ILLINOIS POLLUTION CONTROL BOARD
    June 14, 1973
    )
    GALESBURG SANITARY DISTRICT
    )
    )
    )
    v.
    )
    PCB73—86
    )
    )
    ENVIRONMENTAL PROTECTION AGENCY
    )
    )
    )
    OPINION AND ORDER OF THE BOARD (by Mr. Dumelie)
    Petitioner requests a variance from all applicable stream
    and effluent standards of the Water Pollution Regulations of
    Illinois for a one-year period, to be extended until July 1, 1977.
    Implicit in the petition is a request to be exempted from the
    Permit and Project Completion Schedule filing requirements of
    Rules 921(d) and 1002. Hearing was held on May 2, 1973.
    Petitioner owns, operates, and controls a sewage treatment
    plant and sewage transport system serving the entire City
    of
    Gales-
    burg and certain surrounding unincorporated areas. The majority
    of
    the area within the District is served by separate storm and
    sanitary sewage systems, though combined sewers still serve certain
    areas, The treatment plant provides secondary treatment by means
    of the trickling filter process. Chlorinated plant effluent is
    discharged to Cedar Fork Creek, which affords a dilution ratio
    of less than one to one.
    Grab samples of the plant effluent taken by the Agency
    during 1972 show BOD at 34, 23, 16, 15, 11 and 10 mg/i; suspended
    solids at 14, 10, 23, 1, 6,
    and
    12 mg/i and ammonia nitrogen at
    7.2,
    2.5, 2.0, 1.0 and 5.8 mg/I. The District monthly operational
    reports for 1972 show BOD ranging between 5 and 29 mg/i and suspended
    solids between 12 and 29 mg/i.
    The Agency believes that the plant
    is well operated and that the effluent has
    little or
    no adverse
    effect on Cedar Fork Creek.
    Since Cedar Fork Creek provides a dilution ratio of less than
    one to one, Petitioner must comply with the BOD standard of 4 mg/i
    and the suspended solids standard of S mg/i by December 31, 1973.
    Petitioner anticipates that adequate BOD and suspended solids removal
    will be accomplished in conjunction with the process of ammonia re-
    moval. The District contends that reduction in effluent ammonia
    8— 279.
    -2-
    concentrations and compliance with the Rule 203(f) standard of 1.5
    mg/i will be possible upon construction of proposed upgraded treat-
    ment facilities. Ammonia reduction is said to be possible by
    supplementing the trickling filter process with an activated sludge
    unit (for nitrification) followed by multimedia filtration and break
    point chlorination. The District further maintains that a pilot
    plant study is an essential prerequisite to insure the proper
    physical and economic design of an ammonia removal process. Design
    and operation of the proposed pilot plant would require a one-year
    period.
    In 1967 Petitioner began to expand and upgrade its treatment
    plant. The plant was designed to treat to a standard of about
    7 mg/i of BOD. During construction the Sanitary Water Board Rules
    and Regulations (hereinafter SWB) became effective. Pursuant to
    SWB-14, Petitioner was required to meet a standard of 4 mg/i of BOD
    and 5mg/i of suspended solids. Late in 1971, the Agency conducted
    a sampling program. Samples indicated that the 4/5 standard was
    not being met. Petitioner was notified of this inadequacy. Petitioner
    thereupon retained new engineering consultants and requested a
    report in order to plan further upgrading to meet standards.
    During this period of time the Petitioner had also worked
    upon its sewer separation project; and by the middle of 1972 the
    greater part of this project was completed. Petitioner believed
    that separation was necessary in order to evaluate total plant
    loading.
    The Agency, in its recommendation filed April 26, 1973 points
    out that “ignorance of applicable standards cannot justify the grant
    of a variance
    “
    (p.5). SWB-l4, while it contains an ammonia water
    quality standard of 2.5 mg/i, applies this only to Public Water
    Supply and Food Processing Industry waters (Rule 1.04). There is
    no showing that Cedar Fork Creek is used for these purposes. Thus
    official notice of the need for ammonia reduction must begin with
    the March 1972 enactment by the Board of the 1.5 mg/i ammonia standard.
    We have before us a variance filed March 5, 1973 asking for more
    time in which to do pilot plant work on ammonia, a year after the
    regulation was passed. This delay has not been satisfactorily ex-
    plained and thus we cannot grant the ultimate relief desired which
    is until July 1, 1977.
    On the other hand, we have before us in two regulatory proceedings
    the very issues of the ammonia standard itself and its deadline date
    and the issue of moving back from December 31, 1973 to December 31, 1974
    the due dates for conformance with municipal effluent limits (R 73-3,
    8—
    -3-
    R73-4). Since we have not yet decided these regulatory proceedings
    we grant the variances requested until June 14, 1974
    only leaving
    future Oxtensions to a better showing of prompt pilot work research
    initiated between now and then. We grant a variance from Rule 921 (d)
    to permit the District to obtain construction permits in the absence
    of an approved Project Completion Schedule.
    Finally, we note the Agency’s comment in its recommendat2on that
    “piant effluent has little or no adverse effect on Cedar Fork Creek”.
    The average levels in the effluent for 1972 were 17 mg/i ROD and
    18 ing/l suspended solids or almost four times the incipient 4 mg/l
    BOD and 5 mg/i suspended solids standard for this stream. We invite
    the Agency to propose a new and less stringent effluent standard if
    it has proof that “no adverse effect” on low
    dilution
    streams
    will
    be
    felt.
    This opinion constitutes the Board’s findings of fact and con-
    clusions of law.
    ORDER
    1. Variance is granted until June 14, 1974 from Rule 203(f) as
    regards ammonia nitrogen.
    2. Variance is granted from Rule 921(d) but a Project Completion
    Schedule must be submitted before June 14, 1974 showing the
    best anticipated date for compliance with the standards.
    3. The District shall submit quarterly reports to the Agency
    detailing progress in its pilot plant research and in all
    other steps toward completion.
    4. The sewage treatment plant shall not be operated at effluent
    levels to exceed 20 mg/i BOD and 25 mg/i suspended solids on
    a monthly average.
    5, The District shall diligently pursue correction programs for
    sanitary and storm sewer overflows.
    6. The District shall apply for an extension to this variance at
    least 90 days prior to its expiration.
    I, Christan L. Moffett, Clerk of the Illinois Pollution Control
    Board, hereby certify the above Opinion and Order were adopted on the
    j~day of June, 1973 by a vote of _______________________________
    ristan L. Mo~fett,9’l~rk
    Illinois Pollution Co~)frolBoard
    8— 281

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