ILLINOIS POLLUTION CONTROL BOARD
March 22, 1985
BLOOMINGTON-NORMAL SANITARY
DISTRICT,
Petitioner,
v.
)
PCB 85—34
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
Respondent.
OPINION AND ORDER OF THE BOARD (by W.J. Nega):
This provisional variance
request comes before the Board
upon
a March 22, 1985 Recommendation of the Illinois Environ-
mental Protection Agency (Agency).
The Agency recommends that a
45—day provisional variance be granted
to the Bloomington—Normal
Sanitary District from 35
Ill. Adm.
Code 304.120(c)
and 35
Ill.
Adm. Code 304.141(a)
to
allow bypassing of the tertiary filters
so that media can be added and necessary piping modifications
made and
to allow the
Petitioner
to exceed
its
NPDES Permit
effluent biochemical oxygen demand
(BOD)
and suspended solids
(SS)
limits during
the period that the unit
is out of service.
The Bloomington—Normal Sanitary District, which serves
80,000 residents
in
a
25 square mile area, owns and operates
three wastewater
treatment facilities.
Preliminary, primary,
and
secondary treatment are provided by each of
these three waste—
water facilities before
their
secondary effluents are combined
for
tertiary treatment and disinfection.
(Rec.
1).
Addition-
ally,
each facility has the capacity to disinfect its secondary
effluent individually if necessary.
These
three facilities have
a total design average
flow of 16.0 million gallons per day
(mgd).
The Petitioner’s NPDES Permit provides that its wastewater
treatment facilities must meet effluent limitations
of 10 mg/i
BOD and
12 mg/i
SS.
The following table summarizes the relevant
information obtained from the Petitioner’s discharge monitoring
reports
to the Agency pertaining
to BOD and suspended solids
levels during
the past year:
Month
Flow (mgd)
BOD
(mg/l)
SS
(mg/i)
March, 1984
22.6
10
8
April
24.3
9
9
May
23.6
8
7
June
.17.3
8
3
July
12.3
9
3
August
11.9
11
3
September
12.5
10
3
63-255
—2—
October
14.8
10
4
November
17.1
10
4
December
18.2
11.6
6
January,
1985.
17.5
11
6
February
17.6
16
12
Average
17.5
10.3
5,7
(Rec.
1—2).
The Petitioner has also supplied information pertaining
to
the
secondary
eff1~e~.t
from
each of the three individual treat-
ment facilities
fo~
~.~1endar
year
1984;
March
to
May,
1984;
and
January to aid—Mar~,L, 1985.
The Agency believes that these data
reflect the curren~:.
~end and indicate what concentrations
of BUD
and
suspenc~ed
soli&~
~an
be reasonably expected
in the secondary
effluents
individual:,.; and collectively during the time period of
the
requested
provi~:~.;nai
variance.
(Rec.
2).
The
pertinent
information
is
as
~
BO12~ION
1~NDNORMAL
SANITARY
DISTRICT
1984
Annual
March
~p~il
~y
Jan.
Feb.
Mar.*
Plant
#1
Flow
(mgd)
8.2
11.8
12.6
12.2
7.2
8.1
14.7
BUD
(mg/i)
25.9
21.0
18.3
18.0
29
42
16.2
SS
(mg/i)
25.4
24.8
26.1
27.9
28
42
38.4
Plant
#2
Flow
(mgd)
2.0
2.1
2.1
2.2
2.9
1.7
2.0
BUD
(mg/i)
12.4
12.7
9.4
10.9
23
26
11.6
SS
(mg/i)
14,8
17.3
17.6
13.5
13
14
8.2
Plant #3
Flow (mgd)
7.2
8.6
9.6
9.3
7.3
7.7
9.4
BUD
(mg/i)
7.9
7.8
5.0
4.7
12
13
10.8
SS
(mg/i)
10,0
9..
8.8
5.1
12
12
18.2
Canposite
Sample**
Flow
(mgd)
17.4
22,5
24.3
23.7
17.4
17.5
26.1
BUD
(mg/i)
16.9
15.2
12.3
12.1
20.8
27.7
18.0
SS
(mg/i)
17.8
18..i
18.5
17.6
18.8
26.1
29.1
Accordingly,
the Petitioner has requested effluent
limita-
tions of
30 mg/i
for
both
BOD
and and suspended solids during the
*MARCH
DATA
IS
FOI~ 16
DAYS
FLOW,
12 DAYS BOD, 16 DAYS
SS.
**COMPOSITE
SAMPLE
BASED
UPON WEIGHTED AVERAGING FOR
3 PLANT
EFFLUENTS
WITH
NO
TERTIARY
FILTER
TREATMENT.
63-256
—3—
variance period.
The Agency believes that the Petitioner should
be able
to meet the requested effluent limitations of
30 mg/i for
both BOD and
SS during
the variance
period
based upon the data
submitted by
the Petitioner
to the
Agency.
(Rec,
2),
The Petitioner has stated that it intends to award
the
contract for modification of the drain—down water piping on
April
8,
1985
and to take the tertiary filters out
of service
for
several
days while modifications are
made,
Several weeks after
the
requisite piping modification is
completed,
the
Petitioner
plans
to take the tertiary filters out of service
in order
to
extend
chlorine linne to all filter cells and replace
and/or add
media
to the filter~ Before the actualwork on this part of
the
project
is performed,
the Petitioner plans
to
meet with the manu-
facturer of
these tertiary filters
to
ascertain whether
to
utilize the same type of media or
switch to
a different type.
Once
it
determines what type of media to
use,
a three week bid
process will ensue before
the contract can be awarded and this
work begun.
(Rec,
3).
Although
the sanitary district has previously been aware of
media loss from
the filters and had planned
to work on this
problem during
this coming summer, the Petitioner was not aware
that
the
loss
of media from the filters was
so
extensive until
various problems occurred
in February,
1985,
(Rec,
3),
In order
for the
media to be replaced,
the Petitioner must re~routethe
drain—down
piping,
change
the nozzles,
extend
the chlorine piping
to
all
filter cells,
and take the filter out of service for
a
short period of
time,
To perform the previously described work,
the Petitioner believes that there
is no viable alternative to
removing the filters
from service,
The
Agency has noted that
it
“agrees with Petitioner~sassessment of alternatives”,
(Rec.
3).
The Petitioner has estimated
that it will cost at least
$70,000.00
to perform the necessary
work and
anticipates that the
work will
be completed by the latter part
of
April,
1985
or the
early part of May,
1985,
The
Petitioner
has asserted that denial
of this requested provisional variance
would
cause an arbitrary
or unreasonable hardship as the sanitary district would
be
required to meet tertiary effluent limits while being able to
provide only
secondary treatment.
The
Agency agrees with the
Petitioner’s
contention
in regard
to such hardship and notes that
“due
to the higher stream flow and available dilution during this
time of year that any adverse impact
on
the receiving stream will
be minimal,”
(Rec,
3),
Accordingly,
the Agency has
concluded that
compliance on
a
short—term
basis with the provisions of
35
Ill,
Adm, Code
304.120(c)
and 304.141(a)
would
impose
an
arbitrary or un~
reasonable
hardship upon the Petitioner,
Therefore,
the Agency
recommends
that the Board grant the Bloomington—Normal Sanitary
District
a provisional variance from Sections 304.120(c)
and
304.141(a)
for
a period of 45 days,
subject
to certain
conditions,
63-257
—4—
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 Bloomington—Normal Sanitary District
is hereby granted a
provisional variance from
Si
Ill.
Adm, Code 304.120(c)
and
35
Ill.
P
Code 304
11
,
subject
to the following condi-
tions:
1.
This provisional
.~nrianc~eshall commence when the
tertiary filters are first taken out of service and continue for
45 days,
or until
the work on the media of
the tertiary filters
is completed, whichever occurs first.
2.
The Petitioner
shall apply for any permits required for
this work.
3.
The Petitioner
shall sample
the secondary effluents and
perform laboratory analyses on the samples at the same type and
frequency as specified
in NPDES Permit No.
IL002773i.
The
analytical
results for each sample,
along with the weighted
average,
shall be
incorporated into a table and submitted to the
Agency with the monthly discharge monitoring reports.
4.
During the period
of this variance, the effluent dis-
charged shall be limited
to 30 mg/i for both BOD and SS based
upon a weighted average of all three discharges.
5.
The Petitioner shall chlorinate the secondary effluent
from each of the three treatment facilities.
6.
The Petitioner shall notify Mr. Roger Cruse of the
Agency’s Compliance Assurance Section via telephone
at 217/782—
9720 each time the tertiary filters are removed from service and
each time they are placed back
in service.
Written notification
confirming each telephone notification shall be submitted within
5 days thereof to:
Illinois Environmental Protection Agency
Division of Water Pollution Control
Compliance Assurance Section
2200 Churchill Road
Springfield,
Illinois
62706
Attention:
Mr.
Roger
Cruse
7.
Within
10 days after meeting with the tertiary filter
manufacturer’s representatl~e~s),the Petitioner shall
submit to
the Agency a report
contair’~.:ILng the decision(s)
reached regarding
the type(s)
of media to be
osed in the filter,
as well as an
63-258
—5—
outline of the scope
of work which will
be performed on the
filters.
Such notification shall be sent to Mr. Roger Cruse as
indicated above.
8.
The Petitioner
shall operate and maintain the wastewater
treatment facilities
so as to produce the best effluent practi-
cable.
9.
Within 10 days of the date of the Board’s Order,
the
Petitioner
shall execote a Certificate of Acceptance and Agree-
ment which, ehall be cant to the Agency at the address specified
in item 16 af this
a...’....~r.
Thie
ca:rtificatt’n:~’shall have the following
form:
I, (We~
_______
_________________________,
having read
the Order
ot the Illin~.”~isPollution Control Board
in PCB 85—34
dated March 22,
1985, enderstand and accept 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
~‘Y~
,
1985 by a vote
of
(~—ô
~.
Dorothy M.
Gunn, Clerk
Illinois Pollution Control Board
63-259