ILLINOIS POLLUTION CONTROL BOARD

February

9,

1984

CONTINENTAL GRAIN COMPANY,

Petitioner,

)

v.

)

PCB 84—15

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

)

Respondent.

OPINION

AND

ORDER OF

THE BOARD

(by W.

3. Nega):

This provisional variance request comes before the Board

upon

a February

8,

1984 Recommendation of the Illinois Environ-

mental Protection Agency (Agency).

The Agency recommends that a

45—day provisional variance be granted to Continental Grain

Company (Continental) from 35

Ill. Adm.

Code 304.120(c)

to allow

the Petitioner to discharge about

16 million gallons of water

currently ponded on its spray irrigation

field.

Continental

owns and operates a soybean processing plant on

an

80-acre site in Taylorville,

Christian County,

Illinois.

The

Petitioner’s wastewater treatment facilities include two i—acre

lagoons operated in series

(i.e.,

both an anaerobic lagoon and an

aerobic lagoon).

Effluent which is discharged from this lagoon

system subsequently flows into a

final

spray irrigation system.

The spray irrigation system includes

24 spray nozzles located on

a 32-acre irrigation

field.

A dike which is between two and

three feet high surrounds most of the irrigation field.

(Rec.

1).

Flows sometime exceed the 200 gallon per minute

(gpm)

pumping capacity of the spray irrigation pump during the rainy

season.

Such excess

flows are diverted to

3 storm water dis-

charge pipes which are located along the southern edge of the

irrigation field.

Seepage into the soil is collected by a tile

field underlying the irrigation

field during such wet weather

conditions.

After the water is collected by the tile field,

it

is recycled either back to the spray irrigation system where

additional evapotranspiration can occur or into the cooling tower

to be utilized as makeup water.

(Rec.

1—2).

All noncontact cooling water and stormwater from Continen-

tal’s

site,

as well

as all process water,

is currently combined

and treated in the previously described manner within the Peti—

tioner’s treatment system.

(Rec.

2).

However, Continental is

in

the process of “working on an NPDES permit application to allow

surface discharge of noncontact cooling waters, and is consider—

56-187

---

—2—

ing ecta

13

)-

~

a pling

an?1 analysis program of stormwater

flows to

de1-?rir ‘w

tetIer or rot they can be in the future

exclude( fr~r

ke

t

c

ii’nt

oyster’.

(Rec

2).

Most

-

h

tw er’s

pray irrigation field is presently

covered ty LI

t

fct

~ “tter ath a 6—inch ‘ice cap’ on

top

of tie

it

tc.

~ttc’

c.

lu s of the water currently ponded

on

thi. 3~

c~

1

V

i•

gallots

(I

.t.s ac’ irula ton of water resulted from

3

months in rh

r

~rq

t

r th n n’

-

iia

precipitation occurred in the

area.

Lurirg

C

tc.

r.

November

and

December

of 1983, precipita-

tion ir

tic. “aylor file region was 1.11 inches, 2.78 inches,

and

1.45 inches

above

tornal, respectively.

(Rec.

2).

During the

latter half of October, 1983, ponding on the spray irrigation

field began.

To counteract such ponding, the spray recycle was

startec’ to respray tie water that filtered through the field

tile.

Water from the field tile was pumped to the cooling tower

during overber,

1983

However, because of the freezing of lines

due to the cold wirter weather, the Petitioner’s treatment facil-

ities lost

tic.ir

:apacity to recycle water to the spray system

and to tic coo~1’.s,toter on December 21,

1983.

Similarly, the

petitiorer’e ebi1

~ t’

spray water onto the irrigation field was

lost on

Deceirber

2

,

19a?

due to lines freezing.

(Rec.

2).

The

spray i rigaticn s4re was thawed out on January 7,

1984 and,

since

that.

line

2tt.

wzay

racyUe

line

has

thawed.

Thus,

almost

all

of

Contincntc

‘

treotznent

system

is

now

back

in

operation,

except

.

th..

d)s.liej

ia

rt

jcle

water

to

1.he

cooling

tower.

(Røc’.

2).

Be

au

.~

1?.

c..

r.it

inobality

to

recycle

water

to

the

cool

n

0

--

r

r

a

~

c..

nc.rred

that

impending

spring

rains

n.1.ght

ortner

flood

thc

a~rayirrigation

field

and

cause

runoff

to

a

ro..J0_de

drainage

E.tch

ar.d

nearby

property.

C

Rec

•

3).

Accordiagl

y, Contstental is seeking a provisional variance from

Special

Cuàus~sti

e

u

siC

age.aC.f

permit

issued

on

February

24,

1983

which

taads.

9!here

shall

be

no

discharge

from

the

treatment

lagoons

or

spray

.Lrzsgacion

fleld to any surface waters of the

State’.

(Rec.

1

•

Li

its

Recomnendation,

the

Agency

has

construed

the

reque.flcd

variance

from

Special

Condition 2 to be a request

for variance from

35

Ill.

Mm.

Code

304.120Cc),

and

the

Board

concurs in this assessment.

Thus, the Pstitioner is asking to be allowed to discharge

about

16

nflion

Jats

ss

of

water

presently

ponded

on

the

32—acre

spray

..:r...ça:..

L.....1

Lftar

.ppropriately

draining

the

ponded

water.

‘0

ac

oT)List

ins

drainage,

Continental

could

either

pump

the

arar

over

tnc.

ibce

a

distance

of

about

30

feet

to

a

roadside

diLst

0:

uaseal

the

ouLlet

from

an

18—inch

sluice

gate

and

discnargc.

me

water

..o

~ne

field

tile

system.

Hfluent

from

both

the

anaero~s~

and

the

aerobic

lagoons

would

be

discharged

with

the

~oadcJ

water

if

the

sluice

gate

were

used,

as

Continental

would be unable to keep such waters separated.

(Rec.

3).

What-

ever

method

of drainage would be used, the

ponded

water from the

spray irrigation fiela would travel about 1¼ miles before empty—

56-188

---

ing into an unnamed ditch which is

tributary

to the South Fork of

the Sangamon Rivers

(Rec,

3).

In evaluating this proposed discharge,

the Agency has taken

various water samples and performed a laboratory analysis of the

ponded

water which indicates SOD levels ranging between 4.9 parts

per

million

(ppm)

and i7~7ppm; TSS levels varying between

5 ppm

and

22 ppm; ammonia nitrogen levels of between 0.32 ppm and 0.39

ppm; and pH ranging between 6,7 and 6,97.

(Rec.

3),

After its

laboratory evaluation, the Agency concluded that

the

discharge

of

this ponded water would have a minimal environmental impact

because the receiving waters will be carrying high levels of

dissolved oxygen and biological activity will be at a low level

during the requested variance period,

The

Agency believes that

the receiving waters will have the capacity to assimilate the low

levels of pollutants which would be discharged in such a case.

(Rec,

4).

Accordingly,

the Agency has concluded that compliance on a

short term basis with the provisions of 35

Ill. Mm, Code 304.120(c)

would impose an artitrary or unreasonable hardship.

Therefore,

the Agency recommends that the Board grant Continental Grain

Company a provisional variance from Section 304,120(c),

subject

to certain conditions,

Pursuant to Section 35(b)

of the Illinois

Environmental Protection Act, the Board hereby grants the prov-

isional variance as recommended.

ORDER

Continental

Grain Company is hereby granted a 45—day provi-

sional variance from 35 Ill,

Adm.

Code 304,120(c)

to allow the

discharge of approximately 16 million gallons of water currently

ponded on its 32~~acrespray irrigation

field,

subject to the

following conditions:

1.

This variance shall commence on February 9,

1984 and

shall terminate 45 days thereafter,

2.

By March

1,

1984, Continental

shall:

a).

Submit an application to the Agency for an NPDES

Permit to allow implementation of its compliance plan;

and

b).

Establish a program for sampling and

analyzing

stormwater

flows to collect data for determining whether

or not all, or part, of the stormwater flow can be

safely excluded from treatment in Continentals lagoon

and spray irrigation system.

3.

Continental

shall discharge to the drainage ditch and

shall control such discharge by use of either pumps or another

method which can be turned on and shut off,

56489

---

4,

C ntire’-~al shalt sam1~le using approved methods, any

discharge

2 tines pei ~‘Jeek

for DOD,

TSS, pH,

temperature,

and

am1flOnia nitroger

5.

Withir

~t~5

after

the end of each calendar week of

discharging,

~on~r.

al

shal

subsit sample results to James C.

Frost,

CompiJan

s

~ce

5

+ron, Division of Water Pollution

Control,

11 ~ir~

f~ L o

~ir ~i

~r te-’tion Agency,

2200

Churchill

Road,

Springfield

hr ~

62,06

6.

During

rLc pericd of this variance, Continental shall:

a)~ work to thaw the line to the cooling tower so that

all treatment options can be utilized;

and

h).

return as much of the ponded water as possible

through the recycle spray and cooling tower (after

frozen line thaws

out)

so

as to minimize the amount of

water which is discharged.

7.

Continental

shall notify James

C.

Frost by telephone

whenever discharging is commenced.

8.

Contirental

shall keep record of the length of time

discharge occur3 and Sne voinme discharged on a daily

basis.

A

copy of these recrds shall he submitted with the sample results

(item

5).

9,

Within 10 days of ~de date of the Board~s

Order,

Conti-

nental Grain Corlanl

stall execute a Certificate of

Acceptance

and Agreerrerd. ‘,r~c s~al

?

s

.t to:

Illinois Environmental

Protection Agency,

Div.~sionof Water Pollution Control, Compli-

ance Assurance Section

22J0

Churchill Road,

Springfield, Illi-

nois

62706.

This certification shall have the following form:

CERTIFICATION

I,

(We)

____

_______

______________________

having read the Order of the Illinois Pollution Control Board in

PCB 84—15 dated ~ehruary 9,

1984,

understand and

accept

said

Order,

realizing Suet such acceptance renders all

terms

and

conditions thereto binding and enforceable,

Petitioner

Dy:

Authorized Pgent

Title

Date

56~19O

---

—5.-

IT IS SO ORDERED.

I, Christan L.

Moffett, Clerk of the Ilinois Pollution

Control Board,

hereby ~ertify that th~,above Opinion and Order

was

adopted

on

thej~__day

of

____________________,

1984

by

a

vote

of~j~C

1/

/.~—

1.

Christan L. MoffeL?t, Cl~?k

Illinois Pollution Cont~rblBoard

56-191