ILLINOIS POLLUTION CONTROL BOARD
July 11, 1985
CITY OF DIXON,
Petitioner,
v.
)
PCB 85—103
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
Respondent.
OPINION AND ORDER OF THE BOARD (by S~.J.Nega):
This provisional variance request comes before the Board
upon
a July ii, 1985 Recommendation of
the
Illinois Environmental
Protection Agency (Agency).
The Agency recommends that a 20—day
provisional variance be granted
to
the City of Dixon
(Dixon)
from
35
Ill. Adm. Code 304.141(a)
to allow necessary repairs and
modifications
to
its wastewater treatment facility’s chlorine
contact tank and chlorination system.
(Rec.
1).
The City of Dixon owns and operates
a wastewater treatment
facility
(WWTP)
which has a design average flow of
3.4 million
gallons per day (MGD)
and consists of raw sewage pumps,
comrninutors, primary sedimentation, aeration tanks, grit removal,
final
sedimentation, disinfection, anaerobic sludge digestion,
sludge storage,
and sludge drying beds.
(Rec.
1).
The
Petitioner’s WWTP discharges
its effluent to the Rock River
pursuant
to its NPDES Permit No.
IL 0026450.
The Petitioner’s NPDES Permit provides’ that the city’s
wastewater treatment
facilities must meet final effluent limits
(or
its main outfall 001 and
is required
to meet effluent limits
of
20 mg/i for biochemical oxygen demand
(BOD);
25 mg/l for
total
suspended solids
(TSS),
and a fecal coliform standard
of 400/100
ml.
(Rec.
1).
During
the past year, the Petitioner’s discharge monitoring
reports
to the Agency pertaining
to fecal coliform and chlorine
residual
in its effluent have indicated the following
concentrations:
Month
Flow (Ms))
Chlorine Residual
(rio/i)
Feca.
Coliform (#100 ml)
May, 1985
3.101
0.35
14
april, 1985
3.197
0.25
278
March, 1985
4.373
0.20
3,000
February, 1985
3.156
0.30
142
65-79
—2—
Month
Flow (MQ))
Chlorine Residual (mg/i)
Fecal Coliform (#100 ml)
January, 1985
4.046
——
——
December, 1984
3.255
0.40
223
November, 1984
3.114
0.40
313
October, 1984
3.124
0.30
166
September,
1984
2.588
August, 1984
2.727
July,
1984
2.918
June, 1984
3.164
0.40
7
Average
3.230
0.33
138*
*G~metrjcMean
(Rec.
2)
Although the petitioner added chlorination facilities to its
WWTP in
1967,
no major
repair
work was done
to these chlorination
facilities since
their installation.
However,
the Petitioner has
indicated that,
as an
interim measure, some repairs were
undertaken
in 1984 when they became necessary.
(Rec.
2).
The
City of Dixon
intends to discharge effluent from the final
sedimentation tanks to the Rock River via its old outfall while
its chlorination facilities are out of service.
The outfall
in
question
is
a 20
to
30 foot long open channel which runs
from the
final
sedimentation tanks
to the Rock River.
(Rec.
2).
Because
there
is no feasible way that chlorine can be added
to
the point where the Petitioner’s effluent leaves
the
final
sedimentation tanks and since
the open channel which will be
utilized
“does not allow for sufficient contact time before
the
effluent reaches the river”,
there appears
to be no practical
alternative
to discontinuing disinfection while the Petitioner’s
chlorination facilities are out of service.
(Rec.
2—3).
However,
the Agency anticipates minimal environmental impact
during
the time period of
the requested provisional variance due
to
the high dilution ratio of greater than 200
to
1
of river
water
to effluent.
Additionally, the environmental impact will
be minimized because there are no public bathing beaches
or
potable water supply intakes downstream from Dixon’s discharge
point
to
the Quad Cities.
(Rec.
3).
The Agency has noted that the City of Dixon has applied
for
a standard variance
in PCB 85—47
for relief from the provisions
of 35 Ill. Adm.
Code 304.120
(deoxygenating wastes)
until
it
installs new clarifiers at its WWTP, but emphasizes that the
repair work that will be done on the Petitioner’s chlorination
facilities
is entirely separate and distinct from the repair work
delineated
in Dixon’s regular variance petition
in PCB 85—47.
(Rec.
3).
In reference
to the
instant provisional variance request
in
PCB 85—103, the City of Dixon has indicated that:
(1)
it has the
necessary materials and manpower
to expeditiously repair
and
restore the chlorination facilities at this time;
(2)
the
chlorination facilities do not presently provide
adequate contact
65-80
—3—
time;
(3)
the condition of
its chlorination facilities
is
becoming worse;
and
(4)
if
the requisite repair work
is not
promptly completed,
the chlorination facilities may fail
completely at a time when weather conditions might be unfavorable
or
when the appropriate manpower
is unavailable, thereby
resulting
in the chlorination facilities being out of service for
a longer period of
time.
(Rec.
3).
Accordingly,
the Agency has concluded
that compliance on
a
short—term basis with the requisite NPDES Permit standards would
impose an arbitrary or unreasonable hardship upon the City of
Dixon.
Therefore,
the Agency recommends that the Board grant
the
Petitioner
a provisional variance until July 31,
1985,
or
until
the chlorination facilities are returned
to service, whichever
occurs
first.
Although the Agency was informed
in
a telephone
conversation that the Petitioner began repair work on the
chlorination facilities on July 1,
1985,
the Agency has
recommended that the provisional variance shall commence
as of
the date of the Board’s Order
in the present case.
Pursuant to Section 35(b)
of the Illinois Environmental
Protection Act,
the Board hereby grants
the provisional variance
as recommended.
This Opinion constitutes the Board’s findings of
fact and
conclusions of law in this matter.
ORDER
The City of Dixon
is hereby granted a provisional variance
from 35
Ill. Mm.
Code 304.141(a), subject
to the following
conditions:
1.
This provisional variance shall commence on
July
11, 1985 and shall continue until July 31,
1985,
or until
the Petitioner’s chlorination
facilities
are returned to service, whichever
occurs first.
2.
The Petitioner
shall contact Mr. Gary Reside of
the
Agency’s Compliance Assurance Unit via telephone at
217/782—9720 when
the chlorination facilities are
returned
to service.
This telephone notification
shall
be followed—up within
5 days with
a written
notification sent to Mr. Gary Reside at the
following address:
Illinois Environmental Protection Agency
Division of Water Pollution Control
Compliance Assurance Section
2200 Churchill Road
Springfield, Illinois
62706
Attention:
Mr. Gary Reside
65-81
—4—
3.
Within
10 days of
the date of
the Board’s Order,
the Petitioner shall execute a Certificate of
Acceptance
and Agreement which shall
be sent to Mr.
James
Frost of the Agency at the address specified
in item *2
of this Order.
This certification shall have the following form:
I,
(We)
,
having
read the Order
of the Illinois Pollution Control Board in
PCB 85-103 dated July 11,
1985,
understand and accept said Order,
realizing that such acceptance renders all terms
and conditions
thereto binding and enforceable.
Petitioner
By:
Authorized Agent
i~it1e
Date
IT
IS SO ORDERED.
I, Dorothy
M. Gunn, Clerk of the Illinois Pollution Control
Board,
hereby certijy that the above
pinion and Order was
adopted
on the
J/’~
day of
_______,
1985 by a vote
of
~
,~.
Dorothy M.
unn, Clerk
Illinois Pollution Control Board
65-82