ILLINOIS POLLUTION CONTROL BOARD
June
5,
1986
IN THE MATTER OF:
JOINT PETITION OF THE CITY
)
OF PEKIN AND THE ILLINOIS
)
ENVIRONMENTAL PROTECTION AGENCY
)
PCB 85-226
FOR EXCEPTION TO THE COMBINED
)
SEWER OVERFLOW REGULATIONS
)
MR. PATRICK OBERLE,
CORPORATION COUNSEL, CITY OF PEKIN APPEARED
ON BEHALF OF THE CITY
OF PEKIN; AND
MR.
E. WILLIAM HUTTON APPEARED ON BEHALF OF THE ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY.
OPINION AND ORDER OF THE BOARD
(by J. Anderson):
This matter comes before
the Board upon the filing on
December
31,
1985 of
a joint petition for
a combined sewer
overflow
(“CSO”) exception from 35
Ill. Adm. Code 306.305
(a)
and
(b)
by the City of Pekin
(“Pekin”)
and the Illinois Environmental
Protection Agency
(“Agency”).
A public hearing was held
in
Pekin,
Illinois
on March
11, 1986.
Testimony on Pekin’s behalf
was presented by Mayor Willard
E.
Brinknieier,
and by Gregory A.
Sherwood and Richard Helm
of Randolph and Associates,
Inc.
No
public testimony was presented and
no public comments were
received.
Decision
in this matter
is being expedited consistent with
the City’s need for
a decision on or
about June
1 to allow for
coordination of CSO design with construction
of various grant—
funded wastewater system improvement projects.
CSO REGULATIONS
The CSO regulations
are contained
in 35
Iii. Adm. Code
306.302 et
seq.
They were amended
in R8l—17,
51 PCB 383, March
24,
1983.
Section 306.305 provides
as
follows:
All combined sewer overflows and treatment plant
bypasses shall
be given sufficient treatment
to
prevent pollution,
or
the violation of applicable
water
standards unless an exception has been
granted by the Board pursuant to Subpart D.
Sufficient treatment shall consist of the
following:
a)
All dry weather
flows,
and the first flush of
storm
flows as determined
by the Agency,
shall meet
the
70.114
—2—
applicable effluent standards;
and
b)
Additional flows,
as determined by the Agency but not
less than ten times
to
sic)
average dry weather
flow
for the design year,
shall receive
a minimum of
primary
treatment and disinfection with adequate retention time;
and
c)
Flows
in excess of those described
in subsection
(b)
shall
be treated,
in whole or
in part,
to the extent
necessary
to prevent accumulations of sludge deposits,
floating debris and solids
in accordance with 35
Ill.
Adm. Code 302.203,
and
to prevent depression of oxygen
levels;
or
d)
Compliance with
a treatment program authorized by the
Board
in an exception granted pursuant
to Subpart D.
Subpart D allows the discharger
to
file
a petition for an
exception either
singly,
or jointly with the Agency as the City
had done.
The joint petition seeks an exception based on minimal
discharge
impact as provided
in Section 306.361(a).
COMBINED SEWER SYSTEM
Pekin, population
33,127,
is located
on
the east bank of
the
Illinois River, approximately five miles downstream of the Peoria
Lock and Dam.
It
is served by both sanitary and combined
sewers,
the latter having been originally constructed,
as
is typical for
older
communities, to collect only storm drainage; however, over
time,
the sewers began and continue to serve
the dual function of
conveying both wastewater and surface water
runoff.
During
the past 40
to 50 years, Pekin has endeavored
to
separate out the wastewater flow by constructing sanitary sewers
that convey
the flow directly
to sewage treatment facilities.
(In recent years,
this sewer separation work has been performed
in conjunction with street
improvements and redevelopment
projects, when,
as,
and
if the City has been able to proceed with
such projects.)
Additionally, connections of newly constructed
sanitary sewers to the old combined system
are prohibited.
Presently,
about one—fourth of the City is served by combined
sewers, which drain stormwater from about
1175 acres.
There
are combined sewer overflows at
four outfalls located
above
the plant
and identified by their Street location:
State,
Caroline, Court and Fayette Streets.
CSO from the State and
Caroline .CSO’s discharge
to
a common backwater slough of the
Illinois River.
The Court CSO discharges close
to the bank of
the
Illinois River,
and
the Fayette CSO discharges about
250 feet
back from the
river bank into
a channel created by the
deterioration and washing
away of the outfall pipe.
70-115
—3—
Overflows occur
about
47 times
a year at each location
during rainfalls exceeding about
0.10
inches.
For
a one—year design storm of 1.2 inches per hour,
based
on
suspended solid concentrations,
the peak first flush flow rates
and volumes are
as follows:
Peak First Flush
First
Flush
Site
Flow Rate
(mgd)
Volume
(ft3)
State
16
19,000
Caroline
23
54,000
Court
47
155,000
Fayette
101
366,000
The BOD first
flush volume
is about
60
of that shown
for
suspended solids.
ENVIRONMENTAL IMPACTS AND PROPOSED CSO CONTROL STRATEGY
Uses
of the
river
at Pekin are commercial, primarily grain
loading and storage
facilities,
as well
as recreational,
including boating and
fishing.
There
is
a boat ramp upstream of
Court Street and
a private boat club near the Caroline CSO.
A
railroad
runs
along
the riverbank,
limiting accessibility except
at Court Street.
The supporting justification for
the proposed exception
program
is based on three studies.
The first two, Phase
I
and
Phase
II
(Ex. A) were performed
by Randolph and Associates,
Inc.
Phase
I covered the sewer system,
treatment facilities,
land use, and receiving steam characteristics,
the
latter having
relied on an extensive water quality data base generated during
a
1983 Peoria
CSO study.
Phase II included
a six month CSO
monitoring and sampling program,
an evaluation
of alternative CSO
controls, and recommended
improvements.
The third
study was
performed by the State Water Survey Division of the Department of
Energy and Natural Resources
(ISWS).
It focused
on the benthic
conditions and stream morphology
in the outfall areas
(Ex. B).
Regarding existing conditions,
the ISWS study was summarized
as
follows:
1.
“The State,
Court
and Fayette Street outfall
channels exhibit some pollutional effects due
to
combined sewer
overflows:
the Caroline Street
outfall
channel does
not.
The State and
Caroline outfall channels discharge
into
a
common outlet channel
to the river.
Sediment
degradation and potential public health and
aesthetic problems exist
in the State
and
70-116
—4—
Fayette Street outfall channels and
in the
State—Caroline outlet channel.
Only public
health and aesthetic problems exist at Court
Street.
Problems
in the State—Caroline outlet
channel appear attributable only to State Street
sewer overflows.
2.
The sediments
in the riverine areas around
the
State—Caroline Street outlet and the Fayette
Street outlet show no signs of pollutional
degradation: but several samples
in the area of
the Court Street outlet showed evidence
of
chronic organic contamination.
The limited
contamination in the Court Street area sediments
can probably be attributed
to grain spillage
during barge loading operations which regularly
take place immediately below the outfall.
Frequent spillage was observed during the course
of this study.”
(Ex.
B,
p.
27,
28 emphasis in
original)
The ISWS Peoria study,
assumed
to
be applicable
to Pekin,
noted that the only significant CSO impacts were “substantial
increases in fecal coliform densities and the transitory
occurrences of
floating debris...”
(Ex.
C,
p.
113).
The dilution
factor
is
26
to
1 between
the river’s minimum seven—day,
ten—year
flow and Pekin’s total one—year
first flush peak flow discharge.
(R. 24)
In
lieu of construction which would achieve
full compliance
with the CSO regulations, Pekin and
the Agency propose the
following CSO control strategy:
1)
Construct underground
storage
for complete treatment of
first flush volume
(19,000 Cu.
ft.)
at State
Street.
This will
reduce overflow frequency by 36
and volume by 52,
up
to
approximately a 0.40 inch rainfall.
An overflow baffle will
prevent floating debris from entering the slough.
The storage
will also alleviate basement flooding.
2)
Connect existing regulators
at the Caroline, Court and
Fayette CSO’s
to
a new interceptor sewer, which,
with other
improvements of the treatment plant and use of the existing
interceptor, will
allow full operation of the system up to
a
25
year flood,
and completely treat 14 times dry weather
flow,
capture about 18
of the first flush volume on an annual basis,
and reduce
the number of overflows by about 9.
3)
Modify the Court Street CSO
to provide
a self—cleaning
outfall channel
to the river, thus eliminating the occurrance of
trash and debris which
is caught
in the course
(sic)
riprap
presently below the outfall.
70-117
—5—
4)
Extend the Fayette CSO outfall about
180
feet to its
original discharge point, this eliminating sewage contamination
in
the outfall channel.
Pekin has also agreed to monitor
the four CSOs outfalls
for
up
to three years
to assure
that the CSO effects are adequately
mitigated or, alternatively,
to determine whether
additional
improvements are necessary.
Pekin anticipates that its proposal will “substantially
eliminate
all significant water quality and aesthetic impacts...”
(R.25).
Pekin expects to complete design by October
30,
1986,
to
begin construction by March 31, 1987,
and
to have these
facilities operational
by April,
1988.
The cost
is estimated
to be $1.2 million.
Alternatively,
Pekin asserts
that the most cost—effective method
of
full
compliance with Sections 306.305(a)
and
(b), providing storage
for
first
flush volumes at each CSO outfall
and increasing
transport capacity to
at least
12.5 times dry weather flow,
is
estimated
to be $10 million.
Mayor Willard Brinkmeier testified that local dollars have
funded about $800,000
in sewage treatment system upgrading
in the
past
12 years.
Presently,
the projected costs of necessary major
improvements
to the wastewater treatment plant
and sewer system,
including
the proposed CSO improvements, are estimated
at
$7
million,
of which
$2.5 million
is available through grant funds,
although more grant funding
is expected.
However, the Mayor
also
stated that the $1.2 million needed
to finance the proposed CSO
improvements would
be “funded entirely by our own community”
by
means
of general revenue bonds.
(R.5—8,
12).
CONCLUSION
Having
considered
the factors enumerated
in Section
306.361(a)
and the evidence presented by Pekin jointly with the
Agency, the Board
finds that the proposal
for exception will have
minimal impact.
The Board grants the exception with language similar
to that
recommended
in the petition.
However,
the Board,
in Condition
2
and
3, has substituted language
for proposed Condition 1(f)
addressing monitoring,
and added language
to clarify that relief
is not granted
from water quality standards.
ORDER
1)
The City of Pekin
(Pekin)
is hereby granted
an exception
from 35 Ill. Adm. Code 306.305(a)
as such provision relates
to
first flush
of storms flows,
and from 35 Ill. Adm. Code
70-118
—6—
306.305(b),
subject to
the
following conditions:
a)
Pekin
shall connect the existing
regulators at
Caroline, Court,
and Fayette Street CSO’s to the
new interceptor that will extend from Plant
2
to
Plant
1.
b)
Pekin
shall construct facilities
to provide that
the entire
first flush volume from the State Street
CSO will
be captured and fully treated.
C)
Pekin
shall extend
the Fayette Street outfall
so
that the CSO discharges directly into the main
river channel.
d)
Pekin
shall provide
a self—cleaning outfall channel
to the river
for the Court Street CSO.
e)
Overflows shall only occur while
the
treatment
plant
is receiving and treating its design maximum
flow.
2)
This grant
of exception does not preclude the Agency
from exercising
its authority to require as
a permit condition a)
a CSO monitoring program sufficient to assess compliance with
this exception and any other Board regulations, including Section
306.305(c);
and
b)
other controls
if needed
for compliance,
including compliance with water quality standards.
3)
This grant of exception
is not to
be construed
as
affecting the enforceability of any provisions of this exception,
other
Board regulations,
or
the Act.
IT
IS SO ORDERED.
3.
D.
Dumelle concurred.
B. Forcade dissented.
I,
Dorothy M.
Gunn,
Clerk of the Illinois Pollution Control
Board,
hereby certify that the above Opinion and Order was
adopted on the5~Z~day of
~
,
1986, by
a vote of
~—/
Dorothy M. G~nn,Clerk
Illinois Pollution Control Board
70-119