ILLINOIS POLLUTION CONTROL BOARD
September 17, 1987
IN THE MATTER OF:
THE JOINT PETITION OF THE
)
PCB 86—6
CITY OF WOOD RIVER AND
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THE ILLINOIS ENVIRONMENTAL
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PROTECTION AGENCY FOR EXCEPTION
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TO THE COMBINED SEWER OVERFLOW
REGULATIONS
MR, LON SMITH APPEARED ON BEHALF OF THE CITY OF WOOD RIVER;
MR. RICHARD WARRINGTON, JR~ APPEARED ON BEHALF OF THE ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY~
OPINION AND ORDER OF THE BOARD (by J~D~Dumelle):
This matter comes before the Board upon a January 6, 1986,
joint petition of the City of Wood River (Wood River) and the
Illinois Environmental Protection Agency (Agency) for an
exception to 35 IlL Adm.~ Code 3O6~3O5(a) and (b) of the Board’s
combined sewer overflow (CSO) regulations based on minimal
discharge impacts Hearing was held on June 12, 1986, at which
exhibits and testimony were presented~ The Hearing Officer
issued Orders on February 6 and July 16, 1987, requesting
additional information to which Wood River and the Agency
responded on April 9, and August 17, l987~
Wood River contends that the existing overflows from its
combined storm and sanitary sewer system have minimal impact on
the water quality of the Mississippi River (the receiving stream)
and do not restrict stream use, and that construction of CSO
treatment facilities at an estimated cost of $6~Omillion would
produce little benefits For the reasons described below, the
Board finds that Petitioners have made the showing requisite for
granting a temporary exceptions Relief will accordingly be
granted, subject to conditions as stipulated to by Petitioners
and time limitations deemed necessary by the BoarcL
BACKGROUND
Wood River, population 12,446 is located on the Mississippi
River about seven miles north of Interstate 270, Wood River is
served by 36.5 miles of combined storm and sanitary sewers and
6.5 miles of separate sanitary sewers. The combined sewer
collection system outlets to the Mississippi River through a
single 84—inch outfall sewer which has an estimated capacity of
168.5 million gallons per day (MGD). Upstream of the outfall
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point, the outfall sewer is routed by gravity through a pumping
station operated by the Wood River Drainage and Levee District.
At high river stages, the gravity outlet is blocked by sluice
gates, located in the pumping station, and the flow is pumped to
the pumping station “head box” and then out through the
pressurized 84—inch sewer into the river. The dry weather flow
is treated by a primary plant constructed in 1962 with a design
capacity of L73 MGD. The combined sewer overflow (CSO) is being
discharged into the Mississippi River directly without treatment..
A 72—inch diameter sewer belonging to the major local
industry, Amoco Oil Company (Amoco) provides for the collection
of industrial wastes, storm water, and combined sewer overflows
originating within the Amoco property, The 72—inch sewer acts as
a supply sewer to the pumping station which pumps the normal flow
to the soon to be completed Wood River Regional Treatment
Facility (discussed below) and also as an outlet sewer to direct
storm water flows into large storage lagoons owned by Amoco. The
lagoons have a storage capacity of 150 million gallons. The
storm water is then drawn back through the 72—inch sewer and
treated at the Regional facility. The joint petitioners contend
that these lagoons are used also as a storage area for untreated
dry weather flows from Amoco and partially treated flows from the
other Regional plant users during plant shutdown or malfunction.
In 1976, a State Step I grant was offered to Wood River to
carry out a regional facilities plan study for the four
communities of Wood River, Hartford, Roxana, and South Roxana.
Wood River was designated the lead agency. As part of this
study, an infiltration/inflow (I/I) analysis was conducted for
Wood River’s combined sewer system. It found that there were no
significant I/I problems, and the I/I report had been completed
and approved by the Agency. It was concluded that the most cost
effective water pollution control strategy for Wood River would
be to adopt a regional waste disposal plan which would include
the upgrading of the existing primary treatment system to a 2,46
MGD secondary activated sludge plant. The new plant will provide
treatment of the dry weather flows collected from Wood River,
Hartford and South Roxana, and will consist of a 5.1 MGD design
average flow second treatment plant with a peak flow of 9.8
MGD. The new regional facility will not be large enough to treat
all of the combined sewer overflow from Wood River, but will have
facilities for the interception of up to 4.8 MGD, The Agency, as
a condition of the joint petition, has required that Wood River
(a) intercept and provide full treatment for this 4.8 MGD of
combined sewer overflow and (b) provide for screening of
overflows in the 84—inch sewer prior to discharge. The Agency
notes that Wood River has met condition (a) above by constructing
intercepting and treatment facilities at a cost of $390,000, 75
of which was funded through an Agency grant. The Agency further
notes that Wood River has proposed to meet condition (b) above by
constructing a bar screen facility at the Wood River Drainage and
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Levee District pumping station at a cost of approximately
$85,000.
The primary use of the Mississippi River in the vicinity of
the 84—inch CSO discharge point is barge transportation.
Immediately upstream and downstream of the discharge point are
barge loading, unloading, and repair facilities. The general
area is alleged to be a general mooring area, These docking
facilities and the movement of tows generally preclude other uses
of the River within the discharge area. Further downstream
numerous communities utilize the River for their potable water
supplies. The first intake of River water for public water
supplies purposes, downstream of Wood River’s CSO discharge, is
the Illinois American Water Company’s intake, approximately seven
miles below Wood River.
ENVIRONMENTAL IMPACT
The impact of the overflows on the Mississippi River prior
to completion of the new treatment facilities was analyzed in the
“Combined Sewer Overflow Study for Wood River, Illinois, October,
1981.” The study indicated that the Wood River CSO has a
negligible effect on the water quality in the Mississippi River,
both on a worst condition basis and on an average annual basis,
due primarily to the diluting effect of the river on the
pollutants discharged from the CSO. During the worst conditions
event, consisting of a 1—year frequency storm water overflow
coincident with a 7 day 10 year low flow in the river, the effect
on the Mississippi River is an increase of 0.21 in water volume,
an increase of 0.9 in total suspended solids, and an increase of
3.5 in BOD. Using the average annual combined sewer overflow
and the lowest recorded average annual river flow, (30,540 MGD in
1940) the effect on the river over an entire year is a negligible
increase in water volume, an increase of 0.007 in total
suspended solids, and an increase of 0.026 in BOD. The first
flush analysis indicates a first flush volume of 2.2 MG. For
comparative purposes the entire first flush is only approximately
0.016 of the one-day low flow volume of the river. The joint
petitioners believe that the new treatment facilities will reduce
these figures slightly, and that these effects probably could not
be detected through field testing. The joint petitioners further
assert that a visual inspection of the river bank in the area of
the discharge point indicated that there was no effect on the
river or the river bank. There were no visible signs of sludge
deposits or floating debris, and no sewage related odors in the
vicinity of the overflow.
The combined sewer overflow study analyzed five alternative
methods of interception and treatment of the combined sewer flows
so as to comply with the Board’s CSO regulations. Alternative
No. 1 constitutes the !Ino_actionU alternative. The estimated
amount of BOD in the overflow is 242,100 pounds per year on an
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average annual basis. Alternative No. 2 would, upon completion
of the new regional treatment facility, utilize the entire
capacity of the new interceptor sewer and preliminary treatment
structure rather than limit the flow in the interceptor to the
present intercepting capacity of 2,5 MGD, Also, a manually
cleaned bar screen would be added at the Levee District pumping
station to remove trash and floatable material from the CSO.
Alternative No. 3 would require the construction of facilities to
convey and treat an additional 10 times the design dry weather
flow beyond the 2.5 times dry weather flow being intercepted and
given full treatment at the regional treatment facility,
resulting in the interception and treatment of overflows of up to
24 MGD. The projected cost for this alternative is $2,171,000.
Alternative No, 4 would provide full compliance with Board
regulations by utilizing all the improvements specified in
Alternatives Nos. 2 and 3, but would also intercept, store, and
treat the entire first flush. The projected cost for this
alternative is $4,768,000, Lastly, Alternative No, 5 considered
the total separation of Wood River’s sewer system to eliminate
combined sewer overflows. It was determined that the $23,000,000
project would be prohibitive from a cost standpoint. Apparently,
the joint petitioners have opted to employ alternative No.. 2, as
the Agency has required interception and treatment of the full
4,8 MGD capacity for the combined sewer overflow and the
installation of the bar screen. The total projected cost (in
1981 dollars) for this alternative was $443,400. The $390,000
already spent on the regional facility and the proposed $85,000
for the bar screen result in a total expenditure of $475,000,
Based on the 1981 CSO study, the Board concludes that the
impact from the Wood River CSO is minimal. While the study
indicated that there was a coloration difference at the outfall
point, this difference can be attributed to the clearer color of
the effluent from the treatment plant in relation to the much
browner color of the silt carried by the Mississippi. The Board
notes, however, that none of the alternatives considered the
utilization of the Amoco 150 MG treatment lagoons. These large
lagoons offer space in which to store first flush and an
additional 10 times dry weather flow for future treatment.
On July 16, 1987, the Board requested more information as to
the ownership and usage of these large lagoons. The joint
petitioners responded on August 17, 1987, with a copy of the 1982
Operating Agreement, by and between Wood River and Amoco, which
determines the rights and responsibilities of Wood River as to
the storage lagoons and with estimated costs for the construction
of attendant facilities. The joint petitioners reiterated that
the lagoons function as a storage area for the 72—inch combined
sewer, which is the outlet for surface drainage for the majority
of the Amoco Refinery complex, and for untreated dry weather
flows from Amoco and partially treated flows from other Regional
plant users, In support of this position, the joint petitioners
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pointed to paragraph 8 on pages 17, 18 and 19 of the Operating
Agreement, which specifically addresses the storage lagoons.
The Board recognizes that Wood River is presently precluded
from employing the treatment lagoons in its CSO operations under
the terms of the Operating Agreement. However, the Board is not
inclined to assume that this Operating Agreement cannot be
changed. Perhaps with further negotiation, Wood River may
acquire access to the lagoons for CSO storage and treatment.
The Board also recognizes that the cost of facilities to
employ the lagoons, estimated by the joint petitioners to be
$2,830,000 may be high. The Board notes that the joint
petitioner’s August 17, 1987, response provides the only
indication of what facilities would be required to implement the
lagoons and at what cost. The Board does not understand why all
of the facilities listed in the joint petitioner’s response are
deemed necessary when it appears that some of the facilities are
already in place, Because the joint petitioners have preferred
to not consider this as an alternative, the record is
insufficient for the Board to determine that the Amoco lagoons
cannot be used to alleviate Wood River’s combined sewer overflow
problems. Nor can the Board determine that the costs would be
unreasonable. Thus, the Board is not persuaded to grant a
permanent exception, resulting in the permanent discharge to
untreated sewage into the Mississippi River, at this time.
However, the Board will grant Wood River a temporary exception
for five years, in which time Wood River is to seriously consider
using the lagoons as an alternative and to devise a cost—
effective method of implementation. If on September 30, 1991, it
wishes to pursue the matter, Wood River may submit an amended
petition for exception which details: (1) Wood River’s attempts
to acquire usage of the lagoons; (2) if the lagoons cannot be
employed, the specific reason(s) those attempts were
unsuccessful; (3) if the lagoons can be employed, a plan for the
implementation of the lagoons into the sewer system, with
supporting economical and technical data; and (4) continued
justification for the granting of exception (the Board notes that
the record in this proceeding may be incorporated by reference
into that docket).
In examining the alternatives considered by the joint
petitioners, the Board concludes that alternative Nos. 4—5 are
not justified economically. While these alternatives may result
in discharge that complies with applicable effluent standards, it
would be unreasonable to impose the burden of the costs (No. 4
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$4,768,000, and No. 5
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$23,000,000) on a city the size of Wood
River (pop. 12,446) in relation to the benefit realized in the
receiving stream, The joint petitioners allege that Alternative
No. 3 ($2,171,000) is also not justified economically.. The Board
reserves judgment on the reasonableness of this amount until Wood
River submits the amended petition described above. At that
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time, the Board will know whether the lagoons can be used as an
alternative and will know actual statistics with respect to the
new regional facility’s operations (i.e., actual interception of
Wood River’s combined sewer overflow rather than predicted
amounts). The Board can make a more reasoned determination once
it possesses such information, Alternative No~ 1, the “no—
action” alternative is not justified in light of the Agency’s
recommendation (Alternative No. 2), which the Agency believes
will solve Wood River’s CSO problem at a savings of several
million dollars, The Board concurs. Interception and treatment
of up to 4.8 MGD of flow, in addition to screening of the
overflows prior to discharge, will significantly reduce the
impact on the Mississippi River, Further, the cost is
reasonable.
In conclusion, the Board finds that the evidence in the
record supports granting Wood River a temporary exception to 35
Ill. Adm. Code 306,305(a) and (b), subject to conditions. The
Board notes that the impact of Wood River’s CSO discharge on the
water quality of the Mississippi River will be minimal, In
addition, the Board notes that the cost of alternative controls,
such as they have been considered, are high.
ORDER
The City of Wood River is hereby granted a temporary
exception from 35 Ill, Adm, Code 306.305(a) as such provision
relates to first flush of storm flows and 306.305(b) for its
combined sewer overflows into the Mississippi River, subject to
the following conditions:
1. This grant of temporary exception shall terminate on
September 30, 1992.
2. During this temporary exception period, Wood River
shall, as a minimum:
a) Intercept and provide full treatment for up to 4.8
MGD flow in the 84—inch combined sewer;
b) Provide for screening of the overflows in the 84—
inch sewer prior to discharge;
c) Demonstrate a good faith attempt to acquire the
usage of the Amoco Lagoon for storage and
treatment of excess flows and report on an annual
basis such demonstrations to the Board and the
Agency;
d) Submit the reports described in Subsection (c) not
later than 30 days after the end of a calendar
year.
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3. This grant of exception does not preclude the Agency
from exercising its authority to require as a permit
condition a) a CSO monitoring program sufficient to
assess compliance with this exception and any other
Board regulations, including Section 306.305(c); and b)
other controls if needed for compliance, including
compliance with water quality standards.
4. This grant of exception is not to be construed as
affecting the enforceability of any provisions of this
exception, other Board regulations or the Act.
IT IS SO ORDERED.
I, Dorothy M. Gunn, Clerk of the IJ4inois Pollution Control
Board, hereby certify
that
the above Opuini9j~andOrder was
adopted on the
_____________
day ~
1987 by a vote
of
____________.
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Dorothy M. G44~in, Clerk
Illinois Pollution Control Board
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