METROPOLITAN SANITARY DISTRICT
           GREATER CHICAGO
O'HARE WATER RECLAMATION PLANT
   ENVIRONMENTAL IMPACT STATEMENT
               MAY 1975
                Prepared by:
     US ENVIRONMENTAL PROTECTION AGENCY
                REGION V
               Chicago, Illinois

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         FINAL ENVIRONMENTAL  IMPACT  STATEMENT


                          FOR  THE


   METROPOLITAN  SANITARY  DISTRICT  OF GREATER CHICAGO


      DES PLAINES - O'HARE WATER RECLAMATION PLANT


                  AND  SOLIDS  PIPELINE
                     PREPARED  BY  THE


     UNITED STATES  ENVIRONMENTAL  PROTECTION AGENCY

                        REGION V

                     CHICAGO,  ILLINOIS
                         VOLUME  I
                                     APPROVED  BY:
               .  i protection
U>s. Environmental ?rox

Lion 5,     *™        °°* 1670
    S-
FRANCIS T. MAYO
REGIONAL ADMINISTRATOR

MAY 1975

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                             SUMMARY SHEET


1.  Name of Action (Check One)

    Administrative Action (X)
    Legislative Action    ( )

2.  Brief description of action indicating what States (and Counties)
    are particularly affected.

    The proposed O'Hare Water Reclamation Plant (WRP) is designed as a

two stage process in which carbonaceous biochemical oxygen demand (BOD)

and ammonia-nitrogen are removed in two separate sets of aeration and

sedimentation tank modules.  Final effluent polishing and disinfection

are to be accomplished by dual media filters and injection of sodium

hypochlorite.  Post-aeration is to be employed to raise the dissolved

oxygen content of the plant effluent prior to discharge to Higgins Creek.

Process solids remaining would be transported via a pipeline to the MSDGC

Salt Creek WRP for further treatment.

    The proposed Water Reclamation Plant will receive sanitary and com-

bined sewage flows via a deep tunnel conveyance system (see the EIS on the

Des Plaines-O'Hare Conveyance System) from the following communities:

Arlington Heights, Buffalo Grove, Des Plaines, Elk Grove Village, Mount

Prospect, Prospect Heights, Rolling Meadows, and Wheeling, Illinois.  The

O'Hare Service Area is located in Cook County, Illinois.

3.  Summary of environmental impact and adverse environmental effects.

    A.  Construction Impacts

        1)  Air Quality

            Dust resulting from construction activities will be minimized

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         by using hard paved surfaces and dust control measures.




     2)  Operation of construction equipment powered by internal




         combustion engines will temporarily add to the air pollutant




         loading.  It is not anticipated that this would result in a




         significant temporary change in ambient air quality.




     3)  Water Quality and Quantity




         Increased siltation and temporary flow interruption may occur




         during relocation and channelization of Higgins Creek.




     4)  Noise and Vibration




         Heavy machinery, trucks and other vehicles will be operated




         during hours which cause minimum disturbance to residential




         area.




B.   Operational Impacts




     1)  Air Quality




         a)  Occasional odors may be detected from the proposed WRP.




         These are expected to be infrequent due to odor control




         measures and the absence of sludge processing facilities.




         b)  The Water Reclamation processing facilities, will generate




         a limited quantity aerosols containing bacteria and virus parti-




         cles.  The present state of knowledge indicates that there is no




         demonstratable health hazard associated with these aerosols.




         (See Chapters 3,5, and the Appendices for detailed discussion).




         However, as a precautionary measure to mitigate the potential




         health hazard risk we shall require that the MSDGC design, con-




         struct and maintain facilities to adequately suppress, to the




         satisfaction of IEPA and USEPA, the movement of aerosols,




         emanating from the aeration tanks on the proposed site.
                               ii

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       2)  Water Quality and Quantity Impacts

           a)  The proposed WRP is designed to discharge a high quality

           effluent of BOD5 (4 mg/1) SS(5mg/l) and NH3~N (1.5 mg/1).   The

           effluent flow in the design year is projected to be 72MGD.

           b)  Combined sewage overflows to Weller's Creek and Feehanville

           Ditch will be reduced from approximately 80 to 6 flows a year.

           This will result in a 92% BOD reduction and 75% flow reduction

           in combined sewage waste overflows.  The high percentage of

           BOD reduction is achieved through capture of the "first flush"

           storm flows.

4.  Alternatives Considered

    a)  Service Area Alternatives
    b)  Capacity of the Proposed WRP
    c)  Nine site locations for the WRP
    d)  Underground, at grade, and at grade covered facilities
    e)  Sewage treatment processes
    f)  Sludge processes and disposal alternatives

5.  The follwing Federal State and local agencies have been requested

    to comment on the  Draft Environmental Impact Statement:

                Council of Environmental Quality
                Department of Agriculture
                  Soil Conservation Service
                U.S. Army Corps of Engineers
                  North Central Division
                  Chicago District
                Department of Health, Education and Welfare
                Department of Housing and Urban Development
                Department of the Interior
                  Bureau of Outdoor Recreation
                  Fish and Wildlife Service
                  Geological Survey
                Department of Transportation
                  Federal Aviation Administration
                Energy Research and Development Administration
                  Argonne National Laboratory
                             iii

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                     Governor of Illinois
                     Illinois Environmental Protection Agency
                     Illinois Institute for Environmental Quality
                     Illinois Division of Waterways
                     Illinois Department of Conservation
                     Illinois Department of Public Health

                     Northeastern Illinois Planning Commission
                     Cook County Department of Environmental Control
                     Metropolitan Sanitary District of Greater Chicago

                     City of Des Plaines
                     Village of Elk Grove
                     Village of Arlington Heights
                     Village of Mount Prospect
                     Village of Palatine
                     Village of Wheeling

                     Others

6.  Irreversible and Irretrievable commitment of resources.


Class I   Labor and energy expended in construction of the. proposed

          facilities.

Class II  Land use of the proposed site for a WRP over the useful

          life of the proposed facilities and associated operation

          and maintenance expenditures, of energy, chemicals,  and

          materials.

Acknowledgement

     Portions of this Environmental Impact Statement were taken directly

from the Environment Assessment prepared by the MSDGC (November, 1974),

and the "Facilities Planning Study - MSDGC Overview Report" and "O'Hare

Facility Area" (January, 1975) also prepared by the MSDGC.
                                iv

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                          TABLE OF CONTENTS
Volume I

Summary Sheet 	     i
Acknowledgement 	    iv

1.  BACKGROUND	1-1

    A.  Identification of Grant Applicant 	   1-1
    B.  Description of the Proposed Action	1-1
    C.  General and Specific Location of the Proposed Action  .   1-1
    D.  Water Quality and Quantity Problems 	   1-2
        1.  Sources of Water Supply in the Service Area ....   1-2
        2.  Sanitary and Combined Sewers  	   1-5
    E.  Other Water Quality and Quantity Objectives 	   1-8
    F.  Costs and Financing	1-12
    G.  History of the Application	1-12

2.  THE ENVIRONMENT WITHOUT THE PROPOSED ACTION 	   2-1

    A.  General	2-1
    B.  Detailed Description  	   2-2
        1.  Climate	2-2
        2.  Topography	2-3
        3.  Geology	2-3
        4.  Soils	2-8
        5.  Hydrology	2-10
            a.  Surface Water	2-10
            b.  Groundwater Aquifers in the Service Area  .  .  .  2-13
            c.  Water Usage	2-15
            d.  Water Quality and Quantity Problems 	  2-16
            e.  Water Quality Management  	  2-16
            f.  Flood Hazards	2-17
         6.  Biology	2-18
         7-  Air Quality	2-21
            a.  Particulate Matter	  2-22
            b.  Nitrogen Oxides	2-23
            c.  Total Hydrocarbons  	  2-24
         8.  Land Use	2-25
         9.  Sensitive Areas	2-26
        10.  Population Projections and Economic Forecasts .  .  .  2-27
        11.  Other Programs in the Area	2-27

3.  ALTERNATIVES	3_]

    A.  Service Area Alternatives	3-1
    B.  Capacity of the Proposed WRP	3-9

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    C.   Site Selection for the WRP	   3-19
        1.   Site Selection Criteria	3-19
        2.   Site Alternatives  and Conditions	3-20
        3.   Common Environmental Factors 	   3-26
            a.   Water Quality   ,	3-26
            b.   Noise	3-26
            c.   Visual Effect  on the Surrounding Area  ....   3-26
            d.   Flood Potential	3-27
        4.   Preliminary Screening of Site Alternatives ....   3-27
        5.   Final Selection Process  	   3-28
    D.   Other Facility Alternatives  	   3-33
        1.   Aesthetics	3-33
        2.   Land Use	3-34
        3.   Safety	3-35
        4.   Consumption of Resources	3-36
        5.   Construction and Cost Considerations	3-37
    E.   Process Alternatives 	   3-40
    F.   Solids Handling Alternatives 	   3-41

4.  DESCRIPTION OF THE PROPOSED ACTION	    4-1

    A.   Treatment Facilities 	    4-1
    B.   Effluent Disposal System 	    4-2
    C.   Solids Disposal System 	    4-4

5.  ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION 	    5-1

    A.   Water	    5-1
        1.   Water Quality	    5-1
        2.   Water Quantity	    5-4
    B.   Air Quality	    5-5
        1.   Odor Generation	    5-5
        2.   Aerosol Generation 	    5-8
    C.   Land	5-10
    D.   Biology	5-13
    E.   Environmentally Sensitive Areas  	   5-14
    F.   Aesthetics	5-14
    G.   Operating Personnel  	   5-15
    H.   Impacts of Solids Processing 	   5-18
    I.   Adverse impacts which cannot be avoided should the
        proposal be implemented and steps to minimize harm to •
        the environment	5-19
    J.   The relationship between local short term uses of
        man's environment and the maintenance and enhancement
        of long term productivity	5-20
    K.   Irreversible and irretrievable commitments of
        resources to the proposed action should it be
        implemented	5-21
    L.   Recommendations	5-22

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6.   FEDERAL/STATE AGENCY COMMENTS AND PUBLIC PARTICIPATION ....    6-1

    A.   Oral Testimony at Public Hearing	    6-1
    B.   Written Comments 	   6-65
    C.   Letter Comments	6-120
    D.   Resolution and Petitions	6-176

7.   SELECTED REFERENCES

    VOLUME II - Appendices

    A - O'Hare Area Flood Control Activities
    B - MSDGC TARP Program
    C - O'Hare Service Area Determination
    D - Health Questionnaire and Responses
    E - Geology
    F - Regional Water Resources
    G - Water Conservation and Re-use Measures
    H - MSDGC—Justification of Ultimate Size
    I - MSDGC—Position Paper on Health Aspects
    J - MSDGC—Odor Control Measures
    K - Letter from Bart T. Lynam to Francis T. Mayo
    L - Process Alternatives:  Land Application
    M - Solids Handling Alternatives
    N - Design Criteria—O'Hare Water Reclamation Plant
    0 - HUD Guidelines
    P - MSDGC—Flow Projections
    Q - Additional Site Information
    R - City of Des Plaines—Density Graph and Matrix
    S - Aerosol Literature Survey
    T - Water Quality Data
    U - Ten State Standards
    V - EPA Correspondence

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                            CHAPTER 1




                           BACKGROUND









A.  Identification of Grant Applicant and Planners




         The grant applicant for the proposed Upper Des Plalnes Water




    Reclamation Plant and Solids Pipeline is the Metropolitan Sanitary




    District of Greater Chicago. The Facilities Planning Report for the




    Metropolitan Sanitary District of Greater Chicago is comprised of




    eight separate reports.  These reports consist of an overview report




    and individual reports for the seven facilities areas.






B.  Description of the Proposed Action




         The proposed O'Hare Water Reclamation Plant will be designed as




    two stage activated sludge process.  Carbonaceous matter will be




    removed in the first stage followed by biological oxidation of




    ammonia to nitrite and nitrate in the second stage.  Final effluent




    polishing and disinfection prior to discharge into the re-routed




    Higgins Creek will be accomplished by dual media filters and sodiur,:




    hypochlorite, respectively.  The O'Hare WRP will also provide compl>.




    treatment for combined sewer overflows entrapped and stored by the




    O'Hare Tunnel Conveyance System.  All of the waste activated sludge




    generated in this plant will be pumped via force main to the John E.




    Egan WRP (Salt Creek) for treatment and disposal.  The projected




    average dry weather flow by the year 2000 is 72 MGD.






C.  General and Specific Location of the Proposed Action




         The Upper Des Plaines Service Area,an area of 65.2 square miles




                                  1-1

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    is located     in the northwest portion of the Metropolitan Sanitary




    District, .shown in Figures 1-1 and 1-2.  This area is predominantly




    residential in character.   Growth of the area has been stimulated by




    several factors.   Among the more significant of these is the proximity




    of O'Hare Airport, the Northwest Tollway, the Tri-State Tollway, and




    the Chicago and North Western Railway's tracks which bisect the basin




    in a northwesterly direction.




         The area includes the communities of Arlington Heights, Mount




    Prospect, Prospect Heights, Wheeling, and a part of the City of




    Des Plaines as well as newer urban developments such as Elk Grove




    Village, Rolling Meadows and Buffalo Grove.  As illustrated in




    Figure 1-1, the boundaries encompass an area which lies generally




    west of the Des Plaines River.  Several major drainage courses traverse




    the basin in a generally east-west direction and empty into the




    Des Plaines River.  Two of the waterways are of concern, since they




    receive combined sewer overflows even during low intensity storms.




    They are the Weller's Creek and Feehanville Ditch areas.  No other




    waterways within the Upper Des Plaines River Basin receive; combined




    overflows.






D.  Water Quality and Water Quantity Problems in the Area




    1.  Sources of Water Supply in the Service Area




        There are three water supply sources to the service area:




        a.  Groundwater from shallow glacial-till Silurian aquifer.




            The well records indicate that the majority of wells in the




            shallow aquifer are private domestic service with pumpout




            rates between 5 to 50 gpm.





                                 1-2

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          ..
                                       JUPPER DES PLAINES
                                        DRAINAGE BASIN'
        r
                                                                     Chicago
                                                                               ~L
         LEGEND
                M.S.D.G.C. COMBINED-SEWER SERVICE AREA i	''*¥£,. j£J^-3£-$£zh-~.
1
                      FIGURE 1-1

   METROPOLITAN  SANITARY DISTRICT OF

GREATER  CHICAGO  GENERAL SERVICE  AREA

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    b.  Groundwater from the deeper Cambrian-Ordivician aquifer.




        The pumpage rate in the region of the project has reportedly




        exceeded the sustained yield of the Cambrian-Ordiv:




        acquifer which has resulted in a decline of tht  :  .lometric




        head averaging about 10-15 feet/year in the project area.




        The municipal and industrial pumpate appears to be from the




        deep aquifer which estimated on population, may have amounted




        to 20 to 25 MGD for 1970 in the project area.




    c.  Surface water from Lake Michigan.  It is anticipated that




        larger quantities of Lake Michigan water will be made avail-




        able to municipalities outside of Chicago in the future to




        limit the pumpage rates to the practical sustained yield in




        the project area.  Des Plaines presently obtains 70 percent




        of its water from Lake Michigan through the City of Chicago




        System.






    For a more detailed discussion of water supply issues,  see REGIOM:




    WATER SUPPLY REPORT #8, Northeasternlllinois Planning Commission,




    September, 1974.






2.  Sanitary and Combined Sewers




        Approximately 5,000 acres of the 41,760 acres in the Upper




    Des Plaines Basin are expected to remain undeveloped and unsewerea,




    This 5,000 acre area consists of special use land such as the Ned




    Brown Forest Preserve, cemeteries and the U.S. Military Reservatic




    Of the remaining 36,760 acres, 29, 382 acres are presently (or will




    be in the near future) serviced by separate sanitary and storm





                              1-5

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sewers, and 5,952 acres are serviced by combined sewers.  In




addition, there are 1,370 acres of separate sewered areas that




connect directly to the combined sewer systems in such a way that




the flows cannot be physically separated except through extensive




and costly construction.  Figure 1-3 illustrates the area contrib-




uting combined overflows to the Upper Des Plaines project.  Those




areas indicated are:  1) the combined sewered area, 2) the separated




sewer area contributing to the project, and 3) the boundaries of




all sewered areas contributing to Weller's Creek and Feehanville




Ditch.  There are about 5,448 acres within the boundary of the




sewered area contributing to Waller's Creek and Feehanville Ditch




that are served by separate sewer systems.  The storm flows from




these areas will continue to discharge directly into Weller's Creek




and Feehanville Ditch and are not a part of the proposed project.




    At present all sanitary sewage, and the combined sewage in the




O'Hare Service Area, except for overflows, is finding its way into




Metropolitan Sanitary District interceptors through regulated




control structures, and is diverted through existing interceptors




to the MSDGC's North Side Sewage Treatment Works for treatment.




    During wet weather, the North Side sewage treatment plant is




presently overloaded and existing interceptors are approaching




capacity.  In addition, there is frequent discharge (average: 80




per year) of combined sewage to Weller's Creek and Feehanville




Ditch creating an unsightly, odorous condition, as well as a




potential health hazard.  This untreated sewage then flows into




the Des Plaines River.  Weller's Creek serves as the main conveyance





                            1-6

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                                 SEWERED AREA

                                 CONTRIBUTING

                                 TO WELLER'S CREEK
                                            SEWERED AREA

                                            CONTRIBUTING TO

                                            FEEHANVILLE DITCH
   -I
iS*\

d
 ( %-v a
                               Creek.'
,,  1
 '$
 «j,,-^,
   i^,	v'

x, *j««w?
1  ' ) *1rr?"*!pi?*
 i
?l
,,-U-
r"\    -   "•rv.^v
.      L         '  . «• • 44 • '
      V .>  ;  »!   .  • •   t".
N      i r'^-4.*  ;;: . .   \-
        •   *- ^***i4Ji , '   ' •   ,->„.
               tfill'owsjLree^  :
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                                                        LEGLND



                                                            SEPARATED AREAS

                                                            CONTRIBUTING TC SYb


                                                        Illllllll COMBINED SEWERED A
                                  FIGURE 1-3


                 COMBINED-SEWER  SERVICE AREA


                                      1-7

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    facility for the discharge from combined sewers serving the

    watershed.  Backup in the combined sewers is the primary cause

    for basement flooding.  Some homes are affected in this manner

    from almost all rainfalls in the watershed.  Combined backup

    will flood approximately 100 basements for the 5 to 10-year storm

    event.  Street flooding will begin to appear for this same storm

    event,

        Overbank flooding does not occur until the 25-30-year storm

    event occurs.

        Tb^ wauer quality standards that determine the effluent para-

    meters for the proposed Wastewater Reclamation Plant are found in

    the WATER POLLUTION REGULATIONS OF ILLINOIS.


     -_J:-^Z-j^^ater Quantity Objectives in the Area Other__Th_an_
Solution of Preceding Problems

I:ie ,,vA, ••-.••'• ing psegr&v.TS are relevant:

1,  jJtv* Federal Water Pollution Control Act Amendments of 1972 (Public

    Law 92-500) require:

    a.  Secondary treatment of wastes for municipal sewage arid best

        practicable treatment for industrial discharges by July 1, 1977.

    b.  Best practicable waste treatment technology for municipal

        wastes and best available treatment for industrial wastes by

        July 1, 1983.

    c.  All point-source discharges require a permit under the NPDES

        program (National Pollutant Discharge Elimination System),

        The NPDES permit states the allowable waste loading and flow

        volume that can be discharged to a receiving stream, lake or

        ocean.

                             1-8

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2.  The National Flood Insurance Act of 1968 requires the designation




    of flood-prone areas in the United States and participation by




    the appropriate communities and homeowners to quality .tor aational




    flood insurance protection.  The flood-prone areas in the O'Hare




    service are have been determined for the 100-year storm event and




    these maps, except for the Arlington Heights quadrangle, are




    available from the Northeastern Illinois Planning Commission (NIPC).






3.  The Flood Control Activities planned by MSDGC for the O'Hare Service




    Area are discussed in Appendix A.






4.  The MSDGC Tunnel and Reservoir Plan (TARP) for control of flood




    and pollution problems due to combined sewer discharges in the




    general service area of the MSDGC  is described in Appendix B.




    The U.S. Senate Committee on Public Works (93rd Congress, 1st




    session) directed the Army Corps of Engineers to determine the




    Federal interest in participating  in the TARP program.  Since the




    Corps viewed any potential Federal participation to be a signifi-




    cant Federal action, they determined that part of their response




    in determining Federal interest should be the preparation of an




    Environment Impact Statement (EIS).  Prior to the issuance of a




    draft EIS in November 1972 an Environmental Assessment (EA) on




    the TARP program was prepared.  USEPA participated in discussions




    during the preparation of that EA  and made suggestions with




    respect to potential environmental impacts to be addressed.  A




    public hearing on the TARP EA was  held July 26,  1973, and discussio




    was presented.  The O'Hare Service Area, since it contains some





                               1-9

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combined sewers, was considered in all alternative TARP plans.




In some TARP alternatives, the O'Hare service area was sewered




by tunnels only, with wastewater treatment occurring at the MSD




North Side STP or WSW (Stickney) STP.  Although this alternative




was considered, it was not supported in other engineering studies




for the O'Hare Service Area.  These reports support a WRP for




the O'Hare Service Area and are discussed in Appendix C.




     USEPA has determined that an independent area is cost-effective




and should be separated  from the Mainstream TARP System with respect




to building the treatment plant and conveyance system to it.  This




determination is discussed in Chapter 3.  No final determination has




been made with respect to building a combined sewage overflow reservior




in the O'Hare Service Area because:




     a.  USEPA is now developing a policy that will address the use of




         construction grants for treatment and control of combined sewer




         overflows and stormwater discharges.  This policy will also




         address flood control aspects of such projects and may affect




         the eligibility of USEPA participation in any proposal reservoir.




     b.  An initial determination has been made that benefits derived



         through construction of the reservior can essentially be classifed




         as flood control, whereas, only marginal benefits, in terms of




         pollution reduction, would accrue with operation of  the reservoir




         component.  This determination will be reviewed after the new




         policy is finalized and at such time as the project has priority




         for funding and is otherwise eligible for USEPA participation.




     c.  Given the highly speculative nature of possible USEPA envolvement




         in the O'Hare Reservoir component, we believe it inappropraite to




         reach any final determinations at this time.




                                 1-10

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     The O'Hare Reservoir is now being evaluated by USEPA and the Corps




     of Engineers as part of a joint effort in determining the level and




     character of Federal interest in the entire Tunnel and Reservoir




     program.  Once a clear division of responsibilities is defined, either




     agency will pursue the eligibility aspects related to any possible




     funding program.  The provisions of the National Environmental Policy




     Act of 1969 would of course apply irrespective of which Federal Agency




     or program may be deemed to be the appropriate reviewing authority or




     primarily germane to those aspects of TARP, such as the O'Hare Reservoir,




     where a clear distinction between flood control and pollution control




     benefits must be defined and addressed in such a manner that will




     assure that the limited resources available for pollution abatement




     are not committed to flood control projects.






An issue related to the considerations above and the present deliniation of




the O'Hare Service Area involves the elimination of the Palatine leg of




the O'Hare conveyance system.  The analysis prepared by the MSDGC and




discussed in Appendix B is sufficient to demonstrate that possible ex-




cessive inflow and infiltration exists in the Village of Palatine collection




system.  In other words,  it now appears more cost-effective to eliminate




the sources of inflow by way of sewer separation than to treat the inflow




at the O'Hare WRP.  To confirm this initial analysis, the Village will be




required to perform a Sewer System Evaluation Survey as described under




40 CFR 35.927-2.   The Survey will definitively demonstrate the existance




or non-existance of excessive inflow or infiltration.  The MSDGC has in-




dicated that the present  design of the O'Hare tunnel system will not forego




future options with respect to building the Palatine leg.  Our analysis




confirms this estimate.





                                  1-11

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In conclusion It is the position of USEPA that the proposed projects will




function adequately as a pollution or control system without the construction




of the proposed reservoir, and  the proposed conveyance system will function




as a conventional interceptor with the added benefit of decreasing the



major occurences of combined overflow.






F.  Costs and Financing




         The preliminary cost for the first stage of construction (72 MGD)




estimated in July 1974 is $95 million for a Chicago ENR Index of 2290.




Of this total 25 percent, $23,750,000, would be financed by MSDGC and




75 percent, $71,250,000, would come from Federal grants.






G.  History of the Application




         Most MSDGC projects proposed for the O'Hare Service Basin have




been given a priority ranking of 31 by the Illinois Environmental Protection




Agency (IEPA).  The following is a chronological listing of major steps and




events in the processing of the MSDGC grant applications.






    March 24, 1971  - Letter of Intent to apply for grant funds sent to




    NIPC and the State Clearinghouse.
                                 1-12

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March 5, 1973 - IEPA acknowledges receipt of applications.




April 12, 1973 - Environmental Assessment Statement (EAS) sent to IEPA.




September 21, 1973 - Application to USEPA for Demonstration f>.
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January 9, 1975 - Draft of MSDGC revised Facilities Planning




Study received by the USEPA.




January 13, 1975 - USEPA issued Notices of Intent to prepare r?raft




environmental impact statements for the O'Hare Water Reclamation




Plant and its related conveyance system.




February 6, 1975 - USEPA received Revised Environmental Assessment




and Responses of the MSDGC to Public Comments.





March 7. 1975  - USEPA distributed Draft Environmental Impact




Statements for tunnel conveyance system, water reclamation plant




and solids pipeline.




March 31.  1975 - USEPA held a Public Hearing to receive comments




on the two Draft Environmental Impact Statements.
                        1-14

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                       CHAPTER 2

        THE ENVIRONMENT WITHOUT THE PROPOSED ACTION


A.  General

     The Upper Des Plaines Service Area, under the jurisdiction of the

Metropolitan Sanitary District of Greater Chicago (MSDGC),  is located in

Northern Cook County, Illinois, within the Chicago SMSA (Standard Metropolitan

Statistical Area).

     The service area is a 65.2 square mile area in the northwest region of

the MSDGC's total jurisdiction of 860 square miles within the County.

     The service area has experienced rapid population growth during the last

15 years.  The population for Northeastern Illinois increased 12.2% from 1960

to 1970.  The following figures for communities to be served by the proposed

water reclamation plant (WRP) and tunnel system indicate this growth.

Community                    1960          1970          %  change

Arlington Heights          27,878        64,884            132.7
Buffalo Grove               1,492        11,799            690.8
Des Plaines                34,886        57,239             64.1
Elk Grove Village           6,608        21,866            231
Mount Prospect             18,906        34,995             85.1
Prospect Heights             ...         13,333
Rolling Meadows            10,879        19,178             76.3
Wheeling                    7,169        14,746            105.7

(All figures from U.S. Dept. of Commerce, Bureau of the Census, publication

PC(1)A15-111.)

     Figure 1-2 indicates the service area and location of  the communities.

The service area is predominantly residential in character.  The area is 60%

developed and construction of light industrial facilities and residential

units (both single family and multi-family) is ongoing to date.  The 1970

population for the area was 223,000.  Growth in the area has been encouraged
                             2-1

-------
by several factors including the presence of O'Hare Airport, Northwest

Tollway, Tri-State Tollway and the North Western Railroad Line.

     The economic condition of the area's population is above the Chicago

SMSA median family income of $11,841 and State of Illinois Median family

income of $10,959.

     1970 census figures indicate the following Median family incomes:

     Arlington Heights                $17,034
     Buffalo Grove                    $14,833
     Des Plaines                      $14,056
     Elk Grove Village                $14,155
     Mount Prospect                   $16,503
     Prospect Heights                 $15,992
     Rolling Meadows                  $13,343
     Wheeling                         $13,398

These figures indicate a healthy economic situation within the service area.

     Few environmentally sensitive areas are within the service area.  A

small portion of the Cook County Forest Preserve District's Ned Brown

Preserve of 3,600 acres occupies the western portion of the area.  The Forest

Preserve District's holdings along the Des Plaines River are located in the

eastern portion of the area.

B.  Detailed Description

1.  Climate

     The continental climate of the service area has relatively warm summers

and cold winters, with frequent short fluctuations in temperature, humidity,

cloudiness, and wind direction.  Temperatures of 96° or greater occur in about

half of the summers while about half of the winters may have low extremes of

-15°.  The mean annual temperature is 49°.  Precipitation averages 33 inches

per year,  with about  10% of this occurring as snow.   Summer rainfall is

unevenly distributed  in intense local showers while  precipitation in the fall,
                                2-2

-------
winter, and spring tends to be more uniform over large areas.  Winds arr




most commonly from the southwest and the northwest, on an annual basis.  An




annual windrose is presented in Figure 2-1.  Monthly windrose ch
-------
         NW
W
                            HOURLY WIND ROSE

                                     N
                             CHICAGO, ILLINOIS
                                     O'HARE
                                  ANNUAL
                                1956-1960
                                 3.6% Calm
                                      FIGURE- 2-1

                        Concentric Circles Represent Composite
                                 Percent Frequencies

                                         2-4

-------
System

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RACINE
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(WAUKESHA)
(0-20')



JOLIET Markgraf
(40-70) BrQndon
Bridge

KANKAKEE
(20-50)

(EDGE WOOD)
(O-IOO')
MFDA
10-15')
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Description

Till and out wash deposits. Clayey silt with
sand lenses. (Gravel lenses possible but not
probable - described in soils report. )
Bouldery till, clayey silt with sand lenses,
grovel '. boulders common near base and at
unconformity. (Described in soils report.)


Gray-brown, orgilloc9oustfine groined,
thin bedded dolomite containing reefs
of pure, gray, massive, vuggy, dolomite.




Gray, fine groined, si/fy dolomite.
(Generally absent in northern area )



Light gray, si /ty, very fine groined dolorrute
Red or greenish gray dolomite and
mterbedded shale.
Light brown, fine grained dolomite with
prominent wavy cloy partings.


Brown to gray sholey dolomite.
project area )
3, i~?z~~ ~~~^j ^j "~t^.i *7r»rJ' " — "". , ' — — " — —
— uonte ana rea snoie (benerolly absent )
Oolite and red shale. (Generally absent)
	 Green to brown fossiliferous mudstone
bed
FIGURE 2- 2

-------
      HOCK    TUNNELS
        Surface
                          EARTH    TUNNELS

                                -Surfact
                           +60.
 +52,

SO —
OVERBURDEN:
   ESTIMATED
   PIEZOMETRIC
   HEAD UNDER
   MAXIMUM
   SURCHARGED
   CONDITIONS
PREDOMINANTLY

CLAYS AND SILTS
RANGE OF PREVAILING
GROUND WATER LEVELS
AT TIME OF SUi-SURI'ACE
INVESTIGATION
                     CONC. LINING
                                                PROPOSED 5'
                                                TUNNELS EARTH
                          --BRAINARD
                          '-SHALE
                                                 TOP Of ROCK
                                                 FIGURE 2-3
        GENERALIZED  STRATIGRAPHIC  SECTIONS
                                2-6

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originating from glacial deposits.




      The Silurian System lies under  the Quaternary System and  contains




 material originating from the Niagaran and  Alexandrian  series.   The  Niagaran




 series contains the Racine,  Waukesha and Joliet  formations.  The Racine  and




 Waukesha formations are composed  of  argillaceous fine grained  dolomite while




 the Joliet formation is a lighter  gray dolomite.  The Kankakee and Edgewood




 formations comprise the Alexandrian  Series.   Dolomite is  also  the major




 portion of these formations  ranging  from fine to shaly  in texture.




      The final  system is the Ordovician, composed of the  Cincinnation series




 which has two  formations; the NEDA and Brainard  Shale Red shale and  fossil-




 iferous mudstone comprise the majority of these  formations.




      The above  discussion encompases approximately the  first eight hundred




 feet of earth.   There are two main aquifers contained in  the above mentioned




 geologic structures.   They lie in  the Silurian and Ordivician  Systems.




      The Silurian aquifer has an  average depth of 108 to  205 feet.   It is




 composed mainly of glacial till material.   The uppermost  material, in the




 area of access  tunnels and work shafts is slightly more porous than  that




 surrounding the rock tunnel.   The  coefficient of permeability  (C ) of the




 glacial till is 10   to 10"^ cm/sec.   Because of the low  C there will be no




 significant release of water to the  tunnel  through seepage.  Any seepage that




 will occur results from openings primarily  in the form  of cracks and joints




 in the rock.  The location of inflows in this case can  easily  be located




 after excavation, particularly within the machine bored section of the tunnel




 and may be appropriately grouted.  Another source of inflow may occur during the




 boring of work  shafts or access tunnels. The inflow will originate  from




 ground water seepage, to the upper portions of the shaft  and tunnels.  This





                                 2-7

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seepage may also be arrested by the use of grouting techniques.   Within




the formation there exists sand and gravel pockets which hold limited




amounts of water.  If they are encountered by construction,  the  water may be




released to the tunnel.   These quantities of water appear to be  ?xtremely




limited and are not known to be used as potable water supply sources.




     As an overall view it is anticipated that the drawdown  of the water




supply aquifier during operation of the facility will be virtually zero.




It is expected that grouting will reduce the groundwater flow into the




tunnels to less than 300 gpm over the total length of tunnels based on




the results obtained from previous projects.  Tunnel lining  which is planned,




will further reduce inflows.




     Since the tunneling lies within the glacial till-Silurian system and




concurrently within the Silurian aquifier area, a discussion of  the




Ordivician aquifer will be left to the water supply section  of this statement.




Ground water and surface water recharge of the aquifiers will also be




addressed in that section.  A more complete discussion of the bedrock geology




can be found in Appendix E.




4.  Soils




     The soils of the study area have developed from glacial parent materials,




under prairie and transitional (prairie to woodland) vegetation.  Alluvial




soils have developed along stream flood plains.  Most soils  generally have




fairly  low permeabilites and high seasonal water tables, resulting in poor




drainage.  Despite the slow drainage and flat topography erosion control is




desirable to avoid soil loss and the sedimentation of streams,,




     The proposed plant site is overlain by fill material of variable depth




consisting predominantly of silty clay to clayey silt with variable amounts






                               2-8

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of sand, gravel, organic matter, paper, wood, brick fragments, glass.




The depth of the fill varies from only several feet to as much as 25 feet.




In general, the average depth of fill is 10 to 15 feet.  The enginnering




characteristics of the fill such as consistency, relative density, unconfined




compressive strength, dry unit weight, moisture content and textural




composition are extremely variable.




     The two areas not overlain by fill, the northwest portion of the site




and the area south and west of Higgins Creek, are typically overlain by a




thin mantle of dark brown to black organic clayey silt.




     Underlying the topsoil and fill material over the major portion of the




site are cohesive soils consisting of clayey silts and silty clays.   These




cohesive soils contain variable percentages of sand and gravel with occasional




sand and/or silt seams or lenses.  Pockets and lenses of sand and silt are




also incorporated in the soil mass.  The engineering characteristics of the




cohesive soils vary within a normal range of typical cohesive glacial deposits.




     Within the cohesive soils are numerous small and several larger pockets




or lenses of silt with variable percentages of clay, sand and gravel.   These




deposits vary in thickness up to approximately 15 feet.  The engineering




characteristics vary within a normal range.




     Numerous small and several large pockets or lenses of granular soils




consisting predominantly of sand with variable percentages of clay,  silt and




gravel are incorporated within the mass of the cohesive soils.  These granular




deposits are more numerous in the eastern half of the site and vary in




thickness up to approximately 20 feet and are medium dense as indicated by




the standard penetration tests.




     At the western portion of the site, limestone bedrock has been encountere-.c




at about 85 feet below the ground  surface.




                                 2-9

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5.  Hydrology
a.  Surface Water
     The study area is located in the drainage basin of the Des  Plaines River.
Several small streams originate in the study area and flow eastward  to  join
the Des Plaines River.  The streams and their drainage basins  have been and
are being modified as the area develops.   Named tributaries of the project
area include:  Buffalo Creek and Wheeling Drainage Ditch;  McDonald Creek;
Weller's Creek and Weller's Drainage Ditch;  Higgins and Willow Creek; and
Feehanville Ditch.  All of these watercourses have a 7-day once  in 10-year
low flow of zero.  The natural drainage boundaries for Weller's  Creek and
Feehanville Ditch are indicated in Figure 2-4.
     Weller's Creek, which has a total length of approximately 6.5 miles,  is
joined by a number of smaller tributaries and drains an area of  approximately
10,780 acres.  Portions of this stream have  been relocated,  some areas  have
been channelized and other areas are in underground conduits.   Modifications
of dendritic extremities has been most extensive as many have  been eliminated
by developments and other portions are underground.  The vast  majority  of
this drainage basin has been urbanized.
     Feehanville Ditch extends for approximately 2.5 miles and drains an area
of approximately 1,990 acres.  This watercourse and its drainage basin  have
been substantially modified by urbanization.  The headwaters of  Feehanville
Ditch are underground as is a portion north  of Maryville Academy, and a large
portion of the stream has been channelized.
     Higgins Creek is about five miles in length and drains approximately
5,000 acres before joining Willow Creek at a point approximately three  to
three-an a half miles upstream from the Des  Plaines River.  The majority of
the Higgins Creek area is highly urbanized with some industrial and
                                   2-10

-------
itq „„ v 'X1 -   , I
                                     FEEHANVILLE
                                        DITCH
                            FIGURE 2-4

             NATURAL  DRAINAGE BOUNDARIES
        WELLER'S CREEK AND FEEHANVILLE DITCH
                               2-11

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agricultural uses.  Higgins Creek has been filled,  relocated and channelized

in several places.

     The flow rates of Weller's Creek at Golf Road  have been monitored by

the United States Geological Survey.   The rates of  flow are as  follows:

two-year flood - 520 cfs; five-year flood - 900 cfs;  ten-year flood - 1,200 cfs;

25-year flood - 1,600 cfs; 100-year flood - 2,400 cfs.   No data are available

for the smaller drainage basin of Feehanville Ditch.

     The water quality of Weller's Creek and Feehanville Ditch  has drastically

deteriorated with the increasing urbanization of the  respective drainage

basins.  In the 21 years of record, as compiled and computed by the City of

Chicago, Department of Public Works,  1949 through 1969, approximately 7

million pounds of suspended solids and 1 million pounds of biochemical

oxygen demand have been deposited yearly into Weller's  Creek and the Feahanville

Ditch during combined sewer overflow.

     The United States Geological Survey estimated  the  10, 50,  and 100-year

flow rate of Higgins Creek at Mount Prospect Road to  be 840, 1,250, and 1,650

cfs respectively.  The water quality in Higgins Creek is summarized in Appendix

T.  Parameters indicating sewage loadings were not  tabulated by the IEPA for

1973.  Existing urban activities contribute polluted  storrawater runoff to the

natural flow of Higgins Creek probably adding significant quantities of inorganic

and organic pollutants.

     Grab samples of Higgins Creek at the proposed  site after a prolonged

rainfall gave the following data:

          pH - 7.5                    Total Solids  - 506
          COD - 44                    Total Coliform - 1,300,000
          BOD - 8                     Fecal Coliform - 250,000
          Suspended Solids - 41       Fecal Strep - 9,000

     The State Environmental Protection Agency sampled Weller's Creek during

1971.


                                2-12

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The water quality of Weller's Creek is below State standards for the following




parameters:  dissolved oxygen, total dissolved solids, total phosphate,




ammonia, phenols and fecal coliforms.  The water quality of Feehanville




Ditch probably approaches the same magnitude of degradation as presently




exists in Weller's Creek. Water Quality data from Weller's Creek is in Appendix T,




b.  Groundwater Aquifers in the Service Area




     The Silurian bedrocks of the study area are overlain by 45 to 100 feet




of glacial material.  The textural composition of material, which is often




interbedded, ranges from clay to clayed silt, and usually contains varying




amounts of sand, gravel and boulders.  Waterbearing sand layers are common to




this glacial deposit.  Analysis of drilling data indicates the water tables




of this area vary from 20 to 25 feet in the summer to around 40 feet in the




winter.




     The shallow aquifers of this glacial drift are hydraulically connected




with the underlying Silurian rocks.  Groundwater in the Silurian and Ordovician




rocks occurs in joints, fissures, solution cavities and other openings.  The




water-yielding openings are irregularly distributed both vertically and hori-




zontally.  Available geohydrologic data indicate that the rocks contain




numerous openings which extend for considerable distances and are interconnects




on an areal basis.




     Large quantities of groundwater are withdrawn from wells in shallow




dolomite aquifers of Silurian and Ordovician age in northern Illinois.   The




Niagaran and Alexandrian Series of Silurian age yield moderate to large




quantities of groundwater.
                                2-13

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     Most water-yielding openings occur in the upper one-third of the shallow




dolomite aquifers.  A good relationship exists between glacial drift and the




upper part of the shallow dolomite aquifers.   Highest yielding wells are found




in areas where the glacial drift immediately overlying the shallow dolomite




aquifers is composed of sand and gravel.




     Probable ranges in yields of shallow dolomite wells can be estimated from




specific-capacity frequency graphs, aquifer thickness and  areal geology maps,




and water-level data.  On the basis of these data, potential wells of the




project area could yield up to 40 to 60 gpm (gallons per minutes).




     Recharge of the upper glacial drift-Silurian aquifer  appears to occur




from local precipitation, but the low permeability of the  overburden soils




may be reason to suspect some horizontal movement from the west.




     The lower Cambrian Ordovician aquifer reportedly receives water from




horizontal movement in recharge areas in North-Central Illinois and Southern




Wisconsin; and vertical leakage through the overlying Maquoketa formation.




In 1958 this leakage was estimated to be approximately 11  percent of the total




water pumped from deep sandstone wells in the Chicago region.  The vertical




leakage through the Maquoketa shale is generally due to the large differential




head between the aquifers (and locally may be facilitated  by faults in the




rock).




     According to Walton (Future Water Level Declines in Deep Sandstone Wells




in Chicago Region, 111. State Water Survey-Reprint Series  No. 36, 1974)




the practical sustained yield of the deep aquifers in the Chicago region is




60 MGD which is less than the actual pumpage.  It is anticipated that Lake




Michigan water may be made available to municipalities in the future to limit




the pumpage rates to the practical sustained yield in the project area.
                                 2-14

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     Regionally, the shallow groundwater aquifer system reportedly has a

supply in excess of pumpage and any lowering of the groundwater elevations

is not anticipated except for seasonal fluctuations and local variations

due to pumpage.

     The pumpage rate and the pumpage subdivided by use over the whole basin

from this aquifer has not been established, but available well records indicate

that the majority of wells in the shallow aquifer are private domestic service

with pumpout rates between 5 to 50 GPM.  Municipal and industrial pumpage

appears to be from the deep aquifer which estimated on population, may have

amounted to approximately 20 to 25 MGD for 1970, in the project area.  (Average

per capita consumption 115 gpd) of which approximately 3 MGD (11%) infiltrated

from the shallow Silurian aquifer.

     Regional groundwater quality and quantity data for Cook, Dupage, Lake

McHenry, Kane and Will counties are presented in Appendix F.  This material

is available in Technical Report #8 - Regional Water Supply Report,

September 1974, by the Northeastern Illinois Planning Commission.

c.  Water Usage

     With the exception of that part of the O'Hare Service Area lying within

the City of Des Plaines, all potable and industrial water supplies are obtaineu

from groundwater sources.  Des Plaines presently obtains about 70 percent of it

water from Lake Michigan through the City of Chicago system, with the remainder

coming from groundwater sources.

     Average daily pumpage by municipal systems in the O'Hare Drainage Basin

in 1966 and 1971, expressed in millions of gallons per day, was as follows:

                                            1966          1971

          Elk Grove Twp.                    4.39          6.92
          Wheeling Twp.                     7.21         11.25
          Maine Twp.                        6.25          3.59

                                  2-15

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     The increase in Arlington Heights in the five year period was about




2.0 MGD.




d.  Water Qual .ty & Quantity Problems




     The sewage from the O'Hare Service Area is presently conveyed to t.he




North Side Sewage Treatment Works.   The capacity of the conveying interceptor




is 40 MGD.  Th.ls is adequate to handle the present dry weather flow from the




O'Hare Service Area.  However by 1980 a dry weather flow of 40 MGD is projected,




and it should be noted that the 40 MGD rating for the interceptor is maximum




capacity when flowing full without surcharge.  The projected dry weather flow




for 1980 would create surcharge conditions because diurnal peaks result in a




50% increase above dry weather flows.




     In addition combined sewers presently overflow to Weller's Creek and




Feehanville Dilch, both of which are tributaries of the Des Pljiines River,




during low intensity storms.  The problem is compounded in the Weller's Creek




Basin by dottiest.ic and industrial wastes discharged to the creek as combined




overflows.  Basement flooding is common as are the unpleasant and unsanitary




deposits of wante along banks of the creek.  Flooded street intersections are




also an inconvenience and hazard to health following moderately heavy rainfalls.




     Four commercial or industrial waste treatment plant effluents are discharged




into Higgins Creek upstream of the proposed site.  None is in violation of




the Industrial Waste Ordinance of the MSDGC but surveillance is necessary.




Additionally, water conservation measures are described in the Regional




Water Supply Report and are included in Appendix G.




e.  Water Quali.ty Management




     Section 208 of the 1972 Federal Water Pollution Control Amendments Act




of 1972 provides for areawide planning for waste treatment management in large
                                 2-16

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urban - industrial areas of the nation which have severe and complex water

Duality problems.  The northeastern Illinois counties of which the service

area is a part have been identified as having such water quality problems.

The Northeastern Illinois Planning Commission is currently organizing a 208

planning effort with local governmental units.  With the support of local

governments, the Governor of Illinois may designate an areawide waste

treatment: management planning area (208 area) and may designate the North-

eastern Illinois Planning Commission (NIPC) as the official "responsible

ofanning agency" for 208 planning.

     At this writing, the following service area governmental units have

.supported through resolution, the designation of the six-county area and

NIPC as the 208 planning agency:

     Arlington Heights
     Mount Prospect
     Des Plaines
     Cook County
     Buffalo Grove

     MSDGC has prepared a proposal as to their participation within the 208

planning process.

     The Northeastern Illinois Planning Commission has also completed a

Regional Wastewater Plan (1971), which will be a major component of the 208

study..

     The Illinois Environmental Protection Agency has the responsibility

for Section 303 of the 1972 Amendments whereby water quality problems are

.de.itified and overall pollution abatement strategies are established

 r-r all major river basins in the state.

3 .   Flood Hazards

     The United States Geological Survey (USGS) flood hazard maps indicate

the flood crest of 1957 as the maximum historical occurance.  The flood ere.
                                 2-17

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at the plant site proposed by MSDGC was approximately 656  feet  above sea




level and overbank flooding occurred on portions of  the site.   The flood-prone




areas in the O'Hare service area have been mapped for the  100 year recurring




flood event.  These maps are available in 7.5 minute series  (topographic)




from the Northeastern Illinois Planning Commission.   Figure  2-5 indicates




the 100 year flood potential for the nine sites  which have been suggested




for placement of the O'Hare WRP.  Channelization of  Higgins  Creek is part  of




the Willow-Higgins Creek Watershed plan illustrated  in Figure 2-6.  This




plan consists of locating storm reservoirs along Willow Higgins Creek and




channelizing various sections to protect against the 100 year flood.  A




summary of the O'Hare area flood control activities  is found in Appendix A.




Any grant award made to the MSDGC for a WRP will require that flood insurance




under the National Flood Insurance Act of 1968 is acquired and  maintained.




6.  Biology




     Most of the study area has become urbanized, with the original prairie




vegetation and oak-hickory deciduous forests being replaced  by  agricultural




lands, yards, parks, and urban areas.




     Principal remaining natural areas occur along the Des Plaines River and




its tributary streams, and in the Ned Brown Forest Preserve. A variety of




birds and small mammals inhabit the service area.  Agricultural and urban




runoff have polluted streams and affected the original composition of stream




plants and animals.




     No endangered or rare species on the U.S. Department of Interior list are




known to be present in this area.  There are however several rare and endangered




bird species from the State of Illinois list which could be  present in the




project area.  The rare species are:






                                 2-18

-------

-------
   —f=   W  9    «     ]
   Of    J
                                            a.
                                            cc
                                            oo
                                            to
                                    "V
2-20
                                FIGURE 2-6

-------
          1.  Nycticorax nycticormx - Black-crowned night heron




          2.  Botaurus lentiginosus - American bittern




          3.  Circus cyreus - Marsh hawk




          4*  Tyto alba - Barn owl




          5.  Asio otus - Long-eared owl




          6.  Asio flammeug - Short-eared owl




          7.  Hylocichla fuscescens - Veery




          8.  Euphagus cyanocephalus - Brewer's blackbird






The endangered species are:






     1.  Accipiter cooperii - Cooper's hawk




     2.  Buteo lineatus - Red-shouldered hawk




     3.  Bartramia longicauda - Upland sandpiper






  Numerous rabbits have been observed at the proposed treatment plant site.




Vegetation at the site has been disturbed by man's past activities.  It




consists largely of grasses and other herbaceous plants and some small trees.




No known aquatic studies have been done on Higgins Creek..






7.  Air Quality






    In order to evaluate the existing air quality in the vicinity of the




proposed projects, air quality data was gathered from several sources.  These
                                  2-21

-------
included the Illinois Environmental Protection Agency, the Cook County


Department of Environmental Control, the City of Chicago Department of


Environmental Control, and an "Airport Vicinity Air Pollution Study"


conducted by the Energy and Environmental Systems Division of Argonne


National Laboratory.


a.  Particulate Matter


     The greatest amount of data available is the result of particulate matter


sampling.  Data from the Argonne study indicate that for sampling stations


west of O'Hare levels vary from 46 jug/m-^ in upwind conditions to 66 ^ig/m  for


downwind conditions.  On the other hand, levels at stations east of O'Hare


vary from 112 ^ig/m  in upwind conditions, to 66jug/m  in downwind conditions.


The increase in particulate values when winds are from the west suggests that


the airport does make a measureable contribution to the particulate loading


downwind of the airport.


     The primary national ambient air quality standard is an annual average


no greater than 75 ^ig/nH and a 24-hour maximum no greater than 260 jug/m .
Samples taken on airport property show that 100% of the 24-hour values were


240 ^ig/m^ or less while 100% of the 24-hour samples outside the airport were


180 ig/m^ or less.
     At a Cook County sampling station southeast of O'Hare (Franklin Park)

                                                                       3
the annual mean concentration of particulate matter in 1974 was 74 ug/m .


At another station northeast of O'Hare (and downwind), the annual mean


concentration for 1974 was 67  g/m^.  While both of these stations met the
primary standard for particulate matter, they were in violation of the

                             3
secondary standard of 60 jig/m .   Data from a City of Chicago sampling station


east of O'Hare (Taft High School) from January, 1966 to December , 1974
                                 2-22

-------
                                                     o
shows an average annual mean concentration of 89 ,ug/m  .  Obviously, it is


very difficult to draw any conclusions from this data because of the variability


of wind direction and the effects of surrounding area emissions.  It does


appear however, that samples taken close to airport sources generally violate


standards, but that the concentrations of particulate matter decrease with


increasing distance from the airport.


b.  Nitrogen Oxides


     Because there is even less data available on this pollutant, it becomes


even more difficult to note any significant trends.  National ambient air


quality standards state that, as an annual average, photochemical oxidants

                          ^
should not exceed 160 jug/m  nor should they exceed O.OSppm as a one-hour


maximum.  While some samples taken during the Argonne study recorded levels

                   3
as high as 540 ug/m  (or 0.262ppm), the variability in samples was extensive

                                     *)
with some readings as low as 2.4 yug/m .  For example, samples taken along


the northern perimeter of the airport range from 220 ug/m  to 540^ug/m3.


Along the eastern perimeter of the airport values ranged from 52 /ag/m  to


187 ug/m .  Comparisons of samples on airport property and those outside


O'Hare show levels of 209 /ig/m^ for the former and 109 jag/m^ for the latter.


     Results of samples taken by Cook County show an annual 1974 mean of

       o                          o            ^
65 /ig/m  with a range from 32 JUg/m  to llOyug/m .  Similar samples taken by


the City of Chicago east of O'Hare (Taft High School) indicate a 1974 annual


average of 0.036ppm.  The Argonne study concluded that concentrations of


NO and NO  were substantially higher is active mobile source areas of the


airport than in the surrounding neighborhood.  The highest NO  readings
                                                             X

were obtained at both the gate areas and near the ends of runways 14R and 14L.


As with particulate matter, it can be seen that monitoring over a long period
                                2-23

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of time results in annual averages which are well within the standards.


However, it is very common that in certain areas, spot samples will result


in readings which greatly exceed the hourly standard.


c.  Total Hydrocarbons


     In the case of this pollutant it was found that the background levels


of total hydrocarbons (THC) were so high that it was not possible, in the


case of the Argonne study, to determine the impact of aircraft emissions on


the air quality in the area.  The maximum standard for a 3-hour period, which


is not to be exceeded more than once a year, is 160 /ig/nr (or 0.24ppm).


Sampling of the northern perimeter revealed THC levels from 1934 yug/m^ to

         n                            o             O
2330 /ig/m  with a range from 1700 yug/irr to 1950 ^ig/m  along the eastern


perimeter.  THC levels outside O'Hare in Elk Grove Village (west of Site #1)


ranged from 1535 yug/m  to 2100yug/m3.  The Argonne study noted that the high


background THC could be largely methane which is relatively stable in the


atmosphere while the contributions coming from aircraft may contain a substantial


fraction of reactive hydrocarbons so that these contributions could be


significant with regard to the production of photochemical smog.


     The Argonne study indicated that it was highly questionable whether air-


craft emissions would have a detectable effect at ground levle because of the


interference with ground based emissions.  Visual observations of the exhaust


plumes saw them transported to ground level at distances of about one to two


miles from the runway end.  The visibility of the exhaust plumes near the


surface within one or two miles of the airport as well as their detectability


at flight levels suggest that at least one type of impact of particulate


emissions is to increase the atmospheric pall in the airport vicinity.


     In general, it appears that air quality in the vicinity of the project




                                  2-24

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sites 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.

8.  Land Use

     According to MSDGC estimates, the ultimate growth of the facility area

will include:

             Residential & Commercial land uses            29,382 Acres
             Industrial                                     7,378 Acres
             Open Space (includes forest preserve,          5,000 Acres
                        cemeteries & municipal parks)

     The growth trends have shown vacant land developed to residential,

commercial and industrial uses.  Residential growth trends indicate multi-

family residential units becoming more prevalent than the past predominantly

single-family home suburban-type development.

     Air and water quality may be threatened by the trend in land use

changes which include more people, cars, and construction of homes,  offices,

industrial plants and shopping centers.   The availability of vacant land is

not the only criteria for future development.  Several open space agencies

exist within the service area (for example local Park Districts) which are

authorized to acquire lands for park and recreation purposes.  These agencies

contribute to the overall environmental  improvement by preserving lands for

recreational and environmental educational uses.  The trend toward open space

preservation should be included in land  use alternatives considered in the

various plans prepared by local agencies.

     Comprehensive planning is the process by which a public planning agency

provides for orderly development of an area and promotes a desirable environme;
                                2-25

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By this process, physical development is coordinated in accordance with

present and future needs.

     Plans and programs usually include a land use plan, a thoroughfare

plan, a common facilities plan and public improvements program.   Administrative

and regulative measures to control and guide physical development according

to the plans include a zoning ordinance, an official map and subdivision

regulations.

     A land use plan shows the location and extent of lands designated for

various kinds of residential, institutional, commercial, industrial and

public purposes.  Current land use planning within the service area is being

carried on by a variety of governmental units.

     The "Summary of Local Planning Documents in Illinois," prepared by the

State of Illinois Department of Transportation (1973) lists the following plans:

     Arlington Heights          Comprehensive Village Plan (revised 1967)
                                Preliminary Planning Report 1968
     Des Plaines                Comprehensive Plan 1971, Zoning Ordinance 1971
     Elk Grove Village          Comprehensive Plan, 1967
     Mount Prospect             Comprehensive Plan 1968
     Rolling Meadows            Subdivision Control Ordinance (amended 1964)
     Wheeling                   General Development Plan, 1965

     The Cook County Zoning Board of Appeals is currently preparing a new

zoning map and zoning ordinance.  Additionally, the county has a,.,traffic

safety study in progress.

9.  Sensitive Areas

     No properties included in or eligible for inclusion in the National

Register of Historic Places are in the area of the treatment plant and sludge

line.  No rare or endangered species, at the State or National level, are

known to occur in this area.  The major open space area is in the Ned Brown

Forest Preserve.  It is important both as a biological and recreational resource.
                                 2-26

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10.  Population Projections and Economic Forecasts

     The projected population forecast of the Northeastern Illinois Planning

Commission  (NIPC) is shown in graphical form in Figure 2-7, and in Table 2-2.

The present population in the O'Hare Service Area is approximately 250,000.

The projected population for the design year of 2000 is 300,000.

Table 2-2.  Population forcasts for the O'Hare Service Area.  (Source:
Northeastern Illinois Planning Commission)


	YEAR   	Forecast Population	
          1970                             223,000
          1980                             261,000
          1990                             277,000
	2000	300,000	

     Economic forecasts available are limited to projections of employment

by townships prepared by NIPC.  The three townships principally in the O'Hare

Service Area are Elk Grove, Maine and Wheeling.  The employment forecasts

for these townships are shown in Table 2-3.

Table 2-3.  Employment forecasts for the O'Hare Service Area (Source:
Northeastern Illinois Planning Commission)
Township
Elk Grove
Maine
Wheeling
TOTAL
1970
37,257
52,767
24,916
114,940
1980
43,400
68,600
31,200
143,200
1990
46,300
74,300
34,300
154,900
2000
47,100
75,800
34,700
157,600
11.  Other Programs in the Area

     New federal legislation entitled the "Housing & Community Development

Act of 1974" provides the possibility of funding for community development

activities.  Within the service area, two communities, Arlington Heights and

Des Plaines have populations greater than 50,000 and thus are eligible for theii

own "entitlement" moneys.  Cook County would be eligible for funds as an "Urban

County" under this Act.  Sewer construction is one eligible activity under the

program.  Future growth capacity could be stimulated by this federal program

and ultimately serviced by the MSDGC.

                                    2-27

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       POPULATION FORECAST

       O'HARE FACILITY AREA
c
CD
CO
D
O
_c
h-
c
o
V-1
CO

D
Q.
O
Q_
    400
    350
300
250
200
150
    100
     50
      1960    1970
              1980    1990    2000

                     Years


                     FIGURE 2-7
2010    2020    2030
                           2 26

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                               CHAPTER 3




                              ALTERNATIVES







A.  Service Area Alternatives




         The Northwest Service Area within the MSDGC is comprised of the




    following drainage areas associated with the Des Plaines,  Fox and




    DuPage River Basins:




              - Upper Des Plaines




              - Salt Creek




              - Poplar Creek




              - Upper DuPage




    Shortly after annexation of the 180 square mile Northwest Area to the




    MSDGC in 1956, the District and its consulting engineers began a




    series of studies to determine the most practicable and economic




    method of providing adequate sewerage treatment and conveyance facilities




    consistent with the needs of the rapidly expanding area.  Several




    considerations affected decisions made by the District with respect




    to the Northwest Area.  Briefly, they consisted of:




         a.  The need to keep pace with the rapidly expanding character




             of the Northwest Area.




         b.  The need to prevent the prohification of small package




             treatment plants by providing adequate facilities when required.




         c.  The need to adhere to a basin drainage concept, thus maximizing




             gravity flow systems and minimizing expensive pumping requirements




         d.  The need to minimize basin diversion of wastewater because of




             value for reuse after treatment and because other basins




             experience flooding problems due to inadequate drainage capacity




             under intense wet weather conditions.




                                 3-1

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        e.  The need to develop a program consistent with the above concerns




            and the District's financial capabilities.




        An initial study was completed by the MSDGC in 1961 that recommended




   construction of a Northwest Intercepting Sewer System to relieve existing




   sewers in the Northwest Area and provide service for the ultimate




   development of the entire area.  All dry weather flows would be treated




   at the existing West-Southwest facility.  Consultants, Greeley and Hansen,




   were retained to prepare a detailed report on the "Proposed West and




   Northwest Sewers".  The report, as finalized by Greeley and Hansen




   in June of 1962, indicated the system would comprise 36 miles of sewer




   ranging in size from 60 inches up to 22 feet and costing approximately




   $134,000,000.  The engineers concluded —




        "This large sum will require financing construction




         over a relatively long time so that for some rapidly growing




         areas in the northwest part of the Sanitary District,




         it will be necessary to provide temporary sewage




         treatment plants discharging their effluent into




         nearly relatively small waterways."




        Subsequent to preparation of the 1962 Report, Greeley and Hansen




   were again retained to explore in greater detail the alternatives




   available and in particular those aspects associated with temporary




   treatment plants for the Northwest Area.




        In August, 1965, their "Report on Sewerage for the Northwest Area"




   was submitted to the MSDGC.  Five basic alternatives were examined




   for conveyance and treatment of sanitary flows* generated in the area




   and are summarized as follows:








* dry weather flows with nominal control of wet weather flows




                                  3-2

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        Plan a - All flows to the west-southwest plant.

        Plan b - All flows to the Northside plant.

        Plan c - All flows to a new Salt Creek plant.

        Plan d - All flows to a new O'Hare plant.

        Plan e - Construction of 2 new plants at O'Hare and Salt Creek.


        Based on projected average annual flows of 197 MGD from the

   Northwest Area, at a design year of 2015, the following table summarizes

   the alternatives by year of construction and day required capacity as

   indicated in the 1965 Report:
                  CAPACITY AND STAGE OF CONSTRUCTION
                                 (MGD)
                                                 New STP           New STP
                                                at Salt Creek     at .O'Hare
Alternate
Plan
Plan a
Plan b
Plan c
Plan d
Plan e
Stage
by 1985
by 1985
initial
by 1980
initial
by 1980
initial
by 1980
Expansion of
Exist. STP
197
197



                                                  74.5
                                                +122.5*

                                                                    74.5
                                                                  +122.5

                                                  29.0              45.5
                                                 +63.0             +59.5
* Added capacity MGD


        The capital costs for initial construction and total implementation

   .through design year 2015 are presented as follows:
                          CAPITAL COSTS 1965
                            ($1000 Dollars)

             Plan a     Plan b    Plan c    Plan d    Plan e
Initial
Future
30,430
111,040
29,870
102,560
49,320
66,900
50,330
68,400
49,400
68,900
TOTAL      141,470     132,430   116,220   118,730   118,300

                                    3-3

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     Since it was apparent that interim treatment plants would be




required before adequate conveyance capacity could be constructed to




either the existing Northside Plant or West-Southwest Plant and since




the total capital costs for either of those alternatives exceeded the




independent service area plans, the District adopted Pla.n e which




called for two new facilities to serve the Salt Creek and O'Hare




areas.  This plan was consistent with the District's drainage basin




concept, the District's financial capabilities, and could be implemented




within a reasonable time frame.  The Salt Creek Service Area was




subsequently divided into the Poplar Creek, Upper DuPage, and Salt




Creek sub-basins.  With this modification, flows in the Poplar Creek




basin would be treated at the existing Elgin-Main Plant, the flows in




the Upper DuPage would be treated at the existing Hanover Park facility




and new facilities would be constructed for the Salt Creek and O'Hare




Service Areas.




     The four plant concept was subsequently incorporated into the




Regional Wastewater Plan for Northeastern Illinois and adopted by




the State as the official water quality management plan for that




portion of Illinois.  On March 3, 1972, following certifications by




the U.S. Department of Housing and Urban Development, the Regional Plan




was approved by USEPA under the provisions of the Federal Water




Pollution Control Act (FWPCA), 33 U.S.C.A. 1151 e£ s_e£. (1970).




Since conceptualization of the plan for the Northwest Area in 1965, major




components of the plan have been built or are under advanced stages




of construction in all but the O'Hare Service Area.
                              3-4

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     Passage of the 1972 Amendments to the FWPCA mandated new planning




requirements for support of construction grants authorized under




Title II of the Act.  Two provisions had the potential of altering




the plans for the O'Hare Service Area since new analyses were required




to demonstrate that the conveyance system, tributary to the proposed




plant, was not subject to excessive inflow or infiltration, and for




projects funded from Fiscal Year 1975 or future allotments, that the




treatment works provide for the application of Best Practicable




Wastewater Treatment Technology (BPWTT).  Since the possibility existed




that the O'Hare treatment works would be funded from the FY 75




allotment, the MSDGC pursued the aspect of BPWTT which is discussed




later in this chapter.  The District has also demonstrated that the




facility will not be subject to excessive inflow and infiltration




as defined by this Agency




     Questions were raised at the March public hearings concerning the




interface of the Tunnel and Reservoir Plan with the proposed O'Hare




facilities and the rationale for separating the O'Hare Service Area




and tunnel conveyance system from the Lower Des Plaines tunnel system.




In response to those questions, we have evaluated the cost-effectiveness




of the TARP proposal with respect to an independent O'Hare system.




     As early as August, 1953, planning by various authors had been




directed  towards solution of two serious water resource problems




affecting the Chicago Metropolitan Areas, water pollution  from combined




sewer overflows and flood damage.
                            3-5

-------
     In January 1972, the Flood Control Coordinating Committee (FCCC)




recommended that final planning concentrate on 4 alternatives which




represented the least cost-most environmentally sound concept of the




approximately 50 alternatives evaluated for solving the interrelated




problems.  In summarizing the results of their review, the FCCC states,




"The final plan for flood and pollution control in the study area should




by in the form of the 'Chicago Underflow Plan' (alternatives G, H, J,




and S) with Mod 3 level of storage."




     The Modifications, or Mods, studies for various storage levels




were:




     a.  Mod 1 - Original Plans (various authors)




     b.  Mod 2 - Contain largest storm of record (120,000 acre-ft)




     c.  Mod 3 - Storage to prevent backflow to Lake Michigan (50,000 acre-ft)




     d.  Mod 4 - Conatin 1 year storm (20,000 acre-ft.)




     The recommended plan, identified as the Tunnel and Reservoir




Plan (TARP), was finalized in the August 1972 Summary of Technical




Reports.  The following table summarizes the basic elements of each




TARP alternative along with cost data as derived from the Technical




Report Part 7, dated December 1972.
                           3-6

-------
                         COST SUMMARY OF PRIMARY
                   TARP ALTERNATIVES @ 1972 COST BASE
                           ($ Million Dollars)
      Alternative
                        Present-^  Present  Present
 Storage1    Capital     Worth   Worth     Worth
(acre-ft.)     Costs     Capital    O&M	Total
   G - 1 Quarry @
         McCook
 50,000
1,344     1,002     296
   H - 2 Quarry @       50,000
         McCook & Calumet

   J - 3 Quarry @       50,000
         McCook, Stearns
         & Calumet

   S - 2 Storage <§      50,000
         McCook & O'Hare

TARP - 3   Storage @    57,000
(1972)   Stickney, O'Hare
         Stearns

TARP - 4 Storage @      57,000
(1975)   McCook, Cabinet,
         O'Hare, in-line
              1,223
              1,235
              1,312
              1,246
              1,190
            912     301
            921     303
            979     299
            928     230
            900     230
1,298
1,213
1,224
1,278
1,158
1,130
      1.  Reservoir Capacity below - 100 C.C.D. elevation
      2.  Capture, Conveyance & Storage Costs
          exclusion of local sewer improvements
      3.  50 yr. life @ 7% interest rate
              In evaluating the four alternatives recommended by the FCCC,

         the MSDGC compared alternative G, which included an interconnection

         of the O'Hare tunnels with the lower Des Plaines tunnels and McCook

         reservoir,  against alternative S that excluded the interconnection,

         but provided a separate reservoir in the O'Hare Service Area.  As

         indicated in the above table, the costs of the interconnection resulted
                                       3-7

-------
in net increase of approximately $32 million in capital costs




above the 2 storage concept.  As such, it was concluded that the




interconnection should not be made.




     Following the adoption of TARP in 1972 several considerations




necessitated a reevaluation of the 1972 proposal.  Briefly, they




consisted of:




   - The need to optimize the plan and cut costs where ever feasible.




   - Stearns Quarry was found not to be available.




   - The need to stage the construction effort and proceed in such




     a fashion that benefits would not be delayed pending completion




     of other TARP components.




     The reevaluation resulted in 5 major revisions in the 1972 plan.




These revisions are presented in the January, 1975, MSDGC, "Facilities




Plan Overview Report," and are discussed in Appendix B.  As shown above,




the revisions have resulted in further cost savings.




     Based upon our review of the documents and analyses generated




over a period of several years, we find that separating, the O'Hare




service area, and the building of a Water Reclamation Plant and




conveyance system is justified and should occur at the earliest




practicable date.
                            3-8

-------
B.  Capacity of the Proposed WRP




         Three capacities have been considered in sizing the proposed Water




    Reclamation Plant.  They are 48, 60 and 72 MGD.  The ultimate design




    of the facility for the O'Hare Service Area is projected at 96 MGD.




    (See Appendix H for projection of ultimate size.)




         To evaluate the design plant size, a derivation of forecasted




    flows as a function of projected residential, commercial and industrial




    growth was evaluated.  The flow analysis follows:




         Derivation of Flows




         In forecasting wastewater flows to be generated in O'Hare Facility




    Area, the following information is required:




         *Unit wastewater flow, gallons Per Capita




          Per day (GPCPD), based on sewer gaging records.




         *Projected rate of increase of sewage flow based on




            assessment of historical data and future events.




         *Projection of industrial flow.




         *Quantity of allowable infiltration.




         *Quantity of combined sewer overflows to be captured




            and treated.




         In 1970, flows from the O'Hare Service Area were measured and




    recorded at the Rand Road Sewer Gaging Station.  These data indicated




    that average daily flow was 31.6 MGD.




         Total Population in O'Hare Facility in 1970 = 223,000




         Sewered Population in O'Hare Facility Area in 1970 - 200,700




         Average Dry Weather Flow = 95% (Measured Flow) = 30 MGD






                                   3-9

-------
     Based on these assumptions, the unit wastewater loading In the




O'Hare Service Area in 1970 was 150 CPCPD.  This value includes




contributions from domestic, infiltration and industrial sources, but




excludes quantities spilled from combined sewer overflows.,




     Rate of Increase of Sewage Flow




     In designing a sewage treatment facility it is necesssary to consider




the future flows in terms of anticipated increases In population and




per capita flows.  The methodologies, assumptions, and flow estimates




generated by the MSDGC are presented in Appendix P.




     Our review of the MSDGC O'Hare Facility Plan raised several questions




regarding their projected design flows.  Of particular concern were




projected Increases in the domestic GPCPD (gallons per capita per day)




factor and industrial acreage over time.  Concern was also generated with




the apparent lack of treatment capacity needed for the substantial




quantities of combined sewer overflows that will be intercepted by the




conveyance system.  In order to demonstrate the effects of MSDGC assump-




tions on the design flow, an alternative calculation employing more




reasonable estimates of domestic GPCPD factors and industrial acreage,




together with a discussion of tunnel dewatering requirements follows.




DOMESTIC GPCPD FACTOR




     MSDGC estimates that domestic GPCPD will increase from 73 in 1970




to 113 in 2000, approximately an increase of 1.33 GPCPD per year for




the 30 year period.  Apparently, this assumption was derived from




MSDGC's analysis of 1966 and 1970 data which indicated that the rate of
                              3-10

-------
per capita increase including domestic, industrial and infiltration


flow was 2.67 GPCPD/year; thus MSDGC attributed 50% of the change to


increased domestic GPCPD.


     From MSDGC's data, it is not at all clear that this is a reasonable


assumption.  Their analysis used per capita consumption from one data


source and estimated population from another to derive the rate of increase.


Of the five communities included in their analysis, one had the same per


capita consumption in 1966 and 1970 and two actually decreased in this


period.  The overall increase in water consumption was caused by significant


increases in GPCPD in the two largest communities.  At the minimum, a


separate analysis of increased industrial usage for these areas should have


been performed for the same period.


     Once an area is sewered (which usually results in a marked increase in


GPCPD as septic tank overloading no longer concerns the family) increasing


domestic water usage relates to increasing real per capita incomes and


rising standards of living.  Given the current national economic situation


and projections, it is no longer obvious that per capita water use will


increase as rapidly (if at all) in the coming years as in the prosperous


1960's.  Related to this is the ever worsening inflation causing increased


utilities costs of all kinds to consumers resulting in a very definite


economic incentive to reduce non-essential consumption.


     For the purposes of our alternative calculation, it has been assumed


that domestic GPCPD will annually increase at about half the rate used by


MSDGC.  Given the above discussion, it is debatable that even this rate


of increase is too generous, but it was utilized to arrive at the following


table.
                                 3-11

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                        ALTERNATIVE CALCULATION

                    DOMESTIC FLOWS AND INFILTRATION
                   Domestic    Infiltration    GPCPD    GPCPD
Year   Pop. (1000)    GPCPD     	Allow.	    Exc.     Total     (MGD)
1970
1980
1990
2000
2010
2020
2030
2231
261
277
300
315
332
250
73
77
84
94
95
96
97
33
33
33
32
32
32
31
15
0
0
0
0
0
0
121
110
117
126
127
128
128
— '
24.3
28.7
32.4
37.8
40.0
42.5
44.8
-'-Sewered population in 1970 = 200,700

Note:  Population and infiltration data as presented by MSDGC.


INDUSTRIAL LAND USE

     MSDGC estimated that industrial land use for the area will increase from

approximately 2000 acres in 1970 to 7300 acres by the year 2000; this is an

increase of 265%.  During the same period, population is projected to

increase by 34%.  Thus, MSDGC is saying, in effect, that industrial activity

will increase roughly 9 times faster than population in this area.  This

reaults in an apparent conflict between projected industrial activity and

available labor force.

     As an alternative industrial land use projection methodology we have

employed the OBERS Series E projections on economic activity in the Chicago
                                 3-12

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SMSA.  The OBERS projections are internally consistent with respect to




increased economic activity and increased population and employment.  The




population projections used in the MSDGC plan, which were provided by




Northeastern Illinois Planning Commission, are basically consistent with




OBERS Series E.  OBERS projects an 28% increase in population between 1970




and 2000 for the entire Chicago SMSA;  NIPC projects a 34% increase for the




O'Hare facility area.  This difference can probably be attributed to the




out-lying suburbs growing somewhat faster than the inner core city.




     The employment/population ration for 1970, 1980, 1990, 2000, 2010, 2020,




2030 was taken from the OBERS projections for the Chicago area.  This ratio




was applied to the NIPC population figures, giving projected employment for




the O'Hare study area.  Employment for each decade was then applied to the




1970 industrial acreage/employment ratio to obtain an indication of industrial




acreage.  It is possible that the industrial acreage/employment ratio could




change over time; however, it is not believed that this ratio will vary




significantly.  Also as OBERS earnings data indicate, manufacturing activity




(the major industrial activity) is projected to increase much slower than




other employment activities, particularly services and Government.  OBERS




projections indicate for the listed activities in the Chicago SMSA the




following percentage increases in earnings between 1970 and 2000:




     Total earnings:  176%




     Manufacturing:   132%




     Services:        292%




     Government:      219%




     By using the total number of employees as an indicator of industrial
                                 3-13

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acreage needs, we feel that any probable future increase in the 1970


industrial acreage/employment ratio is more than accounted for.





                        ALTERNATIVE CALCULATION


                           INDUSTRIAL FLOWS
Year
1970
1980
1990
2000
2010
2020
2030
Pop. (1000)
223
261
277
300
315
332
350
Employment
Population
Ratio
.42
.46
.46
.48
.48
.47
.47
Employment
(1000)
93.66
120.06
127.42
144.00
151.20
156.04
164.05
Ind. Acres
Employment
Ratio
.02135
.02135
.02135
.02135
.02135
.02135
.02135
Ind.
Acres
20002
2563
2720
3075
3228
3331
3512
Flow3
MGD
6.4
8.2
8.7
9.8
10.3
10.7
11.2
     Ratio from 1972 OBERS Series E Projections for Chicago SMSA

    o
     Acres given for 1970, derived for all other years


           assumption used: 3200 GPCPD
                               3-14

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                            ALTERNATIVE CALCULATION




                               TOTAL FLOWS (MGD)




                        EXCLUDING DEWATERING CAPACITY




                                  OF 24 MGD

Year
1970
1980
1990
2000
2010
2020
2030

Domestic and
Infiltration
24.3
28.7
32.4
37.8
40.0
42.5
44.8

Industrial
6.4
8.2
8.7
9.8
10.3
10.7
11.2

Total
Calculated
30.7
36.9
41.1
47.6
50.3
53.2
56.0
Alternative
Design Flow
(calc.xl.l)
33.8
40.6
45.2
52.4
55.3
58.5
61.6
MSDGC
Design
Flow
33
50
62
73
77
80
83
     Since preparation of the Draft EIS in March, we have further examined




the cost-effective tradeoffs including relevant factors, particularly




the dewatering requirements, in constructing plant capacities of 48 and




60 MGD with phased additions of 24 and 12 MGD modules versus initial con-




struction of a 72 MGD facility.




     The possibility of constructing initial capacities of 48 or 60 MGD




had to be dismissed since the projected loading to the O'Hare WRP in the




first year of operation is estimated to be as high as 64 MGD for sustained




periods during the wet seasons.  The average dry weather flows to the




facility in the first year of operation are estimated to be approximately




40 MGD.  The difference in these flow values is attributable to captured




combined sewer overflows that must be pumped from the conveyance system and






                                 3-15

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treated at the average rate of 24 MGD.   Since the O'Hare WRP must be capable




of processing the captured combined overflows on a sustained basis,  the




capacity for treatment of the overflows must be firm,  installed and




continuously available.   The rationale  for this determination follows:




     1. As reported in the MSDGC Environmental Assessment for the O'Hare




     WRP, yearly spills  after construction of the conveyances tunnels




     will, on the average, be reduced form 80 per year to six.   During




     all 80 events the tunnels will convey substantially greater volumes




     than average dry weather flows and will surcharge or completely




     fill at least six times each year.  To prevent septic conditions




     from occurring in the tunnels and  to allow for subsequent rainfall




     incidents, dewatering must proceed at an average  rate of 24 MGD




     or be completed in 3 days under surcharged conditions.  Therefore,




     the 24 MGD dewatering rate must be superimposed upon the facilities




     average dry weather flows yielding a total rate of 64 MGD for sustained




     periods during the wet seasons.  Closely spaced rain events, common to




     the Spring and Fall seasons, may result in the need to continuously




     dewater for periods well in excess of 3 days.  Therefore, the need for




     installed treatment capacity to process the combined overflows  is




     apparent.




     2.  It has been suggested that treatment of the combined overflows at




     the average rate of 24 MGD could be accomplished  by utilizing the




     facility's "peaking" capacity.  While peaking capacity is common to




     most treatment facilities for the purpose of accomodating diurnal




     peak flows, it is not available for continuous treatment at the






                               3-16

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increased rates since critical design parameters are generally based




on average conditions.




     Regarding the O'Hare WRP design considerations, the following




statement was extracted from the O'Hare Facilities Plan - "The design




of the O'Hare Wastewater Reclamation Plant shall initially proceed




as a two-stage activated plant providing for biological ammonia




oxidation and meeting or exceeding all applicable IPCB effluent and




stream standards at the average dry weather flow of 72 MGD".




     It is obvious from the above that the design considerations do not




properly account for intercepted wet weather flows.  While a further




reading of the design parameters will indicate that the plant shall have




peaking capabilities up to 144 MGD, the peaking capacity can not be




utilized for sustained dewatering cycles, to do otherwise would




amount to no more than "overloading" the facility with a concomitant




decrease in plant performance.




3.  Given that dewatering capacity must be considered in the design




of the O'Hare WRP, the question of whether or not the plant is over-




designed becomes somewhat academic.  The liberal wastewater projections




generated by the MSDGC appear excessive and may not be realized during




the design period.  The alternative flow projections developed by




USEPA may be more realistic and when interfaced with dewatering require-




ments, may provide a more accurate reflection of the facility's full




service requirements.  The requirements are summarized as follows:
                            3-17

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                        ALTERNATIVE CALCULATION




                           TOTAL FLOWS AND




                      DEWATERING CAPACITY (MGD)

Year
1970
1980
1990
2000
2010
2020
2030

Total
Calculated
30.7
36.9
41.1
47.6
50.3
53.2
56.0
Alternative
Design Flow
(X 1.1)
33.8
40.6
45.2
52.4
55.3
58.5
61.6

Dewatering
Capacity
24
24
2.4
24
24
24
24
Total
Requirement
Capacity
57.8
64.6
69.2
76.4
79.3
82.5
85.6
4.  It is recognized that the calculated flows for the year 2000 at 76.4 MGD




marginally exceeds the MSDGC design of 72 MGD.  Considering the variability




inherent in projecting future flows, we believe either of the above flow




projections are valid for design purposes.




     Therefore, based upon the foregoing analysis of wastewater projections,




we find that the O'Hare WRP design year of 2000 at a design flow of 72 MGD




to be a cost-effective and reasonable approach for treatment: of the waste-




water generated in the O'Hare Service Area.
                                 3-18

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C.  Site Selection for the Water Reclamation Plant




     1.  Site Selection Criteria




          The MSDGC has considered six possible sites and visually inspected




and evaluated the sites as to which suited the intended purpo.-.t-,   rhree




additional sites were suggested by concerned citizens.




     In selecting a site in 1965 - 1966 MSD applied the following criteria:




          *The site must be at least 100 acres.




          *Least expensive in terms of land acquisition and plant construction




           costs.




          *The least cost for construction of the intercepting system and




           plant outfall.




          *Close proximity to a suitable receiving stream.




     Since the original purchase of the proposed site by MSD in 1966 the




following changes in the collection system and proposed plant have occurred:




          *Sludge treatment processing will occur at the John E.  Egan Plant




           located in the Salt Creek Service Area.




          *A nonconventional interceptor system of drop shafts and tunnels




           (See EIS on the Tunnel conveyance system) is planned to transmit




           wastewater to the proposed WRP.




          *The WRP plant has been designed so that it can be accommodated




           on a rectangular plot of land of approximately 65 acres.




     Because of these changes a re-evaluation of site criteria is warranted.




We believe the following site criteria are revelant.




     a.  The site must be large enough to accommodate the proposed WRP




with an adequate buffer zone for aesthetic reasons and to allow flexibility






                                  3-19

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for expansion of facilities to accommodate any new wastewater treatment

technology which may be required.   While an exact acreage is difficult to

specify a desirable total size appears to be in the range of 80 to 100

acres for the proposed facility.

     b.  The costs of land, construction, operation of the interceptors,

location of outfall and WRP construction should be minimized within the

constraint that environmental impacts are given proper consideration in

the selection process.

     USEPA staff have visited all  nine sites which are identified in Figure

3-1.  A general description of each site and a discussion of the availability of

these sites follows:

2.  Site Alternatives & Conditions

    Site_#1  (East of Elmhurst Road, South of Oakton Road, North of the
              NW Tollway, Vacant,  owned by MSB).

          This is a 104 acre site  that is bounded by industry on the east

and west, the tollway on the south, and residential property across Oakton

Street on the north.  It would have direct access to the receiving stream

which would be improved and relocated providing flood relief upstream.

A disadvantage to this site would  be the location of Wille Road which divides

the site.  After setting aside land for a buffer zone and road easements the

total number of usable acres to the north and south of Wille Road is 65 and

28 acres respectively.  This site would require 700 feet of 10 foot diameter

influent sewer tunnel to dewater the 20 foot diameter main rock tunnel of the

conveyance system.

          The only improvement on the site is a single-family dwelling owned

by MSB.
                                  3-20

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3-21

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     Site #2  (South of NW Tollway,  west of Elmhurst Road,  North (east of
               Higgina) 94 acres, Vacant; owned by MSD).

     This site is a triangular parcel with the north, light industrial and

utility on the eastern boundary, a developing industrial  area to the north

west and west across Higgins Road.  Some single family homes are located

west of the industrial development across Higgins Road.   A receiving stream

is located on the site.  This site would require 1,000 feet: of 10 foot

diameter influent sewer to dewater the 20 foot diameter main tunnel.   Gas

and oil pipelines across parts of this site and relocation of some of these

pipelines would be necessary.

     Site #3  (O'Hare Maintenance Expansion area, Approximately 85 acres,
               Vacant; owned by city of Chicago - not known to be in present
               airport expansion plans; the availability  of this site is
               questionable).

     In 1966 the airport authority said the site was not  available.  Recently

(with the support of the airport authority) this site has been considered

for a stormwater retention flood reservoir but not for siting a sewage

treatment facility.  This site is located in a vacant northern edge of the

O'Hare Airport property.  A receiving stream is located on the site and

has had improvements made to it  (for airport drainage purposes).  A few

residences are to the north within an area that is predominantly industrial

development.  This site would require 9,000 feet of 10 foot: diameter influent

sewer to dewater the 20 foot main tunnel.

     Site #4  (East of Elmhurst  Road, south of NW Tollway, Unincorporated
               Cook County, Approximately 80 acres).

     The existing land use is a  residential - trailer park.  Extensive

relocation of residences would be necessary, causing time delays, increased

project costs and inconvenience  to relocatees.


                                  3-22

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     About 600 mobile homes are located on the site with additional mobile

home space under construction in the area vacated by a former Outdoor

Movie Drive-in.  A receiving stream is located on the eastern edge of the

site.  The tollway forms the northern boundary; Elmhurst Road is the western

boundary of the site.  Light industrial development is west of Elmhurst Road.

Petrochemical storage tanks are located southwest of the site.  This site

would require 2,000 feet of 10 foot diameter influent sewer to dewater the

20 foot diameter main tunnel.

     Site #5  (East of Busse, South of Oakton, Unincorporated Area of Cook
               County, Approximately 85 acres)

     Part of this site is under development as the SDK industrial park

(approximately 25 acres).  A 740' x 690' x 22' building is presently under

construction on this site.

     Higgins Road and Busse Road form the eastern and western boundaries

of the site.  A residential development of approximately 30 single family

homes is to the south.  A receiving stream is located on the site.  This

site would require 5,000 feet of 10 foot diameter influent sewer to dewater

the 20 foot diameter main tunnel.

     Site #6  (West of Mount Prospect Road, south of Touhy, Approximately
               100 acres).

     Several homes and industrial firms are located on this site.  Old Higgins

Road divides the proposed site, and Higgins Creek is at the north end of the

site.  This site would require 7,300 feet of 10 foot diameter sewer tunnel to

dewater the 20 foot diameter rock tunnel.  Extensive relocation of businesses

and residences would be necessary.
                                 3-23

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     Site in  (Approach area Runway 9L,  DuPage County,  Approximately  100+  acres)

     This site is located on O'Hare Airport,  which owned  by  the  City  of  Chicago.

Location of a WRP at this site may cause a safety  hazard  to  aircraft  using

Runway 9L.  A receiving stream is located on  the site.  Railroad tracks  and

Elmhurst-York Road are immediately to the west of  the site.   This site is

surrounded by industrial land (developed or proposed).  This site would

require 13,000 feet of 10 foot diameter  influent sewer to dewater the 20 foot

main diameter rock tunnel.  Choice of this site might cause  time delays  due

to its location in another county (DuPage) where MSDGC does  not  have  powers

of eminent domain.

     Site #8  (Vacant parcels south of Devon, west of Elmhurst Road
               One site (off Devon) exists north of the receiving stream,
               another alternative, off  Elmhurst,  would be located south of
               the receiving stream.  Approximately 75 acres at  each  location).

     These sites are located east and south of the existing  Centex Industrial

Park.

     Vacant land and industrial development surround these locations  with a

few residences west of the site.  This site would  require 12,400 feet of 10

foot diameter influent sewer to dewater  the 20 foot diameter main rock tunnel.

     Choice of this site might cause time delays due to its  location  in

another county (DuPage) where MSDGC does not  have  powers  of  eminent domain.

     Site #9  (West of Busse, south of Oakton, Unincorporated Cook County,
               Approximately 80 acres).

     Several light industrial firms, 3 houses, 1  farm structure and the Halo

Light Corporation (approximate Building Dimensions 900' x 990' x 26') are

located on this site.  This site does not have ready access  to a receiving

stream (2,700 feet of outfall sewer would be  necessary) and  would require

7,290 feet of 10 foot diameter influent sewer to  dewater the 20 foot  diameter

                                    3-24

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main rock tunnel.  Extensive relocation of industries would be required at




this site.




     Since the draft Environmental Impact Statement was written additional




information has been obtained for various sites.  At the request of USEPA




the MSDGC prepared detailed engineering, environmental impact and cost data




for all sites.  This analysis is found in Appendix Q.  Mr.  Richard Ward,




Alderman 8th Ward, City of Des Plaines submitted a comparative density




analysis of sites 1 and 2 and an environmental impact matrix for sites which




are found in Appendix R.




     On March 25, 1975 USEPA sent a letter to the Department of Aviation,




City of Chicago requesting information on sites 3 and 7.  On April 11, 1975,




we requested information on site #8 in DuPage County.  These letters by USEPA




and the responses received are found in Appendix V.  The Department of Aviation




has indicated that since the airport land was purchased with funds partially




funded with FAA funds they must adhere to certain conditions on the use of the




land.  Since a water reclamation plant would not have any direct benefits for




the airport they are prevented from allowing such use.  The DuPage County




Regional Planning Commission indicated that considerable delays would be




associated with any proposal to construct the proposed WRP on Site 8.  For




example, the site would require a special use zoning designation which involves




a public hearing process prior to any changes.  Given the critical need for




this project, such delays are unacceptable.




     The site selection process which follows assumes that the reader has




reviewed the Appendices Q, R and V.  USEPA analysis will address these documents




as they relate to our analysis in the site selection process.






                                    3-25

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3.  Environmental Factors Commo^i to All Alternatives




    a.  Water Quality          !




          Impact on the water quality will be beneficial and will be felt




on an area wise basis.  The quality of the receiving stream will  most likely




be enhanced due to the anticipated high quality of O'Hare WRP's effluent.




Other streams within the O'Hare Facility Area which presently receive




combined sewer overflows will also be improved as result of reduction in




such discharges.  These improvements will be effected within and  outside




the O'Hare Facility Area regardless of the plant location.  Therefore,




it can be assumed that one site would be no more or no less advantageous




than another in terms of impact on water quality.




     b.  Noise




          Noise generated by routine plant operation will be. attenuated




by use of acoustical building materials and mechanical devices.  Noise




will be minimized to the extent that it will not be detectable beyond the




plant limits.  Hence, the site selection process is not affected by consideration




of noise as an impact on the environment.




     c.  Visual Effect on the Surrounding Area




          The proposed O'Hare WRP is designed to have an aesthetically




pleasing appearance.  The four main buildings will have an earthy brownish




brick facing mixed with glass and precast architectural concrete.  Areas




exposed to the public will be architecturally landscaped.  In general, the




plant complex will be similar in appearance to many office parks or light




manufacturing buildings found in the surrounding areas.  Since all of the




sites considered, except Site No. 3, are within areas zoned for light





                                  3-26

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industry, the plant is visually well suited for'placement in any of the



                                               !w  i
sites considered.  Thus, site selection process'irte. not influenced to any




substantial degree by consideration of visual impact on the various sites.




     d.  Flood Potential




          In order to avoid creating flow problems with the plant discharge,




the receiving stream will be improved.  A floodplain compensating reservoir




will also be constructed to minimize the potential for flooding.




4.  Preliminary Screening of Site Alternatives




    a.  Site A, (Residential Trailer Park) Site 5, (Large Industrial




Building), Site 6 (Extensive Industrial Development) and Site 9 (Industrial




Building) are being eliminated, from further consideration since these sites




have physical structures committed to specific land uses.  USEPA believes




it would be counterproductive to tear down existing structures and relocate




existing residences and industries when acceptable vacant sites exist within




the service area.




    b.  Site 7 is being eliminated because it lies in the "clear zone" approach




to runway 9L on O'Hare International Airport.  In addition, the WRP would not




have any direct benefits for the airport.




    c.  Sites 3 and 8 are being eliminated for the following reasons:




          1)  The airport authority cannot allow the construction of a sewage




treatment facility (Site 3) on its land.  Site 8 is vacant and for sale, it




lies in DuPage County and the acceptance by DuPage County of siting a WRP in




that location would be a very time consuming process.




          2)  The construction of the WRP should occur as soon as practical




to alleviate the degradation of Weller's Creek due to combined sewer




overflows and to provide treatment capacity for the O'Hare Service Area.





                                   3-27

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                            ;
          3)  The proposed Watei: Reclamation Plant appears to be adequately

designed and will have a positive environmental impact on the water quality

of the receiving streams in the area including the Des Plaines River.

          4)  The funding of needed water reclamation plants should not be

unnecessarily delayed.  Water  reclamation plants are necessary to prevent

severe degradation of water quality and as an economic stimulus to the

local and national economy.

5.  Final Selection Process

     Both Sites 1 and 2 are owned by the MSDGC.  Each site has enough

acreage to allow plant layout  that follows sound engineering design criteria..

     Site 1 has commercial and industrial land-use on 2 sides with residential

to the north and a residential area (beyond the tollroad) to the south.

     The Northeastern Illinois Planning Commission (NIPC) has identified

actual land use by acres as of 1970.  The land use for the quarter section

within which site 1 is located follows:

     Site #1               Category                  Acres

                    Residential single family           3.6
                    Streets                            28.8
                    Vacant, agriculture, forest       126.0

     Site 2 has higher percent of commercial and industrial land use around

it and has residential areas to the North West, North East, East, South East

and South West.  NIPC land use data for the 2-quarter sections within which

site 2 is located follows:

                           Category                  Acres

                    Residential single family         2.4
                    Manufacturing                    47.1
                    Streets                          50.7
                    Trade                            16.9
                    Vacant                          186.2
                    Warehousing                       4.8
                    Hotels                            6.0
                                        3-28

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     Appendix R contains a graphical plot of population versus distance from

the center of the aeration tanks for site 1 and site 2.  From viewing this

graph it is apparent that more people (based on residences) live ir^oser to

site 1 than site 2.

     During investigations into siting alternatives USEPA looked at the

possibility of maximizing distances to residences by alternate placement

of the WRP, on sites 1 and 2 (all distances are approximations based on map

estimations).  A layout of the plant to maximize distance from aeration tanks

was assumed.  The center of the aeration tanks was used as the reference point

in determining distances.  Three options were considered:

     A) - Present WRP layout on site 1 (restricted to North of Wille Road
          by City of Des Plaines refusal to vacate) From center of aeration
          tanks to:

                                (1)  Residential area to North = 530 feet

                                (2)  Residential area to South = 2,380 feet

     B) - Alternate layout on site 1 (Wille Road vacated)

                                (1)  Residential area to North = 1,480 feet

                                (2)  Residential area to South = 1,480 feet

     C) - WRP located on site 2

                                (1)  Residential area to NE = 3,100 feet

                                (2)  Residential area ESE = 2,640 feet

                                (3)  Residential area SW = 1,840 feet

                                (4)  Residential area NNW = 1,840 feet

     After examining the above facts it appears that the greater distances from

residences achievable with Site 2 may give it an advantage with respect to the

viability of dispersed aerosols.  However, we must take all factors into


                                    3-29

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consideration in the site selection process.   Because there has been and




continues to be a critical need for this proposed project .and the associated




tunnel conveyance system, it is clear that this agency must proceed to assist




in the implementation of the proposed project as soon as possible.   Moving




to Site 2 would delay the project from several months to several years.  Since




the plans and specifications are already available for Site 1 and would need




to be revised, USEPA concurs that Site 1 is acceptable for funding under




Public Law 92-500 as the most cost-effective alternative and that it meets




the requirements of NEPA.




     Site 1 however, is subject to objections by nearby ressidents.  Some of




the major concerns expressed by local residents in the siting of the treatment




plant were the degradation of air quality due to odors being emitted from a




sewage treatment plant and the generation of aerosols during the processing




of sewage which might present a potential health hazard to the adjacent




residential communities.




     In responding to these concerns the MSDGC has prepared position papers




on health effects (Appendix I) and odor problems (Appendix J).  The USEPA




Office of Research and Development of Region V corresponded with EPA labs




concerning the status of potential and known health hazards;.  A questionnaire




was developed and distributed to people recommended by (1) USEPA staff,




(2) three individuals suggested by Mr. Richard Ward who represents the City




of Des Plaines and (3) the MSDGC (MSDGC stated their position paper would




represent their response).  The questionnaire, and responses to it can be




found in Appendix D.
                                    3-30

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     Based on all the information available, it is the conclusion of
USEPA that no demonstrable health hazard has been shown to exist with
respect to the operation of activated sludge facilities, such as the
one proposed for the O'Hare WRP.  (Evidence supporting this conclusion
is discussed in detail in Chapter 5).
     However, there is also a notable absence of conclusive scientific
evidence that a potential health hazard does not exist from the operation
of the proposed Des Plaines - O'Hare Water Reclamation Plant.  Additionally,
we must recognize the concern of the local community, expressed both at the
public hearing and through written communications, for the construction of
a facility which will not pose a risk to the public health.  The Illinois
Environmental Protection Agency has also indicated its serious concern with
the risk associated with the aerosol transmission of bacteria and viruses,
and in fact has certified this project conditioned upon provision being
made to account for this risk.  Therefore, we feel compelled to conclude
that the project as presently proposed does not fully satisfy the spirit,
intent and purpose of the National Environmental Policy Act.  As stated in
the Act itself, its purpose is to "encourage productive and enjoyable
harmony between man and his environment; to promote efforts which will
prevent or eliminate damage to the environment and biosphere and stimulate
the health and welfare of man."  The possibility here, if any, of aerosol
transmission of bacteria and viruses to the residential areas in close
proximity to Site 1 should be mitigated given the assurances provided under
the National Environmental Policy Act and the concerns of the IEPA and the
local residents.  Additionally, we feel that to introduce a large facility
into an area where none had existed before and which might possibly pose a
potential health hazard in an environment which is already severely impacted
                                  3-31

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by the degraded air quality and noise resulting from O'Hare International




Airport requires certain mitigative measures.   We believe that the most




unacceptable risks are those taken at the potential expense of public




health.  It therefore behooves us to take a conservative approach in the




application of mitigative measures.




     We shall therefore require that the MSDGC design,  construct and




maintain facilities to adequately suppress, to the satisfaction of IEPA and




USEPA, the movement of aerosols, emanating from the aeration tanks, on




the proposed site.




     With respect to odor  considerations, USEPA believes that the odor




control measures planned for the O'Hare facility will prevent problems




from occuring (See Appendix J and Chapter 5).   Should it be the case that




odor problems occur the MSDGC has indicated their willingness to take




steps to mitigate any future problem.  In a letter to this agency MSDGC




has indicated that they will take every reasonable action to safeguard the




health of the citizens they serve.




     The present buffer zone (150 feet) available on Site 1 is smaller




than MSDGC had planned.  Originally, they had  proposed that the City of




Des Plaines vacate Wille Road, allowing a larger buffer zone,, in exchange




for building a north-south road on the east end of Site 1.  USEPA believes




that a larger buffer zone would allow for additional landscaping, especially




on the northern boundary of Site 1.  Even with a larger buffer zone, however,




we still believe it would be necessary to provide adequate aerosol suppression




facilities in view of the foregoing conclusions.
                                 3-32

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p.  Other Facility Alternatives




    The following three subsystems were evaluated by the MSDGC:   con-




ventional facility at grade,  conventional facility at grade with covered




tanks, and an underground facility.  Further discussion concerning various




environmental effects will be covered by a comparative analysis  of the




effects caused by the three subsystems.









    1.  Aesthetics




        All three alternate subsystems can be designed in an aestheti-




    cally pleasant manner.  While the underground facility may have less




    than half the number of buildings, the total area of buildings com-




    pared to total site area is a small percentage in either subsystem.




    The at grade facility will have a moderate increase in the cost of




    landscaping to screen the tanks.   The covered at grade facility




    will have an added increase in cost for aesthetics, aside from the




    expense of covering the tanks.




        The at grade facility has a low density of buildings and struc-




    tures to the total site area.   The buildings are designed with ma-




    terials and form to be in harmony with the surrounding area.  They




    are arranged to serve the process and form an aesthetically  pleas-




    ing complex.   Tanks are kept low in profile, with earth bermed up




    to them where they do extend above grade.  Further, the landscaping




    has been designed to provide for both screening purposes and con-




    trolled views into the plant site as dictated by aesthetic judgment.




        The completely covered at grade facility subsystem presents a
                                 3-33

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more difficult problem to design In an aesthetically pleasing man-




ner.  The closely spaced geodesic domes which cover the sedimenta-




tion tanks are approximately 160 feet in diameter and 30 feet high




and will require more extensive use of landscaping.




    Either the at grade covered facility or the underground faci-




lity will require extensive heating and/or ventilating over and




above that required by the conventional at grade facility.  This




increased requirement will substantially affect the electrical




service station and result in an open metal structure some 30 feet




high which would be difficult to screen with landscaping.




2.  Land Use




    In reviewing the three alternate subsystems under consideration,




we find land area requirements to be virtually the same for all




subsystems.




    The completely covered at grade facility subsystem would re-




quire a greater percentage of the site to be covered with struc-




tures than the other subsystems because additional building areas




would be needed to house additional air handling systems required




for ventilating the enclosed structures.




    The underground subsystem would require four times the space




requirement for the electrical service station and emergency power




generation equipment than required by the at grade facility, but




would reduce the net site coverage by structures from the other




subsystem.  The allowable rock removal for the Niagaran formation,




in which the underground facility would be constructed approximates
                             3-34

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25%.  The effect is to spread the facilities out and, in fact, cover




an area, underground, similar to that required by the at grade faci-




lity with the 150 foot buffer zone provided.  Because numerous air




shafts and vertical exit ways would be necessary for protection of




employees, the surface site area requirements would remain the same.




The areas of land between air intake and exhaust shafts and exit




stairways could be used for park activities, such as bicycle paths,




walks, and so forth, if a local park district would join the Metro-




politan Sanitary District in a joint effort.  It is the opinion of




the MSDGC that no permanent structures for non-plant usage could be




constructed within the area of the site.




3.  Safety




    Normal safety measures are included in the design of the at grade




facility.  Life safety requirements in either completely covered




facility   would be increased because of ventilation, toxic gases




and explosive gases.  The O'Hare Tunnel Conveyance System will con-




trol the level of wastewater in the tunnel by allowing sewer over-




flows at grade when the tunnel storage capacity is reached.  This




condition could occur six times per year.  If a malfunction should




occur, the possibility of flooding the underground facility does




exist.  The requirement of meeting present code regulations for




exiting from a below ground facility would be more expensive and




more difficult.   This would require numerous vertical shafts to




grade to meet maximum travel distances.




    Many areas of an underground facility would have to be designed
                           3-35

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for explosion-proof construction.  An extensive combustible gas




detection system and lack of oxygen detection system would have




to be installed.  An extensive intercommunication and emergency




evacuation alarm system would have to be installed.




    Redundant electrical systems would have to be provided to in-




sure the utmost in reliability for critical electrical equipment,




such as elevators, sump pumps, and critical ventilation systems.




    Considering safety, it is our opinion that the underground fac-




ility is the least desirable alternate subsystem, while the other




two alternate subsystems are about equal.




4.  Consumption of Resources




    Both the covered at grade facility and the underground facility




will require a significant increase in ventilation as compared to




the conventional at grade facility.  Due to the generally lower




temperatures of the surfaces within the underground facility, con-




densation can occur on those surfaces when moist ventilation air




is introduced into the plant operation areas.  This situation will




result in wet walkways, fog, dripping ceilings, corrosion of elec-




trical fixtures and controls, and other safety and maintenance pro-




blems.  To combat this in the summer time, the air must be mechanically




dehumidified prior to introduction into the underground chambers.




In the winter time the air must be heated before introduction into




the chambers and then mechanically dehumidified and reheated prior




to discharge to avoid the formation of an aesthetically displeasing




cloud at the ground surface.  The underground facility would also
                            3-36

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require an increase  in available lighting and would require con-




tinuous operation of those facilities.




    The combined additional energy requirements  for heating, ven-




tilating and lighting of the covered at grade facility over and




above  that required  for the conventional at grade facility would




be 9,000 KW.  The cost of that energy would be approximately $35,000




per month.  The combined additional energy requirements for heating,




ventilating and lighting of the underground facility over and above




that required for conventional at grade facility would be 35,000 KW.




The cost of that energy would be approximately $150,000 per month.




    Both the covered at grade facility and the underground facility




would  require an additional air handling building at grade not re-




quired by the conventional at grade facility.  The construction ma-




terial required to cover the at grade facility is an additional




depletion of resources.  The underground facility will, at best,




use the same amount of concrete required for the conventional at




grade  facility in the areas of the aeration tanks and sedimentation




tanks, because added concrete would be required due to overbreak in




construction against rock and the advantages of common wall con-




struction in aeration tanks and of ring wall construction sedimen-




tation tanks will be lost.




5.  Construction and Cost Considerations




    The cost for mining of the underground facility is significant.




It could be related to the excavation work required for the con-




ventional at grade facility and the covered at grade facility.
                            3-37

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The volume of rock to be mined is at least four times as much as




the volume of earth to be excavated.  The cost advantage in this




item would go to the two at grade subsystems.




    The cost of labor for the building trades when working in a




mined environment performing work normally done in the open air,




is expected to increase approximately 25% over the at grade sub-




system costs.  Part of this increase would be due to anticipated




loss of productive time for movement of workers to and from the




actual work stations.




    The underground facility has the potential advantage of year-




round work on the project.  However, sufficient work on the at




grade plant probably can be put under roof by a contractor to




keep his work force busy through the cold months.  The projected




construction schedule of the underground facility is five years,




while the construction schedule of the at grade facility is three




years.




    The cost of additional safety equipment, electrical equipment,




heating and ventilating equipment and construction materials is a




disadvantage to the underground facility and the covered at grade




facility.




    Comparative Construction and Operation and Maintenance Costs




for the Three Alternate Subsystems are as follows:
                             3-38

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                                Construction Cost  Operation &
                                    $ Million      Maintenance Cost
                                	  $ Million/Year

Conventional At Grade Facility       95.0              2.85

Covered At Grade Facility           125.4              3.33

Underground Facility                197.2              5.05

    From the standpoint of construction and costs the least desirable

subsystem is the underground facility, while the most desirable is

the conventional at grade facility.  The initial design of the faci-

lity should be a conventional at grade WRP, with the addition of

adequate aerosol suppression facilities as discussed in the previous

section.
                             3-39

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E.  Process Alternatives




     The MSDGC's long range plan for process and collection facilities was




developed on a total systems approach.   Alternative methods of meeting the




needs of each of the MSDGC's sub-areas  were evaluated.   The bases  for adopting




the selected facilities plan for each of the sub-areas  were cost-effectiveness,




environmental soundness and compatibility with the total system plan.




     Four basic alternatives were considered by the MSDGC.   These  were:




land treatment, treatment and reuse, treatment and discharge,  and  no action.




Extensive consideration was given to the land treatment alternative.  It was




however rejected because of the difficulty in obtaining land on the scale




needed for the project and because of the many institutional problems




associated with its implementation.  Wastewater effluent reuse was rejected




because of technical difficulties and the adequate water supply in the




area.  No action would allow the present combined sewer overflow to




continue, resulting in severe impacts on the water quality of local streams.




     As part of the selected alternative, treatment and discharge, several




subalternatives for the provision of nitrogen removal were also evaluated.




As a consequence the proposed plant was designed as a conventional one-stage




plant or as a two stage, nitrification plant.  A detailed discussion relating




to the analysis of process alternatives can be found in Appendix L.
                                 3-40

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F.  Solids Handling^Alternatives




     Several system and subsystem alternatives were considered for processing




the solids generated in the treatment process.  Five basic methods were




evaluated for stabilizing the solids before dewatering.   These Included




anaerobic and aerobic digestion, composting, lime stabilization and thermal




processes.  After examining these alternatives heat anaerobic digestion was




selected because:  1) costs are well defined and the method is cost-effective;




2) MSDGC has design and operating experience; and 3) no  adverse environmental




effects are known to exist.




     Various mechanical solids dewatering processes were investigated by the




MSDGC for the next step in the solids handling process.   They included:




vacuum filtration, centrifugation, plate and frame filters, and the belt




filter press.  The results of an engineering and economic analysis favored




processing the solids generated in the Northwest region  of the MSDGC at a




central facility.  The John Egan WRP, in the Salt Creek  Basin to the west




of this project area, has been chosen as the sludge processing facility.




Centrifugation as a means of mechanical dewatering at the Egan WRP is




based on pilot studies recently conducted by the MSDGC on alternate  dewatering




systems at the Hanover Park WRP.




     The final solids disposal options available to the  MSDGC are landfill




and land application.  At the present time, the MSDGC uses land application




as a method of final disposal.  However, for planning purposes, both methods




are considered viable techniques.  Therefore, various combinations of solids




stabilization processes together with the two final disposal techniques, taken




singularly or together, were evaluated.  Appendix M presents a summary of the
                                    3-41

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cost analyses of the alternative disposal systems recommended for the




Egan WRP as well as a more detailed discussion of all the alternatives




considered, including environmental considerations.   The John E.  Egan WRP




is presently nearing completion and is expected to go on line in September




1975.  Until centrifuges are installed (in approximately two years)  sludge




will be transmitted via interceptor to the MSD Northside plant and then on




to the WSW plant where it will be placed on barges and sent to Fulton County




for land application.  By the time the O'Hare plant becomes operational




sludge will be dewatered with centrifuges at the John E. Egan WRP and then




either spread on land as a fertilizer or hauled to a landfill site for




final disposal.
                                   3-42

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                               CHAPTER 4




                   DESCRIPTION OF THE PROPOSED ACTION




A.  Treatment Facilities




     The O'Hare WRP will be designed as a two stage activated sludge process.




Carbonaceous matter will be removed in the first stage followed by biological




oxidation of ammonia to nitrite and nitrate in the second stage.  Final




effluent polishing and disinfection prior to discharge into the rerouted




Higgins Creek will be accomplished by dual media filters and sodium




hypochlorite, respectively.




     The O'Hare WRP will also provide complete treatment for combined sewer




overflow entrapped and stored by the O'Hare Tunnel System.  Capacity for the




treatment of stored combined sewer overflows is inherent in this design as




the design parameters take into consideration peaking requirements and as the




combined sewer overflow elimination system will provide a flow equalization




capacity.  As a consequence, the treatment of steady state dewatering flows




up to 1.5 times average dry weather flow will be possible within the required




dewatering time ranges.




     All of the waste activated sludge generated in this plant will be pumped




via force main to the John E. Egan WRP for treatment and disposal.  The




decision to treat O'Hare WRP sludge at the John E. Egan WRP was based on




economic and engineering feasibility studies which favored a central sludge




processing facility for those two facilities.




     The anticipated average dry weather flow by the year 2000 is 72 mgd.




The construction of O'Hare WRP will proceed in two stages.  The first stage




of construction is now  designed to treat an average dry weather flow of 72 mgd




The ultimate design capacity is 96 mgd.
                              4-1

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     The plant Is proposed to be located on a 104 acre site north of North-




west Tollway and east of Elmhurst Road.




     Detailed design data is given in Appendix M.  Figure 4-1 shows the site




plan for the plant.




B.  Effluent Disposal System




     The O'Hare WRP  will discharge its effluent to the relocated  Higgins Creek




on the plant site in the vicinity of the relocated creek and Wille Road via




a concrete culvert system sized for two  times the ultimate plant  design flow




of 96 mgd.




     The discharge from the O'Hare WRP will comply with the Illinois Pollution




Control Board (IPCB) criteria of which the significant regulations are a 5-day




BOD of 4.0 mg/1, a suspended solids content of 5 mg/1, an ammonia-nitrogen




level of 1.5 mg/1, and a fecal coliform  concentration of 400 counts/100 ml.




     The dissolved oxygen level of the effluent will be sufficiently high to




support warm water biota.




     Plans are now being made by the MSDGC to improve Willow and  Higgins




Creeks downstream of the O'Hare WRP to provide for the peak plant effluent




and storm flow conditions.  The Higgins  Creek Channel on the plant site will




be rerouted to aid in the arrangement of treatment units.   Willow-Higgins




Creek channel modifications are intended to begin at the east side of the




Lee Street Reservoir (1/2 mile east of Lee Street) and continue to a point




approximately 1/4 mile south of Higgins  Road.  With the reservoirs in place,




the maximum flow in the improved channel would be limited to approximately




1200 cfs at the end of the improvement.   The Creek will be relocated into a




concrete lined channel on the proposed site.  About 300 feet of the channel




will be completely enclosed.  This channel improvement, in conjunction with
                              4-2

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the reservoirs, will protect if or the 100-year storm event.   Without the




reservoirs and channel improvements, flooding can be expected at a frequency




of once every two years.   The channel improvement will convey 120 cfs of




flow whereas the peak flow, without any improvement, is in  the area of 2500 cfs




for the 100-year storm.   Flood flows would cover Mannheim and Higgins Roads.




The commercial facilities adjacent to the Creek would be flooded.   Residential




areas south of Higgins would be flooded with flows seeking  to pass downstream




using the existing streets.  Flows enter the lower levels of buildings




filling the sanitary sewers with storm flows and flooding other basements




through sewer backups.  The Ravenswood Reservoir, Lee Street Reservoir sites,




and the area of Willow-Higgins Creek channel improvements are shown on




Figure 2-5.




     A storm water retention basin may be located on the plant site and would




be integrated with the development of the facility.   The retention basin would




entrap and control the increased runoff due to the development of the site




and would provide for the storage lost in the site development.




C.  Solids Disposal System




     As indicated previously all the waste activated sludge will be pumped via




a pipeline to the John Egan WRP for further processing.  The proposed pipeline




route is illustrated in Figure 4-2.




     Stabilization of solids will occur in four 110-foot diameter digesters




designed for high rate anaerobic digestion.  Mechanical dewatering of the sludge




will be accomplished by centrifugation.  The sludge will then be disposed of




either in a landfill operation or spread on land by manure  spreaders.
                               4-4

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4-5

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                               CHAPTER 5




               ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION
A.  Water
    1.  Water Quality




         There will be a beneficial effect on the waters of Weller's Creek




    and Feehanville Ditch by the reduction in the frequency and volume of




    the combined sewer overflows to those waterways.




         Long term benefits for the waters of Higgins Creek are available




    so long as the Water Reclamation Plant is properly operated.  A constant




    flow from the WRP with 6 mg/1 of dissolved oxygen will provide a swift




    moving well aerated stream which will support warm water biota where an




    intermittent sluggish stream presently exists.




         Using the modified Streeter-Phelps equation found in lEPA's "Guide-




    lines for Granting Exemptions from Rule 404(c) and 404 (f) Effluent Stand-




    ards" (Draft of 10-23-74) the MSDGC calculated dissolved oxygen concen-




    trations and prepared a Dissolved Oxygen Profile Graph (Figure 5-1)  for




    Higgins Creek and the Des Plaines River assuming the following parameters:




                Water Quality of the Des Plaines River for the Year 2000
D.O.
NH3-N
BOD5c
BODultc =
Flow
6.0 mg/1
1.5 mg/1
10 mg/1
25 mg/1
84 MGD


Theoretical concentrations
Resulting from
Plants in Lake

new treatment
County

         Two sets of parameters were considered for effluent from the O'Hare




    WRP for the year 2000.





                                 5-1

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                                                    'i'  '   MI    ! i"".  ;
                                                    ::-^-r- ts1-irit^t


                                                              ITJ""'1 r(T -fTTT 'tt]1 t : : :
                                                              -t-H--f-t-f-4 i—-'-H-M-M i-! i ' -
rv^j-r^lt

-------
       The solid lines reflect effluent parameters of:




             BOD      =        10 mg/1




             SS       -        12 mg/1




             NH3-N    -       2.5 mg/1




       The dashed lines reflect effluent parameters of:




             BOD      =        4 mg/1




             SS       *        5 mg/1




             NH3-N    -      2.5 mg/1




       As the Dissolved Oxygen Profile Curve indicates, the effluent of




BOD - 4, SS - 5, NH3~N =2.5 has the most beneficial effect on the receiving




streams.




       The effluent standards that will be required for the O'Hare WRP are




BOD - 4mg/l, SS * 5mg/l and NH3-N = 1.5mg/l.  Although the D.O. curve was




modeled at NH3~N = 2.5mg/l, Higgins Creek has a 7 day-10 year low flow of




zero which requires that the stream standards of 1.5 mg/1 of NH_-N become




the effluent standard.  This will further decrease the nitrogenous oxygen




demand and result in a lesser D.O. sag than indicated by the dashed lines.




       The environmental impact of discharging the indicated effluent will




be beneficial on Willow-Higgins Creek and the Des Plaines River.  Higgins




Creek has an almost constant D.O. of 6 mg/1 or greater.  The Des Plaines




River with O'Hare effluent at about 4 mg/1 BOD,- level would have oxygen




levels from 3 to 6 mg/1.  A possible secondary benefit may be the addition




in the future of industrial users of the plant effluent downstream of the




plant.




       Most of the buildings and structures of the proposed at grade O'Hare




Water Reclamation Plant will not extend below the Pleistocene glacial




                                 5-3

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deposits.  In the O'Hare Drainage Basin, these deposits are intimately




bound with clays and do not act as aquifers.  The construction of these




buildings and structures will have only a minimal and very local effect




on ground water in the overburden soils.




       The plant site is underlain with Niagaran dolomitic limestone.




Decayed and eroded limestone mixed with clays and some sand are found




about 90 feet below the surface.  This layer is about 20 Eeet thick,




beneath which Is the bedrock limestone having a thickness of about 100




feet.  The proposed deep pumping structures will penetrate this bedrock.




       The proposed construction may have a very local effect on the




water in the dolomite channels.  However, nearly all areas adjacent to




the plant site are in Des Plaines, Mount Prospect, or Elk Grove, in




which municipal water supply is available.  The O'Hare Oasis on the




Northwest Tollway purchases water from Des Plaines, as will the MSDGC




for use in the O'Hare Water Reclamation Plant.




       The plant should not create any significant effect on the area




ground water because the Niagaran dolomite in the O'Hare Drainage Basin




is a poor aquifer and is not used for municipal or industrial use being




relatively thin and with few large crevices and solution channels.






2.  Water Quantity




       The existing system of intercepting sewers in the O'Hare Service




Area divert sanitary and combined flows out of the Upper Des Plaines




River Drainage Basin to the MSDGC North side Sewage Treatment Plant.  (Com-




bined Sewage Overflows discharged to Weller's Creek and Feehanville
                               5-4

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    Ditch flows into the Des Plaines River.  This flow will be appreciably




    diverted to the WRP Plant for processing).  The North side Sewage Treat-




    ment Plant discharges its treated effluent to the North Shore Channel




    of the Chicago River.  (See Figure 5-2).  This Channel flows into the




    Chicago River and then into the Main Channel of the Chicago Sanitary




    and Ship Canal which joins the Des Plaines River below Lockport, Illinois.




           The proposed Water Reclamation Plant will discharge its treated




    flows to Higgins Creek which is Tributary to the Des Plaines River.  By




    constructing the proposed WRP in the O'Hare Service Area, treated sani-




    tary and combined sewage effluent will return some natural flows to the




    Des Plaines River.








B.  Air Quality




         The construction of the O'Hare Water Reclamation Plant on Site 1 will




have two potentially adverse effects on the air quality of the area.  These




are the increased possibility of odor and aerosol generation with the potential




for health implications.  Each of these effects and proposed mitigative measures




will be summarized briefly below.  A more detailed discussion of odors at the




O'Hare WRP can be found in Appendix J.  The aerosol issue is examined in




Appendix S.




    1.  Odor Generation




        One of the major issues expressed by local residents against the




    construction of the O'Hare WRP is the potential odor problem.
                                  5-5

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             COOK
  I      _£°°J!_	COUNTY
 C3 TREATMENT
    WORKS
mm mm mm CHANNELS  CONSTRUCTED TO
       REVERSE FLOW AWAY FROM LAKE
         FIGURE  5-2
                                                      CALUMET STORM PUMPSTA.—7
                                                   ^""w. (125th STREET)     /,
                                                       I              III         I

                                                       j      COOK   /  	  /f°.UNI	i
                                         5-6

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    The design of the proposed water reclamation plant incorporates




several madifications of the conventional wastewater plant to either




eliminate an odor source or control potential odor sources.  As n




result of an economic study, discussed in Chapter 3, sludge will be pumped




to the John Egan WRP for treatment and handling.  This eliminates the




sludge thickening, digestion, and handling facilities which are the




principal sources of possible odors.




   The major potential sources of odors at the O'Hare facility will be




the following locations:




    a)  Raw sewage pump station wet well




    b)  Screening and grit storage area




    c)  Scum handling area




    The most effective method of odor control is to prevent the escape




of the pollutant to the atmosphere.  This is economically accomplished by




eliminating the odor at its source or collecting the odor producing sub-




stance and treating it prior to its release to the atmosphere.  The O'Hare




WRP has been provided with several facilities to achieve the above objective.




    A pre-chlorination facility has been provided to chlorinate the raw




sewage as it enters the treatment processes.  Chlorine reacts with the




odor-producing substances such as lUS and other sulfur compounds through




oxidation which results in chemical compounds devoid of any unpleasant odor.




Chlorination will be accomplished utilizing a commercial sodium hypochlorite




solution.




    The proposed treatment plant will also contain two packaged ozone




generating units.  The units are designed to treat exhaust air from the pump
                                 5-7

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station wet well and from the screenings, grit and scum areas.  The




ozonation system has also been designed so that the ozone concentration




in the discharged air will always be zero.  Electronic monitoring and




control equipment will be installed to detect and control emission




quality.




    Screenings, grit and scum will be collected in such methods as to




prevent the leakage of the noxious gases emanating from them into the




atmosphere.  They will be separately enclosed in areas which will be




temperature controlled to inhibit formation of odors.  Exhaust from




these areas will be conducted to the ozonation chamber to insure




complete deodorization.




    At the present time, it is not possible to judge the exact extent




of the potential odor problems resulting from the operation of the proposed




O'Hare Water Reclamation Plant at Site 1.  Given the extensive control and




pperational measures described above, it cannot be assumed that this plant




will experience the odor problems associated with obher MSDGC facilities.




If significant odor problems result from operation of the proposed plant,




it would be possible to take necessary mitigative measures at that time.




2.  Aerosol Generation




    It should be noted that many previous studies have been made of bac-




teria, virus, and toxic materials originating in sewage treatment pro-




cesses.  Any one of these studies taken as a separate isolated situation




might be interpreted as a potentially alarming problem to someone not




directly involved in the utilization of such information.  The Public
                               5-8

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Health Service and many medical groups have been carefully scrutinizing




these individual problems for many years for the purpose of avoiding the




development of epidemics or similar catastrophic problems related to the




general public.  Reliance must be placed in the hands of such Public




Health officials to take these individual pieces of scientific informa-




tion for their respective values and to put them into perspective in




terms of public need.  For us to attempt to make such an interpretation




at this time, is not in the interest of everyone concerned because of




the many areas of this type of research which are presently incomplete.




We therefore recommend diligence in the pursuit of this missing informa-




tion but also recommend avoiding conclusions that are not justified based




on known facts at this time.




    An extensive literature survey was conducted to determine the extent




of the present knowledge on aerosol generation and its health implications.




A summary of this survey can be found in Appendix S.




    It can be seen that there are innumerable factors which control the




viability and infection potential of microorganisms commonly found in




wastewater aerosols.  To conclude that the presence of these aerosols will




positively result in a public health hazard is not supported by scientific




evidence.  Since it is equally unsupportable to reach a conclusion that a




potential health hazard does not exist for the residents in close proximitv




to Site 1,  we find that in order to accomplish the intent and purpose of the




National Environmental Policy Act mitigative measures are required to




adequately suppress aerosol transmission from the aeration tanks.  Should
                                  5-9

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     evidence become available that these additional facilities are not

     sufficient, we would require, and MSDOC has indicated its willingness

     to implement, whatever additional initiative remedies are necessary.



C.    Land

       Existing land uses are the WRP and site selection alternatives

for the WRP have been discussed in Chapter 3.

       The construction of the WRP at site 1 is planned with improvements

to Higgins Creek and accommodation for the existing flood^lain.

       The use of the proposed site is consistent with the Northeastern

Illinois Planning Commission's (NIPC) Regional Wastewater Plan, March

1971.  The Village of Des Plaines has zoned the site for light industrial

development.   The area north of Oakton Road, north of the site, is an

established single-family residential area with a population of over 8,000

persons.

       Ultimate land use forecasts by MSDOC indicate development for the

       service area of over 65 square miles to be:

       Residential and Commercial            29,382 acres

       Industrial                             7,378 acres

       Open Spaces                            5,000 acres
       (includes cemeteries)

Employment and land use forecasts based on recent NIPC population projections

(350,000 in the year 2030) have not yet been determined.  This project will

not substantially induce a change in either existing or proposed land use.

The suburban Chicago location, pro«imity to the airport and location of trans-

portation systems will continue to influence development patterns within the area.


                                      5-10

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       The City of Des Plaines has raised several objections to the




 location of the WRP at Site 1 for over nine years.  Recently, the Citv




 requested information from the U.S. Department of Housing & Urban Develop-




 ment  (HUD) regarding mortgage insurance, to support its contention that the




 location of the treatment plant near an existing residential area was unsound




 environmentally, socially and economically.  Several portions of HUD Handbooks,




 included in the Appendix of this statement, discuss the location of sewage




 treatment plants in regard to proximity to residential areas.  These HUD Guide-




 lines include:  HUD Handbook 4135.1, Subdivision Analysis and Procedures for




 Home Mortgage Insurance, January 1973; HUD Handbook 4140.1, Land Planning




 Principles for Home Mortgage Insurance, May 1973; HUD Handbook, 4940.3, Minimum




 Design Standards for Community Sewerage Systems, November 1972; HUD Valuation




 Handbook, 4150.1, April, 1973.  HUD Guidelines relate to new residential sub-




 divisions, existing and new homes, as well as basic land planning principles




 which are considered by HUD offices when evaluating applications for home mortgage




 insurance.  In addition, DesPlaines references the Recommended Standards for




 Sewage Works, 1971 edition of the ten member states of the Great Lakes - Upper




Mississippi River Boatfd of State Sanitary Engineers, Chapter 40 of this reference




 is included in Appendix U.




       Our review of applicable HUD regulations and guidelines and discussions




with the HUD Chicago Area Office indicates that there are no specific or fixed




 "isolation distances" which HUD requires between residences and treatment plants;




 rather,  each case is carefully studied for each particular Instance (including




size of  plant and type of treatment).
                                  5-11

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       HUD Handbook 4135.1 (January 1973) states "...the best means of assuring




protection against possible odors is to provide adequate spaces between the




residential properties and the sewage treatment plant."  In the case of Site #1,




the width of Oakton Street (the northern boundary of the site) would be the




fixed distance from existing MSDGC property lines to the property lines of the




residences along Oakton (approximately 100 feet).




       A review of the HDD correspondence received by the City of Des Plaines




in response to their inquiry, (and summarized in Chapter 6) indicates that HUD




has strong concerns, nationwide, regarding mortgage insurance of homes located




near sewage treatment plants.




       MSDGC should consider all steps to maximize distances between process




facilities of the WRP and the surrounding homes.  HUD considers the existence




of "offensive" conditions in the valuation and marketability of homes to be




insured; the possible decrease in value of homes adjacent to the proposed WRP




has been considered.  While USEPA feels there may be a temporary decrease in




market value during the construction of the WRP, any long-term decrease will




be negligible.  The site is located near O'Hare airport which effects air and




noise conditions; and is zoned for light industry.  Similar impact on land




values should occur whether the site is developed for light industry or for




the water reclamation plant.  Once constructed and landscaped, the site should




be consistent with long range land use objectives of the area.
                                  5-12

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D.  Biology




       Construction of the sewage treatment facility will substantially




remove and alter the site vegetation.  This will result in the loss of




most of the site's animal habitat.  Increasingly intensive land use has




reduced the number of suitable locations for wildlife in this suburban




area and reduces the opportunity for migration to another site.  This




loss would be long term and reversable only with extensive replanting




of a large area.  Landscaping will help compensate for the loss incurred




with facility construction, and to many persons will be more attractive




than the present appearance of the site.




       The sludge pipeline route passes through rights-of-way along




roads and through Forest Preserve right-of-way.  Vegetation removed




during construction can be replaced to mitigate this adverse effect.




       Rerouting and enlarging Higgins Creek and construction of a




compensatory flood storage basin will eliminate the natural stream and




flood plain configuration and affect the aquatic and flood plain biota.




Silt from the whole construction site will also erode into the stream,




although this should be greatly reduced by the use of detention ponds.




Upon completion of construction, aquatic plants and animals will




reinhabit the affected stream reach by migration from upstream, if




appropriate habitat is present in the new channel.
                                5-13

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       The long term effect of this project will benefit water  quality




and the stream biota by greatly reducing combined sewer overflows and




producing a high quality effluent.







E.  Environmentally Sensitive Areas




       Flood plains at the proposed project site will be gresatly altered,




with site grading and the construction of a storm retention reservoir.




       A portion of the solids pipeline will traverse Forest. Preserve land.




This right-of-way will have little adverse impact upon park land and




these effects will be corrected upon completion of construction, after




re-vegetation.







F.  Aesthetics




       The appearance of the sewage treatment facility should be comparable




to other low profile industrial buildings in the O'Hare area and compatible




with the site's present industrial zoning.  Particular attention must be




paid to grading and landscaping of the site following construction,  so as




to maximize the ground level visual screening on the northern and eastern




sides of the site.  Gently rolling terrain and the attractive use of trees




and shrubs will enhance the visual qualities of the site, and any adverse




visual impact of the facility itself will be reduced by this vegetative




screen.
                                 5-14

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       Construction will generate noise and dust and temporary site




disarray from earth moving and building activities.   These  adverse




effects are short term, ending with the completion of construction.




Similar temporary adverse effects will occur with the sludge pipeline




installation, with the effects mitigated by restorative vegetation.




       The noise during the operation of the facility will  not be




heard outside of the buildings.  The air blower units which are




expected to produce decibel levels from 100 to 110 are being isolated




in individual sound proof cubicles and provided with noise  attenuating




devices to protect the operating personnel.  Plant service  areas and




in-plant vehicle parking will be handled in internal courtyards to




help reduce noise and visual impact.  Extensive provisions  have been




made in this project for odor control at key odor generating points,




as has been discussed previously.






G.  Operating Personnel




       The greatest hazard faced by the personnel employed  at the O'Hare




Water Reclamation Plant would be any toxic or explosive gases to which




they would be exposed.  The main gases in the toxic group include




gasoline vapors, carbon dioxide, and hydrogen sulfide.




       Gasoline reaching the sewage plant usually comes from garages




and industrial plants.  Though generally not a serious men,ace  to




employee's health,  concentration of vapor in the suction chambers of




pumping stations can reach dangerous levels.  The odor of gasoline is




perceptible when the air contains 0.03 percent by volume.  A concentration






                                 5-15

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of about 1.0 percent is the most a person can tolerate;  concentrations




varying from 2.0 to 2.4 percent by volume are fatal.




       Decomposition of organic materials produces  carbon dioxide.




The gas is prevalent in sewers but the concentration rarely exceeds




1.0 to 1.5%.  Concentrations of 4 to  6 percent cause considerable




discomfort while concentrations of 7  to 10 percent  may be fatal.




       Hydrogen sulfide is a by-product of sewage and sludge de-




composition.  Parameters that affect  the production of this gas




are the sulfate content, the temperature, the age and the strength




of the sewage.  Hydrogen sulfide acts both as an irritant and an




asphyxiant, affecting the respiratory and the central nervous system.




Concentrations of 0.01 to 0.015 percent (100 to 150 ppm)  cause




slight symptoms of discomfort after several hours of exposure.




Gas levels of 0.1 to 0.3 by volume (1000 to 3000 ppm) are fatal




within a few minutes.




       The explosive gases frequently observed at sewage treatment




works are hydrogen sulfide, gasoline  vapor and methane.   Hydrogen




sulfide is produced in sludge gas in  quantities too small - 0.0 to




0.1 percent to cause an explosion. However, it is  undesirable in




that it may attack steel with the formation of iron sulfide.  When




iron sulfide is oxidized in the presence of air, sufficient heat  may




be formed to cause ignition.  The ignition temperature of hydrogen




sulfide varies between 346 to 397°C.   Flammability  limits in air  are
                                5-16

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43 to 46 percent by volume.




       The presence of gasoline in sewage can create a serious




explosion hazard primarily in sewers, in the suction wells of




pumping stations and in covered grit chambers and sedimentation




tanks.  Gasoline has an ignition temperature of 300 to 500°C and




flammability limits are 1.4 to 6.0 percent by volume in air.




       Methane is produced as a result of anaerobic digestion of




sewage solids.  Since sludge will not be processed at O'Hare WRP,




methane will be found only in small amounts in the raw sewage




and the sludge pumping station.  An air mixture containing 5.0




to 19.0 percent methane or 5.3 to 19.3 percent sludge gas is




explosive.  The ignition temperature of methane is 645°C.




       Due to numerous variables such as pH, temperature, and




sewage strength, it is difficult, if not impossible to calculate




the concentrations and quantities of toxic and explosive gases




which will be generated at O'Hare WRP.  However, it may be generally




stated that such gases are normally present in extremely small




concentrations.  Consequently, normal safety measures such as




combustible gas detection/alarm and ventilation systems are employed




to eliminate any possible dangers arising from these gases.
                              5-17

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H.  Impacts of Solids Processing




       The general purpose and methods of  sludge  disposal  investigated




by the MSDGC have been discussed in previous chapters.




       Mechanical dewatering of sludge by  centrifugation has  been




chosen for the John E. Egan WRP.  The sludge can  then be disposed




of either in a landfill operation, or hauled as cake and spread  on




land by manure spreaders.




       The installation and use of centrifuges will not  result in




pollution or turbidity of the receiving waterway.  No heated  or




malodorous gases emitted outside of the building  enclosure because




odor control facilities are included in the design of the  installation.




There will be no instances of non-compliance with State  or Federal




air pollution control regulations.  In summary, this process  merely




concentrates sludge, which is an unavoidable product of  sewage treat-




ment, into an easier to handle less voluminous product.




       The ultimate disposal of the sludge will be by either  landfill




or application to land as a fertilizer. The use  of sludge as a  landfill




will not have any detrimental effects on the surrounding area.




       The application of stabilized dewatered sludge on land will return




nutrients to soils which have been removed by farm crops.   Therefore,




the addition of dewatered sludge to the soil completes  the "natural cycle",




When crops are grown, they consume the organic material  and the  nutrients
                              5-18

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     of the soil during their growth.   Man consumes these farm products




     for his growth and life.  Some of these organic materials and




     nutrients reappear as human or animal wastes.   When applied to the




     soil the organic materials and nutrients,  consumed in the production




     of crops, are returned.
I.   Adverse jj^acts which cannot be avoided should the proposal be implemented,




     and steps to minimize tiarm to the environment.




            Implementation of the proposed project will have several adverse




     impacts.  Adverse construction impacts include the destruction of site




     vegetation,  temporary decreases in water quality due to runoff from the




     site, and noise from truck and equipment operation.  Although the site




     will be landscaped after completion of construction, large portions of the




     natural vegetation (existing grasses, trees and shrubs) will be lost, some




     of which, however, will be replaced by different species.  Temporary holding




     ponds may need to be constructed to reduce the silt reaching Higgins Creek.




     Should these prove to be inadequate, additional control measures will be




     used.  Noise will be attenuated by standard muffler and exhaust systems.




     Construction will also be restricted to regular working hours.  The re-




     routing of Higgins Creek on Site #1 will result in a temporary water quality




     impact, but  this will only be of a short duration.  In general, the water




     quality will be improved because of the increased flow.




            Two potential adverse Impacts resulting from the operation of the




     WRP involve  the generation of adors and/or aerosols.  In order to mitigate
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     any odor problems,  the process  units  most  likely to  generate odors  will




     be in enclosed structures  and  the  exhaust  air  treated  with  ozone.   All




     sludge processing will take place  ftt  the John  E.  Egan  WRP,  thereby  avoiding




     any odor problems from this source at the  O'Hare WRP.   While aerosols will be




     generated at the WRP,  we believe that it cannot  be demonstrated that any




     health hazard will  result  from the transmission  of these aerosols.




     However, since there is alas an absence of evidence  that a  potential health




     hazard does not exist, we  believe  a conservative approach is required to




     mitigate any potential risk.  We shall therefore require the MSDGC  to design,




     construct and maintain such additional facilities as necessary to adequately




     suppress aerosol transmission from the aeration  tanks, subject to the




     approval of IEPA and USEPA including demonstration by  MSDGC of effectiveness




     of aerosol suppression.






j.   The relationship between,  local short term  uses of  man's environment and the




     maintenance and enhancement of long term productivity.




            The construction and operation of  the proposed  water reclamation plant




     will result in efficient treatment of sewage generated in the O'Hare Service




     Area and a general  improvement in the water quality  and reduction in pathogens




     in Weller's Creek,  Feehanville Ditch and the receiving strearn-Higgins Creek.




     By improving the water quality of these streams, the overall water quality of




     the Des Plaines River should also be enhanced.  To accomplish this improvement




     in surface water quality a committment to energy consumption necessary to




     operate the proposed  facility  (flow through the WRP is projected to be 72 MGD




     by the year 2000) and the removal from the tax roles of approximately 104 acres
                                      5-20

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    of land zoned as light Industrial will be required.  In addition to the




    immediate benefit of water quality enhancement, the proposed facility




    will allow the projected growth in the O'Hare service area to occur with




    sufficient capacity for sewage treatment.







K.  Irreversible and Irretrievable committments of resources to the proposed




    action should it be implemented.




          Two classes of irreversibility and irretrievability nedd to be




    identified in evaluating the committment of resources.  Class I is the




    irreversible and irretrievable decisions that cannot be reversed such as the




    expenditure of energy.  And Class II committments are the decision's to




    commit resources which are not likely to be retrieved or reversed during the



    useful life of the project.




          Class I committments resulting from the construction of the proposed




    WRP include the capital costs, energy,  and labor necessary to construct and




    make operational the proposed facility.




          Class II committments for the proposed WRD include:  the operational




    requirements of chemicals,  energy,  mechaaical equipment, labor, the use of




    104 acres  of land zoned as light  industrial and the tax loss associated




    with alternate uses  of the site.   Higgins Creek will be relocated on the site




    and channelized where relocation  is unnecessary.   The habitat for typical



    urban wildlife such  as birds,  rabbits,  field mice, etc. will be diminished.
                                     5-21

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L.  Recommendations






    1.  Fuftding the proposed Water Reclamation Plant on Site 1 is




acceptable to USEPA, provided the recommended mitigative measures




are implemented.




    2.  Present knowledge on the potential health hazard from aerosol




generation is inconclusive.  Consequentially, we believe it is




necessary to provide aerosol suppression facilities on the proposed




aeration tanks in order to suppress the movement of aerosols from




Site 1.  We feel this conclusion is justified with any facility




configuration on Site 1.  Should later evidence demonstrate that these




measures are not sufficient, we will require and MSDGC has indicated its




willingness to Implement, additional, necessary mitigative remedies.




In order to further assure the implementation of this finding, it will




become a special condition of the grant agreement between USEPA and




MSDGC for the proposed Des Plaines - O'Hare WRP.




    3.  In order to ascertain the effectiveness of the aerosol suppression




facilities, we believe it is necessary for MSDGC to demonstrate the level




of aerosol reduction to be achieved by the suppression facilities.  This re-




quirement will ben condition of any grant made to the MSDGC for the




proposed WRP.




    4.  Our review of the odor control measures proposed by the MSDGC




leads Os to the conclusion that there will not be any significant odor




problems originating for the proposed facility.  Should any odor problems
                                  5-22

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arise, the State of Illinois has the requisite administrative and enforcement




ability to affect the resolution of these concerns through facilities of




the IEPA, IPCB, and the Illinois Attorney General.  The USEPA will provide




such assistance as the circumstances may warrant and require.
                                5-23

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                      CHAPTER 6
             FEDERAL/STATE AGENCY COMMENTS
               AND PUBLIC PARTICIPATION
The comments received and our responses will be divided into three
sections.  They are:  1) March 31, 1975 Public Hearing; 2) written
comments of a lengthy nature; 3) shorter comments and letters.  In
responding to these comments we have referenced any revisions or addi-
tions we have made in the text of the EIS.

A.  Oral Testimony at Public Hearing

     1.  Dr. Hutton Slade, City of Des Plaines

"My presentation today will confine itself to the possibility of a health
hazard being involved Ln the location of the O'Hare water reclamation
plant, and other aspects of that immediate problem."

"It seems to me that we have two basic factors to consider.  One of which
is based upon the information that we have about the activities, the
biological properties and the pathogenic activities of microorganisms
which we might be expected to be transmitted in aerosols and secondly,
is it possible that these aerosols will transmit these pathogenic organisms
from the 0"Hare Plant to the surrounding community.  And these are the two
basic decisions which we have to rely upon in order to make a final judg-
ment on this case.

"There have been many changes in the activities of pathogenic microorganit....'
over the years, and I would like to really divide my presentation into
three parts.  The first has to do with these activities which we are ava,- -,
of, the second would be the transmission of these organisms, and the thi •
is what possible hazards are we facing?  I have listed here the number oJ
characteristics of the historical pattern of pathogenic microorganisms.
The activity  of these organisms are very much of importance as far as t^
possibility of transmission goes.  And the general pattern today, and tl «
control of pathogenic disease due to bacteria and virus is not one tna: .,
becoming easier.  In fact, it's becoming more difficult for a number cf
reasons.  We also know that pathogenic microorganisms in some cases ha.v._
practically disappeared from our lifestyle.  For example, scarlet fever
diptheria, we very seldom hear of these diseases today, but yet these
organisms are present in the population, and they do arise at odd tic:e:: .
depending upon the situation in which they find themselves.  We also
know that these organisms are ready and waiting in other characteristics
to infect people under situations which may be appropriate for those
microorganisms.  We also know that we are identifying new organisms fror,.
time to time.   A new virus present in the intestinal tract of man was
                              6-1

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just announced last year.  The techniques of the laboratory are being
perfected to this date that we can expect in the future to isolate
more organisms which today we have no means of identification for.

"Another problem in regard to the control of microorganisms, I am
emphasizing these points in view of the fact that if transmission is
possible, then what are they factors which we have to control Oucii
infections when they reach the patient?  In the case of antibiotics,
microorganisms are becoming more resistant to antibiotics every day.
These organisms undergo genetic change.  The genetic cbange which
brings about a resistance to antibiotics.  Resistance to penicillin by
staphylococci in our hospitals today is very much of an important
problem.  Some of the organisms which we find in the intestinal tract of
man such as Salmonella, Shigella, Proteus, Pseudomonas, these organisms
have been known to develop genetic resistance to antibiotics and to
pass these resistances from one cell to the next, and to build up a
maximum of twelve antibiotic resistances in a single bacterial cell.
If these organisms are the ones that are going to be transmitted in
aerosols, then we are going to have important problems to consider.  In
some cases the activity in regard to resistance to antibiotics has
increased 25 times, and maybe some of you have read recently that
meningococcidal meningitis, which used to be always susceptible to
sulfadiazine, is now resistant to this drug.

"Another factor which we hear mentioned in consideration of aerosol
problems by various people in the field is the subject of virulence.
Virulence is a term which relates the activity of an organism to produce
disease.  Virulence does not indicate in itself the. extent of virulence.
An organism can be low in virulence an organism car: be high in virulence.
But as organisms are passed through animals or through people, they
build up increased virulence.  And so the possibility of these types of
organisms being transmitted in aerosols is something also that we must
keep in mind.  A continued passage through the intestinal tract of man
in attempts to increase the virulence of these organisms, the ones which
we do consider and which we do know to occur in the intestinal tract.
Most of the data which is in the literature relates to Escherichecoli
as an indicator of pollution.  This has been the organism which has
been considered For this type of assay for many many years, but
actually, I think that we are looking at the wrong organisms.  Because
E. coli, even though it is a potential pathogen, is not very frequently
found in human disease.  We need in the future to examine, the occurrence
of streptococceae and staphylococci and Proteus and Pseudomonas as possible
indicators of transmissions of infection when we are considering aerosols
from the typo, of treatment plant which is proposed for construction
close by here.

"How many bacteria are viruses or viruses are needed to cause an
infection?   This is a subject which is practically unknown.
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We have no  information  to  actually rely on .-;.-3 co i'Le number oi part-
icles of virus  or  ;'v number  of  bacterial  cells «i id, can r.ause disease,
After all,  we dcr't ar.ve very many volunteers for iblb type of work, so
we understand it  Is readily understood that we do not have very much
information, and  if we  did have  the information, ic would not apply to
all of us.   It  would only  apply  to the so  called normal individual,
and that would  probabl; not include all of us, because we ail have
different nutritloral states  and resistance to infection, ana other
conditions  which are re.-r   , -;ible for the establishment of an infection.

"Another important  ;.  ml which I had in my nufe., '"or this presentation
this afternoon  was  thti  subject of an article in t.ajs norning's Tribune
by the science  writer who  is  attending a congress,  a cancer congress in
California,  tie wrote about a report given yesterday of a friend of mine
and he spoke about  the  I'acL that viruses can rer-air: ctermant: in the cells
of humans for many  years,  and at some time later th-av are triggered to
develop into a  full blown  type of infection.  And ffiiti if. one of the
important points we h«v*e to consider in aeroscl  transmission, because
we are talking  about .he transmissions of  small siumbers of organisms, but
the Important; point i -  ff.  these  virus particles can hide away in ourselves,
at various  Limes, anc  ^:-..t  chat bacteria could likewise do a similar thing.
So this is  a very Impo?.t-,nt thing, point I believe  in this type of con-
sideration  for  transmission by aerosol.  I brought along some slides with
me, but I don't dxi:cJ,i it is worthwhile showing them,  I had listed on
these slides some of the .important pathogenic organisms which occur in man,
in the intestinal tract, and  which,  of course, are then distributed into
the feces and may eventually  reach the aerosol droplets which are in-
volved in transmission.  It is known from  the literature in a limited
number of studies and the  data certainly is not sufficiently extensive as
we would like,  but  ii has  been proven that under certain conditions of
wind velocity,  temperature, humidity and that sort of, with those different
variables,  the  viable bacteria have been isolate-:; as fai as 8/}Oths of
a mile away from a  sewage  treatment plant.  This vas trie longest distance,
actually determined by  these  workers at thr.t; time.   Ot.ier studies have
proven that aerosols containing  pathogenic microvrgaai^ms have been
isolated at distuTicce of 100,  200,  300 feet.  These organisms in these
particles,  in these cercsoi droplets,  shov; ditferen-:; rates of dl£j of dec-"...1,
or loss of  viability, depending  upon certain ciu.rac'cer-lsit-cs of environmei'.
at that time.   But  it is apparent that these orgaait>ms can be transmit tad
in these aeroaals for a limited  distances.

"Viruses are a  very important aspect of the problem which we are con-
sidering here in odd it ion  to  bacterial,  because many of oar viruses are
present in  Che  intestiaal  tract.   Viruses  which ire know today to cause-
intestinal  upsets,  respiratory problems, and Lhe^e oth^r different dif-eaiv
related co  these conditions which we habitually find in our communities in
the winter  time.  Virus transmission by aerosols has been accomplished in
the lab very readily.   The number of virus particles required to produce
an infection, as i  said earlier,  is somewhat very poorly defined, and
really is not considered to be - - I cannot give you, really, a figure
as to the number of  virus  particles which  would be responsible for tha
infection because all the  laboratory work  has been done with aniuiuls, and

                                 6-3

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it is very risky to relate such data from animals to human beings.
Now the average human will inhale about ten cubic meters of air in
24 hours at rest.  And with exercise, this can increase up to 150
cubic meters.  And if we take the figure somewhere in between say
50 cubic meters of air a day of exercise and a day of rest, we can
take from the data which I have cited, a 10,000 count of viable
bacteria per cubic meter, at 100 foot, or 100 feet from a sewage
treatment plant.  And on other data, based on other data, wt. ecu.'d
some up with a figure of a half a million viable aerobic bacteria
inhaled in a 24 hour day, at a rate of 50 cubic meters a day.  Now
the drinking water standards which were set many years ago, rather
imperilly, I suspect, limited the number of E. coli, per litre of
water to ten E. coli cells.  Now if we assume that we ingest say two
litres, which is a low figure I would suspect, maybe three could be
better, we come up with 30 or 20 E. coli cells per consumption per
person today - - per day.  And the ordinance of the  City of Des Plaines,
their standards that they are requesting are two cells E. coli cells per
cubic meter of air entering the village or the city limits.

"Just a few words about EPA questionnaires, the EPA requested the
opinion of a number of persons as to the possibility of a health
hazard in respect to this proposed plant.  Out of the eight opinions,
five said yes, there is a potential health hazard.  Two said there
was too little data to make a conclusion, and one said that there
have been no outbreaks with workers associated with such treatment
plants, and, therefore, they felt that there was no possiblity of
health hazards.  The EPA includes in their impact statement that
the presence of 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 aspect.  In respect, in consideration of their state-
ment, they do not say yes or they do not say no as to a public health
hazard.  The Argonne study has given, as far as the O'Hare Airport
operation is concerned, has given figures which were obtained in 1972
on the carbon dioxide, the total hydrocarbons and nitrous oxides in
the particulate matter in the atmosphere, at O'Hare Airport.  The
nitrous oxides exceeds the accepted standards, the National Ambient
Air Quality Standards by two or three time depending upon the location
at the plant.  Now these hydrocarbons and these nitrous oxides are
substances which are going to irritate tissues of the human body, in
the lung, certainly, they will cause inflammation of the cell.  They
will cause leakage of cell fluids, they will promote the adherance of
a pathogenic bacteria to these cells.  The adherance of the bacteria
and their growth will be promoted by cell tissue fluid, which may come
from the inflamed tissue, and the penetration of the viruses into such
cells would certainly be increased - - the possibility of penetration
would be increased.  How do we visualize the public health hazard in
this situation?  It is not one, this type of transmission, aerosol
transmission of bacteria and viruses is not one that possibly or
most likely would result in a large number of people being involved
in any one time.  But I visualize it as a consistent low level of
disease which would be related to the health of the person, the
various individuals in the community.  These which are in ill health are

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certainly most likely to be the ones who would ha effected by such
aerosol transmission.  The aged and the affirmed, the people with
respiratory weaknesses would certainly be most likely to become infected
by this aerosol transmission.  The MSB and their impact statements quotes
from the Committee on Infectious Diseases of the American Association of
Pediatrics in 1974.  The ingestion of Picornaviruses very seldom results
in anything more serious than transient infection of the elementary tract.
Well that is just the pol
-------
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

                       6-7

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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

                       6-9

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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
                          6-10

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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.
                          6-12

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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
                      6-13

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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
                      6-14

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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
                      6-15

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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
                       6-16

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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.
                       6-18

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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.
                                        6-19

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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
                         6-20

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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.
                         6-21

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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
                         6-22

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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
                       6-23

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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

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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

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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

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 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

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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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                                                            MoncNy Fobruj''y I/
       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
                                                                                         .
                                                                                         C
                                                                                         O
                                                                                         X3
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                                                                                         C
                                                                                         ffl
                                                                                         2L
                                                                                         Q.
               Richard F. Ward
                                    0)
> 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
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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,
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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

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          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

-------
                     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

-------
         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

-------
     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   
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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

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    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

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 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,

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        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

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        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

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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

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 ,
 &          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

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            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

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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.

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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

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    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,

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'-*!>>  #
            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

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    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

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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?

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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
$
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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

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                                          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

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                                          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.

-------
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
-------
                                 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.

-------
                                   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 
-------
   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

-------
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

-------
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

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               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

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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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/w  ,
                                   6-148

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JL
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-------
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                                                             k*n
             un<«rat«nrf
the M.S.D. wfe«n tfc«y
is f«v«T">bl« (if n«t
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                                6-150
                                                          I

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                                                         DC

-------
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                             6_153

-------



-------
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     £-.2^0 /2 -fiz^i^L a^xi&f. aja^^^^u
                 ^  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

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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  • 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.

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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
                               .Recycled Paper

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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
                           Recycled Paper        .  r,,rlj_.  •  	„.

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V
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
                                           Recycled Paper

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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

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                           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
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                          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

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                                                . 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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