ILLINOIS POLLUTION CONTROL BOARD
    September 30, 1976
    THE METROPOLITAN SANITARY DISTRICT
    OF GREATER CHICAGO,
    )
    Petitioner,
    v.
    )
    PCB 76-54
    ENVIRONMENTAL PROTECTION AGENCY,
    Respondent.
    OPINION AND ORDER OF THE BOARD
    (by Mr. Dumelle):
    Petition for Variance from Rule 405 of Chapter
    3 of the
    Water Pollution Control Regulations was filed by the Metropolitan
    Sanitary district o~Greater Chicago
    (“District”) on February
    27,
    1976.
    The Illinois Environmental Protection Agency
    (“Agency”)
    filed its Recommendation on April
    9,
    1976.
    A public hearing was
    held on July
    30,
    1976.
    Waivers of the 90-day decision period
    have been received running until October
    8,
    1976.
    The District asks to be relieved of the requirement to
    chlorinate its effluent from the West-Southwest Sewage Treatment
    Plant
    (“W-SW”)
    in Stickney for a period of five years or until:
    1.
    The effect of disinfection of
    sewage treatment effluent and the
    economic feasibility in connection
    therewith has been fully resolved.
    2.
    This Board reconsiders the require-
    ment set forth under Section 405
    of Chapter III of the Illinois Pollu-
    tion Control Board Rules and Regulations,
    or any other applicable section.
    The District’s main arguments are threefold:
    1.
    Chlorination poses a significant health
    threat to the environment and to humans.
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    623

    —2—
    2.
    Chlorination provides no significant
    beneficial environmental impact.
    3.
    Chlorination imposes an arbitrary and
    unreasonable hardship upon the District
    taxpayers in that costs
    in excess of
    $1,000,000 annually are incurred with
    no benefits to the environment.
    The Agency’s Recommendation is for a one—year variance grant
    for Battery D at W-SW but a denial as to variance for Batteries A,B,
    and C.
    THE HEALTH THREAT
    The District discusses the National Organics Reconnaissance
    Survey,
    initiated November 1974, which concluded that four volatile
    organics are formed by the chlorination of drinking water.
    These
    chemicals are chloroform, brornodichioromethane, dibromochloro—
    methane, and brornoform.
    Some of these are said to be carcinogenic.
    Viruses are said by the District not to be greatly reduced
    by chlorination because of the turbidity of the effluent and the
    low viricidal properties of the chioramines
    (which are formed
    with the ammonia in the effluent).
    Lastly, the District asserts that fish can be harmed by low
    concentrations of
    free and combined chlorine and by chlorainines.
    Fishing may be precluded in the District waterways by chlorination,
    according
    to the District.
    NO SIGNIFICANT BENEFIT
    The District presents data to show that fecal coliform levels
    downstream return to their prechiorination levels due to regrowth.
    Total coliform levels at Peoria are shown to be higher in 1974 than
    in 1966 when chlorination was not practiced.
    ARBITRARY AND UNREASONABLE HARDSHIP
    Because of the foregoing assertions, the District feels that
    its present expenditure at W—SW in excess of $1,000,000 per year
    constitutes an arbitrary and unreasonable hardship.
    DISCUSSION
    The Agency feels that the entire matter of sewage treatment
    plant effluent disinfection is more appropriately the function
    of a regulatory proceeding.
    The cost of chlorination alone is
    23
    624

    —3—
    not a hardship since W-SW is the world’s largest sewage treatment
    plant.
    On a flow basis,
    it treats the population equivalent
    of 8,500,000 persons
    (using 100 gpcd on its 1975 treated flow
    of 850 MGD).
    Thus any of its expenditures can be expected to
    be large in absolute amounts.
    The District’s contention that at least four volatile organic
    chemicals are formed by chlorination at W—SW is not borne out
    by this record.
    The District, which is well equipped with laboratories
    and qualified personnel, has presented no data showing that these
    organics are in fact formed at W-SW.
    We are thus left with data
    applicable to drinking water which may react differently than
    sewage plant effluent.
    The Alleged carcinogenic properties of
    these chemicals awaits a U.S. Environmental Protection Agency study
    and report which has not yet been made.
    Furthermore, the origin of
    the bromine found in three of the volatile organics listed is not
    given.
    Thus the essential elemental ingredients for these chemicals
    may not even be present.
    The virus question is quite similar.
    The W-SW plant has been
    experiencing excellent effluents low in both suspended solids and
    BOD5
    as stated many times before this Board.
    Thus its effluent
    turbidity may in fact be far lower than those of other sewage treat-
    ment plants and its virus kill thus correspondingly greater.
    Again,
    actual data seems
    to be called for to substantiate the District’s
    assertion.
    The possibility that chlorine levels may preclude fish life
    in District waterways is a moot point since dissolved oxygen
    levels are presently too low to support fish.
    Until the Tunnel
    and Reservoir Plan and/or instream aeration projects are on
    line fish would not generally be able to survive.
    No timetable
    is
    given for the activation of these improvements.
    Fecal coliform is used as an indicator organism.
    Its decrease
    implies a decrease in pathogenic
    organisms like
    shigella, salmonella,
    (typhoid and cholera)
    and dysentery.
    Its subsequent increase may not
    prove a parallel increase in the pathogens.
    Again, actual data could
    answer this point.
    The various combined sewer overflow points to the
    waterways may be the contributors to the high fecal coliform levels or
    they may not.
    The record is not clear on this point. The sampling
    frequency appears to be different.
    What is important is the relation-
    ship of sampling to rainfall events and this
    is not given.
    The data presented in Exhibit “A”
    (Table
    5)
    showing total
    coliform levels at Peoria higher in 1974 than in 1966 is not conclu-
    sive for two reasons.
    First,
    the data are for total and not for
    23
    625

    —4—
    fecal coliforms.
    Total coliforms may be of vegetable origin which
    in turn may come from land runoff and not from
    W—SW.
    Second, the
    sampling frequency for the years compared is significantly different.
    The District makes an argument that no recreational use would
    be made of waterways with their 2,000,000 tons per month of commercial
    commerce.
    We must distinguish several points here.
    First, the
    instant variance applies to W-SW which is on the Sanitary and
    Ship Canal.
    Most of the 24,000,000 tons
    (annual basis)
    alluded to
    is probably registered up the Canal to the junction with the
    Cal-Sag Channel and thence to Lake Calumet.
    In other words the
    traffic densities referred to probably does not occur in the vicinity
    of W—SW.
    Secondly, pleasure craft do in fact use the waterways.
    Personnel on these craft handle lines and may otherwise come into
    contact with the waters.
    Thus there is recreational use of
    these
    waterways.
    The District makes no mention of the capital cost of the chlori-
    nation facility for Battery D that has gone unfunded.
    It does not
    explore alternatives which might lower the cost of disinfection by
    as much as
    50
    such as using bulk chlorine as
    is done at City of
    Chicago water plants.
    The District is presently overdosing the effluents from
    Batteries A,B,
    and C to try to meet standards in the combined
    W-SW effluent.
    In
    February 1976 they met the standard.
    In
    January they did not.
    It
    is not clear
    if the standard is
    impossible to attain on
    a regular basis.
    Perhaps the provision of
    baffles in the effluent conduit to provide better mixing would be
    of value.
    The Board agrees with the Agency that the issues raised
    here are better presented in a regulatory proceeding.
    Specific
    W—SW
    plant data is lacking in this record and the variance is denied
    without prejudice.
    The Petitioner has not carried its burden.
    This opinion constitutes the Board’s findings of fact and
    conclusions of law.
    ORDER
    Variance from Rule 405 of Chapter
    3
    is denied without prejudice.
    IT
    IS SO
    ORDERED.
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    626

    —5—
    I, Christan
    L. Moffett, Clerk of the Illinois Pollution Control
    Board, hereby certify the above Opinion and Order were adopted on the
    ~~day
    of September, 1976 by a vote of
    4.~
    -.
    ~anL~~f&fl~
    Illinois Pollution C
    ol Board
    23
    627

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