ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
1021
NORTH
GRAND AVENUE EAST,
P.O.
Box 19276,
SPRINdFIELD,
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
RENEE
CIPRIANO,
DIRECTOR
(217)
782-5544
TDD:
(217) 782-9143
JAN30
2004
STATE OF ILLINOIS
January
29, 2003
Pollution Control Board
Dorothy Gunn, Clerk
Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, IL
60601
RE:
NOTICE
OF PROVISIONAL VARIANCE APPROVAL
PV-2004-39
Dear Ms. Gunn:
Pursuant to Subsection 37(b) ofthe Environmental Protection Act (415 ILCS 5/37(b)),
attached is a copy ofthe Illinois EPA’s recent approval ofa request for provisional
variance for the City ofTrenton.
As you know, the Board must maintain forpublic
inspection copies of all provisional
variances filed with it by the Illinois EPA.
Please feel
free to call me at the above number should you have any questions.
Sincerely,
Connie L. Tonsor
‘ssociate Counsel
~sionofLegal Counsel
.ford,
IL 61103 —(815) 987-7760
•
DES
PLA1NES
—
951 1
W.
Harrison St.,
Des Plaines, IL 60016
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294-4000
Jgin,
IL 60123— (847) 608-3131
•
PEORIA —5415
N. University
St.,
Peoria, IL 61614— (309) 6935463
iersity St.,
Peoria,
IL 61614— (309) 693-5462
•
CHAMPAIGN —2125 South First Street, Champaign,
IL 61820— (217) 278-580C
~etRd., Springfield,
IL 62706
—
(217) 786-6892
•
COLLINSVILLE
—
2009
MalI Street, CoIIinsviIIe,
IL 62234 —(618) 346-5120
MARION —2309 W. Main St.,
Suite 116, Marion, IL 62959 —(618) 993-7200
PRINTED ON
RECYCLED
PAPER
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
January 29, 2004
City ofTrenton
)
)
Petitioner,
)
)
v.
)
)
IEPA-2004-39
ILLINOIS ENVIRONMENTAL PROTECTION
)
AGENCY,
)
(Provisional Variance- Water)
)
Respondent.
)
)
Re:
Provisional Variance From 35
Ill. Adm.
Code 302.2 12 for Ammonia Nitrogen,
304.120(c) for CBOD5, and 304.120(c) for Suspended Solids
NPDES Permit # 1L0026701
Dear Mr. Rodden:
The
Agency
has
completed
its
technical
review
of the
attached
provisional
variance•
request submitted
by the City of Trenton on January 26, 2004.
Based on the review, the
Agency GRANTS
the requested provisional
variance subject to
specific
conditions
set
forth below for a period of 16
days.
The City ofTrenton has two
activated sludge plants,
one rated at 0.1
million gallons per
day (“mgd”) and the other rated at 0.4 mgd.
The City seeks a provisional variance from
its
current
NPDES
permit
(No.
1L026701)
limitations
for
total
suspended
solids
(“TDS”),
biological
oxygen demand
(BOD)
and
ammonia
for
its
0.4
mgd
extended
aeration activated sludge plant so that it can repair the return activated sludge line,
on its
0.4 mgd plant
In order to make the repair,
the
City must take the plant temporarily
offline to
pump
the water out ofthe clarifier and pump
a portion ofthe water out of the
aeration
tank in
order
to
gain
access to
the
problem
line.
The
pumped water will be
routed to
either the holding tank, sludge
drying bed and/or into the
0.1
mgd
plant.
No
untreated water will be
discharged.
The repairs
are
to
be made on
January
27
and
28
2004, and it is
expected that the plant will be back in compliance by February
11, 2004
The Agency’s review ofthe requested provisional variance has concluded the following:
1.
The environmental impact
from the proposed activity should be minimal;
2.
No other reasonable alternative appears available;
3.
No public water supplies
should be effected;
4.
No federal regulations will preclude the granting ofthis request; and
5.
The City will face an arbitrary and unreasonable hardship if the request is
not granted.
The
Agency
hereby GRANTS
the
City of Trenton a
provisional variance
from
35
Ill.
Adm.
Code 302.212
for ammonia nitrogen, from
304.120(c) for CBOD5
and
suspended
solids
for
a
period
of
16
days
beginning
January
27,
2004,
subject
to
the
following
specific conditions:
A.
‘During the variance period, the City’s effluent shall meet the monthly
average concentrations of70 mg/i for CBOD5,
70 mg/I for
suspended
solids and 12 mg/l for ammonia nitrogen.
B.
The City shall notify Barb Conner ofthe Agency by telephone at 2 17/782-
9720 when construction
starts and again when construction is completed.
Written confirmation of eachnotice shall be sent within five days to
the
following address:
Illinois Environmental Protection Agency
Bureau of Water
—
Water Pollution Control
Attention:
Barb Conner
1021 North Grand Avenue East, MC #19
-
P.O. Box
19276
Springfield, Illinois 62794-9276
C.
The City shall sign a certificate ofacceptance ofthis provisional variance
and forward that certificate to Barb Conner at the address indicated above
within ten days ofthe date ofthis
order.
The certification should take the
following form:
I (We)
,
hereby accept and
agree to be
bound by all terms and conditions ofthe provisional variance
granted by the Agency in
_____________
dated
Petitioner
Authorized Agent
Title
Date
D.
The City shall continue to monitor and maintain compliance with all other
parameters and conditions specified in its National Pollutant Discharge
Elimination System Pe1mit No. 1L0026701.
Sincerely,
Joseph
.
Svoboda
ChiefLegal Counsel
Enclosure
cc:
IPCB, Clerk
6185948217
HMG
ENGINEERS
PA~
82
81/26/2804
15:32
HENRY,
MEISENHEIMER
& GENDE,
INC.
1075
LA~ ROAD. P0 SOx 70
HAROLD D.
M~ISENHEJM~R
CARLYL~,IWNOrS
62231
GARY R.
FULTON
(619) 594.3711
I~AV~D
W. RODDEN
FAX (618) 594-8217
SCOTrA.
RAKERS
HMG~HMGENGINEERS.CQM
BRADLEY G.
HUMMERT
January
26,
2004
Ms.
Barb Conner
illinois Environmental Protection
Agency
Bureau
ofWater
Compliance
Assurance Section
P.O. Box
19276
MC#19
Springfield,
Illinois 62794-9276
Fax~
(217) 557-1407
Re:
Trenton,
Illinois
NPJDES
PemiitNo. 1L0026701
Provisional Variance
Application
-
Dear
Ms.
Conner:
The City of
Trenton has two activated
sludge plants, one being rated at 0.1 mgd and
the
other at 0.4
mgd.
As discussed this same
date,
the
City
of
Trenton
is experiencing a problem with the
return
activated
sludge line on the 0.4
mgd
plant.
This plant
is an
extended aeration activated
sludgeplant
and
the
return
of
activated
sludgeis an essential component to
this
process.
The
City
ofTrenton is
currently
using a
gas
powered portable pump to return activated sludge, but this
will
not result in
a
consistently compliant effluent.
The
City
is
requesting a provisional variance
so
this plant can
be
temporarily
takenofl-line
so
repairs can.
be madc.
Application for
a
provisional variance requires providing specific information
as listed in
Title
35,
Subtitle A, Chapter II,
Part
180. Subpart B,
Section
180.202 B ofthe
Illinois Statutes.
The
following
numbers
correspond to the numbered
items
in this regulation ofwhich a copy is
attached.
1
The CityofTrenton’s current NPDES permit levels
and
11w proposed variance levels
follows:
Requirement (ppm)
Average
Ma,thnu~
Total
Suspended Solids
12
24
BOD
10
20
Ammonia
4
8
2
The
City
ofTrenton desires to
temporarilytake
off-line
their existing
0.4
mgd plant to
repair
the return activated sludge line.
For the
City
to
fix
this
submerged
line
they
must
ENGINEERS
01/26/2804
15:32
6185948217
HMG
ENGINEERS
PAGE
03
pump
the
water
out ofthe
clarifier and a portion
of
the-water
out ofthe
aeration tank
allowing for access to
the
problem
line.
The
exact problem
will pot be known until
the
water
is
pumped
out.
The
pumpedwater will
be
routed
to either the holding
tank,
sludge
drying
bed
and/or
into
the
0.1
rngd plant.
No
untreated water
will be
discharged.
11
water will ultimatelybe
treated bythe 0.1 mgd
plant
or the 0.4 mgd
plant
when placed
back
in service.
There
is no
other
way to fix the problem line.
The CityofTrenton is
a
community
of 2,610 people
and
t~ically
havc flows in thc
vicinity of
0.225 nigd this time of
year.
Ifflows exceed the plants design of 100,000
gpd, and
no more cxccss flow capacity is
available in
their
holding tank, theplant’s
effluent quality could suffer due to
hydraulic overloading.
Therefore
a variance is
sought.
3
The City’s
personnel
will have new piping, clamps
and
miscellaneous repair
items
on-
band to
fix the problem
once the
plant is taken
out
of
service.
4
The
effluent will be discharged to the
normal receiving stream.
5N/A
6
Shutting
the 0.4 mgd plant down. maytemporarily
result
in
higher discharge levels of
BOD, Solids and Ammonia than allowed
for
in the City’s NPDES
permit.
No
adverse
stream affects are expected.
Biologicai activity
is
very
low this
time
of
yearand this
stream is not in direct contact with humans
nor is it
a direct water source for a public
water supply.
7
The existing NPDES
permitted
effluent levels
provide
a
hardship, because
it doesnot
allow
for
this plant
to be
temporarilytaken
out of
service for repairs.
The
problem will
only
worsen
with
time and the
effluent
quality will steadily diminish
to a
point where
the
pennit levels
can
no
longer
be met.
8
Compliance with the NPDES permit will be
met
withIn
7
days ofth,e
repair.
The
repairs
will
be madeon
January
27
and
28 of
2004.
The plant should be back in compliance by
February
5,
2004 ifnot sooner.
9
Alternatemethods of
compliance
iuclude:
a~ Having the community
quit using the sewersystem which
is not
practical
nor
will it stop the influent
and inflows
caused by
leaky sewers
to theplant.
b.
Continuing to pump the return activated sludge with a portable pump.
This
will
not consistently provide effluent meeting thc NPDES permit
and
is not
practical.
c.
Fix
the
problem,
by
taking
the plant
temporarily
out of
service.
Barring
no
additional problems4 this
should
result
in long
term
service in compliance
with
theNPDES permit.
10
The variance is requested
from January
27, 2004
through February 5,2004.
11
No provisional variances have
been granted
to the City ofTrenton
in the last year.
01/26/2004
15:32
6185948217
HMG
ENGINEERS
PAGE
04
12
‘The City
is believed to be currently in compliance, but it is
becoming more and
more
difficult each
day
because ofthe
deteriorating
effluent
quality
from the problem
plant.
13
No.
Should you
have
any questions regarding
these
matters
please contact me at your convenience.
Verytruly yours,
JIENRY, MEISENBEIMER & GENDE, INC.
F~
~
‘~-Z
2 ~
~
.~
~
David W.
Rodden, FE.
~
\;~!
;
‘~~~•~
...~
~.,r
End.
Cc:
Chris Port, IEPA Coilmavilie
Margaret
Conley, Mayor
Pat
Bassler
Roger Mauc
File 5038
6185948217
HMG
ENGINEERS
PAGE
@1
HENRY, MEISENHEiMER
& GENDE, INC.
1075
LAKE
ROAD,
PC)
8ox
70
CARLYLE.
IWNOIS
622a1
(81~)
~94-3711
FAX
(618)
~948217
HMG@HMGENGINEERS.COM
FAX
one:
~1
2
9 ~
I
40
7
Fa~
phone:
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Ô5
CC:
.
HAROLD D.
ME(SENHEIMER
GARy
R.
FULrON
DAVID W.
R000EN
SCoTT
A.
RAKERS
BRADL,~Y
G.
HtJMMERT
Date;
I
24
—
Numberof pages
including coversheet
From:
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phone:
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01/26/2004
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81/26/2004
16:58
1075
LAKE
RoAD. P0 BOx 70
CARLYLE.
ILLtNOIS
62231
(618) 5943711
FAX
(618) 5~4’8217
HMG~Ht~’GENGtNEER5.COM
6185948217
HENRY,
MEISENHEIMER & GENDE,
INC.
HAROLD 0. MEISENH~MER
GARY
R.
FULTON
DAVIDW. R000EN
SCOTT A.
RA(ERS
BRADLEY G.
-IUMMERT
January
26, 2004
Ms.
Barb Conner
Illinois Environmental Protection Agency
Bureau
of
Water
Compliance Assurance Section
P.O. Box
19276
MC#19
Springfield,
Illinois
62794~9276
Fax
#(217)557-1407
Rc:
Trenton,
Illinois
NPDES Permit No. 1L0026701
Provisional Variance
Application
-
Amended
Dear
Ms.
Conner:
As
discussed
we
areamending items
1,8
and
10
from theprevious letter.
This
amendment sets
variance limits
and revises
the
ending
date ofthe
variance
to
February
11,2004 to insure
adequate
time
is
available
for the
activated
sludge to become
active.
Please replace
the previously
numbered
paragraphs with
the
following corresponding numbers:
I
The City ofTrenton’s current NPDES permit levels
and
the
proposed variance
levels
follows:
Total Suspended
Solids
BOD
Ammonia
Requirement (ppm)
Averagç
Ma~dnunn
12
24
10
4
20
8
Variance Levels (ppm)
~ximiim
70
70
12
8.
The repairs
will
be made on January27
and
28 of2004.
The plant should be
back in
complianceby
February
11,2004 ifnot sooner.
ENGINEERS
1.0
Thc
variance
is
requested
from
January 27, 2004 through February
11,2004.
HMG
ENGINEERS
PAGE
83,
@1/26/2804
16:58
6185948217
Should
you haveany
questions
regarding these
matters
please
contact inc at your convenience.
Verytruly yours,
HENRY, ME1SE~HETh,1ER
& GENDE, INC.
David W. Rodden, P.E.
Chris Port, JEPA
Collinsvillc
Margaret Conley,
Mayor
Pat Bassler
Roger Maue
File 5038
End.
Cc:
i~
fZ~
p~F~s~I0NAL
*
‘:.
~
ENGH’4EER
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