ILLINOIS POLLUTION CONTROL BOARD
March
8,
1984
IN THE MATTER OF:
)
PETITION FOE SITE SPECIFIC
)
R82—3
EXCEPTION TO EFFLUENT STANDARDS
)
FOR ALTON WATER TREATMENT PLANT
)
Adopted Rule.
Final Order
FINAL OPINION AND ORDER OF THE BOARD
(by
J. Anderson):
This matter comes before the Board on the petition for site
specific “exception”
filed by the Alton Water Company
(Company)
February
9,
1982 as amended July 21,
1982.
The Company seeks
exception from
15 mg/i total
suspended solids
(TSS) and
2
mgI?
total iron effluent standards of
35 Ill.
Adm, Code 304,124(a),
as they relate to the wastewater discharged by the Company’s
potable water treatment facility.
(Identical variance relief
was granted in PCB 82—13, August 18,
1982 until September
1,
1985 or the earlier completion of this rulemaking
(See Company
Gr.
Ex.
ij.
A consolidated merit and economic hearing was held
in Alton
on February
15,
1~)83,
In addition to the testimony and exhibits
in support of the petition advanced by employees of
the company,
the Mayor of the
City
of Aitori,
a member of the City Council,
and the President of the Greater Alton Chamber of Commerce also
made presentations
in support
CR.
8—16, City Ex.
1, Timmermiere
Ex.
1-2,
Utterback Ex.
1).
On behalf of
the Department of Energy
and Natural Resources
(DENRL, Linda Huff presented testimony
concerning her “Economic Impact Assessment Regarding R82—3:
A
Site Specific Exemption for the Alton Water Company”
(DENR Ex.
1)
(also see PC
1).
The Illinois Environmental Protection Agency
(Agency)
appeared at hearing to examine the Company’s witnesses,
but presented no testimony or witnesses,
The Agency did, however
submit written comments
(PC
2).
The Board adopted
a First Notice Order in this matter on
October
8,
1983,
and a Second Notice Order on January
12, 1984.
On February 23,
1984, the Joint Committee on Administrative
Rules determined that
it had no objection to the rules as proposed.
*The Board appreciates the efforts of administrative
assistant Kathleen Crowley, who acted as Hearing Officer and
provided assistance in drafting this rule and Opinion.
57-139
2
PLANT DISCHARGES AND ENVIRONMENTAL EFFECTS
The Alton Water Company, Madison County,
is
a public utilit~
which provides drinking water to approximately 16,900 residential,
commercial,
industrial, and municipal customers in the City of
Alton and the surrounding area.
The Company owns and operates
a water purification plant which withdraws raw water
from the
Mississippi
River and purifies and distributes finished water to
its customers.
Wastewater resulting from the purification process
is discharged into the Mississippi downstream from the intake.
An
average of 12.5 millions of gallons per day
(mgd) of raw water is
treated prior to distribution by means of coagulation, settling,
filtration,
chlorination and fluoridation.
As
of
1980,
the rate filtered capacity of the Company’s plant
was 10.4 mgd.
On account of lack of reserve treatment capacity,
the plant was placed on the Agency’s Division of Public Water
Supplies’ Critical Review list on July 1,
1981.
As a result of
various modifications to the Company’s system, the rate filtered
capacity was subsequently increased to 13.3 mgd, and the plant
was removed from the Critical Review list.
The Company has recently completed construction of a new
additional treatment system
to increase the plant capacity by 5
mgd to 18.3 mgd.
The Company alleges that the addition is
necessary to enable the Company to meet existing system peaks and
normal summer season demands on the system.
Construction of this
addition proceeded pursuant to a “construct—only” permit issued
by the Agency.
The Agency issued a short—terni operation permit
after grant of variance in PCP 82—13, hut absent site—specific
relief facilities to remove excess TSS and iron from the Company’s
effluent will need to be constructed.
Operation of this plant addition would not change the
treatment process or discharge configuration of the existing
plant,
although the quantity of discharge would increase as
production of finished water increases.
The treatment process
here involved begins with the pumping of raw river water at an
intake structure, where alum and polymer are added to the water.
It is then conveyed to two circular mixers and then to a clarifier
where addition of a small quantity of lime for pH adjustment,
pre—chlorination, and occasionally
a coagulant aid, occurs.
Water
then flows through two sedimentation basins, and finally through
sand and gravel filters,
a
filter aid having been added when
required.
Post—chlorination and fluoride additions are made after
filtration.
Finished drinking water
flows to a clear well before
distribution.
The high TSS
concentration
in the Company’s wastewater was
the subject of an earlier Board proceeding,
East
St.
Louis and
Interurban Water
Co.v.
IEPA and Alton Water
Co.
V.
IEPA
57-140
3
(consolidated),
PCB 76—297 and 298,
24 PCB 801, February 17,
1977.
In that case,
average TSS concentration of Alton’s discharge was
reported as being 11,060 mg/i,
24 PCB at 803.
The Company
unsuccessfully argued that since the high TSS concentration was
largely attributable to high TSS levels in its raw water source
(e.g.
68 mg/I), that
it qualified for a Rule 401(a)
exemption to
the Rule 408 effluent limitations.
The Board affirmed the
Agency’s denial of an operating permit.
Following this Board
decision, the Company began investigating methods of treating its
discharge,
as well as the possibility of obtaining site specific
regulatory relief.
In pursuing the latter option,
the Company contacted the
State Water Survey
(Survey) concerning the possibility of the
Survey doing a study of the environmental impact of the discharge
on the Mississippi.
Due to the Survey’s workload, its commitment
to undertake the study was not made until
May,
1979.
The recently
completed study,
“Waste from the Water Treatment Plant at Alton
and its Impact on the Mississippi
River”,
Ralph Evans
et al.
(1982)
(Evans Report)
(Evans
Ex.
1), and the supporting testimony
of Mr.
Evans,
is the source of much of the information relied on
by the Company.
The Evans Report estimates the volume of wastewater produced
at the plant to be 603,000 gpd,
or roughly 48,000 gallons of
wastewater per million gallons of raw water treated.
Wastes are
produced in the mixers, clarifier, sedimentation basins and
filters,
The significant contributors to the waste loads
in the
discharge were viewed to be the TSS content of the raw water and
the alum added for coagulant purposes.
Average daily production
of dry solids in the treatment system was estimated to be 12,500
pounds,
of which only 150 pounds were attributed to alum usage.
During normal daily plant operations,
in addition to TSS,
the discharge exceeds only one other effluent standard:*
the
2.0 mg/i iron limitation, the average concentration in the
discharge being 14.6 mg/i.
Again, however,
the raw water contains
iron in excess of the limit.
During the twice yearly cleaning of
sedimentation basins, the 2,0 mg/i barium standard and the 1.0
mg/l manganese standard are also violated, as the average
*At the hearing,
the Agencyinquired whether the discharge
had been examined for levels of BOD and fecal coliform
(R.
76-81),
As Mr.
)3lanck noted, the NPDES Permit does not establish
limitations
for these parameters.
Although the Company could not,
at that juncture, submit contemporary information, it did supply
available data.
Based on this data, the Company asserts that the
discharge does not pose any threat of violating water quality
standards,
or even effluent standards,
for these parameters.
(Evans
Ex,
No.
1 at 20—21;
R,
76—81;
Co.
Ex. No,
2 at cover
letter,
5,
10,
25,
30, 134—138,)
rfhe
Agency has not challenged
this assertion.
57-141
4
concentrations
in
the
discharge
at
those
times
are
estimated
to
be,
respectively,
6.0
mg/l
and
3.92
mg/i.
The
Company believes
that
such
excursions
could
be
eliminated
by
more
frequent
basin
cleaning,
which it
has
undertaken
to
do
(R.
27).)
In
assessing
the
environmental
impact
of
these
discharges,
the
Survey
believed
it
necessary
to
perform
a
study
of
in—stream
water
quality,
based
upon
its
earlier
studies
of
water
treatment
plant discharges.
Calculations were made concerning the impact
of
the
PBS
discharge under worst case conditions.
Using the daily
load of suspended solids in the discharge (12,500 lbs.)
and
the
7—day, 10—year
low
flow for the River (21,700 cfs) with a 10
mixing zone and a river PBS concentration of 10 mg/i, Evans
included that the in—stream PBS concentration would be 34 mg/1.
Except during such conditions, the Company’s discharge
was
estimated to represent only 0.018
of the average daily solids
load conveyed by the stream.
Calculations were also made as to the effect of the barium,
manganese and iron discharges during the twice—yearly (April,
November)
basin cleaning episodes
during
the worse
November
(average stream flow) conditions.
Again assuming a 10
mixing
zone, the concentration in the Mississippi without the waste, and
then with it, were estimated to be:
for
barium
0.10 mg/l vs.
0.11
mg/i,
for manganese 0.25 mg/i vs.
0.27 mg/i,
and
for iron
8.60 mg/I vs. 9.40 mg/l.
The
Survey
did
do
sampling
of
river
bottom
sediments,
to
determine their content as well as the types of densities of
macroinvertebrates located in these sediments.
The
Survey
determined that while the Company’s waste flows were detectable
in
the
River’ s
bottom
segments,
that
the
areal
extent
of
their
influence
was
limited
to
200
feet
offshore
and
within
2,000
feet
downstream of the waste outfall.*
Mr. Evans testified that examination
of
the
sediments
did
not
reveal a measurable •blanketM of sludge deposits foreign to
the sediments of the river,
but
that the Company’s discharges
had
changed the character of the sediments.
Usual Mississippi
River Bottom sediments are mainly sand
(i.e. 94
sand, 4
silt,
and 2
clay), while the bottom sediments in the impacted area
consists mainly of silt and clay (i.e. 33
sand, 49
silt and
18
clay).
Examination of the sediments for bottom dwelling organisms
did
not
reveal
an
adverse
impact
on
them
due
to
the
Company’s
discharges.
Mr.
Evans
noted
that
a
mixture
of
sand,
silt
and
*At
hearing,
Mr.
Evans
clarified
that
this
mixing
zone
would
be well within that allowable by Section 302.102, that is, the
area of a circle with a radius of 600 feet
(R. 48—49).
57-142
S
clay
is
a
more
stable
environment
than
sand
for
these
organisms,
and
that
while
“the
impact
of
the
waste
nay
not
be
solely
beneficial
in
enhancing
the
habitat,
it
nevertheless
does
not
have
an
adverse
impact”
(R.
53—54).
in
response
to
a
concern
exuressed
in
a
Concurring
Opinion
in
PCB
82—13,
Mr.
Evans
performed a
literature
search concerning
the
toxicity
of
aluminum
to
aquatic
life.
(As
aforementioned, the
Company’s discharge introduces about
150 pounds of
alum into the
river daily).
Mr0
Evans observed that in the USEPA publications
he consulted,
chlorides,
nitrates,
oxides, and sulfates of
aluminum were suspected of adversely affecting various shellfish.
However, hydroxides of aluminum, those contained in the Company’s
waste, were not mentioned.
Based on this information, as well
as
on his observation that the number,
type,
and diversity of
macroinvertebrae did not differ between sediments upstream of the
discharge and sediments in the area impacted by the discharge,
Mr. Evans concluded
that
the
aluminum
content
in
the discharges
were not a “limiting factor” in the aquatic habitat
(R.
56).
In the ECIS,
Linda huff provided information concerning
stream uses immediately downstream of the Company’s discharge and
Ms.
Huff
noted
that
next
to
the
Alton
Water
Company
are
two
commercial/industrial
facilities,
and
that
a
grain
dock,
a
petroleum dock,
and
a
sand
operation
are
located
immediately
downstream and adjacent
to
the
shoreline,
all within 3000 feet of
the
Conipany~s discharge
(DENR
Ex,
1,
p.
Li).
(As
aforementioned,
the
areal
extent
of
the
Company’s
discharge
is
limited
to
200
feet
offshore
and
within
2,000
feet
downstream
of
the
waste
outfall.)
Ms.
Huff also notes
~ha~:there
is no water
quality
monitoring
point
located
immediately
downstream
of
the
Company’s
discharge,
located
at
river
mile
204.2,
located
1.32
miles
upstream of Lock
and
Dam
No.
26.
The closest downstream station is that at the
East St.
Louis water intake
(river mile 180);
any effects of
the
Alton discharge
would
be dissipated before
that
point
(DENR Ex.
1,
p.
9—10).
TREATMENT
OPTIONS
~rn
cosTs
The Company
has,
since
:L9?3,
considered
various
options
for
disposal
of
the sediments co~tai.ned
in
its
wastewater,
Because
of
the
small
size
of
the
plant
site,
only
off~-site
disposal
is
feasible
(R.
27),
The
possibility
of
discharging
into
the
City’s
sewer
system
was
discussed.
but
rejected
by
the
City
on
the
basis
of
its
engineers’
findings that ~he
treatmen~
system
could
not
accept
the
entire plant discharge
(R.
2:3;
Company
Ex.
No.
1,
Amended Petition for
Variance
at
Ex,
8~
Company
Ex.
No,
2
at
141-
142).
The Company also considered discharge of a portion of the
57-143
6
wastewater to the city system.
This alternative would, however,
require construction of holding facilities which could not be
accommodated on the plant site
(R.
129~130), Negotiations to
acquire nearby property for such holding facilities were unsuc~
cessful
(R.
96’~97).
Nor did this course present a more economical
alternative for disposal.
Construction costs were estimated
(in
1977—78) at some $2 million for the holding facilities
(R.
28—29).
In addition to these capital expenditures, annual user fees of
$147,000 to $196,000 for disposal to the city system would be
imposed
(R.
28—29),
Various alternatives for treatment and disposal of the total
discharge off—site were considered, including lagoon disposal,
barging and mechanical dewatering
(filter press and centrifuge)
(R.
34).
The Company~ssummary
(Herman Ex,
3) of these options
and costs is summarized below in table
form:
StEP!MW SOLI~
DTS~~L
Pt~
to
Lagot~t
~d~ani~11y
~t~era~d
~s1Si~
rPr~s~
!11ir~ia
Mi*~t
~3ooo~
C4*ratthg
Lakx~r
and Energy
~ta
$
33,100
$
76,700
$
9~400
$
6,700
$
5,000
$
16,250
$
17,500
$
U,250
$
11,250
$
16,~50
0
316,950
$
172,200
$
25,~5O
$
23,150
The Company~s
engineers
concluded
that
the
lagoon
disposal
method
was
the
only
feasible
alternative
(R.
34~-36).
The
chosen
compliance
option,
if
ultimately
required,
would
involve pumping of wastewater
to
an
off~-site
lagoon
disposal
system.
A site
3½
miles upstream of the plant
has been purchased
at
a
cost of $243,000.
Capital costs
of construction of a
collection system at the plant, installation of piping and lift
stations, and construction of two drying lagoons, are estimated
to be $3,000,000 with annual operation and maintenance costs of
$16,850.
Such a system would take approximately 20 months to
construct.
Mr. Herman testified that
the
$3,000,000 estimate (updated
to 1982 dollars) included costs for 1) equipment and construction,
2) engineering,
3) interest and contingencies, and 4)
land
(R.
37;
57-144
7
Herman Ex.
1).
Annual operating expenses were estimated
(in
1982 dollars) to be $19,000
(Herman
Ex.
2).
To support the capital
investment,
the Company would have
to request annual increased revenues
in excess of $710,000.
Additional revenues,
in the amount of $19,000, the estimated
annual operating expenses, would also be required.
Finally,
revenues to cover depreciation, in the approximate amount of
$60,000
(reflecting
$3 million in capital costs), would be
needed.
Thus, the total estimated additional revenues per year
would total some $789,000
(R.
30).
To generate these revenues, the Company would be required to
seek an increase in its rates of an average 16 percent for all
customer classes.
Based upon the rate approved by the Illinois
Commerce Commission in its Order of October 27,
1982,
a typical
residential customer now pays an average of $163.00 per year.
If the additional increase to reflect the cost of waste treatment
and disposal facilities were included,
the average residential
customer would pay an additional $26.00 per year,
for a total bill
of $189.000*
(R.
31;
126—127).
At hearing,
Mrs.
Huff generally did not disagree with the
compliance costs estimated by the Company.**
In the EcIS,
a
lengthy comparison of the costs and benefits of full compliance
was made, which were summarized in Table 5—i
(DENR Ex.
1,
p.
55).
This Table is reproduced below:
Table
5-1.
ComparIson
of
Environmental
Costs and Benefits of
the
Alton Water Company Complying with the Hhinois Effluent
Llmitaticns
Impact Category
Annual Costs
—
Annual
Benefits
DescriptIon
S/yr
Description
$/yr
Uton Water Company
~esthetics
Pollution Control
Expenditures
5517.000
Not Quantifiable
nvironmental
Impacts
• Fish
• Benthic Comunity
•
Bacterial
Contamination
• Aesthetics
No i~act
0
No measurable
improvement
0
Not
known
Na shoreline access
for
publIc
0
Public Water Supplies
Reduced sol1d~
Loading on
downstream
users
0-51,200
tavigation
$517,000
Reduced dredging
costs
0-54,000
0-55,200
lotus
*Mrs.
Huff compared Alton
to
three suppliers on the
Mississippi River
(DENR Ex.
1 at 66), finding the existina Alton
(footnote continued on next page)
57-145
8
The EelS also considered treatment of part of the discharge
through mechanical dewatering and disposal
(DENR Ex.
1,
p.
22-28)
Mr. Herman calculated the expenses of such efforts to be
substantially higher than suggested by the consultant
(R.
88—91).
~r. Herman also testified that the construction costs would be
the same as
for disposal of all of the discharge because of the
necessity for disposing off—site
(B.
131—134).
AGENCY COMMENTS
In its comments,
the Agency does not dispute the economic
testimony presented, and agrees that “the continued discharge
will have no significant impact on the Mississippi River.”
However, it declined to make
a recommendation either that the
Board grant or deny the requested relief.
The reasons for the Agency’s maintenance of this posture
will be best conveyed by quotation rather than by paraphrase:
“The Agency is concerned that
a grant of relief here may
cast doubt on the validity of suspended solids standards
contained in the Board’s regulation and continued ability
to enforce them against facilities which discharge contami-
nants that originates in raw river water.
In East St.
Louis
and
Alton Water Comp~nyv.
IEPA, PCB 76—297 and 298,
February 17, 1977 the Board held that these contaminants
must be controlled.
Many facilities along both the
Mississippi and Illinois Rivers,
including other public
water supplies and gravel and sand dredging operations, have
less concentrated waste and perhaps as little impact.
Yet
these facilities must still control
their discharges to meet
the effluent standards,
T~otnotecontinued from preceding page)
rates lower than those of the City of Quincy but substantially
higher than those of Rock Island and East St.
Louis.
**The
EcIS
(Ex.
1,
p.
20—22)
had noted that the capital
costs of treatment options originally submitted by the Company
were substantially higher than Huff and Huff estimates based on
“New Concepts in Water Pollution” by Cuip and Culp
(DENR Ex.
4).
At hearing
(R.
87—93),
it was explained
in detail that the
discrepancy had in
large
part
resulted
from
differences
between
the Alton facility and the facility serving as the basis for the
Cuip and Culp figures, and in use of different indices in bringing
1970’s dollars up to 1982 dollars.
57-146
9
The Board adopted effluent standards on the basis of
the ability of the individual discharger to treat the waste,
rather than the impact on water quality.
This treatibility
basis was enunciated in the Board’s opinion adopting effluent
standards,
R70—8,
January
7,
1972,
and repeated in the
Board’s review of those effluent standards in R76—21,
September 24,
1981.
The concept was that all discharges
should be treated to the degree that the Board found
feasible and reasonable.
Here there is no question the technology is available
to treat the discharge.
The Water Company can treat the
wastewater rather than discharging
it untreated into the
river.
The Water Company has testified however that it
would be costly to include any treatment and that treatment
would raise the rates of the users.
In deciding this case
the Board must consider whether these are sufficient grounds
to grant relief.
If the Board decides that relief here
is
warranted then it should explain this departure from the
usual theory of setting effluent standards.
This explanation
will greatly aid the Agency and other dischargers in deter-
mining future effluent limitation policy”
(PC..
2,
p.
4—5),
THE
RESOLUTION
In its above-cited remarks,
the Agency has accurately
reflected the Board’s general philosophy in enacting effluent
standards.
However,
in so doing,
the Board noted that the
desirability of generally applicable effluent standards
in part
flowed from the fact that “tdeterm.ining
discharge requirements
on a case—by—case basis
so as to tailor discharges to stream
quality requirements is a very time—co:~isumingprocedure that
creates a great deal of uncertainty”
(B.
70—8,
3 PCB 401 at 401,
January 6,
1972),
Too,
in that Opinion,
it was noted that the
effluent standards for both TSS and total
iron were predicated
in
part on prevention of “undesirable” or “harmful” bottom deposits
(Id.,
3 PCB at 416,
419).
The Mississippi River
is naturally high both in TSS and
iron.
In this case,
the study of the Company’s discharge by the
State Water Survey indicates that the bottom deposits are at
worst benign, and may be beneficial.
Assuredly, the Board gives
greater weight
to
the
Survey’s
analysis
than
it
might
to
that
of
another consultant—contractor, based on the Water Survey’s
nationwide reputation and the Board’s own history of dealings
with it.
Given this environmental analysis, the high costs of
removal of TSS and iron from the Company’s discharge are not
justifiable.
The Board will therefore grant
the
relief requested
by the Company.
57-147
10
In
reaching
this
result,
the
Board
realizes
that
it
has
not
provided
the
easily
applicable guidelines the Agency has
request-
ed.
The
Board
further
acknowledges
that
this
may
be
troubling
particularly in light o~another recent site—specific rulemaking
petition
for
discharge
of
TSS
into
the Mississippi River
i.e.
Sauget/East
St.
Louis,
R81—12,
September
23,
1983
(proposed
rule),
and further petitions anticipated pursuant to the Part
306, Subpart D “Exception Procedure”.
However,
in the last
analysis, conditions
for the granting of site—specific relief are
not
capable
of
precise
legal
or
technical definition. ~dditionally~
the fundamental
goal of all standards,
regardless of how establish-
ed,
is to enhance stream quality.
In this case,
the “time consuming
procedure” demonstrates with reasonable certainty that the applica-
tion of the general effluent standards will contribute minimally,
if at all, towards stream quality enhancement.
Given this
“reasonable certainty” the Board does not
feel
that
the dis-
charger should bear the costs of compliance outlined
in this
case.
In
its
January
3,
1984
comments
on
the
first
notice
Proposed
Opinion and Order
(PC
3),
the Agency objected to the “sweeping
language”
of the above
three paragraphs.
its objection,
in
a
nutshell,
is that
“Thus the Board’s resolution
is flawed
in
the
extent
to
which
it
relies
on
the
unquestionably
reliable
proof
of
no
impact.
The
fact
is
that
the
discharger
is
so
small
that
one
would
not
expect
to
find
that
it was having an
impact.
Further
it
ignores
the
question
of
the
impact
if
all
similarly
situated
dischargers
were
to
dump
suspended
so1iri~
in
the
river
without
treatment.
This
impact
would
not
he
discernible
from
a
study
of
the
discharge
of
the
Alton
water
plant.
This
rule
change
shows
implicitly
the
dangers
of
relying
on
impact
in
making
site
by
site decisions on effluent
standards.
While relief
for Alton water company might he
justified
by
consideration
of
the special difficulty that
they
have
in
adding
suspended
solids
treatment
because
of
their
lack
of
space
at
the
plant
and nearby,
a -iustificatio~i
on
the
basis
of
no
impact
would
serve
for many water treat-
ment plants on
the
Mississippi
or
Illinois
Rivers.
While
the
Agency
can
acquiesce
in
relief
for
a
plant
as
Alton’s
it
would
be
difficult
to
justify
relief
for
any
other
plant
which was not so awkwardly situated,
***Even
in
a site specific rule change the Board should
not lose sight of the need for or importance of technology
based effluent standards.”
(PC
3,
p.
3—4).
57-148
1.1
These comments reflect a misapprehension of
the
Board’s
reasoning
in this matter.
Granting of this relief does not
represent a philosophical departure from the enforcement of
general,
technology-based effluent standards.
it
is,
further,
rather
unlikely
that
two
dischargers
would
ever
be
so
“similarly
situated”
that
a
Board
determination
in
one
case
would
serve
to
control
its
determination
in
another.
The
Board
has
not
granted
relief
solely
based
on
the
assimilative
capacity
of
the
Mississippi
River
for
TSS
and
iron
discharges;
it
has
instead
considered
this
as
but
one
factor
in
a
situation
also
involving
“benign,
if
not
beneficial,
bottom
deposits”,
lack
of
feasible
options
to
off-site
sediment
disposal
due
to
the
plant’s
lack
of
acreage,
the
effect
of
the
discharge
on
downstream water
supplies,
side
land
use,
the
costs
of
the
treatment
technology
required
by
the
general
rule,
etc.
To
attempt
to
pinpoint
whic~i
of
these
considerations
is
the
most
crucial
in
this,
or
any
future
case,
is
as
unavailing
as
an
attempt
to
determine
which
strand
in
a
rope
shapes
it
as
a
whole.
In
redrafting
the
rule
as
proposed,
the
Board
has
added
provisions
tying
the
exception
to
the
Company’s
current
18.3
mgd
treatment
capacity;
any
additional expansion will necessitate ~
rule
change
and
new
environmental effects analysis.
ORDER
The
Board
hereby
adopts
the
following
rule,
which
shall
he
filed
with
the
Secretary
of
State:
TITLE
35:
ENVIRONMENTAL
PROTECTION
SUBTITLE
C:
WATER
POLLUTION
CHAPTER
I:
POLLUTION
CONTROL
BOARD
SUBPART
B:
SITE
SPECIFIC
RULES
AND
EXCEPTIONS
NOT
OF
GENERAL
APPLICABILITY
Section
304.206
Alton
Water
Company
Treatment
Plant
Discharges
This
Section
applies
to
the
existing
18.3
million
gallons
per
day
potable
drinking
water
treatment
plant
owned
by
the
Alton
Water
Company
which
is
located
at,
and
discharges
into,
river
mile
204.4
on
the
Mississippi
River.
Such discharges
shall, not be
subject
to
the
effluent
standards
for
total
suspended
solids
and
total
iron
of
35
Ill,
Mm.
Code
304.124.
57-149
12
IT
IS SO ORDERED.
Board
Member
B.
Forcade
dissents.
I,
Christan
L.
Moffett,
Clerk
of
the
Illinois
Pollution
Control
Board,
hereby
certify
that
the
above
Opinion
and
Order
was
adopt~
on
the
~
day
of
________—,
1984
by
a
vote
of
~____
.
-~
Christan
L.
Moff~~
Clerk
Illinois
PollutionCoritrol
Board
57-150
