ILLINOIS POLLUTION CONTROL BOARD
May 31, 1973
)
LEWIS and CLARK COMMUNITY COLLEGE
)
JUNIOR COLLEGE DISTRICT NO. 536
)
)
)
v.
)
PCB 72-246
)
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
OPINION AND ORDER OF THE BOARD (by Mr. Dumelle)
This proceeding is a petition for variance filed by a new junior
college district on September 29, 1972. The district (“Lewis and
Clark”) asks permission to operate its existing sewage treatment plant
beyond the December 31, 1973 deadline for tighter effluent standards
until it can connect to the Godfrey Township Utility Board sewage
treatment plant.
We grant the variance without hearing for a year until May 31, 1974
for the reasons given below.
The present sewage plant was constructed in 1961 and consists of
24-i~our (extended) aeration with a design capacity of 70,000 gallons
per day. Present flow is 21,000 gpd. The present effluent averages
15 mg/l BOD and 10 mg/i suspended solids according to Lewis and Clark.
The petitioner lays out three aitneratives which are (a) expand
and upgrade the present plant, (b) construct a new plant with a capacity
of 85,000 gpd, or (c) connect to Godfrey Township. The consulting
engineers, Sheppard, Morgan and Schwaab, Inc. in a September 11, 1972
report (Exhibit 1) state that (a) is not feasible since the basic treat-
ment unit is not of sufficient size to meet future needs (83,000 gpd
by 1980-81) and cannot be economically expanded. They state that
(b) would cost $48,900 and maximum operating cost would be $10,200 per
year. The last alternate (c) would require 2,926 lineal feet of
10-inch sewer to connect to the Godfrey Township sewer at a capital
cost of $44,720 and an annual sewer service charge (at 83,000 gpd) of
$6,794.
On April 17, 1973 the Environmental Protection Agency filed
its recommendation. The Agency points out that the existing effluent
standard for Lewis and Clark is 30 mg/i BOD and 37 mg/i suspended
solids and effluent data listed show values under these iirrtits in
almost all cases. The standard, however, for the Lewis and Clark plant
goes to 4 mg/l BOD and 5 mg/i suspended solids after December 31, 1973.
8
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123
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The Agency states that the intermittent stream which receives
the effluent flow is 0.6 miles in length, is wholly on the Lewis
and
Clark property and “has no apparent agricultural~recreational or
other social use” and eventually drains to Rocky Pork Creek. “No
significant adverse effect” would occur
on the stream if present effluent
values were maintained, according to the Agency.
The Agency alleges that arbitrary
and
unreasonable hardship has
not been shown by Lewis
and
Clark
and
in its analysis then inexplicably
combines capital
and
annual costs. It recommended denial unless
Lewis ad Clark could show (a) expectations by
Godfrey of a connection
by Lewis and Clark or (b) existence of a Godfrey ordinance requiring
connection or (c) a feasibility analysis of a regional sewage plant
over separate facilities.
We do not fully agree with the degree of proof the Agency
requested. Regionalization of sewage plants is a worthy goal recog-
nized by the Board in many decisions (E. St. Louis v. EPA, PCB 72-393,
February 14, 1973) since it brings with it economies of scale
and
more sophisticated level of operational competence. Prom the Agency’s
standpoint in this proceeding, regionalization means one less treat-
ment plant to inspect, to process reports
and
to certify operators
for. The Board would give all possible encouragement toward establishing
regional sewage plants.
At any rate on May 11, 1973 Lewis and Clark filed a motion supply-
ing the Godfrey Township connection ordinance and engineering reports
showing reliance by Godfrey on receiving the Lewis and Clark load.
On May 24, 1973 the Agency responded to the motion
and
recommended
a grant of the variance from Rule 404(f) of Chapter 3 so long as Lewis
and Clark has interim chlorination facilities operating within 90 days
and posts a bond to insure chlorination and connection to Godfrey.
We grant the variance subject to the conditions of the Order.
Interim chlorination may
now
be operative but
was
due in July 1972
and we here order it to make certain that it is realized. We do not
require a bond because we feel that it is to Lewis
and
Clark’s advan-
tage to connect and that they will do so as soon as they can.
Should additional variance extension be needed we require that they
be requested 90 days in advance of the expiration of this one. We
point out two matters for future guidance: first if the Agency is
correct that “no adverse effects” will follow from discharging the
present effluent then perhaps the 4/S standard now required is too
severe; and second, the design capacity at Lewis and Clark’s plant
will not be reached until 1977-78 which means that 4-5 years may
remain in which to connect to Godfrey given “no adverse harm”.
This opinion constitutes the Board’s findings of fact and conclu-
sions of law.
a
—124
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ORDER
1. Variance is granted from Rule 404(f) of Chapter 3 until
May 31, 1974 provided that the effluent shall not exceed
20 mg/1 BOD and 25 mg/i suspended solids on a monthly
average basis.
2. Interim chlorination equipment shall be installed and be
operated by June 30, 1973 arid bacteriological standards
shall be met after that date.
3. If extensions are needed to the variance they shall be
applied for at least 90 days prior to expiration.
IT IS
SO
ORDERED.
I, Christan L, Moffett~ Clerk of the Illinois Pollution Control
Board,~ hereby certify the above Opinion and Order were adopted on the
3/$
day of May, 1973 by a vote of
q-~
Cliristan L. Moffet~,/C,~?rk
i~
Illinois
Pollution ~di~tro1
Board
8