ILLINOIS POLLUTION CONTROL BOARD
January 9,
1986
In the Matter
of:
JOINT PETITION OF THE VILLAGE
)
PCB 85—33
OF HARTFORD AND THE ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY
)
FOR EXCEPTION TO THE COMBINED
)
SEWER OVERFLOW REGULATIONS
MR. WILLIAM
M.
COX APPEARED ON BEHALF OF THE VILLAGE OF HARTFORD.
MR~. THOMAS DAVIS 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 March
20, 1985
joint petition filed
on behalf of the Village of Hartford
(Village)
and the Illinois Environmental Protection Agency
(Agency) for
an exception
to
35
Ill.
Adm. Code
306.305(a) and
(b)
of the Board~scombined sewer overflow
(CSO)
regulations
as they
apply
to the proposed Hartford Regional Pump Station.
These
overflows will occur at
the existing point
of discharge
when
the
maximum capacity
of the screw pumps
is exceeded.
Since the
existing overflows are presently allowed pursuant
to
35 Ill.
Adm.
Code 306.306(d),
the requested relief will only become necessary
when the Village
begins pumping
its wastewater
to the Wood River
Regional Treatment Plant.
Sections 306.305(a)
and
(b) provide
as follows:
a)
All dry weather flows,
and
the first flush
of
storm flows
as determined by
the Agency,
shall
meet the applicable effluent standards;
and
b)
Additional flows
i.e.
not dry weather flows
or
first flush storm flows,
as determined by
the Agency but not less than ten times
the
average dry weather flow for
the design year,
shall receive
a minimum of primary treatment
and disinfection with adequate retention time.
The Village
alleges that
its existing CSO discharges have
minimal
impact on the water quality
of the Mississippi River
(the
receiving water),
and
that construction of CSO facilities
at
an
estimated cost of $603,000
is unjustified.
Hearing was held on
May
28, 1985,
at which testimony and exhibits were prese~itedonly
by the parties.
There was no disagreement
as
to the facts.
A
proposed Order and motion
to supplement
the
record were filed
on
June 20,
1985.
That motion
is hereby granted.
The Board entered
67-403
—
an Interim Order
on September
20, 1985,
requesting additional
information
to which the Agency filed
a reply
on November
5,
1985.
The Village
is located
on the east bank
of the Mississippi
River along Illinois Route
3 about
7 miles north of Interstate
270.
It
is served
by 7.2 miles
of combined sewers and
0.7 miles
of sanitary sewers which collect wastes from the Village’s
2,450
people
as well
as run—off from
180 urban acres
(approximately
95
percent of the Village’s
incorporated
area).
The entire
collection system drains through
a single 48—inch
interceptor
which has an estimated maximum capacity
of
46.0 MGD
and drains
through
the Corps
of Engineers—maintained Mississippi River
levee
and stormwater pumping station and,
thereafter,
discharges
into
th~eMississippi River.
No other combined
sewer
overflows exist
within
the Village’s sewer system.
At
the discharge point
the
Mississippi River
is heavily used for barge traffic
and repair
facilities,
including
a petroleum barge mooring
area,
and
a major
barge
and tugboat repair
facility.
A visual inspection
of
the
river bank
in
the area surrounding the discharge point
indicated
that there was no visual effect
of the discharge
on
the river
or
the
river
bank.
As
of March
20,
1985,
the existing sewage
treatment facility was inoperable
and
the combined sewer outfall
was discharging
the entire Hartford flow into the river with
no
visible
effect.
The village’s present wastewater treatment facility
(which
consists
of
a grit chamber,
lift pumps
and Imhotf tank), was
constructed
in 1959
and operated until
the early 1960’s.
At that
time
the
Chain
of Rocks Dam was constructed and
the pool
level
of
the
Mississippi
River
upstream
of
the
dam
was
raised,
resulting
in frequent flooding
of the treatment
facility.
This flooding
has
made
it impractical
to operate
the plant,
and all wastes are
now discharged directly into the Mississippi River without
treatment.
The Village
has
been involved
in
the
Construction
Grants
Program
since
1975,
and
therefore
qualifies
for
the
exemption
from
effluent
limitations
and
CSO
requirements pursuant
to
35
Ill.
Adm.
Code
304.140
and
306.306(d).
In
turn,
the
Village
has
been
able
to
comply
with
the
interim
limits
in
its
NPDES
permit
since
those
limits
“reflect
the
inoperability
of
the
existing
primary
treatment
facility,
thereby
allowing
the
direct
discharge
of
untreated
wastes
through
the
combined
sewer
overflow
pipe.”
(Agency
Reply,
p.
2).
If
the
Village
were
held
to
the
generally
applicable
CSO
standards
it
would
have
to
treat
all
dry
weather
flows
and
the
first
flush
of
storm
flows
so
as
to
meet
applicable
effluent
standards
and
provide
primary
treatment
and
disinfection
for
some
additional
flows.
35
Ill.
Adm.
Code
306.305(A)
and
(b)j.
The
impact
of
the
existing
method
of
operation
on
the
Mississippi
River
was
examined
in
two
reports:
C.S.O.
Study,
Hartford,
Illinois,
May
22,
1961,
and
the
First
Flush
Analysis,
67-404
—3—
Hartford,
illinois,
February 1983.
(Appendices A
and
B
of
the
Petition).
The First Flush Analysis found that
the
first flush
has
a volume
of 675,000 gallons with
a peak flow of 19,200 gpm
(App.
B.
).
Three alternatives
to handle
and treat
this
volume
were considered:
1)
Untreated discharge
to Mississippi River.
2)
Pump flow
to Wood River Treatment Facility.
3)
Construct
holding facilities
to store
the flow,
discharge
to Hartford pumping station for
pumping
to Wood River.
Si~ncethe Agency would
not accept the first alternative
(presumably due
to violation of Board rules),
the
study
considered only the
latter
two alternatives.
In order
to pump
the flow
to Wood River
a 48” diameter
force main would have
to
be
installed and the pump station structure enlarged
to allow
for
two additional pumps.
Capital costs are estimated
at $898,000.
The construction
of holding basins
for later pumping
to Wood
River
at
a
rate which would
allow
the use of presently proposed
pumping and
force main facilities would entail construction
of
a
levee
to avoid
flooding, pumps
to lift the flow
to
the holding
basins,
and the basins themselves.
The cost
is estimated at
$693,000.
The combined sewer
overflow report looks
at alternative
storm treatment facilities
and their effect on
the SOD and SS
discharged
to the river.
Annual
costs were ãetermined
for
storage and later treatment with the Village’s domestic flow,
use
of
a swirl
concentrator prior
to discharge to the Mississippi
River
and primary sedimentation prior
to discharge.
A swirl
concentrator
is
a simple
centrifugal device with
no moving parts
which
removes grit and some organic materials and floatables
prior
to discharge.
The separated material
is stored and
returned
to the domestic flow pumping station once the storm flow
subsides.
Suspended solids can
be
expected
to be reduced 20—50
while 0—25
removal efficiencies are expected
for SOD.
Primary
sedimentation allows
flows less than the design capacity
to pass
through the clarifier where settleable material would
be captured
and later
returned
to the domestic
flow pump station while excess
flows
are chlorinated and discharged.
Suspended solids removal
efficiencies
of 50—65
and BOD removal efficiencies
of 25—40
can
be anticipated.
The report found:
The mean annual discharge
for
52 years
for the
Mississippi River near Hartford
is 98,920 C.F.S.
(1065.5 MGD).
SOD and suspended solids
concentrations for the
river are 4.7
xng/l and
303
mg/l respectively.
Hartford discharges 7,263,438 CF/yr.
of storm flow
into Mississippi River.
This value was derived
67-405
—4—
using
a run—off coefficient
of 0.30 and
an average
annual
rainfall
of 37.22
inches.
From
a graph of
storm volume vs.
loading from the two storms which
where monitored,
the BOD and Suspended Solids
loading was found
to
be 530 lbs.
BOD/event and
2,200
lbs.SS/event.
Assuming
a value
of 118 rainfall events/yr.
discharge loadings are 62,450
lbs. SOD/yr.
and
259,600 lbs.SS/yr.
Using
the total discharge per
year from Hartford,
the concentration
of BOD and
Suspended Solids was found
to
be
138 mg/l and
572
mg/l,
respectively.
Because Hartford contributes such minor flow
to
the
Mississippi River,
the BOD and Suspended Solids
concentrations
in
the
river
would
not
be
appreciably altered
by Hartford’s storm flow
discharge.
The CSC study concludes that discharge without treatment
would not appreciably alter
the Mississippi River’s SOD or TSS
concentration and
that storage and later treatment
is
the only
means
of meeting currently applicable effluent standards
but
is
costly and will not significantly improve water quality.
(App.
B
p.
24).
The study further concludes that
a
swirl concentrator
is
the least
costly,
but also the least effective treatment method,
and that primary sedimentation would
be less effective and more
costly
than
storage
and later
treatment.
(io.).
The cost of storage facilities was investigated
in greater
detail
in Appendix C
of the Petition:
“Combined Sewer Overflow
Cost Effective Analysis,” which looks
at the costs
of
three
potential sites.
That study
finds
that “in order
to construct,
operate, provide equipment replacement. and
to treat
the first
flush
volume,
the cost per
1000 gallons would have
to
be
increased by approximately $0.89
to
a total
of $2.33/lUaU gallons
of average daily flow.”
(App.
C,
p.
22).
The study
further
fin~sthat the “level
of pollutant removals would allow
a 5.34
x
l0~ percent improvement
in the Mississippi Rivers
(sic) BOD
loading and
a 3.43
x
10—6 percent improvement
in
the suspended
solid loading.”
(App.
C,
p.
23).
Therefore,
the
study
recommends
that the Village
be
allowed
to continue
to discharge
without treatment,
based upon its findings that
“a) Hartford’s
untreated combined sewer overflow has
little effect on the
Mississippi River,
b)
the cost
to Hartford
to reduce this
original minimal
effect is prohibitively high.”
(App.
C,
p.
23).
The Village
is
a participant
in the Wood River Regional
Wastewater Treatment Project which
involves the Village
of South
Roxana pumping its sewage
to Hartford and Hartford pumping
its
and South Roxana’s sewage
to
a regional treatment facility
located
in the City of Wood River.
The effluent from the
regional facility will
be discharged to the Mississippi River.
67-406
—5—
The proposed Hartford Regional Pumping Station will consist of
two 24—inch diameter screw pumps,
one aerated grit collector, and
four submersible pumps.
The two screw pumps will transport
Hartford’s sewage flow
to ground level where
it will be combined
with the discharge from South Roxana.
This combined flow will
be
moved through the grit collector and
into the submersible pump
pit
for transportation via the four submersible pumps and force
main
to the Wood River Regional Treatment Facility.
Each
of the
proposed screw pumps
has a rated capacity
of 430 gpm,
and with
both operating 5.38 times
the estimated normal domestic flow from
the Village
of Hartford can
be removed from the
sewer system.
The Wood River Regional Treatment Facility began providing
secondary treatment
on October
8,
1985,
and the Village intends
to solicit
bids for construction of
the Hartford Regional Pump
Station
in late 1985.
(Agency Reply,
p.
1).
Presumably,
therefore,
this has already occurred, though the record does not
establish whether that
in fact has occurred.
Connection
to the
Wood River Regional Treatment Facility should occur within one
year
of the commencement
of construction.
(id.).
Thus,
no
relief
will
be
needed
for
at
least
a
year.
However,
such
relief
is necessary to give assurance to the Village
that its intended
course of action will result
in ultimate compliance.
The Board
is concerned
that the granting of
this CSO
exception will permanently allow
the dumping of untreated sewage
into the Mississippi River.
Unlike some,
the Board does not
ascribe
to the theory that the Mississippi River
is so large that
it can assimilate any pollution discharged into
it.
For
that
reason at the May 28, 1985 public hearing the Board requested the
Agency
to provide data on the dissolved oxygen
(D..O.)
levels
in
the Mississippi River
in the Metropolitan St.
Louis area.
The
Agency did
so
in
a June
20, 1985 response.
An Agency report
“Mississippi River Water Quality
Monitoring” describes
a study conducted
in the Metropolitan St.
Louis area show violations of the D.O.
standard on June 23, 1981,
with some levels below 4.0 mg/i.
Further,
the Water Resource
Data Books
for
these stations from 1978—1983 indicate that
similar violations do
occur at stations far removed from major
sources
of oxygen—demanding pollutants.
Finally,
the “Illinois
Water Quality Report 1982—1983”
indicates
that D.O. violations
in
the South Central section of
the Mississippi River
are comparable
in frequency
to other
large rivers
in the State.
However,
the
Agency also pointed out that loadings of BOD
and SS should
decrease dramatically
in the near future
in the Metropolitan St.
Louis area since both East St. Louis and St.
Louis, which
presently discharge primary treated effluents,
are committed
to
providing secondary treatment.
The Agency then concludes that
it
“can
be concluded with reasonable confidence
is that the Village
of Hartford
is not
a primary factor influencing water quality in
the Mississippi River and that Hartford’s proposed improvements
are consistent with municipal wastewater control strategies being
applied
to other
communities on the Illinois side
of the
Metropolitan area.”
67-407
—6—
Based upon this assurance,
the Board
finds
that the
uncontroverted evidence
in this record
supports the granting
of
an exception to
35
Ill. Adm. Code
306.605(a)
and
(b).
While
92.4
of
the first flush flow will be discharged directly
to the
Mississippi River permanently,
all other
flows will
be captured
and treated.
The economic cost of complete control
is
unreasonable.
Further,
the Board notes that the environmental
impact on Mississippi River quality should
be nearly
insignificant.
The Board presumes that the Village will meet all
of its commitments
to ensure expeditious completion of its
pumping station and will condition the exception upon such
participation and will require the construction, operation and
maintenance of
the proposed Hartford Regional Pumping Station.
Finally,
the Board will require the Village’s sewer system to
be
maintained
in optimal operating condition.
This Opinion constitutes
the Board’s findings of fact and
conclusions
of law
in this matter
ORDER
The Village of Hartford
is hereby granted an exception from
35 Ill. Adm. Code 306.305(a)
and
(b),
for excess flows from the
Hartford Regicnal Pumping Station, with discharge into the
Mississippi River at River Mile 196.8,
subject
to the following
conditions:
1.
The Village shall participate
in the Wood River Regional
Wastewater Treatment Project.
2.
The Village shall
construct, operate and maintain the
proposed Hartford Regional Pumping Station,
consisting of
two 24
inch diameter screw pumps,
one aerated grit
collector,
and four submersible pumps.
3.
The Village shall maintain its Municipal Sewer System in
an optimal operating condition,
ensuring maximum
utilization
of the pumping station and force main prior
to and during any overflow event.
4.
Within forty—five days
of
the date
of this Order,
the
Village shall execute
a Certification of Acceptance
and
Agreement
to
be bound
to all terms and conditions
of this
exception.
Said Certification shall
be submitted to
the
Agency
at 2200 Churchill Road,
Springfield,
Il 62706.
The
forty—five day period shall
be held
in abeyance
during any period
that this matter
is
being appealed.
The form of said Certification shall be
as follows:
67-408
CERTI FlCATION
I,
(WE)
,
hereby accept
and agree
to be bound by all terms and conditions of
the Order
of
the Pollution Control Board
in PCB 85—33,
dated
______________________________________________
Petitioner
Authorized Agent
Title
Date
IT
IS SO ORDERED.
Board Members
B.
Forcade and ~J.Theodore Meyer dissented.
I, Dorothy
M. Gunn,
Clerk of the Illinois Pollution Control
Board, hereby certify that the above Opinion and Order was
adopted
on the
9t~Z
day
of
____________,
1985 by vote
of
_____________.
/~
Dorothy
M. Guf~n,Clerk
Illinois Pollution Control Board
67-409