ILLINOIS POLLUTION CONTROL

BOARD

October

:io,

1985

VILLAGE O~’ MORTO1’~,

Petitioner

v.

PCB

85—153

ILLINOIS

ENVIRON~t7NTAL

PROTECTiON

AGENC~

Respond~~

OPINION AND ORDER O~

THE BOARD (by W.

3.

Nega~:

This provisIonal

variance

request comes before

the Board

upon an October

10~

~i985

Recommendation of

the Illinois

Environmental

Protec~tiofl

Rgency

(Agency).

The Agency recommends

that a 45—day provis~ona:i

variance

be

granted to the Village of

Morton (Morton) from 35

III. Adrn.

Code 304.141(a) to allow the

Petitioner to bypass

its sewage

treatment plant (STP) #3 to a

polishing lagoon so

that its STP #3 can he

dewatered and

repaired. (Rec, 1).

The Petitioner owns

and operates STP

#3 which has a design

average flow of 0.5 million

gallons per

day (NGD). ThIs contact

stabilization package

plant has a polishing

lagoon which is about

1.3 acres in size,

Effluent from STP #3 is

discharged to Farm

Creek pursuant

to NPDES Permit #1L0030007.

(Rec. 1).

The Village

of Morton~sNPI)ES Permit

provides that

STP

#3

must meet effluent

limitations of 10

milligrams per liter (mg/i)

for biochemical

oxygen demand (BOD)

and 12 mg/i for total

suspended solids

(TSS)~

(Rec. 1).

During the

past yearF the Petitioner~s

discharge monitoring

reports to the Agency

pertaining to BOD

and

TSS

in

its fiiuent

have indicated

the following concentrations:

BOD (mg/i)

TSS (mg/i)

Month

Flow (MGI)) Influent

Effluent Influent Effluent

July,

1985

0.236

138

11.0

165

8.0

June, 1985

0.235

176

14,9

171

8.5

May, 1985

0.251

176

18.8

205

17.8

April, 1985

0.370

123

15.8

138

10.2

March, 1985

0.4.96

93

10.9

100

6.6

February, 1985

0.410

185

5.5

207

4,5

3anuary,

1985

~331

l9~

8.4

277

8.5

December, 1984

(~37O

l2.~

6.5

117

5.0

November,

1984

369

181

8.0

258

6~7

October,

1984

~385

223

10.6

275

7.0

---

—2-

ROD (mg/i)

TSS (ag/i)

Month

Flow

(MGD)

Infiuent Effluent Influent Effluent

September, 1984 0.204

.

226

20.1

214

12.9

August, 1984

0.226

204

27.4

242

Average

0.315

170.7

13.2

197.4

Rec. 2).

In its letter to the Agency dated October 7, 1985, the

Petitioner indicated that it first discovered on October 4, 1985

that its activated sludge system was draining into its aerobic

digester at STP #3. Because of this problem, when the Petitioner

wastes solids from the activated sludge process to its aerobic

digester, a head builds up which forces the contents of the

aerobic digester to back up into the aeration process.

Accordingly, the net result is equivalent to not wasting sludge

at all

and

is totally counterproductive and inefficient. (Rec.

2). To avoid the back up from occurring, Morton has not wasted

any sludge at its

STP

#3 since it first discovered the problem on

October 4, 1985. The Petitioner estimates that, because of the

solids buildup in the treatment process, the effluent from STP #3

will degrade by October 14, 1985. (Rec. 2). The Agency has

stated that “normally the mixed liquor suspended solids in the

activated sludge process is 2000

—

3000 mg/l, which is

significantly higher than the concentration in the raw sewage”.

(Rec. 2).

The Village of Morton plans to direct the incoming raw

sewage to the polishing lagoon in order to bypass the package

treatment unit. To allow the Petitioner to examine the internal

tank structures, locate the source of the problem, and make the

necessary repairs, the contents of the package treatment unit

will be pumped to two sludge holding lagoons. (Mc. 2).

The Petitioner has identified, considered, and discussed two

possible alternatives to the previously delineated bypassing

procedure. The first alternative is to construct a temporary

treatment facility to use during the time period that repairs on

the existing treatment unit are made. Bowever, the construction

of such a temporary unit would take too long and cost too much

money according to the Petitioner. The second alternative would

be to hire a tank truck

and

driver to haul the raw sewage wasted

to a landfill on a daily basis. Morton contends that “the cost

of renting the truck and the additional cost of landfilling would

soon exceed the entire operation budget for the system” and

concludes that neither of the two alternatives are “very

practical solutions”. (See: page 2 of the letter to the Agency

dated October 7, 1985).

8848

---

..3e

Although

the Petitioner did not request any specific

effluent limitations for the effluent to be discharged from its

STP #3 during the provisional variance period, the Agency

believes that ‘due to the short detention time (6

—

8 days) which

the influent will spend in polishipg lagoon, that the equivalent

of primary treatment (approximately 30 SOD removal and 50 TSS

removal) is the best that can be expected while the package

treatment unit is out of service.’ (Ret. 3). The Agency

recommends that the Board set effluent limitations for Morton’s

STP #3 of 120 mg/l SOD and 100 mg/l TSS as 30 day averages during

the provisional variance period based on the average influent

concentrations for SOD and TSS indicated in the Petitioner’s

discharge monitoring reports to the Agency. (Mc. 3). The Board

agrees with the Agency in this regard and will impose this

condition as item #4 of the Board’s Order.

in reference to the environmental impact of bypassing the

package treatment unit and treating the influent in the polishing

lagoon, the Petitioner has stated that it believes the impact

would be minimal because it is now a cooler period of the year

and the production of odors would be decreased. (Ret. 3). The

Agency also believes that the environmental impact will be

minimal and indicates that:

‘The Agency, although not in total agreement with

petitioner’s reasoning for stating that the

environmental impact will be minimal, has determined

that, in the long run, the environmental impact of

removing the package treatment unit from service and

repairing it now will be minimized. The Agency’s

reasoning is that this will get the problem corrected

and Petitioner’s STP #3 back in operation rather than

allow a chronic problem to develop which will entail

the same solution to solve, i

•

e., bypass and remove the

package treatment unit from service...The Agency bases

this position on the fact that to not resolve and

correct this problem now won’t make it go away, it will

still be there and will have to be faced at some point

in time. Additionally, by doing the work now it is

possible to repair the unit, get it back into

operation, and give it a chance to reach stable

operating conditions prior to the onset of cold

weather. The alternative would be to wait until spring

and have a substandard effluent for 6 months or

longer.’

(Ret. 3—4).

The Agency has therefore concluded that compliance with the

applicable NPDES Permit standards while bypassing the package

treatment unit and treating the influent in the polishing lagoon

would impose an arbitrary or unreasonable hardship upon the

Village of Morton. (Rec. 3). The Agency has recommended that

the Board grant the Petitioner a provisional variance from 35

0847

---

—4—

Ill. Adm. Code 304.141(a), subject, to specified conditions.

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 Village of Morton is hereby granted a provisional

variance from 35 Ill. Mm. Code 304.141(a) to allow bypassing of

its package treatment unit, subject to the following conditions:

1. This provisional variance shall commence upon initiation

of bypassing of the package treatment unit and continue for a

period of 45 days, or, until 2 weeks after the package treatment

unit is returned to service, whichever occurs first.

2. The Petitioner shall notify Mr. Ken Newman of the

Agency’s Peoria Regional Office via telephone at 309/691—2200

when bypassing of the package treatment unit is begun and when it

is returned to service. Written confirmation of each

notification shall be sent within 5 days to:

Illinois Environmental Protection Agency

5415 N. University

Peoria, Illinois 61614

Attn: Mr. Ken Newman

3 The Petitioner shall monitor the effluent from its STP #3

on a daily basis for the parameters listed in NPDE5 Permit

#IL0030007. The results of each sample shall be recorded and

submitted to the Agency with the discharge monitoring report for

the Petitioner’s 5TP #3.

4. During the time period of this provisional variance, the

effluent from the Petitioner’s 5TP #3 shall be limited to 120

mg/l SOD and 100 mg/i T5S as 30 day averages.

5. The contents of the package treatment unit shall be

pumped by the Petitioner to the 2 sludge holding pits or disposed

of in another manner acceptable to the Agency.

6. During the time period of this provisional variance, the

Petitioner shall operate its wastewater treatment facility so as

to produce the best effluent practicable. Additionally, the

Petitioner shall perform the necessary repair work on the package

treatment unit as expeditiously as possible so as to minimize the

period of time that it is out of service.

7. within 10 days of the date of the Board’s Order, the

Petitioner shall execute a Certificate of Acceptance and

8848

---

Agreement which shall be sent to Mr. James Frost of the Agency at

the following address:

Mr. James Frost

Illinois Environmental Protection Agency

Division of Water Pollution Control

Compliance Assurance Section

2200 Churchill Road

Springfield, Illinois 62706

This certification shall have the following form:

I, (We),

___

_______________,

having read

the Order of t~TTinoi~ ollutionCorEE’olBoardin PCB 85-~l53,

dated October 10, 1985, understand and accept the said Order,

realizing that such acceptance renders all terms and conditions

thereto binding and enforceable.

Petitioner

By: Authorized Agent

‘~

Title

Date

IT IS SO ORDERED.

I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control

Board, hereby certify that the above Opinion and Order was

adopted on the ~

day of

~

1985 by vote

of

____________

Dorothy M. Gunn, Clerk

Illinois Pollution Control Board

66~69