, Illinois 60007
Gene H. Rocklin
President
wational Threaded Fasteners Corporation
630 Lively Boulevard
Elk Grove Village, Illinois 60007
Dick Neville
President
Continental Studios
100 North Gordon Street
Elk Grove Village, Illinois 60007
Roland Tetmeyer
Regional Distribution Manager
Sperry Remington Electric Shavers
177-179 North Randall Street
Elk Grove Village, Illinois 60007
John M. Hyslop
Business Manager
John Sexton & Company
1099 Pratt Boulevard
Elk Grove Village, Illinois 60007
6-161
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Joseph A. Nava Henry Cretors
President Iroquois Popcorn Company, Inc.
Timing Gears Corporation 1330 Louis Avenue
2425 American Lane Elk Grove Village, Illinois 60007
Elk Grove Village, Illinois 60007
Larry W. McCormick Gerald S. Howard
President President
McCormick's Enterprises, Incorporated Exliibitgroup Chicago, Incorporated
1570 Louis 2800 Lively Boulevard
P.O. Box 97 r,lk Grove Village, Illinois 60007
Elk Grove Village, Illinois 60007
Lewis B. Handler Lewis B. Handler
General Manager Managing Partner
Elk Grove Bowl Billiards Elk Grove Tennis Club
75 Park and Shop 1650 Howard Street
Higgins and Arlington Heights Roads Corner Route 83
Elk Grove Village, Illinois 60007 Elk Grove Village, Illinois 60007
6-162
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Advisory Council
On.Historic Preservation
1 ).': Fv Suu-t .\.\V. Suite 4 H)
\\'.isliinyton D.C 20005
April 8, 1975
Mr. Francis 1/kr'o
Regional Administrator ''RONMENrAL p'--oitCr(cj
Environmental Protection Ageroy _ ^ r< £ I ;- (
Region V
?2.30 3. Dearborn Street
Chicago, Illinois 6060U
6itHl\uj -
Dear Mr. Mayo: ' "Lt"°- .•
This is in response to your request of March, '1975 for comments on the
environmental statement for the O'Hare Water Reclamation Plant and
Solids Pipeline, Cook County, Illinois. Pursuant to its responsibilities
under Section 102(2)(c) of the National Environmental Policy Act of 1969,
the Advisory Council on Historic Preservation has determined that
your draft environmental statement is inadequate regarding our area
of expertise as it does not contain sufficient information to enable
the Council to comment substantively. Please furnish additional data
indicating:
a. Compliance with Section 106 of the National Historic
Preservation Act of 1966 (16 U.S.C. ^70(f)j.The Council
must have evidence that the most recent listing of the
National Register of Historic Places has been consulted
(see Federal Register, February 4, 1975 &nd monthly
supplements each first Tuesday thereafter) and that either
of the following conditions is satisfied:
1. If no National Register property is affected by the
project) a section detailing this determination must
appear in the environmental statement.
2. If a National Remaster property is affected by the
project,, the' environmental statement must contain an
account of steps taken in compliance with Section 106 and
a comprehensive discussion of the contemplated effects on
the National Register property. "Procedures for the
•Protection, of Historic and Cultural Properties" are
detailed in the Federal Register of January 25, 197^,
PP.3366-3370.
6-163
T/'c Council />• c.n hidf/h-mlmf unit of tbf Ilxcciitnr Brunch of the Fd1cr.il Government i-bai^al /'>• the Act of
Ot /, her 15, /'i(,f, ,r> j.lvhc the Prriijfut anJ Cony,tc^ in the field of llhforic Prncrration.
-------
c
b. Compliance with Executive Order 11^93 of May lj;
In the case of lands not uncle; the control or jurisdiction
of the Federal Government, r statement should be made as
to whether or not the proposed undertaking will contribute
to the preservation and enhancement of non-federally owned
districts, sites, buildi-j^r^ structures, and objects of
historical, archeolo&lcal, architectural, or cultural
significance.
To ensure a comprehensive reviev of historical, cultural,,archeological,
and architectural resources, the Advisory Council suggests that the
environmental statement contain evidence of contact with the appropriate
State Historic Preservation Officer and that a copy of his comments con-
cerning the-effects of the undertaking upon these resources be included
- in the environmental statement. The State Historic Preservation
Officer for Illinois is Mr. Anthony Dean, Director, Department of
Conservation, 602 State Office Building, UOO South Spring Street,
Springfield, Illinois 62706.
Should.you have any questions or require any. additional assistance,
please contact Jordan Tannenbaum (202-25^-3380) of the Advisory Council
staff.
Sincerely yours,
John D. McDermott
Director, Office of Review
and Compliance
r-
6-164
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EMVIRONMENTAl PROTECTION AGENCY
April 24, 1975
Mr. John D. McDetwotf-
Director. Office of Review & Corrrpli.fince
Advisory Council on Historic Preservation
1522 K Street, N.W., Suite 430
Washington, 1). C. 20005
Dear Mr. McDermott:
This will acknowledge receipt of your letter of April 8, 1975 to Mr. Mayo
regarding the Draft EIS for the O'Hare Water Reclamation Plant and Solids
Pipeline, Cook County, Illinois.
You are advlaed that the most recent Hating of the National Register of
Historic Places has been consulted and we have determined that no national
register property/ (listed or eligible therefof) is affected by the above-
uantiuiecl project.
Per Exi-cu;lye Ordar 11593, there are no known non-federally owned districts,
witea, buildings, structures and objects of historical or architectural
significance to be affected by the project. With regard to non-federally
owned objects of archaeological and cultural significance, you are advised
that we are in communication with the Illinois Archaeological Survey to
determine archaeological concerns.
We enclose copies of our letter to the State Historic Preservation Office
for Illiuoibi dated'January 16, 1975 and letters from the Illinois Historic
Landmarks Survey dated April 18, 1975 and Illinois Historic Structures
Survey 'dated April 9, 1975 to this agency. We will forward copies of
correspondence from the State Historic Preservation Office upon receipt of
sane. - - -- .
We hope this letter enables the Council to complete its review of the
Draft EIS. If further information is needed, please contact this office.
Sincerely yours,
6-l65
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Er 'IRONP.iENTAL PROTECTION AGEr '<
January 16, 1975
Mr. Anthony T. Dean, Director
Department of Conservation
605 State Office Building
400 South Spring Street
Sprinsfie.ld, Illinois .62706
Dear Mr. Been:
We are initiating the preparation of a draft" Environmental Itapact
Statement on a proposed sewage treatment project in the Upper Des Plaines
River Basin, Illinois. Enclosed are maps of the area and descriptions
of the conveyance system, the water redaction plant, and thft solids
pipeline.
As a part of this process, we need to determine If there are any sites
affected by this project which have significant historical, archeological,
architectural, or cultural value, particularly those included in or
eligible for inclusion in the National Register of Historic Places. To
the best of our present knowledge, no such sites will be adversely
affected by these proposals.
P3r .••»?•.'<'"'advise us of the status of this project's historical, archeological,
architectural or cultural impact. Feel free to contact Cathy .Grissots of
iay staff at 353-7730 if you have any questions regarding the project.
Sincerely yours,
&vW ,<(Pxs"i«* Jw-i'Xj/'"^ "Titr.r''
cc: Virgil Horath/Hist.Soc.A
UALXOU D. Hirt
Mary Virginia Wright, Des Plaines chief, Planning Branch
Historical Society •
6-166
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FaclH H r IF.
The oorvlce area for the O'Hsre Water Reclawntlon Plant (Mop 3) is 58.2 r,q. mi.
and Includes DCS PJalues, Mt. Pror.pect, Arlington Heights, Elk Grove, Rolling
Meadow.j, Prospect tieights, Wheeling, P >.d Buffalo Grove, Illinois.
The proposed treatment pl*nt slta is in Dos Plaines, bounded on the north by
Oaktoa Street, on the weat by Elmht rat Road, on lie south by the Northwest
Tollway, and on the east by Marshall Road. Willy icoad tranaversea the site
and will remain in its prrsent location. (Map 2)
A new waatewater conveyance system will be constructed in the Mt. Prospect and
Des Plaines area. (Map 3) Tbo tunnels will be excavated at 40-160 feet below
the surface, with the major .surface construction impacts occurring at the
drop shaft points, as indicated on Map 3. Manholeo will also connect the
sewers to the surface. Following are specific route descriptions:
Upper Des Plaines 20, Contract 73-317-25
This consists of constructing 22,200 linear feet of 20* I.D. sewer in tunnel
approximately 150* below the ground surface in bedrock. Also Included in the
construction are five (5) hydraulic drop shaft structures, a main construction
shaft and access manholes to be located at intervals of approximately. 2000'
along the tunnel. This contract will be located along Elmhurst Road between
the Northwest Tollway and Weller Creek and along Weller Creek Between EMhurst
Road and Central Road. . •
Upper Des Plaines 20A, Contract 73-318-28
This consists of constructing connecting structures and sewer laterals to
intercept combined sewers presently discharging water to Weller Creek and
Peehanvilla Ditch and «l»o dry weather flow. This contract will divert the
combined sewage to the rock level tunnels until they are filled thereby reducing
the frequency of spillage of combined sewage to waterways from an average of
80 times par year to fewer than 6. This contract will be constructed at the
locations of combined sewer outfalls along Weller Creek between Centre! and
Rand Roads and at the FeehanvUle Ditch near Rand Road.
Upper Des Plaines 20JB, Contract 73-319-28
This consists of construction of 6,000 linear feet of 5' I.D. sewer in earth
tunnel approximately SO1 below the ground surface and also includes construction
of manholes at approximately 600' intervals along its lougth as well ,as connect-
ing structures. The contract will i* lercept the District's Upper Des Plaines
1AA Interceptor at Rand and Wolf Roads, which serves Wheeling Township north of
Rand Road and a small area in the western portion of Northfield Township,
thereby diverting sewage presently being treated at th« North Side Sewage
6-167
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— 2 ~
Treatment Works In Skokia to the propoued O'llare Water Reclamation Plont.
This contract will bs constructed alcag Tit. Prospect Road fro;n teller Creak to
Princeton Street- (extended) and onst along Princeton Street and Princeton Street
(extended) to Wolf Road thence north ale • •«, Wolf Road to Rand Road.
Uj^r_PjR£_jlain^
Tula contract consists of construction .-.<: 11,200 linear feet of 16* I.D. aad
2,000 linear feat of 9f I.D. sower fn tunnel approximately 120' to 150' below
the gi-ouAd surface in bedrock. Also included is construction of three (3)
hydraulic drop shaft atructureo and access manholes to be located at intervals
of approximately 2000* along the length of the tunnels. This contract will
serve aa a sanitary sewage interceptor and will also intercept and convey
combined sewage overflows presently discharging to Waller Creek and Feehanville
Ditch. The 16' I.I), tunnel will extend from Elmhurst Road and Lonnquist
Boulevard east to William Street then north in William Street to a point nor-
therly of Rand Road and Isabella Street. The 9" I.D. branch will extend along
Wellnr Creek from William Street to Mt. Prospect Uoad.
Upper Pea Plainea 20C,Contract 69-307-2S
This coi'sists of constructing 11,000 linear feet of 5'0" I.I), 'sever in earth
tunnel approximately 25' to 45' below the ground surface, also construction of
manholes at approximately 600' intervals along the length of the tunnel as
well BS connecting and .Junction structures. This sewer will intercept the
District's Interceptor UD 11D at Wildwood Road and Oakton Street, and at Busse
Road and Oakton Street thus providing relief and diverting the flow to Upper
Des Plalnes 20 at Elmhurst Road and Oakton Street. The contract will be con-
structed along Oakton Street between Wildwood and Elohurst Roads.
Sludge generated at the O'Hare Water Reclamation Plant will be piped west to
the Salt Creek Plant for processing. Open trench construction will be employed
for this pipeline. Alternate 1 of the following discussion is the proposed
pipeline route.
-6-168
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STATC. OF ILLINOIS
DEPARTMENT OF CONSERVATION
605 STATE Ci F1C.H DUILDING
400 5OI Til SPRING ST.
SPRINGFIELD 62706
CHICAGO OFFI,;e—1227 S. MICHIGAN AVE.
ILLINOIS HISTORIC STRUCTURES SURVEY
1800 South Prairie Avenue Chicago, Illinois
GLESSNER HOUSE
60616
9 April 1975 - .
Mr. Harlan D. Hirt .
Chief, Planning Branch
U.S. Environmental' Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Subject: Environmental Irap.ict Statement: . Proposed Sewage Treatment
Project, Upper Des Plaines River Basin, Illinois
Dear Sir: . . -
So far as we can tell from our incomplete survey of this region of
Cook County, the proposed improvement will not impact any structures of
historic visual significance.
Yours sincerely,
E. Sprague, director
Illinois Historic Structures Survey
PSS/psk
ENVIRON MENTAL PROTECTION AGENCV
RECEIVED
APR 1 1 1975
WKAWCH - Region V
«« wo,
6-169
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STATE OF ILLINOIS
DEPARTMENT OF CONSERVATION
605 STATE OFHCE BUILDINc;
•WO SOUTH SPRING S'l.
SPRINGFIELD 6T 706
CHICAGO OFFICE— 1ZZT S. MICHIGAN AVE. «060S
April 18, 1975
Mr. Harlan D. Hirt
Chief • '
Planning Branch
United States Environmental Protection Agency
Region V . • • •
230 South Dearborn Street
Chicago,. Illinois 60604 i
Dear Mr. Hirt: |
Enclosed is a memorandum from my northern area field
surveyor concerning the historic impact of the proposed sewage
treatment project in the Upper Des Plaines River Basin. As.
you can see by the memo, your project appears to have no adverse
impact on historic sites. Mr. Hild does note the existence of
marsh prairie and I assume that you are taking that into
account:
If you need any further information on this, please
feel free to contact me. ,. ' '
* t
Sincerely,
. WILLIAM G. FARRAR
Director
Illinois Historic Landmarks Survey
P. 0. "ox 986
Carbondale, Illinois 62901
Enclosure • •. •
WGF/kpg ' , ' ' •
' ' - ' - . ENV1RONMENTAL PROTECTION AGENCV
R >E -S E I V E n
6-170 ' ' - -
- ' . - APR^iS/,;
PLANNING BKANCU - on V
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c
STATF OF ILLINOIS
DEPARTMENT OF CONSERVATION
W> S PATH O! Ml 1 HUIiniNi;
400 .SOUTH SPRING ST.
SPRINGFIELD 6Z706
CHICAGO orrif---!Z27 s. MICHIGAN AVE.
Illinois Historic Landmarks Survey / 1^ April 1975
To;, Bill Farrar '
Fronj T. HildTW - -
Subject?. Environmental Impact Statement: Proposed Sewage Treatment-
~"~"""*"~~~~" Project, Upper Des Plaines River Basin
Since our research in the area under consideration has .hardly begun it
was deemed advisable to nake an irrnediate field-survey. This was done
on Saturday, April 12. *
To 'accomplish this I traveled all the routes (alternates and sub-alternates)
indicated on the enclosed maps. I .did not enter the Cook Bounty Forest
Preserve lands except for those portions through which public highways ran.
The ma^or part of the land in question is covered by industrial parks,
apartasnt complexes, and residential subdivisions all of relatively recent
construction. The remainder of the land was open space which prwixled r-.e
unobstructed views of wide vistas.
.After covering the entire route I 'found no places that would .appear to
qualify for the National Register. In fact", I found nothing that would
•oven qualify for inclusion in our inventory that would be in the »way of
the proposed sewage project. ...
I night- add, however,- that much of the open land in the forest preserves
night be virgin prairie since it appears quite marshy in places and was
.not settled until relatively late (after the Civil War).
6-171
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u ,'
ILLINOIS ARCHAEOLOGICAL SURVEY
109 DAVENPORT HALL UNIVERSITY OF ILLINOIS URBANA, ILLINOIS 61801
Itutiwtion*:
Unirenity "' Illinois
St/n Illuiou Univeriity
Illinois State Museum
Mr. Harlan D. Hirt
Chief, Planning Branch
United States Environmental Protection Agency
Region 5
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Hirt:
Dr. Peter Roberts of the Illinois Department of Conservation '
has sent me a copy of your letter of January 16 and maps regarding
the proposed sewage treatment project in the Upper Des Plaines
River Basin, Illinois.
A check of our master archaeological site file indicates that at
least one known site (a mound) is located near Alternate 2 and one is
'located south of Alternate 1 (village) on the*map showing the alignment
alternates. We recommend that an archaeological reconnaissance survey
be undertaken of the proposed treatment plant site, the pipeline,
and throughout the wastewater conveyance system when an alternate
is selected. The portions of the system traversing the Cook County
Forest Preserve or any tracts not previously disturbed by urban
development will .be particularly important to check.
Please get in touch-with our office if we can be of any further
.assistance with this project.
Cordially yours,
Charles J. Bareis
Secretary-Treasurer
CJB:cb
cc: Peter. Roberts
6-172
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April U,
Hr. Charles J. Barois
Secretary - Treasurer
Illinois Archaeological Survey •
109 Davenport Hall
University of Illinois
Urbaoa, Illinois 61SQ1 •
Dear Mr. Barala
This nlll follow up oar letter to the Illinois DeparW8e*t *f
dated January 16, 1975* end yottr letters to this Agency dated February 10
and March 18, 1975.
We concur that archaeological input is a necessary part of environtsental
assessments relating to projects considered by this offlea. We hope that
* tocotlng vith your office, Illinola Eaviromwatal Protaction Agency and
the Department of Cowaerratlon and o«r office can b« held to disease
theso isauas.
Presently wt ask your attention to the propo««d Metropolitan Sanitary
District of Greater Qiicago project* in the Upper Dies Plainea River Basin,
Cook County. Oar letter of January 16, 1975 to Director Dean included a
facilities deacriptlon of the proposal*
A reconnaiaaanca sunmy at selected locations may b« necessary to identify
archaeological concerns. Specifically,:
A. Solids Pipeline (6.22 miles in length)
Alternate i on the map previously seat has been the
alignment chosen. The nipellne is planned for existing
rights-of-vay in tnost locations. A dlscusaloa with
the Cook County Forest Preserve District Indicated
that the portion proposed through District property
is within aa open field and within an existing eighty
-foot right-of-way granted _to a Petroleum Products
Company* ' -
. 6-173
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Mr. Charles J» B&rai»
April 14, 1975
Pag* Two
B. Coaveyaac* System
Tho ttrauiila will 5>« c-xcave.ed at 40-140 feet below
tlid our£ac«« Major eurfo >•& couatruction impacts
occur at aigftt drop shaf :; points sad it appear® thfct
the drop shaft locations anH tunael construction
other t'hfen i» barfirock vorsld have arehoeolostcal
C* Water fccclaaatiem P^.
^»
Tiro 01t«3 pt*««tttly owued by T'SBGC way require a
Site It located at th« southeast coraar of Oaktos
Soada (Hiinoic Route $3) cecuoiste of 104 &cre««
Sit* 2, locatad Booth of the Ncrthweat Tollway «a4 west
of Elsiiurat: fi04ul con?,i»te of
Ve ask that you refer to your ftrcha«ological files aad incfctccce t© tliis
office th*
• . 1. A4diti
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ILLINOIS ARCHAEOLOGICAL SURVEY
109 DAVENPORT HALL UNIVERSITY OF ILLINOIS URBANA, ILLINOIS 61801
Cooperating Institutions:
University of Illinois
Southern Iliinou Univ»-rsity
Illinois State Museum
May 2, 1975
Mr. Harlan D. Hirt
Chief, Planning Branch
United States Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, IL 60604
Dear Mr. Hirt:
Thank you for your letter of April 14 and enclosure of maps pertaining to the
proposed Metropolitan Sanitary District of Greater Chicago projects in the. Upper
Des Plaines River Basin, Cook County.
There is no new additional information or changes in the data that we have pre-
viously provided you'for these projects. A check of our master site file indicates
that no known archaeological sites are recorded within the right-of-way of Alternate 1
for the solids pipeline or in the areas of sites 1 and 2 for the Water Reclamation
Plant. A field check would have to be made to ascertain whether the village (Ck-97)
we previously mentioned, is still located south of Alternate 1. We do not know the
specific locations of the eight drop shaft points to check for archaeological sites in
our records. .
* .
We, of course, recommend a detailed reconnaissance archaeological survey of all
project areas to be developed. Please contact Dr. Robert L. Hall, Chairman, Depart-
ment of Anthropology, University of Illinois-Chicago Circle, Chicago, Illinois.
Dr. Hall is a member of the Illinois Archaeological Survey and will be able to prepare
a time and cost estimate for the proposed survey work..
I agree with you that we should have a meeting in the future to discuss the Impact
of the many applications for interceptor-collection systems and sewage treatment plants
by various cities and towns throughout the Illinois. East separate project could very
well effect the archaeological resource base in each particular area, and every effort
should be taken to insure preservation of our archaeological resources.
We appreciate your concern and interest. Please stay in touch Vith our office.
Cordially yours,
Chai
Secretary-Treasurer*
CJB:sh
cc: Robert L. Hall .. " 6-175
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D. Resolutions and Petitions
6-176
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Chronology of Interest
by Elk Grove Vi11 age
i n the
O'Hare Water Reclamation Plant
March 31, 1975
Hay 7, 1971 Letter to NIPC re: A-95 #71-067 O'Hare Treatment Plant.
Federal Grant of $13,95^,200 toward $46,51^,000 (now $82,500,000
toward $110,000,000).
48 MGD 450,000 POP. 37,250 AC.
(72 & % MGD) (3000,000 TOP.) (37,250 AC.)
Des Plaines, Mt. Prospect, Elk Grove, Rolling Meadows, Wheeling
and Buffalo Grove.
1972
In 1972, we spent an enormous amount of time working with the
Metropolitan Sanitary District in an attempt to reduce the amount
cf storm water infiltration into our sanitary sewers. The reason
we had to do that, I will tell you, is because the City of Des
Plaines, Village of Mount Prospect and the Village of Arlington
Heights operate combined sewers which allows storm water into the
MSD system and thereby usurping the capacity of the MSD lines
otherwise available to EGV.
January 31, Letter from Village; Manager to MSD President requesting information
1373 about the Proposed Retention Basins south of the NW Toll road
removing 138 acres from our future tax base.
Expressing reservations about failure of MSD to consider Elk
Grove Village Comprehnnsive Plan.
February 13,
1973
Letter from Village President to MSD President regarding the
position of Elk Grove Village.
-- Remained silent on the O'Hare Plant Issue in respect of
our neighbor, Des Plaines, to permit the MSD and City of
Des Plaines to explore and resolve their differences.
-- Further delays and increased costs to taxpayers to occur if
the plant is to be relocated.
— Pollution and flooding would continue to worsen.
-- Upper Salt Creek Plant (now called John E. Egan WRP) is
being built adjacent to Elk Grove Village west of Inter-
state 90 within 350 feet of a single family subdivision.
-- Delays in constructing O'Hsrc Plant represents a failure
to act responsibly in protecting the public health.
February 27,
1973
Resolution #13-73
Proceed without delay, incorporate Village President's
February 13, 1973 'Position Statement' sent to MSD; send
copies of Resolution to City of DCS Plaines and others.
6-177
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-,e 18, 1973 Letter from Village Manager to Chairman, MSD Committee 0,1
finance, recommending early construction of
— O'Harc Plant
— Oakton Interceptor Lines to O'liare Plant
Ju.'ia 28, 1973 Letter from NSD President providing information re: farming
of waste treatment by-produ ts and retention basins south
__ cf'Northv/ost Toll way. C |0™ A4jMCawT TO SGrV^)
(Higgins basin of 135 acres to store overflow from Des
Plaines, Mt. Prospect and Arlington Heights combined
sanitary and storm sewers. Liquids in Basin would
~ • have to be 24 feel deep to store 3,300 acre-feet of
overflow.)
Ouly 2, 1973 Letter from Village Manager to NIPC concerning A-95 #73-124
(O'Hare Solids Pipeline to Salt Creek Plant) and A-95 #73-
125 (Northwest Liquid Fertili.-r Pipeline from SaU Creek
Plant to West/Southwest MSD Plant).
— Support both projects.
"ctober 3, 1973 Letter to NIPC re: A-95 #73-265 (Demonstration Grant for
putting O'Hare Plant entirely underground).
— Support and favor, but
— Proceed with a Plant to avoid sewage back-ups and
overflows.
~ . -- Particular caution requested in design and operation of
open-air retention and overflow basin in interest of
public health and public safety.
— ' -- However, it is unfortunate, unfair to delay the O'Hare
Plant any longer.
March 29, 1974, MSD letter to Elk Grove Village requesting permission and
an ordinance for the Oakton Street Interceptor line to
__ provide relief to the MSD lines in Oakton and Buss Road.
:ril 9,1974 Minutes of Village Board meeting reviewing need for the
— • O'Hare Plant and supporting Ordinance granting an easement
to MSD for an Interceptor lire in Oakton Street, Elk Grove
Village.
. ;ril 9,1974 Ordinance #920 granting easement, construction and maintenance
_ • rights to MSD for Oakton Street Interceptor.
6-178
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_ "2 —
April 23,
May 16,
December 2,
December 19,
Resolution #37-7** urging the Illinois Municipal League to
withdraw support from Des Plaines' efforts to delay construc-
tion of the O'Hare Plant.
— Support Home Rule but believe need for O'Hare Plant
to be of overriding importance.
Letter Village President to Alderman Ward, Des Plaines.
-- Appreciate your interest and your constituents' concerns.
— We believe the gsneral public need for the O'Hare Plant
transcends Ward's objections.
-- See no need to meet, but ask reconsideration by
Alderman Ward.
Letter to NIPC re: A-95 7^-603-
(Federal Grant to MSD for Step 1 Facilities Planning
for $9,000 of $12,000 study.)
-- 20 year sewage collection and treatment needs in
O'Hare basin area.
-- Support application.
Village Trustee Edward Kenna and Village Manager testified at
the MSD Public Hearing in Mt. Prospect on the Environmental
Assessment Statement to the effect:
-- O'Hare Plant is essential,
-- Parties in dispute should resolve differences,
-- Contemporary pollution control standards should be observed,
-- Public health requires that delays not be tolerated, and
— That the O'Hare Plant be built now.
January 2, Letter to NIPC re: A-95 1
1975 O'Hare Water Reclamation Plant Environmental Assessment Statement.
-- Supported the construction of the Plant and use of
environmental protection measures in its design and
eventual operation.
-- Supported the 'overflow' basin adjacent to Elk Grove
Village and recommended use of environmental protection
techniques to minimize adverse air quality conditions.
6-179
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January 31»
1975
January 2, Letter to NIPC re: A-95 7
1975 Solids Pipeline between the O'Hare Plant £ John Egan Plant
(via EGV).
-- Supported the 6.2 mile project ^s essential to a total
system of modern waste disposal.
-- Expressed belief that both dSD S its contractors will
exercise due consideratior when working on the 5.0 miles
of pipeline within Elk G jve.
Letter to NIPC re: A-95 7^-650;
-651
-652
-653
concerning Deep Tunnel facilities.
— Supported their construction,
-- And other improvements essential to a total system of
Waste Water Treatment.
March 31, Village of Elk Grove testified at the U.S. EPA Public Hearing
1975 in Des Plaines re: 'Environmental Impact Statements' about:
-- Deep Tunnel System. " _
— O'Hare Water Reclamation Plant.
' 6-180
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While a smaller plant was proposed in 1971 at a cost of
some $i|6 million, that cost ts now approaching $95,000,000. You know
where costs are going because you buy bread and eggs and milk at the
grocery store. This plant is no different to you and me, it is vital
to the public health of this total area, and, if it is not built soon,
its cost is simply go'\rj to go up, and you and I and others in this
District are going to pay for it.
We believe that the Metropolitan Sanitary District is
responsive to reasonable suggestions for the protection of the
environment. We still encourage the District to listen carefully
to the City of Des Plaines and to observe the environmental standards
being suggested. We would hope that if the proposed plant is not
successfully operated, that such modifications as made the Clavey
Park and Sacramento plants will also be carried out in the O'Hare
Plant.
6-181
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Finally -
Our position remains unchanged. But our interest in having
a modern waste water treatment plant is increasing. We believe it is
better to have sanitary sewage treated in a modern urban treatment
plant which has been designed and 'c operated at the highest most
reasonable standards of environmental protection possible, rather than
to continue to overload existing facilities with storm water to the
point where raw, untreated sanitary waste spills out on the streets,
in yards, and, yes, into the basements of private homes.
We continue to respect the concern of our sister municipality,
but it seems to us that raw sewage belongs in a modern treatment plant
and not in the basements and yards of private citizens.
Please, we urge you to proceed without further delay.
Thank you.
6-182
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RESOLD!I ON ]3-73
O'HflRr TREATMENT PLANT
WHEREAS: The Metropol itan Sanitary District of Greater Chicago is prepared
to construct the O'Hare Water Reclamation Plant at Elnihurst and
Oakton Roads, and
WHEREAS: The objections and concerns of an adjoining municipality have
been given considerable rttontion by the Metropolitan Sanitary
District both in Court and out of Court, and
WHERL'.AS: Said rev lev/, debate and legal proceedings have not only served
their purpose but have caused an inordinate delay in the
construction of a much needed public health service facility, and
WHEREAS: Further delay will serve little purpose but it v/ill create extras
hardship and increased public health hazards.
NOW, THEREFORE, BE IT RESOLVED by the President and Board of Trustees oT the
Village of Elk Grove Village that:
One: The Metropolitan Sanitary District proceed without further delay
to construct the O'Hare Water Reclamation Plant as planned for
the intersection of Oakton & Elmhurst Roads.
Two: The letter of February 13, 1973 from Charles J. Zettek, Village
President, to John E. Egan, President, Metropolitan Sanitary
District, be incorporated into and made'an official part of this
Resolution.
Three: Copies of this Resolution and the February 13 communication be
sent to the City of Des Plaines and others.
BE IT FURTHER RESOLVED that this Resolution shall take full force and effect
Trri;,! ;uH after it", passage and appro "1 ciccrding to lav;.
PASbL') '(HIS 2/lh day of February , 1973. AYES 6 NAYS 0_
APPROVED THIS 27th day of February , 1973.
ATTKT: ,
. /, • . •' - '/ /I ' '. / . 6-183
' - ' ' "
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CIIAK1 I S |. XI '[ 11 K , )
VllUj.r I Icil.
RICH \M> A M.f.KI XI K \
C1IAKI.LS A. V.'ll.l Is
l.l) 1.. (.1II f, M^ K
«)l:i.UI II. I.'. , MM.
I.'I)\V \KI) \V. r.l S'X \ \
(iF.oiu.r. '[' ^:-t.i<
THr.OiK)!;t~. |. SI \Dhl.
NANCY L. VANin.r^vi
February 13, 1973
Mr. John E. Egan, President
Metropolitan Sanitary District
of Greater Chicago
TOO East Erie Street
Chicago, Illinois 6C611
Dear Mr. Egan:
We have remained relatively silent with regard to the O'Hare
Sewage Trcotrn.cnt Plan and its ultimate construction at the southeast
corner of Oakton Street and Elrhorst Road in Des Plaines. V/e have done
so in respect for the Sanitary District and the City of DCS Plaines, as
well as to maintain our good neighbor standing and policy v/i th both
parties.
However, we now feel compelled to speak out on the matter.
We were painfully surprised to hear of Mayor Behrel's proposal that the
sanitary site be built on the south side of Oakton Street, west of Busse
Road. It is our understanding this proposal, if acted upon, would result
In an added delay of two or more years and would cost some additional
8 to 11 million dollars. Elk Grove Village cannot afford this considera-
tion being given any serious thought. The delay would cause to our
residents an increase in taxes and bring about unnecessary delay in the
resolvcrnent of sewage pollution and flooding in the eastern part of Elk
Grove. \,'e cannot and will not allow this to occur.
We wish to remind the Sanitary District of the Upper Salt Creek
Plant which is located adjacent to the western boundary of Elk Grove and
our complete cooperation and support of same. V/e have long recognized
the need to accept public responsibility, including cur share of facilities
which nay not always receive the. endorsement and applause of our residents.
V/e appreciate our need to ensure and provide for the public safety, health
and welfare of our residents. In the :nstance of the Upper Salt Creek
Plant, our support and .cooperation was given with pride and courage to
maintain a posture that was in the best interest of the general public.
Therefore, we rr.ust G.I behalf of the residents of Elk Grove
Village encourage you to proceed without further delay in the construction
of the O'Hare Treatment Plant at the southeast intersection of Oaktcn
and Clr.hurst Roads. To explore other sites would require further unwarranted
6-184
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Mr.
February 13,' 1573
delay in tin-c, increase the burden to the taxpayer and fail to r.ect
for thr icjh.t ly the responsibility for the rra i n teruir.ce of the public health,
Me support you and are ready and anxious to assist and/or cooperate with
you in any way which v/i 1 1 contribute to an early construction of the
O'Hare Treatment Plant as presently proposed.
Si nee re 1y yours /
CJZ:ins
Charles J
President
cc: Village Trustees
Vil lagc Clerk
Vi 1lage At torney
Vi 1 1 acje Manager
Vi 1 lage Eng i r.eer
Herbert Behrel, fiayor of Des Plaines
Trustees - Metropolitan Sanitary District of Greater Chicago
Nicholas J. deles, Vice President
.. - Joanne Al ter (!',rs .)
Joan G. Anderson (firs.)
Valentine Janicki
V/i 1 1 i am Jasku 1 a
James C. Kirie
Chester P. Majewski
John V/. Rogers
Acting General Superintendent Bart Lynam -
Metropolitan Sanitary District of Greater Chicago
V/illiam E. Shannon, EJk Grcve Village Plan Commission Ch.airnan
6-185
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MINUTES Of Till REGULAR Ml"III IMG OF
THE PRESIDENT AND BOARD Of TRUSTEES
OF THE VILLAGE OK ELK GROVE VILLAGE
HELD ON APRIL 9, 19"/"*
President diaries J. Zettck called I lie- meeting to order at 8:08 p.m. in the
Municipal Building, 901 Wellington Avenue, Elk Grove Village and directed the
Village Clerk, Eleanor G. Turner to coll the roll. Upon the roll being called
the following answered PRESENT: Trustees Ronald L. Chernick, George T. Specs,
Theodore J. Staddler, Michael Tosto, Nancy L. Vanderweel ; ABSENT: Trustee Edward
\l. Kcnna. Village Attorney, Edward. C. Hofert and village Manager, Charles A.
Willis were present at this meeting.
The Chief of Police, Harry P. Jenkins, dc'livered the invocation.
It v/as moved by Trustee Specs and seconded ' ,y Trustee Vande rwee 1 that the minutes
of the regular meeting of April 2, 197'* I (" approved as submitted and that the
Board dispense with the reading thereof. The motion was voted upon by acclamation;
whereupon the President declared the :notion carried.
President. Zettek issued a Proclamation, proclaiming the week beginning May 1, 197^
as Youth Week by the Benevolent and I'rotective Order of Elks, Lodge No. 2k23.
It v/as moved by Trustee Chernick and seconded by Trustee Tosto that the Board
authorize the disbursement of $17,'/'l8.55 from the Water and Sewer Department
Operating Account, $39,693.08 from the General Corporate Account, $29^.95 from
the Civil Defense Fund Account, and $P>,'tOO.OO from the Municipal Buildings
Construction Fund Account in payment of invoices as shown on the April 9, 197^
Accounts Payable V/arrant. The President directed the Clerk to call the roll on
the motion and upon the roll being called the following answered AYE: Trustees
Chernick, Spees, Staddler, Tosto, Vanderweel; NAYS: None; ABSENT: Trustee Kenna;
whereupon the President declared the motion carried.
It was moved by Trustee Chernick and seconded by Trustee Staddler that the Board
waive the first heading rule with respect to an ordinance making transfers among
appropriations. The motion was voted upon by acclamation; whereupon the President
declared the motion carried.
It was moved by Trustee Chernick and seconded by Trustee Staddler that the Board
adopt Ordinance No. 919 entitled " A,J ORDINANCE AUTHORIZING TRANSFERS AMONG
APPROPRIATIONS". The President directed the Cleric to call the roll on the motion
and upon the roll being called the following answered AYE: Trustee? Spees, Staddler,
Tosto, Vanderweel, Chernick; NAYS: None; ABSENT: Trustee Kenna; whereupon the
President declared the motion carried. __
It v/as moved by Trustee Tosto and seconded by Trustee Staddler that the' Board
waive the first reading rule with respect to an ordinance relating to installation
of a 60 inch sanitary sewer on Oakton Stieet. The motion was voted upon by accla-
mation; whereupon the President declared the motion carried.
It was moved by Trustee Tosto and seconded by Trustee Staddler that the Board
adopt Ordinance No. 920 entitled "AN ORDINANCE AUTHORIZING THE METROPOLITAN SANITARY
DISTRICT OF GREATER CHICAGO TO CONSTRUCT AND MAINTAIN A 60 INCH SANITARY SEVER
INTERCEPTOR ALONG OAKTON STREET FROM WILDUOOD ROAD EAST TO APPROXIMATELY ELMHURST
ROAD". The President directed the Clerk to call the roll on the motion and upon
the roll bning called tho following answred AYE: Trustees Staddler, Tosto
V.nderweel, Chernick, Spees; NAYS: None; ABSENT: Trustee Kenna; whereupon the
President declared the motion carried.
The Village Manager stated that the installation of the interceptor line on Oakton
Street is^onc of the most important improvements the Metropolitan Sanitary District
can make in the immediate area, the next most •, portant improvement is the proposed
O'Hare Water Reclamation plant which has been under consideration for many years.
One of the conitiunity needs is relief from the enormous back pressure on the existing
Metropolitan Sanitary District interceptor system adjacent to the Village. Tho back
pressure causes, on occasion, sanitary backups in .the Village, a problem the Village
has had for over three and a half years. The proposed interceptor line will relieve
and el iinin.ilc! th.it pressure entirely, and will result in the eventual elimination of
the Ridge Avenue Lift Station and other lift stations in the Village.
6-186
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RESOLUTION NO.
A RESOLUIION URGING CERTAIN ACTION BY THE ILLI'IOIS MUNICIPAL LEAGUE
REGARDING THE METROPOLITAN SANITARY DISTRICT OF GREATEf. CHICAGO
WHEREAS, the Village of Elk Grove Village is a member of the Illinois
Municipal League; and
WHEREAS, the Village of Elk Trove Village is within the jurisdiction of
the Metropolitan Sonitory District of Greater Chicago; and •
WHEREAS, on February 27, 1973, the Village adopted Resolution Ho. 1/-73 urging
the Metropolitan Sanitary District to proceed without further delay the construction
of the O'Hare Sanitary Sewage Treatment Plant; and
WHEREAS, the Village of Elk Grove Village was informed through the news
media that the Illirjis Municipal League has commenced active support of the
City of DesPlaines, Illinois in that city's efforts to prevent construction of
e sewage treatment plant at the southeast corner of Oskton Street and Elmhurst
Road; and
.WHEREAS, the expressed purpose of Illinois rVjnici pal Lesgue support is
based on the assumed right of the City of DesPlaines to exercise Municipal Home
Rule powers as represented in the Constitution of the State of Illinois and that
such home rule powers supercede Metropolitan Sanitary District jurisdiction; and
WHEREAS, the Village of Elk Grove Village considers iraied i ate construction^
of said sewage treatment plant to be vital in resolving sewage pollution and
flooding In Elk Grove Village and neighboring co~.'njni t ies.
NOW, THEREFORE, BE IT RESOLVED by the President and Board of Trustees of the
. «
ViHege of Elk Grove Village, Counties of Cook and'DuPage, State of Illinois, that
the Illinois Municipal League cease its support of the City of DesPlaines in that
city's dispute. with the Metropolitan San'tary District of Greater Chicago.
BE IT FURTHER RESOLVED by the President and Board of Trustees of the Village
of Elk Grove Village, Counties of Cook and DuPage, State of Illinois thdt the
Village of Elk Grove Village strongly supports h'o.'e Rule for Illinois Municipal-
ities, but considers the importance of the construction of the aforementioned
sewage treatment plant to be of overriding importance.
BE IT STILL FURTHER RESO.^tD, that a certified copy of this resolution be
distributed to the Executive Connittee of the Illinois Municipal League.
PASSED this 23rd day of __ Apr! 1 __ , 197*4.
' APPROVED this 23rd day of ___ ^JilLl— _ • '97^-
.Charles J. Zcttck
ATTtST: President
6-187
Ele.inot C. Turner
-------
RESOLUTION NO.
A RESOLUTION URGING THE METROPOLITAN SANITARY DISTRICT TO PROCEED WITH A
__ DEEP TUNNEL PLAN A^hTHE O'HARE TREATMENT PLANT
WHEREAS, urbanization has taken place in the Greater Chicago Metropolitan
Area, and -as a result thereof large areas which were formerly rtiarsh land
and lowland have been filled in and storm sewer system-s have been in:
stalled changing the character of the land and imposing excessive flows
on the rivers, streams, and creeks; and
WHEREAS, urbanization is continuing throughout tne drainage basin and
the adjacent states, counties, local communities and developers have pre-
viously failed to provide adequate collection and storage for storm water
and sanitary sewerage collection in new developments; and
WHEREAS, the people in and adjacent to the tillage of Mount Prospect and
neighboring communities are continuing to experience severe property
damage, hazards to health, and inconvenience; and
WHEREAS, the Village of Mount Prospect is presently served with an inade-
quate combined storm and sanitary sewer system owned and operated by the
Metropolitan Sanitary District; and
WHEREAS., the Metropolitan Sanitary District is currently studying the al-
ternate designs for the O'Hare Sewage Treatment Plant Interceptor System;
' and
WHEREAS, the deep tunnel system is an alternate design that will- have
great benefits to the Metropolitan Area and the Village of Mount Prospect
in the prevention of severe flooding by storm waters and sanitary sewerage;
and
WHEREAS, a solution to this property damage, hazards to health and incon-
venience rests in the Metropolitan Sanitary District's proposed O'Hare
Treatment Plant and implementation at the earliest date possible;
NOW, THEREFORE, BE IT RESOLVED BY THE PRESIDENT AND BOARD OF TRUSTEES OF
THE VILLAGE OF MOUNT PROSPECT, COOK COUNTY, ILLINOIS;
SECTION ONE: That the Metropolitan Sanitary District select the Deep
Tunnel System design and construct the O'Hare Treatment Plant and In-
terceptor System at the earliest -possible date.
SECTION TWO: That this Resolution shall be in full force and effect from
an'd after its passage and approval in 'the manner provided by law.
AYES: 5
NAYS: 0
PASSED AND APPROVED this 5th day of July _ ; __ , 1972.
ROBERT D. TEICHEIIT
Village President
ATTEST:
DONALD W. GOODMAN
Village Clerk
6-188
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r:a.-
STATE OF ILLINOIS
COUNTY OF COOK
ss
I, Marie T. Hard, do hereby certify that I am the duly
qualified and acting Deputy Clerk of the Village of Mount Prospect
1n the County and State aforesaid, and as such Deputy Clerk I am
the keeper of the records and files of the Board of Trustees of
said Village.
I do further certify that attached hereto is a full, true
and correct copy of RESOLUTION 14-72
duly adopted by the Board of Trustees of the Village of Mount
Prospect, Cook County, Illinois, at its legally convened meeting
held on the 5th day of July, 1972 , and that at the
time of adoption of said RESOLUTION 14-72
the Board of Trustees voted as follows:
• AYES: 6
NAYS: o '
ABSENT: '0
all as appears 1n the official records of said Village In my care
and custody,
Dated at Mount Prospect, Illinois, this 27th day of
March, 1972.
It-
!1
1
//UU ^ _^
Deputy C"U>rl
-------
RESOLUTION NO. 7-75
A RESOLUTION GRANTING A CERTAIN LICENSE TO THE
METROPOLITAN SANITARY DISTRICT OF GREATER CHICAGO
WHEREAS, Section 6(a) of Article VII of the 1970 Constitution of the State of -
Illinois provides that "any municipality \\.iich has a population of more than
25,000 (is) a Home Rule Unit" and the Village of Mount Prospect, Cook County,
Illinois, with a population in excess of 25,000 is, therefore, a Home Rule Unit
and may, under the power granted by said Section 6 (a) of Article VII exercise
any power and perform any function pertaining to its government and affairs;
and
WHEREAS, pursuant to such authority, the Mayor and Board of Trustees of the
Village of Mount Prospect have heretofore passed and approved an ordinance
amending the Mount Prospect Municipal Code of 1957, by adding thereto Sections
9.202 and 9.203 requiring certain approvals by the Mayor and Board of Trustees
of the Village of Mount- Prospect prior to certain work within certain areas of
the corporate limits of the Village of Mount Prospect; and
WHEREAS, the Metropolitan Sanitary District of Greater Chicago has requested
certain licenses, easements, rights, and authorities be granted it in order to
construct and maintain the "Tunnel and Reservoir Plan" as well as certain
conveyance facilities and appurtenances thereto.
NOW, THEREFORE, BE IT RESOLVED BY THE MAYOR AND BOARD OF TRUSTEES OF THE VILLAGE
OF M3UNT PROSPECT, COOK COUNTY, ILLINOIS:
SECTION ONE: That, subject always to the approvals required of Section 9.202
and Section 9.203 hereinabove mentioned as well as subject always to the
conditions hereinafter stated, the perpetual license, right, and authority be
and the same is hereby granted and given to the Metropolitan Sanitary District
of Greater Chicago (hereinafter referred to as "Sanitary District"), to construct,
reconstruct, repair, maintain, and operate the Tunnel and Reservoir Plan, Rock
Tunnels and Drop Shafts, Weller Creek, Central Road to Elmhurst Road and Elmhurst
Road, Upper Des Plaines No. 20, Contract 73-317-2S; Tunnel and Reservoir Plan,
Rock Tunnels and Drop Shafts, Weller Creek and Feehanville Ditch, Lonnquist
Boulevard and William Street, Upper Des Plaines 21, Contract 72-320-2S; Tunnel
and Reservoir Plan, Earth Tunnel, Weller Creek, Mount Prospect Road, Princeton
Street and Wolf Road, Upper Des Plaines 20-B, Contract 73-319-2S; and Tunnel
and Reservoir Plan, Connections and Laterals, Weller Creek, Various Locations,
Upper Des Plaines 20A, Contract 73-318-2S; together with the appurtenances thereto,
hereinafter designated as "Coneyance Facilities" upon, under and through those
certain streets, highways, public lands, public rights-of-way, and public ease-
ments of the Village of Mount Prospect, (hereinafter referred to as "The Village")'
within the territorial limits of The Village traversed by said Conveyance
Facilities, which rights-of-way within said territorial limits are shown upon
a map attached hereto and hereby made a part hereof as Exhibit "A" and which
rights-of-way are described as follows to wit.
That portion of Elmhurst Road lying within the corporate limits
of the Village of Mount Prospect bounded on the South by Dempster
Street and on the North by Council Trail: the West Half (1/2) of
Elmhurst Road bounded on the North by a point approximately 720 feet
South of the center line of Dempster Street and on the South by
6-190 ,
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Oakton Street; those portions of Council Trail, and Mknawa Trail,
bounded on the East by Elmhurst Road and on the West by We-Go Trail
(extended); and that portion of Keller Lane bound on the North by
Central Road and on the Soutli by a point approximately 417 feet
South of the South line of C3even Avenue in Sections 23, 14,13,12 ^id 11
in Township 41 North, Ram;e 11, East of the Third Principal Meridian
and also in Section 33, i\,vvnship 42 North, Range 11, East of the
Third Principal Meridian, Cook County, Illinois; and also
That portion of Lonquist Boulevard between Elmhurst Road and a
point approximately 1?0 feet East of the East line of Albert Street
in Sections 12 an;" j.3, Towm>hiD 41 North, Range 11, East of the Third
Principal Meridian, Cook County, Illinois; and that portion of
William Street between Lonriquist Boulevard and Isabella Street in
Section 12, Township 41 North, Range 11, East of the Third Principal
Meridian, -r,•'• in Section 34, Township 42 North, Range 11, East of the
Third Principal Meridiem, al] in Cook County, Illinois, and also that ,
portion of .sabella Street between William Street and Edward Street
extended :;nd that portion oi Gregory Street between Rand Road and a
point SOS. 00 fc-et ):.ast of the Uest line of Section 35-42-11, all in
Sections 34 arid 35, Township 42 North, Range 11, East of the Third
Principal Meridian, Cook County, Illinois; and also
That portion of the West Half (1/2) of Mount Prospect Road
between a point approximately 250 feet South of the South line
of Prospect Avenue and the South line of Milburn Avenue in
Section 12, Township 41 North, Range 11, East of the Third
Principal Meridian, Cook County, Illinois; and also
That portion of Lincoln Street between Weller Creek and
Kenilworth Avenue in Section 11, Township 41 North, Range 11,
East of the Third Principal Meridian, Cook County, Illinois;
and also
That portion of Central Road between Weller Creek and Bobby
Lane in Section 11 of Township 41 North, Range 11, East and
Section 33 of Township 42 North, Range 11, East of the Third
Principal Meridian, Cook County,'Illinois; and. also
Those portions of Can-Dota Avenue, Na-Wa-Ta Avenue and See-Gwun
Avenue between Council Trail and Manawa Trail in Section 11,
Township 41 North, Range 11, East of the Third Principal Meridian,
Cook County, Illinois; and also
That portion of We-Go Trail not heretofore vacated by the Village
of Mount Prospect which lies between Shabonee Trail and Manawa
Trail in Section 11, Township 41 North, Range 11, East of the
Third Principal Meridian, Cook County, Illinois; and also
Those portions of Manawa Trail between Na-Wa-Ta Avenue and Wapella
Avenue and between I-Oka Avenue extended and Elmhurst Road in
Section 11, Township 41 North, Range 11, East of the Third
Principal Meridian, Cook County, Illinois; and also
That portion of William Street lying within the intersection of
Berkshire Lane and Weller Creek in Sections 12 and 13, Township 41 .
North, Range 11, East of the Third Principal Meridian, Cook County,
Illinois.
SECTION TOO: That the location, size, and manner of construction of the
Conveyance Facilities shall be in accordance with plans and specifications
prepared by the Sanitary District, as approved by the Mayor and Board of
6-191
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Trustees of the Village of Mount Prospect.
SECTION THREE: That the rights hereby granted to the Sanitary District are so
granted upon- the following conditions:
A. That the Sanitary District shall, at its own expense, make
such changes in the location of the police and fire alarms
and street lighting, and electric wires of The Village as
may be rendered necessary by the construction of the
Conveyance Faci'Jties of the Sanitary District.
B. That the Sanitary District shall, at its cost and expense,
install all such safety devices and traffic control signals
as may become necessary and required by The Village for the
public convenience, health and safety, as a result of any
routing or rerouting of traffic caused by the construction
contemp ated in this Resolution,
C. That the Conveyance Facilities of the Sanitary District
shall be constructed, reconstructed, repaired, and efficiently
maintained and operated solely by the Sanitary District at its
sole expense and cost; and The Village shall not be held
responsible in any manner for the location or manner of
construction, reconstruction, repair", or operation of the same.
D. That the Sanitary District shall defend, protect, indemnify,
keep and save harmless The Village, its Mayor, Trustees, officers,
agents, employees, contractors and sub-contractors and/or their
employees against all claims for damage to real and personal
property as well as against all injuries, liens", suits, liabilities,
judgments, costs, expenses, and attorneys fees .suffered and/gr *.
incurred by The Village, its Mayor, its Trustees, its officers,
its agents, its employees, its contractors and sub-contractors
and/or their employees, and/or its citizens which claims, injuries,
deaths, losses, damages, liens, suits, liabilities, judgments,
costs, expenses, and attorneys fees may directly or in-
directly be incurred, suffered, and/or arise by or from the
construction, reconstruction, repair> maintenance and/or operation
by the Sanitary District of the Conveyance Facilities. The
Sanitary District shall defend, indemnify, and hold The Village
and/or citizens thereof harmless from any and all liability,
cost, or expense resulting from the failure of the Sanitary
District to keep and perform the foregoing covenant.
B. That the Sanitary District shall, at its sole cost and expense,
restore to their former condition of usefulness the pavements
of all streets, public alleys and highways, as. well as all other
structures, shrubs, trees and sod which may be disturbed or
interfered with or damaged by the construction, maintenance,
repair, -or operation of the Conveyance Facilities, as well as
all walks, crosswalks, curbs, gutters, catch basins, and ditches
as soon as practicable, and shall thereafter maintain such
restoration from ^.ime to time as may be necessary, but not to
exceed two (2) years. All surplus excavation and other spoil
shall be removed from the paved streets, public alleys, and high-
ways by the Sanitary District.
F. That The Village does hereby order and direct all persons,
partnerships, or corporations which shall at the time of the
6-193
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ccnstruction of the Conveyance Facilities cum, operate or maintain
, any conduits, wires, poles, pipes, gas mains, cables,electric, I
\l steani' and street railway tracks and equipment or other St.. jctures
|! within any portion of the streets, public alleys and highways to
6e excavated in the construction of the Conveyance Facilities, at
is, its, or their own expense, to make such changes in the j
,| location of such conduits, wires, poles, pipes, gas mains >
'i ' and cables, electric, steam and street railway tracks;, and ;
equipment or other structures as may be rendered necessary by '
the construction of the Conveyance Fpcilities. \
G. That the Sanitary District and its contractors are hereby given
and granted the right to use in the construction of the
Conveyance Facilities such mot jr trucks, excavators, hoisting
engines, and other plant, equipment and materials as may be
necessary for the complete construction of said work,
H. That the Sanitary District shall, at its own expense and cost,
make such alterations in the location of the water mains of The
Village as may be rendered necessary by the construction of the
Conveyance Facilities ;f the Sanitary District. And in all such
cases, where it shall become and be necessary that water service
pipes be removed, cut off, or damaged in any way on account of
the construction of the Conveyance Facilities, the Sanitary
District shall remove, alter, repair, and replace such water
service pipes at its own cost and expense, providing.any water
service pipes disturbed shall be replaced by the Sanitary District;
provided, however, that all work done on said water mains and
water service pipes shall be subject to the approval of the
Village Engineer.
I. That The Village shall give, grant, and issue without fees or cost
therefor, to the Sanitary District or to any contractor to whom
this work or any part thereof specified in this Resolution shall
be awarded, all permits or licenses required for doing said work
upon application and shall not require the Sanitary District or
its contractors to deposit any sums of money required under any
ordinance of The Village for similar work and, further, shall not
require the payment by the Sanitary District of any fees or
salaries for inspectors employed by The Village on said work.
Water shall not be furnished the Sanitary District or any
contractor to whom said work or any part thereof shall be awarded,
unless and until construction meters have been paid for by the
Sanitary District and then all water needed in the performance of
said work shall be paid for by the Sanitary District, at the then
regular rate charged by The Village to its consumers, all said
water to be measured through meters furnished as aforesaid by
the Village at the expense of the Sanitary District or its
contractors.
SECTION FOUR: That this Resolution shall, be in full force and effect from and
after its passage and approval in the manner provided by law.
AYES: S
NAYS: °
PASSED and APPROVED this /f day of FE&G.O*&Y , 1975.
/s/ Robert 1). Tcichcrt
Mayor
6-194
ATTEST:
VnTagc Clerk
-------
. J
) SS
STATE OF ILLINOIS
COUNTY OF COOK )
I, DONALD W. GOODMAN, do hereby certify that I am the duly qualified
and acting Village Clerk of the Village of Mount Prospect in the County
and State aforesaid, and as such Village Clerk I am the keeper of the
records and files of the Board of Trustees of said Village.
I do further certify rhat attached hereto is a full, true and correct
copy of RESOLUTION NO. 7-75 duly adopted by the Board of Trustees of the
Village of Mount Prospect, Cook County, Illinois, at its legally convened
meeting held on the 18th day of February, 1975, and that at the time of
adoption of said RESOLUTION NO. 7-75 the Board of Trustees voted as
follows:
AYES: 5
- NAYS: 0 •
ABSENT: 1
all as appears in the official records of said Village in my care and
custody.
Dated at Mount Prospect, Illinois, this 4th day of.March, 1975. ^
Village Clerk, Village of Mount Prospect
Cook County, Illinois
6-195
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T H l_ CITY O f- G O O D N E I G II 13 O R S
Village of Arlington Heights
MUNICIPAL BUILDING • 33 S. ARLINGTON HEIGHTS ROAD 60005
Area 312/253-2340
STATEMENT IN SUPPORT OF THE NEW
SEWAGE COLLECTION AND TREATMENT FACILITIES
PROPOSED FOR THE NORTHWEST SUBURBS BY THE
METROPOLITAN SANITARY DISTRICT OF GREATER CHICAGO
MAr^II 31, 1975
THE ARLINGTON HEIGHTS VILLAGE BOARD HAS VOTED UNANIMOUSLY
TO SUPPORT THE PROPOSAL BY THE METROPOLITAN SANITARY DISTRICT OF
GREATER CHICAGO TO CONSTRUCT A DEEP TUNNEL SEWAGE COLLECTION SYSTEM
AND A NEW SEWAGE TREATMENT FACILITY FOR THE NORTHWEST SUBURBS. THE
PROPOSED SYSTEM WILL IMPROVE THE ENVIRONMENT IN ARLINGTON HEIGHTS
BY PREVENTING THE BACKUP AND FLOODING OF COMBINED SEWAGE AND RAIN
WATER INTO RESIDENTIAL BASEMENTS AND STREETS DURING HEAVY RAIN
STORMS. SUCH FLOODING HAS OCCURRED PERIODICALLY FOR MANY YEARS IN
ARLINGTON HEIGHTS AND HAS BEEN HAZARDOUS TO THE HEALTH AND WELL-
BEING OF OUR CITIZENS. THE SEWAGE BACK-UP IS LARGELY DUE TO THE HIGHLY
INADEQUATE SEWAGE COLLECTION AND TREATMENT FACILITIES WHICH NOW EXIST.
THE PROPOSED NEW DEEP TUNNEL SYSTEM AND THE SEWAGE TREATMENT
FACILITY WILL ALSO PREVENT THE PERIODIC POLLUTION OF WELLER CREEK,
WHICH OCCURS WHEN COMBINED SEWAGE AND RAIN WATER OVERFLOW INTO
WELLER CREEK DURING EVEN MODERATE RAIN STORMS. THE POLLUTION OF
WELLER CREEK CAUSES A PERSISTANT ODOR PROBLEM ALONG WELLER CREEK
AND IS HIGHLY DETRIMENTAL TO THE ENVIRONMENT OF THE RESIDENTS NEAR
THE CREEK.
THE VILLAGE BOARD OF ARLINGTON HEIGHTS BELIEVES THAT THE
PROPOSED NEW DEEP TUNNEL SYSTEM AND SEWAGE TREATMENT FACILITY
SHOULD BE CONSTRUCTED AS SOON AS POSSIBLE TO OVERCOME THE HAZARDS
OF FLOODING AND POLLUTION WHICH ARE NOW BEING EXPERIENCED IN THE
ARLINGTON HEIGHTS AREA.
RESPECTFULLY SUBMITTED,
FRANK PALMATIER,
VILLAGE TRUSTEE
CHAIRMAN, FINANCE COMMITTEE
CHAIRMAN, CITIZENS ACTION
COMMITTEE AGAINST FLOODING
6-196
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April
Mr. Francis T, Mayo
U. S. Environmental Protection Agency
230 South Dearborn
Chicago, Illinois 6060^
Dear Mr. Mayoi
C
The attached petitions were presented to Congressman Crane's
Administrative Assistant at the March 31t 1975 USEPA Public
Hearing and are now being submitted as comment on your draft
Environmental Impact Statement. Please incorporate the peti-
tions into the final EIS document.
The petitions were circulated by the following citizens in the
Devonshire and Waycinden areasi
Pat Lutsch
Pat Alfano
Alice DeSilvia
Sorrell Pischke
Diane Ruh
Sandy Gualano
Jean Arredia
Judy Janczak
Nancy Janczak
Karen Frahtn
Terry Lipa
Toni Burdi
Camille Dressel
Loretta Anthony
Fay Butler
Dolores Hermansen
Virginia Lonigro
Audrey Munger
Pat Yaccino
Ann Yurkiewicz
Lucille DiCianni
Barbara Davison
Norma Kalb
Angie Cozzi
Virginia Respond
Ann Randall
Shirley Campanella
Ilene Arshonsky
Diane Losinski
Florence Adamczyk
Stacia Choroznak
Gerry Francione
Dolores Leuthner
Al Barry
Don Dvorak
Pete Lazzara
Richard Brown
William Kent
Michael Opager
David Cox
Donald Argus
Robert Argus
Martin Cain
Dan Lutsch
Allen Dvorak
David Cox
Jim Conrad
Gregg Ochab
John Jamrozik
Jack Wilds
David Wilds
Brian Friberg
We anticipate your objective consideration of the OfHare structure.
Thank you.
Very truly yours,
Rosemary Argus
^95 Courtesy Lane
Des Plaines, Illinois 60018
6-197
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\ 4* 0 • ^ ttllMrt I *"»«. -r
. . »»•-—
Petition to the Honorable Philip M. Crane
Congressman 12t'h Congressional District
WHEREA'S the Metropolitan Sanitary District of Greater
Chicago is proposing to construct a sewage treatment plant
having a capacity approaching 100 million gallons a day and
described as the O'Hare Water reclamation Plant in surburban
Cook County within the City of Des Plaines and within the
12th Congressional District;
WHEREAS the residents of the area and the City of Des
Plaines have opposed location of such plant at the proposed
site for at least eight years because of the dangers to the public
health and the odor nuisances associated with such plant;
WHEREAS the Sanitary District has publically indicated that
in building the proposed plant it will not take the necessary
precautions to limit the emissions of odor or air-borne pathogenic
bacteria from the plant so as to avoid a serious hazard to public
»
health; and
WHEREAS the Sanitary District is now seeking Federal funds
to construct such plant;
NOW THEREFORE, we, the undersigned, hereby petition you to
.to take all necessary steps to prevent the expenditure of
Federal funds for the construction of the proposed plant which
will create a potential threat to the public health and par-
ticularly to the citizens now living within the immediate area
of the proposed plant.
Name Address
U"
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CHAPTER 7
SELECTED REFERENCES
Adams, A. P. and J. D. Spendlove, 1970. Coliform Aerosols Emitted by
Sewage Treatment Plants. Science 169:1278
Albrecht, C. R. 1958. Bacterial Air Pollution Associated with the
Sewage Treatment Process. Master's Thesis, University of
Florida.
Alvoro, Budick and Howson, 1969. Report Upon Adequate Water Supply for
the Chicago Metropolitan Area, 1969-2000.
Argonne National Laboratory, Energy and Environmental Systems Division,
1973. Airport Vicinity Air Pollution Study.
Bauer Engineering, Inc. 1973-A. Environmental Assessment, Alternative
Management Plans for Control of Flood and Pollution Problems Due
to Combined-Sewer Discharges in the General Service Area of the
Metropolitan Sanitary District of Greater Chicago.
Bauer Engineering, Inc. 1973-B. Preliminary Draft Environmental Impact
Statement, A Plan for Control of Flood and Pollution Problems
Due to Combined-Sewer Discharges in the General Service Area of
the Metropolitan Sanitary District of Greater Chicago.
Baum and Parker, 1974. Solid Waste Disposal, V.I. Ann Arbor Science
Publishers, Inc.
Bielenberg, D. and T. Hinesly, 1970. The Basin Plan. Metropolitan
Sanitary District of Greater Chicago.
Brown and Caldwell, 1968. Design Report, O'Hare Reclamation Plant.
Metropolitan Sanitary District of Greater Chicago.
Burd, R. S., 1966. A Study of Sludge Handling and Disposal.
Federation of Water Pollution and Control.
Burd, R. S., 1968. A Study of Sludge Handling and Disposal, Federation
Water Pollution Control Administration, Pub. WP-20-4.
Camp, Dresser and McKee, Salt Creek Report for the Metropolitan Sanitary
District of Greater Chicago.
7-1
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SELECTED REFERENCES
Consoer, Townsend, and Associates, 1973. Mount Prospect 1973 Flood
Control Report.
Csallany, S. and W. C. Walton, 1963. Yields of Shallow Dolomite Wells
in Northern Illinois, Illinois State Water Survey, Report of
Investigation No. 46.
DeLeuw, Gather, and Co. 1972. preliminary Plans for O'Hare Collection
Facility, Conventional Intercepting Sewers and Tunnel and Reservoir
Plan.
DeLeuw, Gather and Co., Geotechnical Report on Upper Des Plaines Tunnel
and Reservoir Plan, V. 2.
Dowling, H. F. 1966. Airborne Infections - the Past and the Future.
Bact. Rev. 30:485.
Druett, H. A. and K. R. May, 1968. Unstable Germicidal Pollutant in
Rural Air.Nature 220:395.
Fair, G. M. and W. F. Wells, 1934. Measurement of Atmospheric Pollution
and Contamination by Sewage Treatment Works. Proc. 19th Ann. Mtg.
N. Y. Sewer Works Association 1934.
Federation of Sewage Works Association, 1946. Manual of Practice,
Utilization of Sewage Sludge as Fertilizer.
Flood Control Committee, August, 1972. Summary of Technical Reports,
Development of a Flood and Pollution Control Plan for the
Chicagoland Area.
Foundation Sciences, Inc., 1974. Geotechnical Report on Upper Des Plaines
Tunnel and Reservoir Plan, Contracts 73-317-2S, V.I. Bedrock
Geologic Investigation for DeLeuw, Gather, and Company.
Greeley and Hansen, Report on Basic Data.
Herr, G. A., 1973. Odor Destruction - A Case History. Paper presented
at the 66th Annual AICHE Meeting, Philadelphia, Pa., November 13, 1973.
7-2
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SELECTED REFERENCES
Herr, E and R. L. Potorak, 1974. Program Goal - No Plant Odors. Water
and Sewage Works, October, [974.
Herzik, G. R. 1958. From Effluent to Alfalfa: Texas Approves Irrigation
of Animal Crops with Sewage Plant Effluents. Wastes Engineering
27:418.
Higgins, F. B. 1964. Bacterial Aerosols from Bursting Bubbles. Doctoral
Dissertation, Georgia Tech.
Hinesly, T. and B. Sosewitz, 1968. Digested Sludge Disposal on Crop
Land. Paper presented at Water Pollution Control Federation
Conference, Chicago, Illinois.
Kenline, P., 1968. The Emission, Identification and Fate of Bacteria
Airborne From Activated Sludge and Extended Aeration Sewage
Treatment Plants. Doctoral Dissertation, University of Cincinnati,
Ohio.
Koenig, L., October 1973. Ultimate Disposal of Advanced - Treatment
Wastes. AWTR - 3.
Ladd, F. C., 1966. Airborne Bacteria from Liquid Waste Treatment Units.
Master's Thesis, Oklahoma State University.
Ledbetter, J. 0., 1964. Air Pollution from Aerobic Waste Treatment.
Water Sewage Works 111 (l):62-63.
Ledbetter, J. 0. and C. W. Randall, 1965. Bacterial Emissions from
Activated Sludge Units. Ind. Med. and Surg. 34 (2):130-133.
Lightheart, B., 1973. Survival of Airborne Bacteria in a High Urban
Concentration of Carbon Monoxide. Appl. Micr. 25(1):86-91.
Magill, P., F. Holden and C. Ackley, 1956. Air Pollution Handbook.
McGraw-Hill, New York.
May, K. R. ejt.a.1., 1969. Toxicitv of Open Air to a Variety of Micro-
organisms. Nature 221:1140-1147.
Melnick, J. L., 1967. Comment on D. M. McLeans paper, Transmission of
Viral Infections by Recreational Water. In Trans Virus by the Water
Route, ed. G. Berg, Interscience Publisher, New York.
7-3
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SELECTED REFERENCES
Metropolitan Sanitary District of Greater Chicago, Engineering Department
1971. Utilization of Liquid Fertilizer.
Metropolitan Sanitary District of Greater Chicago, 1972. The Beneficial
Utilization of Liquid Fertilizer on Land.
Metropolitan Sanitary District of Greater Chicago, 1973-A. Environmental
Assessment of the Prairie Plan-Fulton County, Illinois.
Metropolitan Sanitary District of Greater Chicago, 1973-B. Fortieth
Annual Report.
Metropolitan Sanitary District of Greater Chicago, October, 1974.
Evaluation of Mechanical Dewatering Facility for Project 73-181-2p
at West-Southwest Sewage Treatment Works, Pro Fac, MSDGC.
Metropolitan Sanitary District of Greater Chicago, November, 1974.
Environmental Assessment for Proposed Projects for the Upper Des
Plaines Service Basin, O'Hare Tunnel System.
Metropolitan Sanitary District of Greater Chicago, December, 1974.
Facilities Planning Report. MSDGC Overview Report.
Napolitano, P. J. and D. R. Rowe, 1966. Microbial Content: of Air Near
Sewage Treatment Plants. Water and Sewage Works 113:12.
Northeastern Illinois Metropolitan Area Planning Commission, 1966. The
Water Resource in Northeastern Illinois, Planning tts Use. Technical
Report No. 4.
Northeastern Illinois Planning Commission, 1971. Regional Wastewater Plan.
Northeastern Illinois Planning Commission, September, 1974. Regional Water
Supply, Report No. 8.
Peterson, R. J. and Associates, 1973. A Report on Flood Control of
Arlington Heights, Illinois.
Poon, C. P., 1966. Studies on the Instantaneous Death of Airborne
Escherichia coll. Am. J. Epidemiology 84(1):l-9.
Poon, C. P. 1968. Viability of Long-Storage Airborne Bacterial Aerosols.
J. Sanitary Eng. Div. ASCE. 94(SA6):1137-1146.
7-4
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SELECTED REFERENCES
Randall, C. W. and J. 0. Ledbetter, 1966. Bacterial Air Pollution
4 from Activated Sludge Units. Am. Ind. Hygiene Assoc. J. 27:506-519.
\ Roy F. Weston, Inc., 1971. Process Design Manual for Upgrading Existing
f Wastewater Treatment Plants. EPA Technology Transfer.
Sanitary District of Los Angeles County. Composting Studies at the
County.
Sasman, R. T. et^-al_- 1973. Water-Level Decline and Pumpage in Deep Wells
in Northeastern Illinois. Illinois State Water Survey, Circular 113.
Schicht, R. J. and A. Moench, 1971. Projected Groundwater Deficiencies
in N. E. Illinois, 1980-2020. Illinois State Water Survey,
Circular 101.
Spendlove, S. c., 1957. Production of Bacterial Aerosols in a Rendering
Plant Process. Public Health Reports 72:176-180.
State of Illinois, Department of Transportation, 1973. Summary of Local
Planning Documents in Illinois.
State of Illinois, Environmental Protection Agency, 1971. Water Quality
Network, Summary of Data, V. 2.
State of Illinois, Environmental Protection Agency, March 7, 1972.
Water Pollution Regulations of Illinois.
State of Illinois, Pollution Control Board, July, 1973. Rules and
Regulations, Chapter 3.
Stone, R., 1974. Sewage Sludge Processing, Transportation, and Disposal.
Paper presented at Am. Soc. of Civil Engineers on Water Resources
Engineering, Jan. 21-25, 1974.
U.S. Army, Corps of Engineers, November, 1973. Draft Environmental
• Assessment on Tunnel and Reservoir Plan.
U.S. Army,Corps of Engineers, Chicago District, April, 1974. Summary
Report, Wastewater Management Study for Chicago-South End of Lake
Michigan. (C-SELM).
U.S. Department of Commerce, Bureau of the Census, 1970. Census of
Population, Numbers of Inhabitants, Illinois. Pub. PC(1)A15-I11.
7-5
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SELECTED REFERENCES
U.S. Department of Commerce, National Ocoanic and Atmospheric Adminis-
tration, Environmental Data Service, 1973. Local Climatological
Data, Chicago, Illinois, O'Hare Irternational Airport.
U.S. Environmental Protection Agency, March, 1974. Alternative Waste
Management Technique for Best Practicable Waste Treatment.
U.S. Environmental Protection Agoncy, October, 1974. Process Design
Manual for Sludge Treatment and Disposal.
U.S. Environmental Protection Agency Task Force, March, 1972. Sewage
Sludge Incineration. EPA Task Force No. PB211-323.
Walker, John £jt.aA. Sludge Disposal Studies. U.S. Department of
Agriculture, Beltsville, Maryland.
Walton, W. C., 1964. Future Water-Level Declines in Deep Sandstone Wells
in Chicago Region. Illinois State Water Survey. Reprint series No.36.
Wascher, H. L. e_t.si.l. 1960. Characteristics of Soil Associated with
Glacial Tills in Northeastern Illinois. University of Illinois
Agricultural Experiment Station, bulletin 665.
Webb, S. J. _et^.3tl_. 1963. The Effects of Relative Humidity and Inositol
on Airborne Viruses. Can. Jour. Micro. 9:87-92.
Wells, W. N. 1961. Irrigation as a Sewage Reuse. Pub. Works 116:118.
Winklepleck, R. G. 1973. Particulate Collection by Scrubbing. Water
and Wastewater Engineering.
Won, R. D. and H. Ross, 1969. Reaction of Airborne Rhizobium mellloti
to Some Environmental Factors. Appl. Micr. 18:555-557.
Woodcock, A. H. 1955. Bursting Bubbles and Air Pollution. Sewage Ind.
Wastes 27:1189.
Zetner, R. J. 1966. Physical and Chemical Stresses of Aerosolization.
Bacterial Review 30(3):551-558.
Metropolitan Sanitary District of Greater Chicago, 1975. Transcript
of Public Hearing, O'Hare Sewage Collection System, plus Additional
Statements and Testimony and Response by the Metropolitan Sanitary
District of Greater Chicago, V.I-III.
7-6
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SELECTED REFERENCES
City of Des Plaines, Illinois, 197^. An Ordinance Amending Title VIII
of the City Code by Adding Chapter 15 Entitled "Health and Welfare
Standards for Waste and Sewage Treatment Plants and Works" M-23-74.
Metcalf and Eddy, October, 197'+. Process Design Manual for Upgrading
Existing Wastewater Treatment Plants.
Metropolitan Sanitary District of Greater Chicago, Engineering Department.
January, 1974, December, 1974. Infiltration-Inflow Analysis, Upper
Des Plaines Service basin (O'Hare Water Reclamation Plant).
7-7
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