ILLINOIS POLLUTION CONTROL BOARD
June 5, 1986
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Complainant,
)
)
v.
)
PCB 86-37
)
BLAKE WATER CORPORATION, an
)
Illinois corporation,
)
)
Respondent.
)
MR. JOSEPH J. ANNUNZIO, ASSISTANT ATTORNEY GENERAL, APPEARED ON
BEHALF OF THE COMPLAINANT.
MR. AND MRS. BLAKE APPEARED ON BEHALF OF THE RESPONDENT.
OPINION AND ORDER OF THE BOARD (by W.J. Nega):
This matter comes before the Board on an eight-count
Complaint filed on March 12, 1986 by the Illinois Environmental
Protection Agency (Agency) pertaining to the Respondent’s
operation of a public water supply system doing business near the
City of Galesburg in Knox County, Illinois.
Count I of the Complaint alleged that water samples of the
Respondent’s potable water taken by the Agency between June, 1984
and February, 1985 indicated that the concentration of coliform
bacteria was in excess of one coliform colony per 100 milliliters
(ml) and at least one sample during this time period showed a
concentration in excess of four coliforrn colonies per 100 ml, and
that this presence of total coliform bacteria in the
aforementioned concentrations rendered the Respondent’s potable
water less than assuredly safe in quality, and that these
bacteria concentrations above that which the regulations allow
was in violation of 35 Ill. Adm. Code 604.102(a) and Section 18
of the Illinois Environmental Protection Act. (Act).
Count II alleged that, from June, 1984 through February,
1985, the Respondent failed to give the required public notice of
exceeding total coliform maximum allowable concentrations (MAC)
and failed to provide public notice of potable water that is less
than assuredly safe in quality in violation of 35 Ill. Adm. Code
606.201 and 35 Ill. Adm. Code 606.202 and Section 18 of the Act.
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Count III alleged that, from January, 1983 through
September, 1984, the Respondent failed to provide the required
public notice regarding its variance from the 2.0 mg/i maximum
allowable fluoride concentration standard (see: Opinion and
Order of the Board dated December 3, 1981 in PCB 81-137, Blake
Water Corporation v. IEPA which granted the Respondent a five-
year variance) in violation of item #1(c) of the Board’s December
3, 1981 Order in PCB 81-137, 35 111. Adm. Code 602.201 and
Section 18 of the Act.
Count IV alleged that, from February 11, 1982 until March
12, 1986, the Respondent failed to maintain a minimum free
chlorine residual of 0.2 mg/i or a minimum combined residual of
0.5 mg/i in all active parts of the distribution system at all
times, and that this failure to maintain residuals of free or
combined chlorine at levels sufficient to provide adequate health
protection rendered the potable water provided less than
assuredly safe in quality in violation of 35 Iii. Adm. Code
604.401(a) and Section 18 of the Act.
Count V alleged that, from August 28, 1984 until May 21,
1985, the Respondent failed to have a properly certified operator
in responsible charge of its public water supply in violation of
Section 1 of “An Act to Regulate the Operating of a Public Water
Supply”, Ill. Rev. Stat., ch. 1111/2, par. 501 (1985) (hereinafter
“Water Supply Act”); 35 Ill. Adm. Code 603.102; 35 Ill. Adm. Code
603.103(a); and Section 18 of the Act.
Count VI alleged that, from December 30, 1981 until June 1.
1985, the Respondent failed to submit the necessary monthly
operating reports to the Agency in violation of 35 Ill. Adm. Code
606.101 and Section 18 of the Act.
Count VII alleged that, from June 5, 1984 until March 12,
1986, the Respondent failed to adopt an appropriate program for
the control of unsafe cross-connections in violation of 35 Ill.
Adm. Code 607.104(d) and Section 18 of the Act.
Count VIII alleged that the Respondent, from June 5, 1984
until March 12, 1986, failed to maintain the continuous operation
and maintenance of its water supply facilities so that the water
would be assuredly safe in quality, clean, and adequate in
quantity in that there wasa potential for contamination of the
potable water because: (1) it did not have an operable air
compressor on—site to pump air into the pressure tank to maintain
pressure in the distribution system; (2) the capacity of its high
service pump was as low as 11 gallons per minute, and (3) it
failed to adopt a program for the control unsafe cross-
connections in violation of 35 Ill. Adm. Code 601.101 and Section
18 of the Act.
70.123
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A hearing was held on May 1, 1986 at which two members of
the public were present. (R.2.—3). The parties filed a
Stipulation and Proposal for Settlement on May 7, 1986.
On June 2, 1986, the Assistant Attorney General, on behalf
of the Agency, filed a series of microbiological analysis report
forms from the Agency (covering water sample testing on various
specified dates between June 9, 1984 and October 16, 1984) which
have been designated as “Attachment A” to the Stipulation and
Proposal for Settlement. The aforementioned “Attachment A” was
inadvertently omitted when the original settlement agreement was
filed with the Board.
The Respondent, the Blake Water Corporation, owns and
operates a public water supply system which serves a population
of about 160 persons in the Windcrest Subdivision, Cedar
Township, about Y/2miles south of the City of Galesburg in Knox
County, Illinois. The Respondent is an Illinois corporation
which is engaged in the business of supplying potable public
water pursuant to a certificate of convenience and necessity
issued by the Illinois Commerce Commission. The official
custodians and owners of the Blake Water Corporation are Mr.
Russell Blake and his wife (Mrs. Irene Blake). The Respondent’s
facilities include one well drilled 520 feet deep into rock, an
aeration installation for the removal of hydrogen sulfide, a
collecting tank, a chlorination installation, a pressure tank and
a water distribution system.
The Respondent’s single 520 feet deep well presently
provides water with fluoride concentrations ranging from 2.0 mg/i
to 4.3 mg/i (and averaging 3.3 mg/i) and, accordingly, the
Respondent received in PCB 81-137 a five-year variance from the
2.0 mg/i fluoride drinking water maximum allowable concentration
standard set forth in 35 Ill. Adm. Code 604.203(a)*. (See
Opinion and Order of the Board dated December 3, 1981 in PCB 81-
137, Blake Water Corporation v IEPA).,
Pursuant to applicable regulations, the Respondent has
submitted monthly bacteriological samples to the Agency for
subsequent laboratory analysis. The Agency has indicated that
the results of the sampling of the Respondent’s finished water
are as follows:
*Formerly, Rule 306(B)(4) of Chapter 6: Public Water Supply
Regulations.
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Monthly
Sampling Period
June, 1984
July, 1984
September, 1984
Number of
Samples
5
6
7
Total Coliform
(n/lOO ml)
G+ (1 sample)
G+ (1 sample)
G+ (1 sample)
October, 1984
February, 1985
5
5
2+ (1 sample)
G+ (1 sample)
5+ (1 sample)
(Stip. 2).
In reference to interpreting the previously shown sampling
results, the Agency has stated that:
“The notation
“+“
indicates the sample was
confirmed positive for coliform bacteria. The
notation “G+” is to be counted as 80/100 ml
for purposes of averaging to determine
compliance with the total coliform MAC
pursuant to 35 Ill. Adm. Code 654.303(a)(2).
All samples analyzed using a different
technique than membrane filter (MF) were
counted as zero for purposes of averaging to
determine compliance with the total coliform
MAC.” (Stip.2).
Moreover, the Agency has asserted that the average of all
samples of potable water (which includes finished water or
distribution system water) taken during the previously delineated
monthly sampling periods exceeded 1/100 ml. Additionally, the
Agency pointed out that less than twenty samples were taken
during each of the monthly sampling periods in question, and that
at least one sample result was greater than 4/100 ml.
(Stip. 3). Nonetheless, the Respondent has denied that it has
ever provided potable water which exceeded the total coliform
maximum allowable concentration.
The Agency has also contended that the Respondent improperly
failed to provide appropriate public notice following the
apparent violations listed below:
Month
January-March, 1983
June, 1984
July-September, 1984
July, 1984
September, 1984
October, 1984
February, 1985
Exceeding
Exceeding
Exceeding
Exceeding
Exceeding
Exceeding
Exceeding
fluoride MAC*
total coliform MAC
fluoride MAC
total coliform MAC
total coliform MAC
total coliform MAC
total coliform MAC
*
MAC
=
maximum allowable concentration
(Stip. 3).
Nature of Violation
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It is undisputed by the parties that public notice
pertaining to any exceedance of the fluoride maximum allowable
concentration standard was required pursuant to the Board’s
December 3, 1981 Order in PCB 81-137. However, the Blake Water
Corporation has denied that any public notice of the exceedance
of the total coliform maximum allowable concentration limits was
required, because it denies that any violation occurred.
Nevertheless, the Agency provided public notice in each of the
above instances following the Respondent’s failure to do so.
(Stip. 3).
On February 11, 1982 and September 18, 1984, the
Respondent’s public water supply was inspected by Agency
employees. These Agency inspectors tested chlorine residual at
two locations in the Respondent’s distribution system, and
ascertained that the chlorine residual was less than 0.2 mg/i of
free chlorine or a minimum combined residual of 0.5 mg/I, thereby
indicating a violation of the applicable standard for chlorine
residuals. (Stip. 3).
The Respondent’s public water supply is required to be under
the supervision of a Class C (or higher) certified public water
supply operator. Although a properly certified Class C operator
named Mr. G.L. Porter was supervising the Respondent’s public
water supply operations up to, and including, August 27, 1984,
during the interim time period between August 28, 1984 and
May 21, 1985, the Agency alleges that the supply was not under
the active supervision of a properly certified operator.
(Stip. 4). Active supervision of the facility was taken over by
Mr. Jeffrey M. Moore, a properly certified Class C operator, on
May 22, 1985. Both Mr. Potter and Mr. Moore filed the requisite
“Certified Operator in Responsible Charge” forms with the Agency,
so the allegation in Count V of the Complaint only relates to the
interim time period in question. (Stip. 4).
During the Agency inspection of September 18, 1984, the
Agency inspector observed: (1) there were openings around the
top, under the eaves, and in the joint opening in the middle of
the aerator roof, thereby noting that the aerator roof needed to
be covered or screened to prevent the possible entry of insects,
dust, dirt, debris, or animals into the aerator which could
possibly result in system contamination; (2) the high service
pump capacity was only 11 gallons per minutes based upon a
reading from the master meter, thereby indicating a pump
insufficient to provide an adequate quantity of water during peak
usage periods, which in turn would help to maintain adequate
*The Agency calculates that the high service pump should
have a minimum output of 33 gallons per minute, based upon the
user population and assumption that each person uses
approximately 50 gallons of water per day. (Stip. 4).
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system pressure; and (3) there was no operable on—site air
compressor to pump air into the pressure tank to provide the
appropriate air blanket necessary to maintain the proper system
pressure. (Stip. 4).
However, the Respondent has denied the existence of the
previously alleged operation and maintenance deficiencies and has
contended that:
“The openings in the aerator roof and eaves
were present solely because the roof was
undergoing repair, and the openings were
properly closed or screened shortly after the
date of inspection. There was inadequate high
service pump capacity because a replacement
pump was being used at the time, and the pump
normally used (which was undergoing repair)
was of sufficient capacity. Finally, the on-
site air compressor was in fact operable, but
the person who was responsible for maintaining
the supply did not know how to operate it.
Moreover, an operable air compressor was
available from a nearby residence.”
(Stip. 5).
In the instant case, the Agency has placed the Respondent’s
admitted acts or omissions into five major categories of
violations. The Agency has asserted that the Respondent has,
during the specific time periods alleged in the Complaint, failed
to: (1) provide public notice pertaining to its variance from
the fluoride maximum allowable concentration pursuant to
PCB 81-137; (2) maintain a residual of free or combined chlorine
at levels sufficient to provide adequate protection in the
distribution system; (3) place its supply under the active
supervision of a properly certified operator and failed to
expeditiously file the “Certified Operator in Responsible Charge”
form with the Agency; (4) submit monthly operating reports to the
Agency, and (5) establish an adequate cross-connection control
program. (Stip. 5).
On the other hand, the Agency has alleged (while the
Respondent has denied) that: (1) the Respondent’s potable water
exceeded the total coliform bacteria maximum allowable
concentration standard; (2) the Respondent failed to provide
public notice when the total coliform bacteria maximum allowable
concentration standard was exceeded, and (3) the Respondent
caused or allowed the operation and maintenance deficiencies
which rendered the public water supply facility’s drinking water
less than assuredly safe in quality and adequate in quantity.
(Stip. 6).
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In reference to the uncontested violations, the parties have
stipulated that, for the purposes of settlement only, the
Respondent has admitted violations of 35 Ill. Adm. Code 603.102,
603.103, 604.401, 606.101, 606.201 and 607.104(d), as well as
violations of the Board’s December 3, 1981 Order in PCB 81-137;
Section 1 of the Water Supply Act, and Section 18 of the Illinois
Environmental Protection Act. (Stip. 6-7).
Because of their failure to reach an agreement in reference
to the contested violations, the parties have requested the Board
to make findings, based upon the limited evidence contained in
the Stipulation and Proposal for Settlement, on the three
disputed issues:
1. Whether the Respondent provides drinking water which
exceeded the maximum allowable concentration for total coliform
bacteria in violation of 35 Ill. Adm. Code 604.102(a) and Section
18 of the Act;
2. Whether the Respondent failed to provide public notice
when the total coliform maximum allowable concentration was
exceeded in violation of 35 Ill. Adm. Code 606.201 and 35 Ill.
Adm. Code 606.202 and Section 18 of the Act, and
3. Whether the Respondent caused or allowed the existence of
operation and maintenance deficiencies which rendered the
drinking water less than assuredly safe in quality and adequate
in quantity in violation of 35 Ill. Adm. Code 601.101 and Section
18 of the Act.
CONTESTED ISSUE #1: BACTERIA CONCENTRATIONS IN EXCESS
OF APPLICABLE STANDARDS
The sampling results of the monthly bacteriological samples
submitted to the Agency for laboratory analysis were not
contested by the Respondent, in that no claim was made that the
analysis was improperly done; that there was an unaccounted for
break in the chain of custody; or that a scientific or procedural
mistake was made during the actual sampling or analysis
procedure. No independent laboratory analysis was provided by
the Respondent and no evidence was indicated to show that total
Coliform levels were other than represented by the Agency.
(See: Attachment A to the Stipulation).
Accordingly, the water samples taken by the Agency between
June, 1984 and February, 1985 indicate that, on average, a
Concentration of coliform bacteria in excess of one per 100 ml
existed on more than one occasion. Additionally, at least one
Sample result apparently was greater than four coliform colonies
per 100 ml and, given the relatively small numbers of samples
taken, it is entirely possible that further unknown excursions
may have occurred.
70.128
—8-
Although we are cognizant of the difficulties encountered in
the day-to-day operations of smaller public water supplies such
as the facility operated by the Respondent, it cannot be
overemphasized that any exceedance of the maximum allowable
concentration for coliform bacteria is serious in nature and
creates an unacceptable risk of illness to system users.
In light of the lack of any showing, data, or evidence to
the contrary, the Board finds that the Respondent did, in fact,
provide drinking water which exceeded the maximum allowable
concentration for total coliform bacteria on some occasions,
thereby violating 35 Ill. Adm. Code 604.102(a) and Section 18 of
the Act.
CONTESTED ISSUE #2: FAILURE TO PROVIDE ADEQUATE PUBLIC NOTICE OF
EXCEEDING THE TOTAL COLIFORM MAXIMUM
ALLOWABLE CONCENTRATIONS
The Respondent has denied that any public notice of the
exceedance of the total coliform maximum allowable concentration
standards was necessary because it contends that no violation
occurred. Once again, the Board must conclude that, given all
the facts and circumstances of this case, it would have been
better for the Respondent to have promptly acted on the side of
safety. Instead, the Agency was forced to take action and
provide the public notice following the Blake Water Corporation’s
failure to do so. The Board notes that the purpose of the public
notice requirement is simple: it is to notify the public so
that, if an individual chooses, they can take steps to protect
themselves from possible personal health problems or injury by
perhaps boiling their water, or buying distilled or bottled
water, or not drinking the water during certain time periods when
they may be at increased risk or taking other common sense steps
to protect themselves from potential harm. If there is an infant
or an elderly person in the home, this option of taking
precautionary steps to insure personal safety and health can be
vitally important. By notifying the public of a possible
problem, the public water supply is aiding those individuals in
exercising their freedom of choice: they can make an informed or
reasoned decision once all the salient facts are known to them.
By not telling one’s customers of potential problems that might
be encountered in their drinking water, one is taking a somewhat
short-sighted view of the situation. Customer loyalty is
increased when they have reason to believe that the water supply
operators are zealously guarding their health.
In any event, the protection of the public health is a top
priority of paramount importance. Appropriate public notice of
potential problems is a vitally important part of the procedural
mechanism used to insure that the individual’s freedom of choice
and the individual’s right to preserve their health are
respected.
70-129
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The Board therefore finds that the Responden failed to
provide the requisite public notice when the total. coliform
maximum allowable concentration standard was exceeded, thereby
violating 35 Ill. Adm. Code 606.201 and 35 Ill. Adm. Code 606.202
and Section 18 of the Act.
CONTESTED ISSUE #3: THE EXISTENCE OF OPERATION AND MAINTENANCE
DEFICIENCIES WHICH RENDERED THE DRINKING
WATER LESS THAN ASSUREDLY SAFE IN QUALITY
AND ADEQUATE IN QUANTITY
The Respondent has denied the existence of any alleged
operational and maintenance deficiencies and has presented
plausible explanations for the three major problems observed by
the Agency inspector. However, upon closer examination, the
Respondent’s contentions are not persuasive.
At the outset, the Board emphasizes that there is a
distinction between whether or not a violation occurred, and
extenuating circumstances or lack of them.
For example, when the Respondent asserts that the on-site
air compressor was in fact operable, but the person who was
responsible for maintaining the facility did not know how to
operate the compressor, one’s first question might be: “why
not?” If the facility is not under the active supervision of a
competent operator, the likelihood for problems, accidents, and
possible water contamination is unduly increased. To rely on an
off-site operable air compressor which may be available from a
nearby residence appears to indicate a somewhat lackadaisical
approach to one’s operations. Moreover, if the person in
temporary charge did not know how to operate a compressor, the
availability of another compressor off-site would not be of any
help either, since even the on—site air compressor close at hand
would be useless to an unknowing or incompetent operator.
Similarly, it is indeed possible that the openings in the
aerator roof and eaves were present only because the roof was
undergoing repair. However, during such repair work, it would
undoubtedly have been a good idea to make some provisions to
insure that the infiltration of debris, dirt, insects, or animals
into the aerator would be at least partially prevented or
protected against to insure that water supply system
contamination would not occur.
It is also conceivable that the pump normally used was
undergoing repairs and that the replacement pump did not have
adequate high service capacity. However, it might have been more
appropriate and prudent to have taken active steps to obtain a
replacement pump that did have sufficient capacity and to have
previously obtained reliable sources of supply for such equipment
in the event of any necessary maintenance and repair work.
70.130
-10-
There is nothing in the record in this case to indicate that
the Respondent was not acting in good faith in trying to properly
operate its public water supply system. It is stipulated that
the “Respondent’s operations have not been acceptably profitable,
and Respondent has filed a request for a rate increase which is
currently pending before the Illinois Commerce Commission”.
(Stip. 6). However, the record does indicate that, despite the
economic contraints that are present, there appears to be
significant room for improvement in the Respondent’s operations
of its public water supply facility.
Accordingly, the Board finds that the Respondent did, in
fact, cause or allow the existence of operation and maintenance
deficiencies which rendered the drinking water on some occasions
less than assuredly safe in quality and adequate in quantity,
thereby violating 35 Ill. Adm. Code 601.101 and Section 18 of the
Act.
The proposed settlement agreement provided that the
Respondent admitted the uncontested violations alleged in the
Complaint and agreed to: (1) cease and desist from further
violations; (2) follow an agreed-upon compliance plan to rectify
past violations and prevent future excursions, and (3) pay a
stiuplated penalty of $500.00 within 45 days into the Illinois
Environmental Protection Trust Fund. (Stip. 8-10).
In evaluating this enforcement action and proposed
settlement agreement, the Board has taken into consideration all
the facts and circumstances in light of the specific criteria
delineated in Section 33(c) off the Act and finds the settlement
agreement acceptable under 35 Ill. Adm. Code 103.108. The Board
strongly agrees with the Agency’s conclusion that “the violations
alleged in the complaint, and particularly those alleging the
exceedance of the MAC for coliforni bacteria and the failure to
maintain an adequate chlorine residual, are serious in nature as
they create an unacceptable risk of illness to system users”.
(Stip. 6). Concomitantly, the Board believes that the proposed
compliance plan and stringent conditions to be imposed in the
Board’s Order will provide adequate safeguards to rectify the
past environmental problems and protect the public health and
safety and the drinking water quality for local residents.
As admitted in the Stipulation, the Board finds that the
Respondent, the Blake Water Corporation, has violated 35 Ill.
Adm. Code 603.102, 603.103, 604.401, 606.101, 606.201*, and
607.104(d), as well as the Board’s December 3, 1981 Order in PCB
81-137; Section 1 of the Water Supply Act, and Section 18 of the
Illinois Environmental Protection Act.
Additionally, the Board also finds that the Respondent has
violated 35 Ill. Adm. Code 601.101, 604.102(a), and 606.201*
(i.e., the contested violations which were denied by the
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Respondent) and Section 18 of the Illinois Environmental
Protection Act. The Respondent will be ordered to cease and
desist from all further violations, to follow the agreed-upon
compliance plan, to take specified steps to insure appropriate
water quality and quantity, and to pay the stipulated penalty of
$500.00 into the Illinois Environmental Protection Trust Fund.
This Opinion constitutes the Board’s findings of fact and
conclusions of law in this matter.
ORDER
It is the Order of the Illinois Pollution Control Board
that:
1. As admitted in the Stipulation, Respondent Blake Water
Corporation has violated 35 Ill. Adm. Code 603.102, 603.103,
604.401, 606.101, 606.201 (for failure to provide public notice
regarding its variance from the fluoride maximum allwable
concentration standard), and 607.104(d) and has violated the
Board’s December 3, 1981 Order in PCB 81—137, Section 1 of the
Water Supply Act, and Section 18 of the Illinois Environmental
Protection Act.
2. The Respondent has also violated 35 Ill. Adm. Code
601.101, 604.102(a), and 606.201 (for failure to provide public
notice when the total coliform maximum allowable concentration
was exceeded).
3.
The Respondent shall cease and desist from all further
violations.
4. The Respondent shall provide drinking water which
complies with the maximum allowable concentration standard for
total coliform bacteria.
5. The Respondent shall provide the required public notice
in the event of any future violation of the maximum allowable
concentration standard for total coliform bacteria.
6. The Respondent shall provide public notice regarding
its variance from the maximum allowable concentration standard
for fluoride during the effective period of the variance granted
in PCB 81-137.
*
The admitted violation of Section 606.201 pertains to the
failure to provide public notice regarding the Respondent’s
variance from the fluoride MAC, while the contested violation of
Section 606.201 relates to the alleged violation of the
Respondent’s failure to provide public notice when the coliform
MAC was exceeded.
70-132
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7. The Respondent shall maintain a chlorine residual of at
least 0.2 mg/i free or 0.5 mg/l combined chlorine in all portions
of the distribution system at all times.
8. The Respondent shall maintain its public water supply
under the active supervision of a properly certified operator at
all times.
9. The Respondent shall file all the requisite monthly
operating reports with the Agency.
10. The Respondent shall operate and maintain its public
water supply system so as to provide drinking water which is
assuredly safe in quality and adequate in quantity.
11. The Respondent shall expeditiously develop and
implement an adequate cross-connection control program as per the
compliance program delineated on page 9 of the Stipulation and
Proposal for Settlement.
12. Within 45 days of the date of this Order, the
Respondent shall, by certified check or money order payable to
the State of Illinois and designated for deposit into the
Environmental Protection Trust Fund, pay the stipulated penalty
of $500.00 which is to be sent to:
Fiscal Services Section
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois 62706
The Respondent has waived any right to have any portion of
the stipulated penalty returned from the Environmental Protection
Trust Fund.
13. The Respondent shall comply with all the terms and
conditions of the Stipulation and Proposal for Settlement filed
on May 7, 1986, which is incorporated by reference as if fully
set forth herein.
IT IS SO ORDERED.
Board Member J. Theodore Meyer dissented and Board Member
Dr. John C. Marlin concurred.
70.133
—13-
I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control
Board, hereby certify that the above Opinion and Order was
adopted on the ~
day of _______________________, 1986 by a
vote of
__________________.
~62~4 ~
Dorothy M. G~nn, Clerk
Illinois Pollution Control Board
70-134
