1021 NORTH GRAND AVENUE EAST, P.O. Box] 9276, SPRINGFIELD, ILLINOIS 62794-9276-( 217) 782-3397
JAMES R. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601
- (312) 814-6026
ROD R. BLAGOJEVICH, GOVERNOR
DOUGLAS P. SCOTT, DIRECTOR
(217) 782-5544
Dorothy M . Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite . 11-500
Chicago, Illinois 60601
Re :
Springfield Metro Sanitary District (Sugar Creek Wastewater Treatment Facility)
(Provisional Variance)
Dear Ms. Gunn :
Attached please find a letter from the Illinois Environmental Protection Agency (Illinois EPA) granting a
provisional variance to Springfield Metro Sanitary District for its Sugar Creek Wastewater Treatment
Facility, effective upon the District removing its tertiary pond from service for cleaning . The Illinois EPA
is hereby submitting the letter to the Pollution Control Board for publication
.
Thank you for your
assistance in this matter. If you have any questions regarding this matter, please contact the assigned
attorney, James Day, at (217) 782-5544
.
Sincerely,
Connie L. Tonsor
Associate Counsel
Division of Legal Counsel
Attachment
ROCKFORD-4302 North Main Street, Rockford, IL 61103-(815) 987-7760
DES PLAINS-9511 W. Harrison St., Des Plaines, IL 60016 -(847) 294-4000
BON-595 South State, Elgin, IL 60123-(847) 608-3131
•
PEORIA-5415 N. University St., Peoria, IL 61614-(309) 693-5463
BUREAU OF LAND - PEORIA - 7620 N. University St., Peoria, IL 61614-(309) 693-5462
CHAMPAIGN -2125 South First Street, Champaign, IL 61820- (217) 278-5800
SPRINGFIELD-4500 S . Sixth Street Rd., Springfield, IL 62706-(217) 786-6892
••
COLLINSVILLE - 2009 Mall Street, Collinsville, IL 62234 - (618) 346-5120
MARION-2309 W. Main St., Suite 116, Marion, IL 62959-(618) 993-7200
PRINTED ON
RI( VI [ID
PAPER
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
RECEIVED
CLERK'S OFFICE
JUL 2 4 2006
STATE OF ILLINOIS
Pollution Control Board
IEPA 07-002
ILLINOIS ENVIRONMENTAL. PROTECTION AGENCY
July 20, 2006
Springfield Metro Sanitary District
)
Sugar Creek Plant
)
Petitioner,
)
v
.
)
IEPA - 07-02
(Provisional Variance-Water)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent.
)
Re
:
Provisional Variance to discharge all effluents thru
Outfall 010 for treatment plant maintenance
.
Dear Mr. Slead :
The Agency has completed its technical review of the attached provisional variance
request submitted by The Springfield Metro Sanitary District for the Sugar Creek
Wastewater Treatment Facility (Sugar Creek W WTF) on July 5, 2006 and revised on July
19, 2006 .
Based on the review, the Agency GRANTS the requested variance subject to specific
conditions set forth below for a period of 45 days
.
The Sugar Creek WWTF is located at 3300 Mechanicsburg Road, Springfield, Sangamon
County, Illinois . Dry weather flows to Sugar Creek WWTF receive treatment through a
system consisting of bar screens, aerated grit removal, flow measurement, activated
sludge, secondary clarifiers, and a tertiary pond . Dry weather flows discharge to Sugar
Creek through Outfall 008 . The design average flows for secondary treatment is 10 .0
MGD and the design maximum flow is 25 MGD . Excess flow treatment is provided by a
primary clarifier, chlorination and an excess flow pond . Excess flows, flows above 25
MGD up to 100 MGD, discharge to Sugar Creek through Outfall 010
.
The tertiary pond is currently in need of need of cleaning due to over 30 years of silt and
solids build up . Petitioner is proposing to divert all flows
, secondary treated flows and
any excess storm water flows, to the excess flow pond with discharge to Outfall 010
while this essential maintenance work is completed . Petitioner predicts that 26,300 cubic
IEPA 07-002
yards of solids materials will be removed from the tertiary pond during the variance
period. With the removal of this material the tertiary pond will be returned to its original
designed volume and depth .
NPDES Permit IL0021971 issued to the Springfield Metro Sanitary District Sugar Creek
W WTF requires the following monitoring and effluent limits
:
OUTFALL 010
Parameter
CONCENTRATION
LIMITS mg/L
Monthly
Daily
Average
Maximum
BOD5
Suspended Solids
Fecal Coliform
Daily Maximum Shall Not Exceed 400 per 100 mL
Chlorine Residual
0.75
OUTFALL 008
Petitioner is requesting interim limitations of 30 mg/I for CBOD and total suspended
solids and 7 .0 mg/I for ammonia nitrogen during the 45 day provisional period
.
Sample
Frequency
Daily When
Discharging
Daily When
Discharging
Daily When
Discharging
Daily When
Discharging
CONCENTRATION
LIMITS mg/L
Monthly
Daily
Sample
Parameter
Average
Maximum
Frequency
CBOD5
10
20
2 Days/Week
Suspended Solids
12
24
2 Days/Week
Ammonia Nitrogen
as (N)
:
April through October
1 .5
4.0
5 Days/Week
November through March
3.0
5 .4
5 Days/Week
IEPA 07-002
The Agency has reviewed the requested provisional variance and has concluded the
following
:
1 . The environmental impact from the requested relief should be minimal
:
2. No other reasonable alternatives appear available
;
3. No public water supplies will be affected
;
4. No federal regulations will preclude the granting of this request ; and
5. Springfield Metro Sanitary District will face an arbitrary and unreasonable
hardship if the request is not granted
.
The Agency hereby GRANTS the Springfield Metro Sanitary District a provisional
variance for its Sugar Creek W WTF to be allowed to discharge all flows through Outfall
010 subject to the following conditions :
A. The provisional variance will begin the date the tertiary pond is taken out
of service and continue for 45 days
;
B. During the term of the provisional variance the effluent being discharged
from
Outfall 010 shall not exceed 30 mg/l CBOD, 30 mg/I total
suspended solids and 7 .0 mg/1 ammonia nitrogen ;
C. Effluent sampling during the term of the provisional variance shall be
performed in accordance with the Sampling and Reporting of Plant
Discharges document attached to the petition for provisional variance ;
D. Springfield Metro Sanitary District shall notify Roger Callaway of the
Agency by telephone at 217/782-9720 when the tertiary pond is taken out
of service and again when it is returned to service
.
Written confirmation
of each notice shall be sent within five days to the following address :
Illinois Environmental Protection Agency
Bureau of Water - Water Pollution Control
Attention : Roger Callaway
1021 North Grand Avenue East, MC #19
Springfield, Illinois 62794-9276
IEPA 07-002
E .
Springfield Metro Sanitary District shall sign a certificate of acceptance of
this provisional variance and forward that certificate to Roger Callaway at
the address indicated above within one day of the date of this order . The
certification should take the following form
:
I(We) , hereby accept and agree to be bound by all
terms and conditions of the provisional variance granted by the
Agency in dated
Petitioner
Authorized Agent
Title
Date
Springfield Metro Sanitary District shall continue to maintain compliance with all other
conditions specified in its NPDES Permit No . IL0021971 .
.
The Illinois EPA grants this provisional variance in accordance with its authority
contained in Sections 35(b), 36
(c), and 37(b) of the Illinois Environmental Protection
Act (415 ILCS 5/35(b), 36(c), and 37(b) (2004) . The decision to grant this provisional
variance is not intended to address compliance with any other applicable laws or
regulations
.
Robert A .
essina
Chief Legal Counsel
cc :
IPCB, Clerk
IEPA 07-002
3017 North Eighth Street
Springfield, Illinois 62707
=
217528-0491
TEL
pp
217-5280497
FAx
~'
smsdluliet Qaol.com
f-MAI
IAWA
MEMBER
Illinois
Association of
Wastewater Agencies
If you have questions, comments or you need more information, please contact
Jeff Stead at 217-528-0491 or 217-306-6991 (Cell)
Sincerely,
Attachments: Pond Sounding Chart
Flow Pattern and Sampling Diagram
Jeff W. Stead
Operations Supervisor
CC: Tim Zook
Al Keller
Board of Trustees
Richard T. Ciotti
Roger Callaway
Date: 7-5-2006
President
Anthony P. Libri
Vice President
Darryl W.
Harris
Illinois Environmental Protection Agency
BOW CAS#19
1021 North Grand East
P.O. Box
19276
Clerk
Tim Timoney
Trustee
James W. Flemming
Trustee
Bruce Stratton
Attorney
Robert A. Alvey
Director/Engineer
Zeyn B. Uzman, P.E .,
S .E
.
District Engineer
Paul Ed Vehovic
Treasurer
Springfield, Illinois 62794-9276
Dear Sir,
Please find attached a proposal for cleaning the tertiary pond at the
Sugar Creek Facility of the Springfield Metro Sanitary District . The proposal
includes a description of the work to be performed, cleaning time frame and
sampling of effluents. Also attached are diagrams of the pond sounding data
showing the deposits that need removed and of the flow pattern that will be used
for discharges from the secondary and excess flow systems .
We are looking to start this project as soon as possible to take advantage
of the drier summer weather .
IEPA 07-002
Springfield Metro Sanitary District Proposed Sugar Creek Tertiary
Pond Cleaning
TERTIARY POND DRAINING AND CLEANING
:
The Sanitary District proposes to clean the Sugar Creek Facility tertiary pond of
the 30+ years of silt and solids build up . In order to take advantage of dry weather the
Sanitary District would start draining the tertiary pond on July
20, 2006,
and expect the
project to take approx .
45
days with dry weather. By opening the tertiary pond drain gate
at the bottom of the effluent structure, the pond will drain to the tertiary effluent channel
.
The process of draining the pond will take approximately two days . The effluent from the
tertiary pond will be sampled while draining and the drain gate will be closed if TSS
concentrations increase visibly to a point that might cause an excursion of the permit limit
.
The remainder of the pond water will be pumped from the pond to the excess flow pond
for settling. Currently there is approximately
16
MG of water in the pond that will need to
be drained. The Agency will be notified when the pond draining and cleaning has begun
and when the pond is returned to service
.
Once the tertiary pond is drained, the excess deposits will be removed by
mechanical means . The material in the pond will be removed to the edge of the pond
berm and allowed to dry, before moving to the sludge farm or property contiguous with
the farm that was previously used for farm soil removal . Approximately
26,300
cubic
yards of material will be removed from the tertiary pond . The amount of material
removed will return the tertiary pond to the original volume and depth (See attached pond
sounding chart)
.
THE USE OF THE EXCESS FLOW POND
:
To remove the tertiary pond from service, secondary effluent flow will have to be
directed into the excess flow channel before the excess flow pond (Cook Street Pond) .
Currently the excess flow receives flow from rain events approx .
6 - 10
times per year
.
This flow, when discharge occurs, is chlorinated and samples for solids, pH, BOD, fecal
coliform and chlorine residual are taken
.
With flows from the secondary effluent, up to
25
MGD, being diverted to the
excess flow pond, discharge will be constant. I believe that the excess flow pond
discharge after a couple of days will be very nearly what we could have expected from the
tertiary pond. The excess flow pond is
9.3
acres and holds approx
.
15 .2
MG of water
.
Therefore the detention time in excess flow pond will be about the same
.
There is the chance that the excess flow clarifier will discharge into the same
channel as the secondary effluent and discharge into the excess flow pond (Flows up to
100 MGD) during a rain event. In this event, the entire flow (Secondary and excess flow
discharges) would need to be chlorinated and sampled as excess flow discharge
.
IEPA 07-002
SAMPLING AND REPORTING OF PLANT DISCHARGES
:
During the pond cleaning period, we propose sampling as follows
:
Secondary Effluent - A composite sample of the secondary clarifier effluent is
sampled 5 days per week presently and this will remain the same . This sample is
already tested for all of the tertiary discharge limits
.
Tertiary Effluent (No excess flow discharge) - Tertiary effluent for this period will
be discharged via the excess flow pond discharge (0010) . There is no power at
this location, so I propose sampling this discharge by means of 2 hour grab
composites collected by the operator during the eight hour shift that the plant is
currently manned. The sample will be tested for all of the current tertiary effluent
permit required constituents . The sample will be collected and stored in a
refrigerated sample cooler every two hours during the day shift
.
Combined Tertiary and Excess Flow Discharges - During a rain event that causes
an excess flow discharge to the excess flow pond, the effluent from the excess
flow pond will represent both tertiary and excess flow discharges. We propose
that the excess flow pond in this case will be sampled for all tertiary discharge
permit constituents as well as all constituents for excess flow discharge permit
limits . This will include chlorine residuals and fecal coliform tests . Depending on
the amount of excess flow discharge to the pond, the tertiary limits for solids,
BOD and ammonia may temporarily exceed the current tertiary limits . Excess
flow discharges have been averaging 14 mg/L TSS, 16 mg/L BOD and 2 .3 mg/L
Ammonia and when combined with tertiary effluent which has been averaging 8
mg/L TSS, 3 mg/L BOD and 1 .19 mg/L ammonia, I believe that the discharge
from the excess flow pond will average somewhere in between. However, the
secondary effluent sample analysis for this discharge time period will reflect the
affect that the excess flow portion of the discharge had on the total discharge
.
Pond Draining Discharges - While the pond is being drained it will be discharge
mainly to the current tertiary discharge outfall (008) as described above . The
current tertiary composite sample will be used until the pond is either empty or the
remainder of the water contents are pumped to the excess flow channel . If
pumping the remaining water to the excess flow channel is needed, a grab
composite will be collected each 2 hours during pumping and stored in a
refrigerated sample cooler for analysis . The analysis of this discharge will be the
same as the secondary effluent composite
.
IEPA 07-002
SAMPLE AND FLOW REPORTING
We believe that the DMR's that we currently use do not reflect the proposed
discharges for the pond cleaning time period. Flow that normally discharges from
outfall 008 will be directed to outfall 001 OA so the DMR reporting will need to be
changed accordingly. We will need some direction on DMR reporting for this
period so that an accurate reflection of the discharges will be reported. All sample
analysis will be reported on the DMR'S where applicable as well as a separate
report that will reflect all samples taken throughout this project
.
If there are any recommendations or questions as to reporting, sampling or
communications for this proposed pond cleaning period please contact Jeff W
.
Slead, Operations Supervisor at 217-528-0491 or 217-306-6991 (Cell)
.
IEPA 07-002
0
Excess Flow
Clarifier
Tertiary Pond
Influent Line -
0
u
Secondary
Composite
Sampler
Secondary Effluent
Distribution Box
.
Switching two gates
to redirect flow to
~/
the excess flow
channel
Excess Flow Channel
Flow
Diagram
Tertiary Effluent Channel
Tertiary Pond
Discharge and
Location Of
Drain Gate
Tertiary Effluent
Composite Sample
Sampled Until Pond
Is Drained
Outfall 008
No Discharge After
Pond is Drained
Outfall 0010A
Grab Composite site
(Tertiary Flow)
IEPA 07-002
Springfield Metro Sanitary District Proposed Sugar Creek Tertiary
Pond Cleaning
TERTIARY POND DRAINING AND CLEANING
:
The Sanitary District proposes to clean the Sugar Creek Facility tertiary pond of
the 30+ years of silt and solids build up. In order to take advantage of dry weather the
Sanitary District would start draining the tertiary pond as soon as dry weather returns, and
expect the project to take approx. 45 days with dry weather. By opening the tertiary pond
drain gate at the bottom of the effluent structure, the pond will drain to the tertiary effluent
channel. The process of draining the pond will take approximately two days . The effluent
from the tertiary pond will be sampled while draining and the drain gate will be closed if
TSS concentrations increase visibly to a point that might cause an excursion of the permit
limit. The remainder of the pond water will be pumped from the pond to the excess flow
pond for settling. Currently there is approximately 16 MG of water in the pond that will
need to be drained. The Agency will be notified when the pond draining and cleaning has
begun and when the pond is returned to service
.
Once the tertiary pond is drained, the excess deposits will be removed by
mechanical means. The material in the pond will be removed to the edge of the pond
berm and allowed to dry, before moving to the sludge farm or property contiguous with
the farm that was previously used for farm soil removal. Approximately 26,300 cubic
yards of material will be removed from the tertiary pond . The amount of material
removed will return the tertiary pond to the original volume and depth (See attached pond
sounding chart)
.
THE USE OF THE EXCESS FLOW POND
:
To remove the tertiary pond from service, secondary effluent flow will have to be
directed into the excess flow channel before the excess flow pond (Cook Street Pond)
.
Currently the excess flow receives flow from rain events approx . 6 - 10 times per year .
This flow, when discharge occurs, is chlorinated and samples for solids, pH, BOD, fecal
coliform and chlorine residual are taken .
With flows from the secondary effluent, up to 25 MGD, being diverted to the
excess flow pond, discharge will be constant . I believe that the excess flow pond
discharge after a couple of days will be very nearly what we could have expected from the
tertiary pond. The excess flow pond is 9 .3 acres and holds approx. 15.2 MG of water
.
Therefore the detention time in excess flow pond will be about the same
.
There is the chance that the excess flow clarifier will discharge into the same
channel as the secondary effluent and discharge into the excess flow pond (Flows up to
100 MGD) during a rain event. In this event, the entire flow (Secondary and excess flow
discharges) would need to be chlorinated and sampled as excess flow discharge
.
We are asking for a variance to discharge plant tertiary flows from outfall
010 instead of outfall 008
.
IEPA 07-002
SAMPLING AND REPORTING OF PLANT DISCHARGES
:
During the pond cleaning period, we propose sampling as follows
:
Secondary Effluent
- A composite sample of the secondary clarifier effluent is
sampled 5 days per week presently and this will remain the same . This sample is
already tested for all of the tertiary discharge limits
.
Tertiary Effluent (No excess flow discharge) - Tertiary effluent for this period will
be discharged via the excess flow pond discharge (0010). There is no power at
this location, so I propose sampling this discharge by means of 2 hour grab
composites collected by the operator during the eight hour shift that the plant is
currently manned. The sample will be tested for all of the current tertiary effluent
permit required constituents . The sample will be collected and stored in a
refrigerated sample cooler every two hours during the day shift
.
Combined Tertiary and Excess Flow Discharges - During a rain event that causes
an excess flow discharge to the excess flow pond, the effluent from the excess
flow pond will represent both tertiary and excess flow discharges. We propose
that the excess flow pond in this case will be sampled for all tertiary discharge
permit constituents as well as all constituents for excess flow discharge permit
limits. This will include chlorine residuals and fecal coliform tests. Depending on
the amount of excess flow discharge to the pond, the tertiary limits for solids,
BOD and ammonia may temporarily exceed the current tertiary limits. Excess
flow discharges have been averaging 14 mg/L TSS, 16 mg/L BOD and 2.3 mgfL
Ammonia and when combined with tertiary effluent which has been averaging 8
mg/L TSS, 3 mg/L BOD and 1 .19 mg/L ammonia, I believe that the discharge
from the excess flow pond will average somewhere in between . However, the
secondary effluent sample analysis for this discharge time period will reflect the
affect that the excess flow portion of the discharge had on the total discharge
.
Pond Draining Discharges
- While the pond is being drained it will be discharge
mainly to the current tertiary discharge outfall (008) as described above. The
current tertiary composite sample will be used until the pond is either empty or the
remainder of the water contents are pumped to the excess flow channel . If
pumping the remaining water to the excess flow channel is needed, a grab
composite will be collected each 2 hours during pumping and stored in a
refrigerated sample cooler for analysis . The analysis of this discharge will be the
same as the secondary effluent composite
.
SAMPLE AND FLOW REPORTING
We believe that the DMR's that we currently use do not reflect the proposed
discharges for the pond cleaning time period . Flow that normally discharges from
outfall 008 will be directed to outfall 001 OA so the DMR reporting will need to be
changed accordingly. We will need some direction on DMR reporting for this
period so that an accurate reflection of the discharges will be reported . All sample
analysis will be reported on the DMR'S where applicable as well as a separate
report that will reflect all samples taken throughout this project
.
IEPA 07-002
Permit Variance Application :
Answers to questions 1- 13
1 . The District believes that if the pond is not cleaned that eventually suspended
solids concentrations in the plant effluent will increase due to the reduced
detention time in the pond
.
2. A description of the pond cleaning procedure is located on page 1 of this
document. The pond is on plant grounds so no population or outside
geographical area will be affected .
3. N/A
4. Approximately 26,300 cubic yards of material will be removed from the pond
and disposed of on District property as described above . Water removed from
the pond during draining will be discharged to the excess flow pond for
discharge into Sugar Creek via discharge 0010 . We are requesting a variance
from permits of 12 mg/L suspended solids, 10 mg/L BOD and 1 .5 mg/L
ammonia to 30 mg/L Suspended solids and BOD and 7 .0 mg/L ammonia for
the variance period .
5
.
N/A
6. No adverse impact on Sugar Creek is expected . No treatment processes prior
to the discharge into the excess flow pond will be affected by this variance,
therefore the discharges from the excess flow pond should be the same that we
could have expected from the tertiary pond
.
7. If the tertiary pond is not cleaned eventually the lack of appropriate detention
time will cause a hardship on the District by increases in suspended solids
discharges
.
8. Cleaning the pond will help assure that the treatment plant discharges remain
within permit limits. This is a routine maintenance procedure that should be
completed within the 45 days allowed by a permit variance
.
9. There are no other alternatives for compliance other than to ask for this
variance. The plant effluent flow can only be discharged to either the tertiary
pond or the excess flow pond .
10. The time period for completing this project is 45 days or less, depending on
weather. The pond needs to be drained of water and then the deposits removed
mechanically .
11. The District has received no other variances for this or other projects at the
Sugar Creek Facility in the past twelve months .
12. The current NPDES permit will expire on Aug 31, 2006 . Permit renewal
application has been completed and sent to the IEPA
.
13. The current NPDES permit will expire on Aug 31, 2006. Permit renewal
application has been completed and sent to the IEPA . This represents the only
issue before the IEPA regarding the Sugar Creek Facility
.
If there are any recommendations or questions as to reporting, sampling or
communications for this proposed pond cleaning period please contact Jeff W
.
Slead, Operations Supervisor at 217-528-0491 or 217-306-6991 (Cell)
.
IEPA 07-002
V. . 50.
NOTE
I. NUMBERS
SHOWN ARE DEPTHS OF WATER
IN FEET .
IEPA 07-002
