ILLINOIS POLLUTION CONTROL

BOARD

August

9,

1990

IN THE MATTER OF

PETITION OF THE CITY OF

JACKSONVILLE FOR ADJUSTED

STANDARD FROM 35

ILL. ADM

CODE SECTION 306.305(b)

CONCURRING OPINION:

)

)

)

)

AS 90—1

(Adjusted Standard)

There are three concerns with this proceeding.

First,

neither

the IEPA nor Jacksonville discuss possible alternatives

to chlorination such as ozonation or ultra—violet radiation.

These latter processes leave

no chlorine residual, of course.

The December, 1987 report

from the Illinois Department of Energy

and Natural Resources titled “Assessment of Wastewater

Disinfection Technologies and Regulatory Strategies”

is a good

source for information about

these non—chlorine disinfection

alternatives.

Second,

the IEPA Response filed March 13,

1990 agrees with

Jacksonville that chlorination of flows after

the first

flush

“is

a technologically infeasible method to accomplish

disinfection”.

This statement, which

is brief and not referenced

to any special circumstances seems

to also attack the general

rule, namely Section 306.305(d).

Perhaps Jacksonville has some

unusual circumstances that are not mentioned.

But how is one to

square IEPA’s agreement here

to not disinfect with the general

rule absent knowing these special circumstances?

Third,

the IEPA mentions

“substantial primary contact uses

in certain areas on Mauvaise Terre Creek”.

What

if a rainstorm

occurs just upon Jacksonville?

Might not swimming occur

downstream in the Creek

in waters polluted with undisinfected

sewage from the combined sewer overflows?

The point

is that a

waterborne disease hazard exists in the granting of

this adjusted

standard.

For these reasons,

I concur

I,

Dorothy

M.

Gunn,

Cler

Board hereby certify that the

submitted on the

~‘4/T±

the Illinois Pollution Control

ave Concurring Opinion was

day of

_________________

,

1990.

erk

Do

Illir~oisPollution Control

Board

:ot

D.

Dumelle

oard Member

1 I?~-i47