ILLINOIS POLLUTION
CONTROL BOARD
April
5, 1984
CITY OF GRANITE CITY,
)
Petitioner,
V.
)
PCB 84—42
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent.
OPINION AND ORDER OF THE BOARD
(by N.
J. Nega):
This provisional variance request
comes before the Board
upon
an
April
5,
1984 Recommendation
of
the Illinois Environmental
Protection Agency (Agency).
The Agency recommends that a 45—day
provisional variance be granted to the City of Granite
City
(Granite City)
from 35
Ill, Adm,
Code 304.105 and 35 Ill.
Adm.
Code 304,141 to allow the bypassing of raw sewage into the Missis-
sippi River during the period of time when the city repairs the
high voltage electrical distribution system in its wastewater
treatment plant.
The
Petitioner owns and operates a wastewater treatment
plant
(WWTP)
in Granite City,
Madison County,
Illinois which
provides secondary treatment of wastewater and
discharges into
the Chain of Rocks Canal upstream of its confluence with the
Mississippi River.
The treatment processes which
take place at
the Petitioner~sfacility include “screening, pumping,
preaeration,
comminution, flow measurement, grit removal,
primary sedimenta-
tion, activated
sludge
process,
secondary clarification, and
chlorination” as
well
as “sedimentation and chlorination of storm
flows;
and thickening, decanting,
vacuum filtering,
and land—
filling of sludge”.
(Rec,
1).
Granite
City~sWWTP has
a design
average flow of 23 million gallons per day.
Granite City has previously experienced serious problems in
the city-owned portion of the
WWTP~s
high voltage electrical
distribution system, which have resulted in the occasional
loss of
power to the entire plant at times.
(Rec.
2).
To prevent the
recurrence of such electrical problems, Granite City proposes to:
(1) install cutouts at
two locations in its electrical distribution
system, and
(2) inspect, repair,
and seal various electrical
connections through the distribution system.
After the cutouts
are
installed and the necessary repairs
are
completed, the Peti-
tioner
will be able to turn off the electrical
power
in different
sections of its treatment facility without
affecting the remainder
57-391
of
the. treatment processes..
Thus,
if
an electrical
problem
develops in only one area
ci.
the WWTP,
it
will not result in a
loss of electric power to the entire plant.
Additionally,
the
inspection,
repair,
and sealing of
electrical
connections
should
result
in
an improved system
with
a
reduced
frequency
of high
voltage
electrical probi eras.
(Rec.
2).
The Agency has stated that Granite City
has requested “...up
to
96 clock hours of treatment works bypassing of raw
sewage to
the river.”
(Rec~ 2),
During the
time period that electrical
power is shut off to the raw sewage pumping station and to
the
combined
overflow
pumping
station,
it
will
be
necessary
to
bypass
raw
sewage into the Mississippi
River.
Granite
City has indicated
that
bypassing will occur only when work is actually being
done
on
the
electrical system
in.
order to minimize the
length of time
that such bypassing occurs.
The electric
power
will
be
turned
back on
after
work
is
done
for
the
day.
(Rec.
2).
The
Petitioner,
which
discharges
effluent pursuant
to NPDES
Permit No.
1L0033481,
has
requested that its NPDES
Permit
limita-
tions for
biochemical
oxygen
demand
(BOD)
and
total suspended
solids
(TSS)
be
revised
during
the variance period to
allow for
poorer
quality
effluent
due
to
the
anticipated
interruption
in
electric
powers
(Rec,
2~~3),
Granite
City
has
stated
that
the
aeration
process
vii
~Lhe
out
of
service
no
more
than
eight
hours
per
day
over
two
consecutive
days
under its
proposed
schedule
for
performing
the
necessary
e:iectrical
work,
This
schedule
is
designed
to
reduce
the
stress
on
the
microorganisms
in
the
acti—
vat.ed
sludge
process
and
will
aiso
help
to
minimize
any
dele-
terious
effects
on
the
eff.uent,
(Rec,3),
Moreover,
because of
the
e~ected
high
filution
involved,
the
effects
on
the
receiving
stream
of raw sewage bypassing and
any
reduced
effluent
quality
during
the
time
period
that
the
electrical
repair
work
and cutout
installation
:is
being
done
will
he
minimized.
Granite
City
has
considered
various
alternatives
to
turning
off
the
electrical
power
to
the treatment facility while
the
electrical
work
is
being
done,
These
alternatives
include:
(1)
doing
the
repair
work
with
the
system
“hot”;
(2)
doing
the
work
as
part
of
future
grant—funded
construction;
or
(3)
providing
portable
generators
or
other
scurce.s
of
power
during
the
time
period
that
the
electrica:1
work
is
being
performed.
The Agency
agrees
wlt:h
Granite
City’s
contention
that,
because
of
safety
considerations
for
both
its
employees
and
equipment,
the
first
two
alternatives
are
~?intolerahle~,
(Rec,
3),
The
Agency
has
stressed
that
working
“hot”
with
over
4,000
volts
of electricity
is
extremely
dangerous
and
would
subject
the
city~s
personnel to
unconscionable
risks,
Furthermore,
to
do
the
work
as
part
of
future
grant— funded
construction
would
put
off
the
necessary
repairs
for
at
least
a
:year
and
result
in
an
unreasonable
delay.
As
the
Agency
states,
“the
problems
which
have
occurred
are
better
solved
now
than
at
some
point
in
the
future,”
(Rec.
3).
57-392
The third alternative is not technically feasible because the
plant equipment is not equipped to be hooked up to portable
generators and all the electrical power comes into the WWTP
via
the line which the city will
be working on,
Although the treat—
ment plant is supplied by two separate lines from the power
company so there
is a backup power
source, there is
only
one
line
distributing the power within the WWTP.
The Agency believes that the provisional variance
is
appro-
priate because
it
will
allow
the
Petitioner
to
correct
problems
which result in unsafe conditions and contribute
to the unreli-
able
operation of the WWTP,
The Agency has
emphasized that the
“Petitioner could have decided
to
wait
for grant
monies to correct
these problems,
hut
has instead decided to correct
them now using
its own money.”
(Rec,
4).
Accordingly,
the Agency
believes that
the
denial
of the provisional variance would
impose an arbitrary
or unreasonable hardship
on
Granite
City.
Thus,
the Agency recommends that the Board grant the City
of
Granite City a provisional variance from Sections 304.105
and
304.141, subject to certain conditions.
Pursuant to Section 35(h)
of the Illinois Environmental Protection Act, the Board hereby
grants the provisional variance as recommended,
The
City
of
Granite
City
is
hereby
granted a provisional
variance
from
35
111,
Adm,
Code
3O4~i05 and
35
Ill.
Adm. Code
304,141 to allow the bypassing of raw sewage into the Mississippi
River during
the period of time when the city repairs the high
voltage electrical distribution system in its wastewater treatment
plant,
subject to the following conditions:
1.
The variance shall be for
a period of 45 days which
shall commence no later than May
1, 1984,
2.
The Petitioner shall notify Bonnie DeLay of the
Agency~s
Compliance Assurance Section by telephone when the work on
the high voltage power distribution system is begun.
3,
The Petitioner shall
notify Bonnie DeLay by telephone
of the time(s)
raw sewage bypassing to the river is
commenced
and of the time(s)
such bypassing is stopped.
In addition,
the Petitioner shall sample the bypassed sewage a minimum of
one
(1)
time
per
bypass
occurrence
or
one
(1)
time per each
eight
(8) hours of continuous bypass.
Such samples shall be
analyzed
for
SOD
and
TSS~
4,
During the periods when work
is being done on the
electrical system for the activated sludge process, the
—4—
incoming wastewater shall be held in the stormwater tank
and
processed when power has been restored to the
activated
sludge process.
The activated sludge process
shall be off
for
no more than eight
(8) hours per day for no
more
than
two
(2) days consecutively.
5.
The Petitioner shall meet the following
SOD
and
TSS
effluent
limitations:
~ntrationLimits~m/l~
~imits(lbs/da~
~v.
~Max,
~v,
Max.
SOD
100
mg/l
150 mg/I
9,175
lbs/day
14,385
lbs/day
TSS
100
mg/1
150 rng/l
9,175 lbs/day
17,838
lbs/day
6.
The Petitioner shall notify Bonnie Delay
by telephone
when all work to the high voltage power
distribution system
is completed.
7,
The Petitioner shall operate and maintain the treatment
facility in such a manner so as to obtain the
best quality
effluent possible.
8.
Within fifteen
(15) days after completion of the
repairs
to the electrical system,
the Petitioner shall submit a
report summarizing the actions taken to repair the electrical
system including,
but not limited to:
a)
the date, time and duration of each bypass
event;
b)
a summary of associated analytical test results;
and
c)
the dates on which the repair project began
and
concluded.
9.
Within 10 days of the date of the Board’s
Order,
the
City of Granite City shall execute a Certificate
of Acceptance
and Agreement which shall be sent to:
Illinois
Environmental
Protection Agency,
Division of Water Pollution Control, Com-
pliance Assurance Section, 2200 Churchill Road,
Springfield,
Illinois
62706.
This certification shall have the following
form:
CERTIFICATION
I, (We),,
having read
the Order of the Illinois Pollution Control Board in
PCB 84—42
dated April
5,
1984,
understand and accept the said Order, real-
izing
that such acceptance renders all terms and conditions
thereto binding and enforceable,
57—394
—5—
Petitioner
By:
Authorized
Agent
Title
Date
IT IS
SO ORDERED,
I,
Christan L. Moffett,
Clerk of the
Illinois Pollution
Control
Board, hereby certify that the above
Opinion and Order
was adopted on the,~~dayof,
1984 by
a
vote
1/
Christan
L. Moffett,
C~~k
Illinois Pollution
Control
Board
57-395