ILLINOIS POLLUTION CONTROL BOARD
December 19, 1974
VILLAGE OF ADDISON,
Petitioner,
vs.
)
PCB 74-288
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
)
OPINION AND ORDER OF THE BOARD (by Mr. Duaielle):
This is a Petition for a Variance filed by the Village of Addison
(hereinafter Addison) with the Environmental Protection Agency (here-
inafter Agency) on July 29, 1974.
On August 15, 1974, the Board found the petition to be inadequate
in that it did not address the issue of environmental impact of the
discharge on Salt Creek. On September 4, 1974, the Agency received
Petitioner’s amended petition.
Petitioner seeks a variance from certain rules of Chapter 3:
Water Pollution Regulations of Illinois (hereinafter Chapter 3) to
continue operation of the existing wastewater treatment facilities at
the South Plant in Addison until the proposed improvements can be
designed, constructed, and placed into service. The Agency interprets
the petition as requesting a variance from Rule 2O3(d’)., 203(f), 203(g),
and 4O4(c)(ii) of Chapter 3, Water Pollution Regulations.
Addison’s South Sewage Treatment Plant consists of two plants
operating in parallel. The first plant is a high-rate trickling filter
plant and the second is an activated sludge plant. The effluent is
presently passed through tertiary filters and discharged through a
comon pipe. Total plant effluent presently meets the current BOD
and suspended solids standards of 20/25 mg/i but will be unable to meet
the 10/12 mg/i standard of Rule 404(c)(ii) upon the effective date
of December 31, 1974. The Agency calculated the low flow of Salt Creek
to be 6.2 MGD using the discharges of the sewage treatment plants into
Salt Creek above the Addison South Plant. Using the design average
flow of the South Plant of 2.1 MGD the dilution ratio is about 3 to 1.
Listed below are BOD and suspended solids concentrations as reported
by Petitioner in its monthly operational reports to the Agency.
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719
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DATE
BOD
July 1973
16
11
August 1973
14
10
September 1973
16
12
October 1973
20
November 1973
15
1
December 1973
11
9
January 1974
13
10
February 1974
16
9
March 1974
12
12
April 1974
12
7
May 1974
12
11
June 1974
11
July 1974
31
15
The subject plant has been designated as a regional wastewater
treatment facility. A 2.0 MGD expansion has been proposed for the
activated sludge process with the elimination of the trickling
filter operation. Petitioner believes that the proposed improvements
should produce an effluent conforming to the standards of Rule 404(c)
(ii).
The Step 1 grant priority for this project is #40. Petitioner
alleges that the Village would suffer an unreasonable hardship if
required to meet the December 31, 1974 deadline since it would have
to relinquish its grant for Federal assistance. The estimated cost
for the upgrading project is $5,281,500.
The impact of the Addison South Sewage Treatment Plant on Salt
Creek is difficult to assess.. Nine treatment plants discharging
above Addison South Sewage Treatment Plant have a total dry weather
flow of 6.23 MGD. There are five more discharges with a combined dry
weather flow of 9.73 MGD below the plant.
The following Agency data indicate that the stream below Addison
is of lesser quality than upstream for the parameters of dissolved
oxygen, ammonia, and fecal coliform.
1973
ABOVE ADDISON
BELOW ADDISON
LOCATION:
IRVING PARK RD. RR. AT WOOD DALE
ST CHARLES RD. RR. AT VILLA PARK
AMMONIA
AMMONIA
PARAMETER
D.O.
FECAL COLI.
AS N.
D.O.
FECAL COLI.
AS N.
# of Analysis
9
9
9
11
11
11
Max. Value
11.9
30000
1.80
10.4
880000
4.10
Mm. Value
4.0
10
.13
1.5
100
.37
Mean
7.5
389
.64
5.7
4939
1.37
Median
7.7
500
.44
6.0
3700
.90
Criterion
5.0
200
1.50
5.0
200
1.50
14
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-3-
1972
ABOVE ADDISON
BELOW ADDISON
LOCATION
IRVING PARK RD.
RR. AT WOOD DALE
ST. CHARLES RD. RR. AT VILLA PARK
AMMONIA
AMMONIA
PARAMETER
D.O.
FECAL COLI.
AS N.
D.O.
FECAL COLI.
AS N.
# of Analysis
4
2
3
3
3
4
Max. Value
10.0
400
.70
10.0
16000
2.30
Mm. Value
7.5
200
.20
7.5
100
.20
Mean
8.6
199
.40
8.5
2519
.89
Median
8.5
250
.30
8.0
10000
.53
Criterion
5.0
200
1.50
5.0
200
1.50
It is clear from the above that Petitionerts effluent diminishes
water quality and results in apparent violation of Rules 203(d),
203(f) (Ammonia Nitrogen), and 203(g). The Agency believes that the
operation and maintenance of the Addison South Sewage Treatment Plant
and other sewage dischargers to Salt Creek must be continued and
optimized to produce the best effluent possible from existing
facilities to prevent critical stream degradation until upgraded
treatment facilities are in operation.
The Agency believes that it will be at least 1 1/2 to 2 years
before construction can begin on the addition to Plant No. 2 and may
take even longer depending on design approval and grant priority.
Thus, in the event the requested variance is~granted, renewal will
apparently be required.
Balanced against the adverse environmental harm described above,
we must weigh the hardship to Petitioner in the event the variance
is denied and must consider the explanations or justifications for
the delay in compliance. In the event Petitioner proceeded with
upgrading, the possibility of grant assistance would be eJimi~ated.
Requiring the ‘Village to bear the total cost in excess of $5 million
would impose an extreme financial burden on the municipality and
its taxpayers.
The Agency has recommended a grant of the Variancewith certain
conditions and we agree.
This Opinion constitutes the findings of fact and conclusions of
law of the Board.
IT IS THE ORDER of the Pollution Control Board that:
1. A Variance from Rules 203(d), 203(f) (Ammonia Nitrogen),
and Rule 203(g) of the Water Pollution Regulations be granted
for a period of one year;
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721
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2. That a Variance from Rule 404(c)(ii) be granted fora period
from December 31, 1974 until one year from the date of the Board
Order in this matter; and
3. That the above Variances be granted subject to the
following conditions during the term of the variances:
i. That Petitioner not increase the strength
or quantity of contaminants discharged;
ii. That plant BOO and suspended solids concentrations
at no time exceed 20/25 mg/i.
I, Christan L. Moffett, Clerk of the Illinois Pollution Control
Board, hereby certify the above Opinion and Order were adopted was on
/71*
day of December, 1974 by a vote of
1/
Christan L. Moffett, Cler
Illinois Pollution Control Board
14—722