Document Vm9Lom6eEJ5aGV4a7NjJ2Eyw
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
230 SOUTH DEARBORN ST. \ CHICAGO. ILLINOIS 00604
CERTIFIED MAIL RETURN RECEIPT REQUESTED
Honorable Paul Sauget Mayor of Sauget Sauget, Illinois 62201
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. MAY 27 1977** ^
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I. Dear Mayor Sauget:
Rei Request Pursuant to Section 308(a) of
the Federal Water Pollution Control Act, As Amended, 33 U.S.C. S 1318(a) and Section 114 of the Clean Air Act, As * Amended, 42 U.S.C. * 1857(c)-9.
Present Information available to the United States Environmental Protection Agency (U.S. EPA) Indicates that the Village of Sauget Is discharging polychlorinated biphenyls (PCB's) from Its outfalls 001 and 002 Into the the Mississippi River. In addition, due to the principal Iy Industrial character of the wastes received by the Village treatment system. It may be expected that other potentially toxic, persistent chemicals are being discharged unidentified through the outfalls. In order to help achieve this Agency's Congressional mandate of restoring and maintaining the chemical, physical and biological Integrity of the nation's waters by setting reasonable pretreatment and effluent limitations. It is extremely Important that a precise analysis be made of the discharges.
Therefore, pursuant to the authority provided by section 308 of the Federal Water Pollution Control Act, as amended, 33 U.S.C. 1318, and section 114
of the Clean Air Act, as amended, 42 U.S.C. S 1857(c)-9, I request that the following investigation. Including sampling and monitoring, be conducted by the Village and the reports thereof be submitted to me by the dates speci fied herein:
I .A. Sauget shall effectively monitor the operation and efficiency of all treatment and control facilities and the quantity and quality of the treated discharge. Monitoring data shall be summarized on an average calendar month basis, and individual reports for such summaries are to be submitted on a monthly basis to the United
States Environmental Protection Agency, Region V, Enforcement Division, Attention: Engineering Unit.
Monitoring as described herein Is required for discharge 001,
and for 002 only when overflow occurs. Both discharges shall be monitored until December 31, 1977.
DSW 355860
STLCOPCB4085449
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The analytical and sampling methods used shall conform to 40 C.F.R.
Part 136, 41 Federal Register 52780, dated December f, .1976, which
cites the following: .
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1. Standard Methods for the Examination of Water and Wastewater.
14th Edition, 1976, American Public Health Association, Washington. D.C. 20036.
2. A.S.T.M. Standards, Part 31, Water,
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1973, American Society for Testing and Materials, Philadelphia,
Pennsylvania 19103.
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3. Methods for Chemical Analysis of Water and Wastes. 1974, U.S. Environmental Protection Agency, Office of Technology Transfer, Cincinnati, Ohio 45202.
Analytical procedures not covered In the above references can be obtained from the Environmental Monitoring and Support Laboratory, U.S. EPA, Cincinnati, Ohio 45268, (513) 682-7301. Different but equivalent methods are allowable If prior written approval from the U.S. EPA Is obtained.
Sauget shall periodically calibrate and perform maintenance procedures
on all monitoring and analytical Instrumentation to Insure accuracy
of measurements.
8. The data collected and submitted sha11 be taken at the following test frequencies and shall Include the following parameters:
(mg/1 Except Where Indicated)
Frequency
Total Flow, mgd
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BOO, 5 day
Suspended Solids
pH (Units)
Fecal Collform, H per 100 ml
COD
Total Dissolved Solids
011 and Grease
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Total Copper
Cyanide
Total Mercury
Total Lead
Total Zinc
Total Ntckel
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Total Iron
PCB's
Dally Dally Dally Dally
1 x Weekly Dally 2 x Weekly 2 x Weekly 2 x Weekly 2 x Weekly -
2 x Weekly 2 x Weekly
2 x Weekly 2 x Weekly 2 x Weekly
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l/See Part 11.A. for PCB monitoring requirements.
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Sample Type
Continuous 24-Hour Composite 24-Hour Composite Continuous Grab 21-Hour Compos Ite 24-Hour Composite Grab 24-Hour Composite 24-Hour Composite 24-Hour Composite 24-Hour Composite 24-Hour Composite 24-Hour Composite 24-Hour Composite y
DSW 355861
STLCOPCB4085450
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Samples and measurements taken as required herein shall he representative of the volume and nature of the monitored discharge. .... .,.
5 . Effluent values are to be determined by a 24-hour composite sample consisting of several effluent portions collected in a 24-hour period and composited
according to flow. For fecal col!form bacteria, a sample consists of one effluent portion collected during a 24-hour period.
i C. The date and time of sampling, the sampling method used, the date the analysis was performed, the analytical test procedure
used, the name of the analyst performing the test, the name and address of the laboratory where the test was performed, and the
result of the required analysis shall be recorded for each sample.
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II. Based upon present Information, Monsanto Chemical Intermediates
Company appears to be the principal discharger of PCB's Into the
Sauget treatment plant. Monsanto has stated Its Intention to
cease all production of PC8's by August 31, 1977, and has further
stated It will cease distributing PCB*s by October 31, 1977.
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i Sauget shall carry out the following monitoring program to determine i what effect. If any, this PCS production and distribution el Imlnatlon
program has on the PCB*s discharged from Sauget*s Sewage Treatment
Plants
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A. Pr ior to PCS product Ion shutdown
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Polychlorinated Biphenyls
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Sampling Location \
I. Sauget Effluent
2. Sauget Influent
Frequency I x Week I x Week
Sample Type
24-Hour Vertical Iy Integrated Composite
24-Hour Vertically Integrated Composite
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3. Sauget
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a. Separated Oil
and Grease b. Sludge .
As necessary to establish a mass balance
at the Sauget Sewage Treatment Plant and an average concentration.
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-4, Dead Creek and 18" Village Sewer
As necessary to establish average loads from these sources.
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DSW 355862
STLCOPCB4085451
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Sampling Location
Frequency Sample Type
Same requirements as stated In 11 .A. 1.-4. above.
5. Such other sampling as is needed to determine the existence of contaminated sewers qr runoff areas.
1M. Sauget shall determine the physical Integrity of the sewers which carry the production wastes from Monsanto*s PCB facility to the
Sauget Wastewater Treatment Plant and submit the results no
i later than June 30, 1977. '
IV. A. The following Information regarding all sludges, slurries,
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screenings, and other solids which are generated by the treatment facilities shall be submitted no later than
June 30, 1977s
1. The amount of sludges, screenings, slurries, and other solids collected on a dally, monthly or annual basts;
2. The name and address of each sludge transporter, the methods of transportation, and the amounts of sludge transported; and
3. A description of the ultimate sludge disposal. Including the .j site and method of actual disposal.
B. The following Information regarding all separated oil and grease generated by the treatment facilities shall be submitted no later
. than June 30, 1977s
1. The amount of waste oil and grease collected on a weekly, monthly or annual basis;
2. The name and address of each waste oil and grease trans
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porter, the method of transportation, and the amounts of waste oil and grease transported; and
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3. A description of the ultimate waste oil and grease disposal, , Including the site and method of actual disposal.
WrMM&
sw 355863
STLCOPCB4085452
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V. For each Industrial facility which discharges Industrial waste
' water to the Sauget collection system, Sauget shall provide all i of the following Information no later than September I, I977i
A. For each full-scale production operations
I. A general description of the production operation}
2. The Identity qf the product(s) and. If a chemical,
i4 the chemical name and formula using stondord chomlcal
nomenclature}
3. The identity of all raw materials used in the production operations and If a chemical, the chemical name and formula using standard chemical nomenclature}
B. All chemical substances, other than those listed In Item (A)
above, which the industrial facility has reason to believe might
be present In the industrial wastewater, based on a thorough exami
nation of the production operations. For chemical operations,
this shall Include all possible side reactions, feedstock 1m-
purities, or other possible contaminants}
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C. The dally volume of wastewater discharged to the Sauget collection system;
D. All results of any chemical analysis which has been performed on
the wastewater stream; and
E. A description of any pretreatment which Is provided by the in ' dustrlal facility. .
VI. The Information requested must be provided notwithstanding Its
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possible characterization as confidential or a trade secret. Should you so request, however, any Information (other than effluent or emission data, which by law must be made available to the public) which the Administrator of this Agency determines
. to constitute methods, processes, or other business Information
entitled to protection as a trade secret will be maintained as confidential, pursuant to the procedures specified In 40 C.F.R.
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Part 2 (41 Federal Register 36902, September I, 1976). Please *
Indicate clearly or submit separately any portion of the response
you consider to be confidential or a trade secret, since any data
V not so Identified will not be accorded this protection by the
Agency.
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DSW 355864
STLCOPCB4085453
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VII. All reports and Information required herein are to be submitted to the United States Environmental Protection Agency, Region V
. Enforcement Division, Attention* Engineering Unit. -
Very truly yours.
II
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David Kee, Acting Director Enforcement Division
*. cct Mr. Richard J. Kissel
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Martin, Craig, Chester &' Sonnenscheln ,
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i * Iil DSW 355865
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STLCOPCB4085454