ILLINOIS POLLUTION CONTROL BOARD
August
18,
1988
IN THE MATTER OF:
)
AMENDMENT TO 35
ILL. ADM.
CODE
)
R88-22
SECTION 304.301, EXCEPTION FOR
)
AMMONIA NITROGEN WATER QUALITY
)
STANDARDS
)
PROPOSED RULE.
FIRST NOTICE.
ORDER OF THE BOARD
(by R.
C. Flemal):
On July
11,
1988 the Illinois Environmental Protection
Agency (“Agency”)
filed
a public comment
in
a separate
proceeding,
R88—1.
Therein
the Agency proposed that 35
Ill.
Adm.
Code Section
304.301(d)
be amended
to extend the exemption
termination date from July
1,
1988 to July
1,
1991.
In the
belief that the subject matter
of the Agency’s proposal
is more
properly considered
in a dedicated docket,
the Board today
dockets
the Agency’s proposal~within the instant proceeding and
sends the proposal
to first notice.
In so doing,
the Board notes
that
it takes
no position on the substantive merits of the
Agency’s proposal.
BASIS FOR PROPOSED AMENDMENT
The Agency provides the following argument for adoption of
the proposed amendment:
Paragraph
(b) provides an exemption
for winter
(November thru March) water quality violations.
In
adopting this rule in PCB R77—6,
the Board noted that
“biologic treatment of domestic wastewater
is virtually
universally practiced...”
(Final Order dated June 22,
1978, page 9).
The Board continued as follows
(page
10):
“The process
of
riitrification, however,
is
temperature dependent;
the rate of
nitrification decreases as the temperature
decreases.
It
is not cost—effective
to design
biological processes capable of
removing
ammonia nitrogen to 1.5 mg/i from very cold
1 The document wherein
the Agency’s proposal
is presented,
Public
Comment #3 of Board Docket R88—i,
is hereby incorporated into the
instant docket
as the Agency’s Proposal.
91—433
—2—
domestic wastewater.
In Illinois,
facilities
treating domestic wastewater utilizing the
types
of biologic processes which yield
effluent concentrations of 1.5 mg/l during
the
warm
months
are
usually
incapable
of
consistently
reducing
ammonia
nitrogen
concentrations below 4.0 mg/i during cold
weather.”
Since adoption,
it has been evident that these same
technological limitations remain relevant.
Biological
processes are still the only cost—effective and
environmentally acceptable means of ammonia nitrogen
reduction; and the efficiency of these processes
is
s~iilgreat1~affected by cold temperatures.
Attachment
A
provides an analysis
of the performance
of
74
municipal wastewater
treatment facilities designed for
nitrification
in Illinois.
Each facility represents
“state—of—the art” nitrification and has
a record
of
good operation.
The overall performance of these
facilities falls within the expected range.
It
is clear
that application of the most stringent effluent
standard,
1.5 mg/i,
during the winter months would
result
in unacceptably high violation rates on
a monthly
basis
for these facilities.
Water quality based permit
limits, however,
are established as daily maxima,
rather
than monthly averages.
The violation rate for
the
facilities
in Attachment
A would be significantly higher
if calculated on a daily maximum basis.
In addition,
nearly 300 other municipal sources are regulated for
ammonia discharges.
Many of these sources perform
significantly worse with regard to ammonia removal.
Typically this is due
to organic or hydraulic
overloading or operational problems.
As indicated in
Attachment B, many of
those 300 facilities are currently
designing or constructing nitrification equipment.
Each
of these facilities
is designed in accordance with the
same stringent design standards as the facilities
in
Attachment A.
The Agency believes that the prudent
course
of action would be
to extend the exception for
winter months
(Paragraph
b)
an additional
3 years.
This
will allow time for completion and performance
2 Board note: Attachments
A and B,
as referenced in this quote,
refer
to attachments
to the Agency’s Proposal
in the instant
docket
(see footnote
1).
Attachment A consists of
a two—page
tabulation
of ammonia effluent concentrations for
various sewage
treatment plants
in Illinois.
Attachment B consists of
a one—
page list
of sewage treatment facilities
in Illinois which are
currently proposing nitrification of effluents.
91—434
—3—
evaluation of most of these facilities.
At that time,
the Agency will be
in a better position
to assess the
need for
a permanent rule change.
ORDER
The Board hereby proposes the following amendment
for
First
Notice:
SUBPART C:
TEMPORARY EFFLUENT STANDARDS
Section 304.301
Exception for Ammonia Nitrogen Water Quality
Violations
a)
Section 304.105 shall not
apply to 6ee~en 35
Ill. Adm.
Code 302.212
for any effluent from
a source in existence
on April
1, 1977, having an untreated ammonia influent
loading not exceeding
60 pounds per day and not otherwise
needing upgrading to meet the requirements
of this
chapter.
b)
Section 304.105 shall not apply to Bee~±ei~
35
Ill.
Adm.
Code 302.212 for any source during the months of November
through March;
except that during
the months of November
through March no source not exempt under
~
subsection
(a)
shall discharge an effluent containing a
concentration of
ammonia nitrogen greater than 4.0 mg/i
if the discharge,
alone or
in combination with other
discharges,
causes or contributes
to
a violation of that
portion of See~4ert35
Ill. Adm. Code 302.212.
c)
Compliance with the provisions
of
pai&agt~pl’~
subsection
(b)
shall be achieved by March 31,
1979,
or
such other
date as required by NPDES permit, or
as ordered by the
Board under Title VIII or Title IX
of the Environmental
Protection Act.
d)
After July
1, ‘~988l991, the exemption provided
in this
9Section shall terminate.
IT IS SO ORDERED.
I, Dorothy M.
Gunn, Clerk
of the Illinois Pollution Control
Board, hereby certify that the above Order was adopted on
the
/,
day
of
,4?ç~p-
,
1988, by a vote
of
~
.
d
~
J~14.
Doif’ôthy
M.
G~n,
Clerk
Illinois
Pol’lution
Control
Board
9 1—435