ILLINOIS

POLLUTION

CONTROL

BOARD

August

8,

1972

City of

LaHarpe

)

v.

)

PCB

72-168

Environmental

Protection

Agency

City of Carbondale

V.

PCB 72-203

Environmental

Protection

Agency

~

City

of

Marion

)

v.

)

PCB

72-225

Environmental

Protection

Agency

Opinion

and Order

of the

Board

(by Mr.

Dumelle)

The

three

applications

embrace

a

common

topic

and

ask

a variance

from

the

water

quality

standards

to

permit

the use

of

copper

sulfate

in

their

drinking

water

reservoirs

to prevent

algae

nuisances.

The

Agency has

recommended

a grant

subject

to

certain

conditions

and we

concur

for

reasons

given

later.

City

of

LaHarpe

The

City of

LaHarpe

in

Hancock

County

has

a population

of

1,240.

The

petition

for variance

was

received

by

the

Board~

on

April

21,

l9~?2and a hearing

held

in LaHarpe

on

July

14,

1972.

The

reservoir

is

10 acres

in

area,

has

an

average

depth

of

15

feet

and

a

capacity

of

45

million

gallons.

The

Agency

report

by

Ronald

W.

Jahns

indicates

that

copper

sulfate

treatment

at

this

reservoir

has

been practiced

since

at least

1949.

The

Agency

report,

which

was

stipulated

to

by

the

City

of LaHarpe,

cites

excessive

algae

growth

two years

ago

with

clogging

of

the

filter

bed,

improper

settling

in

the

clarifier

and numerous

complaints

of taste

and odor

from

users

of the

City’s water.

Dosages

of

300

to

600 pounds

of

copper

sulfate

applied

5-~-

115

---

—2-

In the usual way of

towing

the

crystals

in

a sack behind

a motor boat have

stopped

the problem.

It is further

stipulated that no

fish

kills have

been

caused by the copper

sulfate treatment

and

that the reservoir

is

well stocked with fish.

The

concentra-

tions

of copper

resulting from the treatment

are

given as 0.3

mg/l for

300 lbs.

of chemical

used

and

0.6

mg/l for

City of Carbondale

The

City of Carbondale,

population 22, 816,

is

in

Jackson County.

The

variance petition

was received

May

ii,

1972.

No

hearing

has

been

held.

The

reservoir

is

144 acres

In area with an

original

average

depth of 9.6

feet.

Original

capacity was

350

mIllion gallons

which the Agency states

Is

now

330

million

gallons.

The

City of Carbondale,

in Its petition,

states

that excessive

algae

growth

produce taste and

odor

problems

In the water

supply.

Use of copper

sulfate

In the reservoir,

which is used as water

supply

Intermittently when

Crab Orchard Lake is low,

has been 4,900 lbs.

in 1969,

4,

700 lbs.

in 1970

and

5,100 lbs.

in

1971.

The

statement is

made that no

fish

kills

have

occurred in these three years.

The

Agency

recommend

applications of 1.700 lbs.

per treatment

and

states that the

copper levels

will

not exceed

City of Marion

The

City of Marion,

population ii,

724,

is

In Williamson

County.

The

variance petition

was

received by the Board

on June 2,

1972.

A public hearing

was held on July

27,

1972

in

Marion.

The variance Is requested for the large

reservoir

about four miles

south of Marion which is

stated to

have

a

capacity

of 482

million gallons.

No

area or

average

depth is

given.

Mr.

Russell

Fisher,

thief

operator of the Marion water plant testified

that

copper

sulfate had been

applied for the past

six

years

to his knowledge

to this reservoir.

Commissioner

Paul Joyner in

his

petition for the

variance

discusses

an algae bloom

condition

In April of this year which

caused the

drinking water to be

“unfit to drink” because of taste

and

odor

problems.

He

also

stated that some $2, 500

in

activated carbon had to be

used to treat the water

that month.

In his testimony

on this point he

stated

that copper

sulfate would have been lower

in cost

had

Carbondale been

able to

use It.

No ifi

effects

on aquatic life because of copper

sulfate treatment are

known

to Mr.

Joyner

or

Mr.

Fisher.

The

Agency recommends

up to 4,000 lbs.

of copper

sulfate per treatment

every

six

weeks

and

states that concentrations will

not

exceed 0.3

mg/i as copper.

5—116

---

—3-

Discussion

The

Agency

recommendations

in these

three

cases

are

virtually

identical.

A grant

of the variance

is

recommended

and dosage

limits

are

specified.

We

concur

in

the grant

but

do

so

reluctantly

because

of

what

appears

to be

an

in-

complete

discussion

by

the

Agency

or

by

the various

cities

of

alternative

methods

of treatment

or

of possible

harm.

However,

the

algae

bloom

season’

is

now

almost

over

and no

discernible

harm

from

using

copper

sulfate

appears

in

these

records.

Ample time

remains

before

next

summer

for

both

the

Agency

and all

Illinois

water

supply

users

to prepare

fuller

discussions

on

both alterna-

tive

methods

and possible

harm

from

the present

practice.

The

Agency

recommendations

state

flatly

that the

“only

alternative

to use

of

copper

sulfate

for

algae

treatment

is

chlorine.

‘~

In

the

Marion

hearing,

Mr.

Dennis

Stover,

representing

the

Agency,

affirmed

this

opinion,

Yet a highly

respected

sanitary

engineering

text,

Water

Purification

and Wastewater

Treat-

ment

Vol.

2

by

Fair,

Geyer

and Okun

(1968)

lists

three

other

methods

for

algae

control.

These

three

methods

are

(1)

spreading

of activated

carbon

on

the

reservoir

surface

to

shut

out

sunlight

(2)

dosing

with lime

in

amounts

sufficient

to produce

caustic

alkalinity

to

deprive

the

algae

of

needed

carbon

dioxide

and

(3) use

of viruses

selective

to

algae,

(33-41

to

33-47).

Two

other

references

provide

information

on

possible

additional

alterna-

tives,

A

paper

by

Symons,

Weihel

and Robeck

in

Water

Quality

Behavior

in

Reservoirs

by

the

U. S.

Department

of

Health,

Education

and

Welfare

(1969)

mertions the possibility

that

algal

toxins

may have

inhibited

algae

blooms

on

the

Ohio

River

(p.

19).

An

article

by

howard

in Reclamation

Era

(February

1972)

(p.

6-7)

describes

how air

injection

into

Casitas

Lake

near

Ventura,

California

brought

coaler

water

to the

surface

and thus

inhibited

algae

growth.

The

annual

costs

for

copper

sulphate

and citric

acid

treatment

of the

reservoir

were

$20, 000 and

dropped

to

$12, 000

for

air

injection

(exclusive

of

capital

charges).

It is

possible

that

none

of

the

alternatives

listed

above

are

suitable

for

application

in the

instant

cases.

But nothing

in the

records

of these

cases

showed

that

they were

considered

by

any of

the

parties.

The

record

i.s

not

clear

on

whether

these

reservoirs

are

“flow-through’

impoundments.

If these

reservoirs

feed

streams

below them,

then

the

high

copper

concentrations

proposed

(0. 6

mg/i)

may

destroy

some

forms

of

aquatic

life.

McKee

and

Wolfe

in their

authoritative

work,

Water

Quality

Criteria,

report

“.

.

.

concentrations

(of

copper)

of

0.

015 to

3.

0 mg/i

have

been

reported

as

toxic,

particularly

in

soft

water,

to

many

kinds o~

fish,

crustacea,

mollusks,

insects,

phytoplankton,

and

zod~lankton” (p.

171).

Clearly

a biological

survey

is

indicated

in the

streams

below

these

reservoirs,

if any

such

streams

exist,

to

determine

which

may have

occurred

in

the past

from

the use

of

copper

sulfate.

5—

1

i

7

---

-4-

Lastly

no

data

are presented

by

any of

the

parties

as

to the possibility

of limiting

these

algae

blooms

by

limiting

a critical

nutrient,

such

as

phosphorus.

In

adopting

the

revised

Water

Quality

Standards

(R7l-l4)

on

March

7,

1972

we

set

a phosphorus

limit

for

reservoirs

and lakes

at

0.

05

:mg/l

to prevent

just

such

obnoxious

blooms.

The

Agency

should

investigate

phosphorus

concentrations

in

the

instant

reservoir

waters

and

take

action

to

reduce

controllable

upstream

phos-

phorus

inputs

under

its

powers

to

abate

water

quality

standards

violations

if

such

are

found to

exist.

The

Federal

Environmental

Protection

Agency

in

its

letter

of July

10,

1972

(entered

into

the

City

of

Marion

record)

makes

the

point

that

nutrient

removal

upstream

may

well be

a superior

alternate

method

of eliminating

algae

blooms.

We

ought

not

to pollute

and

then

be forced

to poison

to

eliminate

the

effects

of

the

pollution.

And the

fact

that

the

Agency

requests

in its

recommen-

dations

data

on

copper

levels

in

each

reservoir

before

and after

copper

sulfate

treatment

leads

us to believe

that

data

of

this

type

are

lacking.

Perhaps

what

is

needed

is

a research

study

by

the

Institute

for

Environmental

Quality

which the

Agency

might

well

request.

In recent

months

we

have

found that

old

practices

are

not

necessarily

environmentally

sound

practices.

Metallic

mercury

discharged

in

effluents

is

converted

in

sediments

by bacteria

to

the

highly

toxic

methyl.

mercury

which

is

then

concentrated

into

fish

flesh.

Copper

sulfate

usage

may

have

some

environ-

metal

consequences

which

are

undesirable

and

about

which

we know

little

on

the

basis

of these

records.

Fair,

Geyer

and Okun

sum

up

the

case

against

chemical

treatment

succinctly:

There

is

a growing

awareness

of

the

dangers

of

indiscriminate

and

largescale

use

of chemicals

for

the

destruction

of

specific

popu-

lations

of

living

things.

It

is

generally

true

that

dislocations

of

biological

equilibria

should

be

avoided

where

possible.

Useful

or

otherwise

wanted

members

of

normal

plant

and

animal

communities

should

not

be

killed.

Relief

from

nuisance

growths

or

otherwise

runaway

proliferation

of

unwanted

organisms

should

not

be

obtained

at that

price.

Thinking

has

turned

more

and

more

to

the

promotion

of

biological

self-regulating

mechanisms

that

will

right

the

imbalance

and

not

create

a

new

imbalance

---

in ab-

normal

ecological

systems.

The

introduction

of

specific

parasites

that

keep

unwanted

components

of

the

plant

or

animal

community

in

check

is

one

example.

Breaking

the

food

chain

or

otherwise

modifying

the

existing

environment

to

the

disadvantage

of the

organisms

to be

controlled

is

another.

Biological

control,

in

5—118

---

—5--

comparison

with

chemical

destruction,

is

more

likely

to

be

a

reversible

or

an

incomplete

reaction.

Equilibrium

is

restablished

of

its

own

accord.

Damage

does

not

become

irrevocable.

An

important

example

is

interference

with

the

biological

destruction

of

bottom

deposits

when

lakes

and

imp~

)undages

ar-c

treated

with

copper

salts.

(p.

33—37)

rJ~j~

opinion

constitutes

the

Board’s

findings

of

fact

and

conclusions

of

law.

0

RDER

Variances

are

granted

to the

cities

of

Marion,

Carbondale

and

LaHarpe

to

exceed

the

water

quality

standard

of

0.

02

mg/I

in

their

water

supply

reservoirs

by

treating

with

copper

sulfate

to

prevent

algae

blooms

subject

to the

following

conditions:

1)

Dosage

shall

be

limited

as

follows:

a)

For

Marion,

to one

treatment

every

six

weeks

until

November

30,

1

972

not

to

exceed

4,

000

lbs.

of

copper

s

U fate

per

1

realm ent.

I))

F~o

r

(arhondal

e,

to one

treatment

during

August

1

972

not

to

exceed

1,

700

lbs.

of

copper’

sulfate.

r)

Vor

Lailarpe,

to

one

treatment

per

month

for

the

months

ot

August

through

November,

1072

not

to

exceed

600

lbs.

of

copper

sulfate

per

treatment.

2)

Copper

concentrations

at.

the

raw

water

intake

to

the

water

treatment

plant

shall

never

exceed

1.

0

mg/i.

3)

(opper

concentration

in

the

reservoir

shall

be

measured

immediately

before

and

after

each

copper

sulfate

treatment

and

the

results

subriiitted

to

the

Agency

on

a

monthly

basis.

I,

Chri stan

L.

Mnffett,

Clerk

of

the

Illinois

Pollution

Control

Board,

hereby

certify

the

above

Opinion

and

Order

were

adopted

by

the Board

on

-,

‘~

day of

August,

1972

by

a

vote

of

.3

~

6:~L~

L

~1//)

~

~

Christan

L.

Moffett,

~It~k

Illinois

Pollution

Control

Board

5

—

119