ILLINJI3 PDLL’JTI3~
C3’~TROL 3D~D
January
8, 1987
CFIT~NUTE ~IR FORCE
BASE,
Petitioner,
V.
)
PCB 86—152
ILLINOIS ENVIRON~4ENT’~LPROTECTION
)
ASE~CY,
Respondent.
OPI~ION ND OSD~ROF TIE BORD
(by
R.
C.
Flemal):
This matter comes before the Board uoon
a petition
and
amend2d
oetition
for
variance files
Se’otember
16 and October
13,
1996,
by
Chanute
Air Force Base
(“Chanute11).
Chanute requests
that
the
Five—Day Biochemical
Oxy;eri Demand (“BOD~”) and
Suspended Solids (“TSS”)
effluent limitations of
35
Ill.
Adm.
Code Section 334.123,
which presently are
13
mg/i and
12 mg/i
as
monthly averages respectively,
be relaxed
to
20 mg/i and
25 mg/i
for the
\~air~
Sewage Treatment Facility
at Chanute
ir Force
Base.
The variance
is requested
for the period until
the new
Rantoul Regional Treatment Plant,
to
which Chanute will
discharge,
is completed.
Completion
is anticipated
in summer
or
early
fall 1937.
On
~‘1ovembe’r
3,
1935,
the Illinois Environmental Protection
gency (“Agency”)
filed
a recommendation (“Agency Rec”)
that the
variance
be granted with conditions.
Petitioner waived hearing
and
no hearing has been held.
BACK~R)U~D
Ch~nute
is
located
in
Champaign
County,
Illinois,
adiacen~.
to and contiguous with
the Village of Rantoul
(“Rantoul”).
Petitioner
owns and presently operates
a s2oarate wastewater
treatment facility located
on its grounds.
This facility has
a
design average flow
of 1.5 mgd and discharges
to
an unnamed
tributary of
the Upper Salt Fork Drainage Ditch,
and thence
to
the Vermilion River.
Influerit
to the Chanute facility
is
virtually all domestic wastewater.
In 1931 Chanute entered
into
a Federal
court consent decree
in which
it
agreed
to participate
in and cooperate
in funding
a
new regional wastewater
treatment facility designed
to
meet
the
wastewater
treatment needs
of both Rantoul and Chanute.
Constructio-i of
the
n~wfacility
i~underway and timely
completion
is anticipated.
Chanute will continue
to operate
its
present
facility
until
the
new
re~ional
facility
is
ooerational.
The relief Petitioner requests
is
for this
interim
o~riod.
74-403
—2—
Petitioner had previously filed
a petition
on February
27,
1934,
reque;ting,
among other matters, variance from t~esame
BOD5 and TSS limitations
at issue
in the current matter.
That
request was denied by the Board because Chanute
at that time
“failed
to provide sufficient information
to allow the Board
to
make an
informe~3decision”
(PC3 84—24,
53 P03
239,
242,
May
29,
1984).
Petitioner acknowledges that its oresent facility
is
incapable o~consistently meeting the 10/12 BOD5 and TSS
limitations
.
Petitioner argues that this occurs
in spite of the
fact that
it has undertaken substantial effort
and expense,
including expenditure
of “over
$2 million”
(Pet.
p.
5)
for
an
activated carbon adsorption system,
in an attempt
to comply with
the 13/12 limitations.
Additional recent efforts to achieve
compliance
have included tightening of training and operational
proce~uresto assure
that the facility
is functioning
optimally,
altering
sludge handling
facilities
and operations,
and reducing
infiltration
arid
inflow
(Pet.
~.
6).
HARDSHIP
~iven the
imminent completion of the new regional facility,
Petitioner
argues that the further expenditures necessary
to
achieve full compliance during
the interim period would impose
a
substantial, arbitrary,
and unreasonable hardshin.
~mong interim
comoliance options which Petitioner has considered
are additions
of polishing lagoons, microscreening,
filtration,
and activated
carbon adsorption.
Polishing lagoons were formerly used, but have been
abandoned as ineffective
(Pet.
p.
5).
Microscreening
and
filtration are alleged
to be costly,
although no figures
for
these options have been specified apart from their
inclusion
in
a
1975 estimated
$3.1
to
3.6 million upgrading program.
Th2
activated carbon adsorption unit
is on site.
However,
it
is not
pres3ntly functional,
and Petitioner estimates
triat r~oair and
parts replacement would cost $120,000.
Neither the Agency nor
Chanute
believes that returning
the activated carbon
adsorption
system
to service would be sufficient by itself
to allow
compliance with the 13/12 limits
(Agency Rec.
o.
5;
Pet.
p.
5).
ENVIRONMENTAL IMPACT
Both Petitioner and the Agency assert that grant
of the
reguested relief woul5
cause little adverse environmental
1
Data orovided
by the
gency (Agency Rec.
p.
3—4)
from
Petitioner’s discharge monitoring reports indicate that during
tha
oeriod Jctober 1985
to
August 1935 3OD~had monthly average
concentrations ranging from 8
to
18 mg/i and TSS had monthly
avera~e
concentrations ranging from
12
to
24
mg/i.
74-404
—3—
imoact.
The Agency cites 1980—86 water quality
sampling data
from various locations around the Ckianute Base,
noting that “no
violations of water quality standards were observed” where the
receiving ditch leaves
the base
(Agency Rec.
~.
4).
CONCLUSION
Based on the record before
it,
the Board finds that
Petitioner
would
suffer arbitrary ot unreasonable hardship
if
denied variance relief,
and that such hardship would not be
justified by the environmental
impact of Petitioner’s
discharge.
Accordingly,
the relief will
be granted with
conditions.
This Opinion constitutes
the Board’s findings of fact and
conclusions
of law
in this matter.
Chanute
Air
Force Base i~hereby granted variance from the
Five—Day Biochemical Oxygen Demand
(“BOD5”)
and Suspended Solids
(“TSS”)
limitations of
35
Iii.
Ad-n.
Code Section 304.123,
subject
to the following conditions:
1.
Variance shall begin
this date
arid shall
exoire
on September
30,
1987,
or upon the Rantoul
ragional STP achieving ooerational
status,
whichever occurs
first;
2.
Petitioner’s effluent shall
be limited
to
23 mg/i
8cm5
as
a monthly average,
and
25 mg/i TSS,
also
as
a monthly average;
3.
Petitioner
shall continue its participation
in
the Rantoul
regional STP and shall
do everything
in
its power
to assure
its completion
in as
timely
a manner
as possible;
4.
Chanute shall
comply with all efforts
to minimize
any adverse environmental effects occasioned
by
this variance,
including items 16(a)
through
15(e)
of the Petition
for Variance
as attached.
5.
Within forty—five days after this date Petitioner
shall execute
and send
to:
Illinois Environmental Protection Agency
Attention:
James Frost
Division of Water Pollution Control
Compliance Assurance Section
2200 Churchill Road
Sortngfield, Illinois
62736
74-405
—4—
a certificate of acceptance of this variance by
which
it agrees
to
be
bound
by
its terms and
conditions.
This forty—five day period shall be
held
in abeyance for any
ocriod during which
this
matter
is apoealed.
The form of the
certification shall be
as follows:
CERTIFICATION
I,
(We),
____________________________,
having
read the
Opinion and Order of the Illinois Pollution Control Board,
in PCB
86—152,
dated January
8,
1937, understand
and accept the said
Opinion and Order,
realizing that such acceptance renders all
terms
arid conditions thereto binding
arid enforceabl~.
Petitioner
By:
Authorized Agent
Title
Date
Board Members Bill Forcade dissented
and John Marlin
concurred.
IT
13
SO ORD3R~D.
I,
Dorothy
‘1.
Gunn,
Clerk
of the Illinois Pollution Control
Board,
hereby ceç~ifythat the ~ove
Opinion and Order was
adooted
on
the
XT~-
day of
~
,
1937,
by
a
vote
of
-.5—-/
.
/
/,
Dorothy M.
unn, Cl~rk
Illinois Pollution Control Board
74-406
8 ~86
STATE
OF
ILLINOIS
)
STATE
OF
ILUNO~S
)
POLLUTION
CONTROL SO~
COUNTY OF
CHAMPAIGN
)
BEFORE
THE
ILLINOIS POLLUTION CONTROL
BOARD
Chanute Air Force Base,
)
)
Petitioner,
)
)
v.
)
PCB-86-
\5
)
ILLINOIS
ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
PETITION FOR
VARIANCE
AND
REQUEST
FOR HEARING
Chanute Air
Force Base hereby petitions
the
Board under 111½ Illinois Revised
Statutes 1035,
et
seq..,
and Part
104
of
the Procedure Rules of
the Pollution
Control Board,
to grant petitioner
a variance for its Main Sewage Treatment
Facility,
from 35
111.
Adm.
Code,
Subtitle
C,
Ch
I,
of the Board’s regulations,
and in support of this petition, states
as fol1ows~
1.
A variance
is sought
from compliance with Section 304.120--Osoxygenating
Wastes:
“No effluent whose dilution ratio
is
less than five to
one
shall exceed
10 mg/i
of BOO5 or 12 mg/i of suspended solids.”
2.
We requested
a modification of the
NPDES
Permit
No. 1L0027073
(Discharge
001), under which the
treatment facility
is operating,
to allow effluent discharge
not
to exceed
20 mg/l of BOO5
or
25 mg/i of suspensed solids,
in accordance
with Section 309.184,
Permit Modification Pursuant to Variance.
The
NPOES
Permit
in issue is Appendix
A.
It became effective
12 October
1983 and expires
1 July
1988.
3.
The
requested relief
is
sought
for
a period to extend until
the
incorporat
of the Chanute Air Force Base wastewater treatment system into the
R.antoui Regiori~
Wastewater Facility.
The completion of
the Regional Treatment Facility and
our hookup
to
it
is anticipated
in
the Fall of
1987.
74.407
4.
Granting of the variance
is consistent with Federal Effluent Guidelines
of
30 mg/i BOO5,
and 30 mg/i suspensed solids.
STATEMENT
OF
PACTS.
5.
Petitioner
owns
and
operates
a
Main
Sewage Treatment Facility at Chanute
Air
Force
Base~
Illinois.
a.
Existthg Facilities
Chanute
Air
Force
Base’s
Main
Sewage Treatment Facility
(MTF)
was
initially
put into service
in 1942.
Appendix B is a
map shoving
the location of the
Treatmen
Facility on
Chanute
Air Force Base and th,
tributary into which it discharges.
Several subsequent modifications
and
expansions have been
made to the
original
MTF.
The various changes to the system are documented
in Appendix C of this
document.
Prior to the
addition
of the tertiary treatment
system (a
carbon
adsorption system)
in 1979,
the MIT consisted of a secondary standard rate tricklis,
filter plant with a design capacity of 1.56 MCD.
Primary treatment was provided
by a co~inutorfollowed by a clarifier and
Imboff
Tank operating in parallel.
Due
to operational problems,
the primary clarifier was removed
f
rots
service
in 1979.
Secondary treatment now consists of the trickling filter followed
by final clarifiers.
Sludge,
since 1985,
is handled with a service contractor
due to
poor performance
by anaerobic digester,
which
had been installed in
1967.
As Appendix B shows,
Chanute
Air Force Base is traversed by the Salt
Fork Creek,
which
enters
in
the
southwest and exits in
the southeast.
It
enters
from and exits to
farm
land.
Appendix
0 shows Chanute Air Force Ease’s proximity to local
cotmuunities..
The base is
in the Village of Rantoul, population roughly
28,000,
in
east central
Illinois,
in
Champaign
County.
It
is about
15 miles
north of Champaign-Urbana.
The base
is abutted on three sides by
farm
land,
with residential and commercial
land on the base’s north boundary.
b.
Activity of Petitioner
Chanute Air Force Base provides independent
military and
technical
training for officers and
airmen
of the
Air
Force, Air Force Reserves, Air Nation~
Guard, Air Force civilian employees *nd other Department of Defense agencies.
As part of this mission, Chanute Air Force Base houses tbousandB of
airmen
in
dormitories and thousands of military dependents
in
military family
housing
located on
Chanute
Air Force Base.
The installation was activated
in 1917 and
presently encompasses an
area
of 2,125 acres.
Staff requirements of the base
involve approximately 3,500
permanently
assigned personnel.
The present student
enrollment on base
is estimated at 4,000 students but has historically ranged
to a level of 7,000 students.
The bulk of the training involves aircraft and
aircraft
support
equipment maintenance training.
2
74-408
Chanute Air Force
Base,
as
mentioned,
is contiguous to
the
Village of
Rantoul.
By contract, we already forward large quantities of wastewater to
R.antoul.
The Village of Rantoul currently has interim standards of 20 mg/i
of BOO5 and 24
mg/I
of suspended solids, compared to our 10/12 standards.
These
interim standards for Rantoul are in effect until Rantoul completes its regional
wastewater treatment
plant,
which
is projected for Fall
1987.
As will be developed below in more detail
the Air Force through Chanute
Air Force Base has joined this regional project and has contributed nearly $11
million
to it.
Chanute will hook up to the regional system when it becomes
operational and anticipates no problems meeting the 10/12 limits then.
6.
Petitioner is presently discharging
under
Permit No.
11.0021073, effective
12 October
1983,, expires
1 July 1988 (See Appendix A).
7.
Petitioner
is presently in compliance
with
all applicable Board regulatioi
except 35 Ill. Adm.
Code,
Subtitle C, Ch
I,. Section 304.120.
8.
Petitioner
is having substantial difficulty
in achieving compliance
with
35
Ill. Mm.
Code,
Subtitle
C,
Ch
I,
Section 306.120, despite its best
efforts
to
comply.
The WV? as described above
is unable to meet
NPDES
permit
effluent limitations
A major
modification to the system co~encedin 1979.
This modification consisted
primarily
of two major changes,
the first
involving the trickling filter.
The
effectiveness of the trickling filter was often reduced due to freezing conditions
during cold weather.
To eliminate this problem, the trickling filter was equippec
with a
metal
cover., Nonetheless, we haven’t achieved compliance.
In addition,
a physio-chemical tertiary treatment system consisting of chemic~
treatment followed by activated carbon adsorption was added to the treatment
scheme.
This did not help achieve compliance either.
Each of these systems will be discussed in more detail below.
Appendix
E shows our BOO5 and suspended solida results.
9.
Quantity and
Type
of Wastewater Influent
Influent flow to the NT?
is
virtually all domestic wastewater.
The
data presented represents average values compiled
from
sampling information
obtained at the NT? from January of 1980 to July of
1986.
Detailed
information
is provided in Appendix B.
This data
comes
from the
period
after
installation
of the carbon adsorption system.
The make-up of the waltewater constituents
and overall quantity has not varied significantly over this
six-year period.
Average values are displayed in Table
1.
3
74-409
TABLE
1
INFLIJENT CEARACTERISTICS
AVERAGE DAILY
FLOW
1.23 MCD
AVERAGE
BOD5 CONCENTRATION
259 mg/i
AVERAGE SUSPENDED
SOLIDS
CONCENTRATION
134 mg/i
The following typical values of effluent constituent concentrations
were compiled from NTF records
for the period from January
1980 to July 1986.
The average effluent flow
is essentially the
same
as the average influent value
from Table
1.
The average effluent concentration values are presented in Table
2.
TABLE 2
EFFLUENT CONCENTRATIONS
AVERAGE
EFFLUENT
BOO5
13 mg/i
AVERAGE EFFLUENT SUSPENDED SOLIDS
10
mg/i
These values represent an average removal efficiency of eighty-five
percent of the BOO5 and eighty-three percent of the suspended
solids.
The MTF
has remained unable
to consistently meet the existing NPDES permit discharge
requirements
of 10 mg/i BOB5 and
12 mg/i suspended solids.
10.
Statement of Reasons,
Purpose,
and Effects.
Petitioner has been activel:
working toward achieving full compliance.
a.
Various methods of compliance have been investigated by Chanute Air
Force Base over a
long period of time.
On the assumption that an increase
in
overall removal efficiency of 10
to 20 percent
is required,
several effluent
polishing processes were deemed worthy to investigate.
These include:
(1)
Polishing lagoons
(2)
Microacreening
(3)
Filtration
(4)
Activated carbon adsorption
4
74-410
(1)
Poiishing lagoons.
Chanute Air Force Base comaissioned Clark,
Deitz
Engineers
to undertake a study of potential sewage treatment facility
modifications
in March
of 1967.
For this study, polishing lagoons were considered
as a method of tertiary treatment.
The
study concluded that the required acreage
was not available
in the immediate vicinity of the existing sewage treatment
plant.
Thus,
pumping facilities would be required
to transport the secondary
effluent to a
remote
site on base.
The NT! is located in close proximity to
the Base Hospital and other habitable buildings leading
to potential odor and
insect nuisance problems.
The polishing lagoons
were
implemented at a
remote
site in 1972; however) three years later due to operational problems,
they were
abandoned as ineffective.
(2)
Nicroscreening
and Filtration.
Options involving screening or
filtration were investigated in a subsequent study by Clark, Diets Engineers
in
Hay
1975.
Filtration was selected over microscreening as the preferred
means
of achieving improved effluent quality.
Various alternatives involving
upgrading
of
the existing plant, construction of a new plant, or construction of a new
plant utilizing
some
existing treatment
units
were evaluated and assigned costs.
Construction cost estimates in 1975
for the various alternatives ranged from
$3.1 to 3.6 million.
The additional cost of operation and maintenance for a
twenty—year operation period raised the estimates from $5.7
to 6.6 million.
We implemented many changes, as
Appendix C
shows.
(3)
Activated carbon adsorption.
The use of a carbon adsorption system
was investigated as a Bhort-tern solution to meet effluent standards in the
interim period prior to the construction of a regionalized sewage treatment
plant.
The regional approach was first being considered in 1979.
A feasibility
study was conducted by the
Calgon
Corporation in 1979.
It concluded that a
combined chemical treatsent/carbon adsorption system for
polishing
sanitary wastews
from
the
existing facility could be constructed on the present site and would
be capable of meeting the effluent limitations of 10 mg/i BOB5 and 12 mg/i euspenc
solids.
In
December
of 1979,
the Air Force entered
into a contract for $1.4
million
for the
design
and construction of modifications to incorporate Calgon’s
proposal.
Calgon
Corporation originally retained ownership of the carbon adsorpt:
system necessitating an additional contract.
The service
fee and maintenance
contract was initially for a three-year period of operation.
Renewal of the
service contract was available in six-month increments for an additional three
years.
The treatment modifications vent into service in
January
of 1980.
Althou
there were some problems confirming that the system obtained the
performance
specification of
10
mg/i
NOD5 and
12
mg/i
suspended solids,
the plant was accepte
in
May
1980.
In
the
spring
of
1985,
Chanuta
Air
Force
Base
purchased the Calgon
lease
for an additional $389,000.
Plant
records
indicate
that
compliance
with
the
current
NPDES
require
baa been achieved less than fifty percent of the
time
since
Calgon
installation.
Reports we’ve
furnished to the Illinois F~nvironmentalProtection Agency show
this.
See also
Appendix
B.
Consequently,
the carbon adsorption system, though
costing us over $2 million,
baa not been an effective
tool
in meeting our NOD5
and suspended solid limits.
Though we can purchase a new carbon filter, install
it
and
make other repairs at the price of $120,000, we sac no potential that
it will help us achieve required limits.
5
74-411
b.
We’ve also tightened our administrative controls.
Since January
l9a6,
we’ve
closely
inspected
and
tightened
our
management
procedures.
Our MTF
Supervisor
re—checked
training
records
and
procedures
to
insure
our
facility
is
being
optimally
run.
lie
reemphasized
the
finer
points
to
stress
optimum
operation.
He
re-checked
all
of
our
procedures
on
stream
sampling
and
testing
to
insure
accurate
test
results.
Appendix
E shows
thie
administrative
tightening
has
had
negligible
effect
on
our
NOD5
and
suspended
solid
levels.
Our
MTP
Supervisor
coordinated
with
water
pollution
specialists
in
the
IEPA,
Champaign
County,
to
insure
he
wasn’t
missing
any
administrative
techniques.
c.
The
handling
of
the
sludge
build-up
in
the
ItT?
was
considered
essential
for
a
proper
operation
of
the
treatment
process.
In
the
pest,
due
to
vet
or
cold
periods
of
weather,
the
available
capacity
in
the
drying
beds
has
been
severely
limited.
In
1981,
a
permit
was
obtained
to
increase
the
volume
of
the
sludge
drying
beds
by
raising
the
wall
heights
approximately
nine
inches.
The
quality
of
the
effluent
was
still
severely
impacted
from
not
maintainin
sufficient
freeboard
below
the
Imlioff
tank
slots.
Recognizing
sludge
handling
was
a
major problem
in
obtaining
good
effluent
quality3
Chanute
started
processing
a
service
contract
for
land
application
of
liquid
sludge
on
farm
land.
By
December
1985,
a
service
contract
with
A.
B.
Soil,
Inc.,
was
initiated
with
all
necessary
IEPA
permits
at
an
estimated
annual
cost
of
$24,000.
This
is
further
evidence
of
our
attempt
to
comply.
However,
Appendix
E
shows
this
hasn’t
helped
enough.
d.
With
chemical
treatment
through
carbon
and
the
processing
of
the
sludge
disposal
contract,
we
hoped
the
quality
of
the
effluent
would
improve
by
increased
settling
time.
By
the
summer
of
1985,
Chanute
started
action
to
place
on
line
an
additional
secondary
treatment
tank
that
would
allow
an
additional
five
hours
of
settling
time.
This
was
a
primary
clarifier
distributor
system.
Bogged
with
administrative
and
weather
delays,
the
installation
of
the
pump
needed
to
transfer
the
sewage
to
the
secondary
tank
was
not
completed
until
February
1986.
On
the
second
day
of
operation,
the
pivot
drive
assembly
broke
and
the
secondary
treatment
tank
idea
was
abandoned.
The
pivot
drive
will
cost
in
excess
of
$100,000
to
repurchase
and
install.
Even
with
its
installation,
we
cannot
predict
full
compliance.
Nonetheless,
this
is
evidence
of
our
efforts
to
comply.
e.
In
Spring
1985,
Chanute
obtained
CRS
Sirrine,
Inc.,
at
a
cost
of
$180,000
to
prepare
an
Engineering
and
Preventive
Maintenance
Management
Study
for
the
Wastevater
Collection
System.
The
objective
was
to
evaluate
the
maintenance
and
rehabilitation
needs
of
the
system
and
prepare
recommendation
for
required
improvements.
The
recommendations
will
lead
to
the
reduction
of
infiltration
and
inflow
sources.
It
is
anticipated
that
this
viii
reduce
the
wastewater
flow
volume
during
heavy
rainfall
periods.
This
should
help,
but
not
enough
probably.
6
74-412
ii.
Effect of variance on toxics, ammonia level.
Appendix F
is a
summary from
March
1980
-
March
1986 of the effluent from
the sewage treatment plant and other surface water sampling sites both before
and while the Salt Fork Creek
is on base property.
The data relates
to toxics,
ammonia and heavy metals.
Appendix C is
a
map
showing
the
various
sampling
sites in relation to
the treatment
facility.
Site
3
is where the facility diecharge~
In
the majority of cases the ammonia
levels
and
toxic
chemicals
or
heavy
metals
are
below
the
general
use
water
quality
standards
set
forth
in
Title
35, Subtitle
C,
Subpart B,
Section 302.208 of the Illinois Revised Statutes.
Technically, heavy metals,
such as chromium
and
cadmium,
could clog the
trickling filter if discharged
in high concentrations.
But here,
they were
not discharged
in excess of recommended standards.
If the trickling filter
is
clogged,
this of course would cause a rise
in the NOD5
levels.
This, however,
should not be a problem.
We discharge only small amounts
of iron on a regular basis and we do not foresee increasing the discharge of
any toxics or
heavy
metals.
Further,
a review of Appendix E compared
to Appendix
F shows when our NOD5 and suspended solids were above 10/12,
there was little
or no correlation to
increased levels
of toxics or
heavy metals.
Based on this lack of correlation and the fact we will not
increase discharges
of toxics or heavy metals, we
see no reason to believe the variance will negatively
affect
toxic,
anunonia
or heavy metal concentrations
itt
the water.
Also,
ammonia and nitrogen pollutants
can be placed
in the water prior to
the stream’a entry onto the base, as
the map at Appendix B shows.
During
periods
of high rainfall, these can come
from upstream agricultural,
residential and
possibly industrial sources.
The base has
little or no control on the quality
of the incoming waters.
This
is an explanation of why certain materials were
detected
in higher than normal
levels while the creek entered base property.
Also,
the use of fertilizers on Chanute Air Force Base
is minimal.
This diminishes
the possibility of ammonia and nitrogen problems.
12.
Environmental Impact of Variance.
The discharge from the MTF will have minimal impact on the receiving stream
during the requested period of the variance
(approximately one year).
Effluent from the
NTF is discharged
to
a drainage ditch
located on the premises
of the base.
This small ditch originates at the base of
a series of drain
tiles
and has minimal and changing flow rates during
the
sununer months.
Due to this
instability of flow and
the
lack of shade,
it
is unlikely that any type of extensi~
stable aquatic environment exists.
7
74-413
The stream into
which
the ditch empties
is a
tributary to
the Upper Salt
Fork Drainage Ditch.
See Appendices B and
D.
The
seven-day, ten-year low-flow
upstream of the NT! outfall
is 0 c.f..s. with a seven-day,
ten-year
low-flow
for the Upper Salt Fork Drainage Ditch of 4.0 c.f.s.
No unnatural sludge deposits
have been observed along the 22,000 feet of drainage ditch prior to
the confluence
with the
Upper
Salt Fork Drainage Ditch.
The
receiving water has been classified
general use.
By iaaking reference
to Appendix F, operation of the treatment plant from
1980 to 1986 indicates
very
little difference in sampling results regarding
toxica and metal, when the plant was exceeding effluent limitations as appears
in Appendix B.
Discharge of any toxic chemicals or fire retardant chemicals used
in the
fire protection training area is not expected and should not have any impact
on the environment.
We have no evidence from the
times
we exceeded
NOD5
or
suspended solid limits (Appendix B) that we
harmed
the environment,
plant or
animal.
This was
so even when we exceeded limits for several
months in a row.
We therefore believe there will be no environmental harm during the variance
period.
Human
contact along
the receiving water is
limited by the fact that it meanders
through primarily agricultural land.
Only three active residences are in the
general vicinity of the drainage ditch after it
leaves the base grounds, with
none of these in close proximity to the path of the stream.
No known sources
of public water supply use the receiving stream as a source.
In addition, no
threatened
or endangered plant and animal species have been observed along the
stream.
No known environmental factors such as wetlands, flood plains, air quality,
unique plant or animal
communities,
or other important fish and wildlife
habitat8
would be significantly affected.
Also,
there are
no historic,
archaeological
or cultural features
in the immediate area
which
would be affected.
13.
Petitioner estimates achieving full compliance with
35
Ill. Ada.
Code,
Subtitle
~,
Ch
I~, following implementation of Regional
connection with the Village
of
R.antoul
and Chanute Air Force Base.
This regional connection and
new Rantoul
Treatment
Facility
is
planned to
be completed by
Fall of 1987.
To alleviate the wastewater management problems identified above and to
meet the wastewater management objectives,
we had to reconsider our approach
to basic
methods
of vastewater treatment, especially after realizing theniethods
mentioned above were not wholly satisfactory.
We considered:
(1) non-regionalizal
consisting of upgrading the existing
plant, or (2)
complete regionaiization
involving the transport of all sewage to the Village of Rantoul facility for
treatment and discharge.
Having
evaluated
the economic
and environmental impacts
of the
two alternatives,
Chanute APB
pursued regionalisation with
the Village
of R.antoul
for
full treatment and discharge at a cost of $10.6 million
to
the
Air Force.
8
74-414
Appendix H is a consent decree entered
into by the Air
Force and the Illinois
Environmental Protection Agency in 1981 from Federal court
in which we agreed
to regionalize and to cooperate in funding..
We’ve
met
all of our fund and
engineering responsibilities to regionalice as spelled out
in the consent decree.
We’re right
on schedule
in
building our pumping station on Chanute’s premises
to tie us into the regional system.
We’ve paid all of our funding request to Rantoul promptly.
We’ve
not
attached
bills and vouchers
because
of their cumberso~vo1ume
We can produce them,
if required.
Appendix
I
show, the proposed
and actual schedules for completion
of the
regionalization.
None
of the delays
is attributable
to the
Air
Force.
Any
delays resulted from the Village of Rantoul, the State of Illinois, or from
design problems and contract bid protest beyond our control.
Note
also
that USEPA inspectors visited
the regional facility construction
Bite and
our pumping station construction site since February 1986, and were
absolutely pleased
or.
the facilities and progress.
14.
This variance can be ~&rancedby the
Board
consistent with all federal
effluent guidelines of
30
mg/I
for B0~ and 30 m~/1for
suspended solids.
15.
t~ediatecompliance
with
35
lii. Ada.
Code,
Subtitle
C,
Oh
I,
Section
304.120,
on the other hand, would impose
a substantial, arbitrary, and unreaaonabl
hardship
on petitioner for the following reasonst
Chanute Air
Force
Base has expended over $2.9 million on a carbon adsorption
system
in
an attempt
to comply with present effluent
limitations.
It has been
documented that
this expenditure has not
allowed
the wascevater final effluent
to
meet discharge limitations on any
type of continuous basis.
In fact, many
times
the reduction in pollutant
load
over
the secondary effluent
is insignificant
See Appendix E.
Without the granting of a variance, Chanute
is
faced with one of
two
options
to consider while we wait to regionalize.
The first
is
to purchase a carbon
changer and repair existing equipment of the carbon adsorption system at an
estimated cost of $120,000, requiring six months.
The second choice is to make
major repair to the primary clarifier distributer equipment (pivot
drive)
at
an estimated cost of $100,000, requiring six to nine months
until fully operationa
We cannot justify either of these
expenses
for a system that
has
proven
not to
meet with present NPDES
permit
effluent standards or
is of dubious value
and
which provides minimal long-term environmental benefits to the receiving
water.
Considering this, along with major
funding reduction from the
Gra~n-Rudman
Act, the expenditure of such sums of money and
the additional time and cost
of
maintenance
associated
with
continued
operation
of
either
choice
constitutes
an
uztreasou.able hardship.
9
74-415
With the regionalization scheduled in approximately
one year at a cost
to us of
$10.6 million, any major design
and construction modifications to the
treatment system to meet current NPDES effluent standards would
be
economically
unsound and again create an unrea8onable hardship.
Most importantly,
they would
not help meet the effluent
standards,
as history has shown.
Requiring us
to comply with 10/12
is also arbitrary.
The Village
of
Rantoul
has interim standards of 20/24 pending completion of the regional facility.
Admittedly we do not have nor can we now apply for interim standards, but requiring
a tougher standard on Chanute Air Force Base
than on our contiguous neighbor
is arbitrary.
This is especially so in light of the fact that the only reason
the
regional
facility
is
not
done
is
not
because
of
any
Air
Force
delay.
The hardship of compliance
is no doubt substantial
when
you consider we’ve
done
all
we
can
from
a
technical
and
management
viewpoint
and
committed
$10.6
million to the regional facility.
We would have to spend
nearly
one-quarter
million dollars
to fix or update systems which can’t do the job individually.
The whole reason for regionalizing was to deal with wastewater management
comprehensively and finally.
It
would
have
cost
us
less
to
deal
with
the
problem
piece-meal,
in all likelihood, but
the solution would not have been optimum.
We
chose the better solution.
To require
us
to now spend nearly one-quarter
million dollars while we’re waiting
to regiorialize
is unreasonable and arbitrary,
especially since Rantoul can operate on 20/24 until regionalization.
Our
bottom line,
regardless of Rantoul’s
limits,
it’s unreasonable and
arbitrary to impose 10/12 on
us
pending regionalization.
We should also note
that the current NPDES
permit with the 10/12 standard came after our consent
agreement to regionalize.
16.
It
is the intent of Chanute Air Force Base
to obtain a variance of
the present
NPDES discharge
standards until the on-line operations of the new
Rantoul Regional Treatment Facility are
in effect
and
to minimize any adverse
environmental
effectB.
In order to minimize
the impact of
the
reduced effluent
standards during
the period of variance, the following measures will be maintained or begun:
a.
Chemical
treatment will continue with strict monitoring
to assure
NPDES standards are met or that levels will be as
low as possible..
b.
Maximum allowable effluent will be diverted
to the Village of Rantou:
c.
The new Treatment Plant Manager (assigned February 1986) will contin
with
close attention to management and administration.
He will review on-the-j
training
with all
plant operators including
initial
lab training briefings,
and will continue these on a regular
basis.
d.
The
sludge service contract will continue at
an annual estimated
cost of $24,000.
e.
We will implement
the recommended Engineering and Preventive
Mainten
Management
Study (mentioned above)
for reducing infiltration
arid inflow
sources
into wastewater.
10
74~4j6
It
is expected that for the interim period,
the treatment plant can achieve
the discharge limits
of
20 vigIl for B0D5
and
25 mg/i for total suspended solids.
Of course,
we will strive
for lower results.
Although this would be exceptional
performance for this type of plant,
where
a removal efficient of approximately eight-five percent might
be expected,
under good operating conditions,
a relatively high quality effluent can be expectec
For the entire year of 1985,
the secondary effluent averaged
13
vig/l BOD5 and
10 mg/i
suspended
solids
in the discharge.
We want to keep our averages down
like this until regional hookup.
We’ve
taken further actions to minimize adverse impact.
In some instances,
during periods of excessive rainfall,
the increased hydraulic loading on the
plant caused operation
difficulties.
Presently, excessive flow
is stored
in
the collection system,
to
the extent possible,
reducing shock loadings.
17.
Request
for Relief.
Wherefore, petitioner requests that the Board grant
it
a variance from
35
Ill.
Advi.
Code,
Subtitle
C,
Ch
I, Section 304.120 until on-line operations
of
the new
Rantoul Regional Treatment Facility (Fail, 1987), subject
to the
proposed plan,
allowing 20
vig/l of BOD5 and
25 mg/i of suspended solids.
We request
a hearing in
the event the Agency recommends against
this petitior
FOR CHANUTE AIR FORCE BASE
At~orneJAdvisor
ChaiilI?e Technical Training Center/JA
Chanute AFB, Illinois 61868-5000
Telephone:
217 495-2015
74-417
STATE
0?
ILLIN~YIS
)
)
(X)UNTY OF CHAMPAIGN
)
AFFIDAVIT
I, Rènald I.
Cowger,
Base Co~nderat
Chaxmte
Air Force Base, Ilflnais, having
been duly sworn, desposes
and
says
that:
I have received the attached do~msnts req*~atinga variance
fec’ Chanute
Air
Force
Base
and all
the
information
contained therein
is
true
to
the
beet
of
my
knowledge.
/‘)
7
2~L~
~
RONALD I.
COWOER,
Colonel,
Base Co~ander
Subscribed and sworn to before me this 12th
day
of September 1986.
My
commission expires
11
ifl
1969.
74-418
