ILLINOIS POLLUTION CONTROL BOARD
April
8,
1976
CITY OF RED BUD,
Petitioner,
PCB 75—458
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
OPINION AND ORDER OF THE BOARD
(by Mr. Young):
This matter comes before the Board on the amended
variance petition filed January
22,
1976 by the City of
Red Bud seeking relief
from the chlorination and the
finished water quality requirements as
established
by
the
Board in Rules
305
and 304(b)
of Chapter
6:
Public Water
Supplies,
and from Section 18 of the Act.
An Agency Recom-
mendation was filed with the Board on March
12,
1976.
The City of Red Bud, with
a population of 2900 people,
owns
and operates a public water system which presently
consists of ten wells,
two elevated storage tanks, and
a
distribution system.
The only treatment currently being
provided the water
is fluoridation.
Seven of the wells are
active;
one
is
retired;
and two
(wells
#9 and #10) have not
yet been put into service.
Because of the future needs
of Red Bud, Petitioner now plans
to abandon the present well
system after constructing new wells on the Kaskaskia River
and transmitting the finished water some five miles
to the
City.
Petitioner estimates that the new
system
will not be
operational until September 30, 1978.
Petitioner was made aware of the inadequacy of the
existing water supply sources
to supply future requirements
in December of 1972
when the Southwestern Illinois Metro-
politan Area Planning Commission released its reports de-
tailing improvements that Red Bud and other municipalities
in the area
should make
in
order to meet future population
needs.
In addition to this report,
the Illinois State Water
Survey released studies which emphasized that this particular
area of the State was subject to limited water resources.
The City of Red Bud funded several studies directed toward lo-
cating adequate future water sources,
the last one being com-
pleted
in December of
1975.
After careful consideration of
these studies and reports, Petitioner has decided to construct
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a well system on the Kaskaskia River.
The City’s consultant
estimates that it will cost $1,700,000 for this system,
which includes
a one million gallon per day treatment plant
and pumping facility, two wells,
five miles of transmission
line,
and an elevated storage facility.
In order to presently meet the chlorination requirements
of Rule 305, Petitioner alleges that it would be necessary
to treat each of its existing wells separately at a capital
cost per well of $1,500.00.
Chlorination is not the sole
problem however.
Petitioner notes that water from its existing
wells has measured iron content of 0.6
to 1.2 mg/i and a manganese
content up to
.04 mg/i.
After January
1,
1978 the City is also
required by Rule 304(b)
to limit iron concentration to a maxi-
mum of 0.3 mg/i and manganese concentration to
a 0.05 mg/i.
It appears Petitioner would have to provide filtration equip-
ment at each well in order
to meet the standards for iron and
possibly manganese.
While the iron standards do not have to
be met until January
1,
1978,
the high iron concentration would
present a problem if chlorination were undertaken at this time.
The Petitioner~sconsultant states there
is a strong possibility
that the oxidation of the iron in the water may cause serious
operational and esthetic problems.
To meet the chlorination
requirements the Petitioner would be forced to provide for iron
removal as well.
Although Petitioner makes no estimate of
the cost of installing iron and manganese removal equipment,
the Agency estimates the cost for installing iron removal equip-
ment would be at least $200,000.00, even
if
the
treatment were
concentrated at one central point.
Since
the present wells
will not be part of the planned new system, Petitioner claims
that it will suffer an unreasonable hardship if it is required
to make these substantial short—term investments to achieve
compliance.
The Agency recommends the grant of
this variance subject
to several conditions.
Agency records indicate that well #9
has had a pattern of bad samples ever since it was drilled.
While
the Petitioner has not placed this well on line because
of the failure to obtain good samples, in addition to the fact
that the well has been pumping sand;
the Agency, nonetheless
recommends that good samples on two consecutive days should be
required prior to placing the well on line.
If the well is
placed on line, bacteriological samples
should be submitted
to the Agency for the next six months.
If any of these samples
indicate contamination continues to exist in the well, Peti-
tioner must either take the well off line or provide continuous
chlorination so long as the well is in line.
The Agency also recommends that the absence of continuous
chlorination at the supply for the time period requested makes
necessary the adoption of an active cross—connection program
to further assure that contaminants will not inadvertently enter
into the system.
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The various studies and reports that were done recom-
mended alternative methods
of updating the water facilities.
Some of the alternatives considered
in depth by Petitioner
were as follows.
One plan Petitioner considered was the
purchase of 275 acres of land to be used for the construction
of reservoirs,
including solicitation of the existing land-
owners.
Another plan involved the purchase of water from
the Sunixnerfield-Lebanon-Mascoutah water system which was
discarded when it was determined that although a connection
with the
(SLM)
system would be a quick and easy solution
to the problem, the water supplied by this means would also
be the most costly.
A third plan involved the construction
of the well system on the Kaskaskia River.
Other alterna-
tives were also considered and the final study was completed
in December of 1975.
Faced with this important and expensive
decision, Petitioner thoroughly investigated each alternative
before choosing the Kaskaskia River well system as the long-
term solution to its problems.
Petitioner estimates that
this system will be completed
in
September 1978 and is ex-
pected
to serve the community for the next forty to fifty
years
at an estimated capital cost of $1,700,000.00.
In
consideration of these factors, we find that Petitioner
has established
a legitimate and adequate reason for its
delay.
Any compliance program chosen by the City naturally
depended upon
which
particular water supply system was
finally chosen,
and it would have been irresponsible for
the Petitioner to proceed in any other fashion.
The Board
finds
the Petitioner has established
a hardship sufficient
for a grant of this variance.
While samples reveal that the iron concentration exceeds
the standards
as established by Rule
304 (b),
the same
is not
true for manganese.
For this reason it will not be necessary
to grant a variance from Rule 304(b)
as it concerns manganese.
The Board agrees with the Agency that it will not be necessary
to
grant
a
variance
from
the general requirements of Section
18
of
the
Act
which
requires
that
owners
and
operators
of
public
water
supplies
provide
water
which
is
“assuredly
safe
in quality and adequate in quantity.”
A
variance
from
the
provisions of Rules
304(b)
and 305 is sufficient
to meet
Petitioner
s needs.
This Opinion constitutes the Board’s findings of fact and
conclusions of law in this matter.
ORDER
1.
Petitioner, City of Red Bud,
is granted variance from
the chlorination requirements of Rule
305 of Chapter
6:
Public
21—93
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Water supplies from December
21,
1975 until September
30,
1978.
2.
Petitioner, City of Red Bud,
is granted variance
from the finished water quality standard for iron set by
Rule 304(b) of Chapter
6 from January
1,
1978 until Septem-
ber
30,
1978.
3.
Petitioner, City of Red Bud, shall follow the water
sampling program for well
#9
as detailed in this Opinion.
4.
Petitioner,
City of Red Bud, shall adopt
a cross—
connection control program and submit such program to the
Agency for approval within sixty days of the date of this
Order.
5.
Petitioner, City of Red Bud,
shall file
a satis-
factory project completion schedule with the Agency within 35
days of this Order and thereafter file bi-monthly progress
reports with the Agency until completion of the
facilities.
6.
Petitioner, City of Red Bud,
shall complete and send
within 35 days of the date of this Order the following certi-
fication to the following address:
Environmental Protection Agency
Division of Public Water Supplies
2200 Churchill Road
Springfield, Illinois
62706
I,
(We),
having read
the Order of the Illinois Pollution Control Board
in
PCB 75-458, understand and accept said Order, realizing
that such acceptance renders all terms and conditions
thereto binding and enforceable.
SIGNED
TITLE
DATE
7.
Those portions of the petition seeking variance from
Section
18 of the Act and Rule 304 (b)
as it concerns manganese
are dismissed.
IT IS SO ORDERED.
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I, Christan L. Moffett, Clerk of the Illinois Pollution
Order were
adopted on the
~
~
day of ________________________
Control Board, he9by certify the a~~~~pinion
and
,
1976
by a vote of
~
Christan
L.
Illinois Pollution ~a~oi
Board
21—95