ILLINOIS POLLUTION CONTROL BOARD

April 5, 1984

GEORGIA-PACIFIC CORPORATION

)

Petitioner,

V.

)

PCB 83—179

ENVIRONMENTAL PROTEC TI ON AGENCY

MR. GARY KING

~ATTORNEY AT

LAW) APPEARED ON BEHALF OF THE

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY;

MS. SARA

SADLER TURNIPSEED (ATTORNEY AT LAW) APPEARED ON BEHALF

OF GEORGIA-PACIFIC.

OPINION

AND ORDER

OF THE

BOARD (by 1. D. Dumelle):

This

matter

comes before

the Board upon a November 30, 1983

petition and a December 302 1983 amended petition for variance

filed on behalf of the Georgia—Pacific Corporation requesting

relief from a Board Order requiring a particular plan for closure

of its wastewater lagoon system. On January 11, 1984, the

Tilinois Environmental Protection Agency (Agency) filed a

recomr~endationthat variance be granted subject to certain

conditions.~ Hearing was held on February 23, 1984 at which the

parties, hut no Tnernbers of the public, appeared.

Georgia—Pacific owns and operates a paper mill located in

Tayiorviiie1 Christian County which manufacturers fine grade

papers including stationery2 envelope stock, ledger paper, and

associated products from cellulose pulp received from other

mills, The plant produces about 100 tons of paper per day

utilizing fresh water from private wells on the property and

water fron~the City of Taylorville in the plant boilers and for

backup services Wastewater

results from excess in the

paper.~makingprocess, pump seal water, hose and pipe leakage, and

cooling

water~

Sanitary wastewater is

discharged to

a

City

sanitary sewer~

The wastewater flows approximately 2½ miles to wastewater

treatment facilities. During the period of October, 1982 to

september, 1983, the flow averaged 0.853 mgd, SOD averaged 76

mg/l and TSS averaged 29 mg/i. Pursuant to a settlement in PCB

76-241, Georgia—Pacific has been building a

series of lagoons

each of about 0.75 acres in size which are used as presettling

57-351

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2

ponds and which are closed, dewatered and :covered when they

become filled with sludge. The wastewater is then treated in

settling basins UD~ and ~

followed

by a 25—acre aerated lagoon

(Lagoon two) with a discharge to a small tributary to the South Fork

of the Sangamon River,

On April 2, 1981, the Board, in PCB 76—241, (41PCB151) found

Georgia—Pacific in violation of Rule 102 of Chapter 2, Rules 402,

410(a), and 901 of Chapter 3, and Sections 9(a), 12(a), 12(b),

and 12(f) of the Environmental Protection Act. The Board ordered

Georgia-Pacific to

comply with all the terms and conditions of

the Stipulation and Proposal for Settlement filed on

December 30, 1980. Under the terms of the Settlement,

Georgia—Pacific agreed to discontinue the use of the wastewater

lagoon facility as soon as the wastewater from the paper mill

could be diverted to the Taylorville Sanitrary District, which

was issued a federal construction grant on November 13, 1981, in

the amount of $2,542,575 for expansion and upgrading of the

District’s facility. The remaining local share of the project

w~sto be paid by Georgia—Pacific under the terms of an agreement

with the District.

Construction on this project has been substantially

completed, although a number of operational items have to be

resolved before diversion of the Georgia—Pacific effluent to the

District’s facilities can begin. The most current projection in

the record is that diversion was to have begun between

January 15, 1984 and February 1, 1984.

Georgia—Pacific requests that Paragraph E of the Proposal

for Settlement as incorporated into the Board’s April 2, 1981

Order be modified to allow Georgia-Pacific to utilize a more

practical and cost effective method of closure of lagoon two.

The proposal also incorporates a method to dewater Basins D and

to enable compliance with Paragraph D.ii of that Order.

The materials treated in the settling basin portion of the

waste treatment system are approximately 700,000 gallons of

papermill. effluent per day containing 10,000 pounds of suspended

solids and 52000 pounds of SOD. This material is treated in

these basins to remove the suspended solids and a portion of the

BOD, The materials discharged from the settling basins into the

aerated basin for treatment are comprised of approximately

700,000 gallons per day of clarified effluent containing approx-

irnately 450 pounds of total suspended solids and 2,400 pounds of

SOD. The discharge from lagoon two is to Flat Branch Creek

tributary to South Fork River and consists of approximately

700,000 gallons per day containing 290 pounds of SOD and 230

pounds of suspended solids.

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The Board’s Order in 76-241

generally calls for covering

abandoned sludge settling

ponds and aerated basins with at least

1. foot of dirt and establishing a vegetative growth within 1 year

of abandonment~ Georgia-Pacific alleges that this closure method

has proven impractical and overly

expensive in that covering the

25-acre aerated basin (lagoon 2)

with

a

minimum

of 1 foot

of dirt

is virtually impossible. The amount of cover actually required

has proven to be much more than anticipated in that it must be

several feet thick in order to provide enough support for earth

hauling equipments Also, when attempting to cover the sludge in

place in such a large area, Georgia—Pacific states that “the

sludge oozes ahead of the fill being applied and ends up being

entombed in a mound of dirt at the far edge of the basin.” For

these reasons, Georgia-Pacific proposes to remove the sludge from

lagoon 2 and consolidate it into the E3 settling basin, enabling

all of the sludge to be covered in one area and permitting

grading from this area outward and downward to the natural

contours surrounding the site,

Georgia—Pacific further alleges that the closure cost

pursuant to the Board2s Order in PCB 76—241 is $525,027 while the

cost of the proposed closure plan is only $196,960. Its

Corporate Environmental Engineering Department has made an

“extensive analysis” of environmentally acceptable and cost

effective alternatives, hut could not identify any. Finally,

while alleging that granting of the variance will result in a

beneficial environmental impact, Georgia—Pacific also agrees to

monitor biochemical and chemical oxygen demand and suspended

solids and to limit the discharge of BOD and SS to certain levels

to minimize any adverse environmental impact.

The agency agrees with Georgia—Pacific that the method of

closure proposed in this proceeding is more practical and sub—

stan~iallymore cost—effective than the method set forth in the

Settlement, and that if variance is granted, the quality of the

effluent should be unaffected. Therefore, the Agency believes

that an unreasonable hardship would exist if variance were to be

denieth

The Board concludes that denial of variance would impose an

arbitrary and unreasonable hardship and also finds that the

conditions which Georgia-Pacific and the Agency have agreed

should be imposed upon the granting of variance are appropriate.

The Board will2 therefore, grant variance subject to conditions

generally in accordance with Georgia—Pacific’s variance request.

This Opinion constitutes the Board’s findings of fact and

conclusions of law in this matter.

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4

ORDER

The Georgia~PacificCorporation is hereby granted variance

from Paragraph E of the Stipulation and Proposal for Settlement

filed December 302 1980 in PCB 76—241 which is incorporated by

reference in Condition E of the Board’s April 2, 1981. Order in

that matter, subject to the following conditions:

1. This variance shall expire December 31, 1984 or upon

completion of Conditions 3, 4 and 5, below;

2. Georgia~Pacificshall cease discharging to its lagoon

facilities once connection to Taylorville Sanitary

District facilities is achieved and the District

accepts full diversion of flows from Georgia—Pacific’s

paper mill;

3. By April 30, 1984 Georgia—Pacific shall:

a.

Divert the flow

from the “Hopper Sewer” into the

existing drainage ditch;

h. Install drain pits in the dike between “C” and

“0”

c, Install drain pits in the dike between “D” and

‘3

*

d~ Dewater “C” and “D”

by pumping excess water to

lagoon 2~

a. Pump free water from “E3”

as needed to lagoon 2;

f. Relocate two aerators in lagoon 2 toward the

discharge end of lagoon; and

g, Remove the three remaining aerators;

4. By June 30, 1984 Georgia—Pacific shall:

a. Remove excess fill from “E1, “B”, and “C” and

b.

coverSeed

and“D’2fertilize all

filled areas;

C.

Dredge and pump sludge from lagoon 2 into

d. Drain water from lagoon 2 through the existing

outfall to the proximity of any residual sludge.

57-354

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5

DOD compliance shall be

maintained

through

COD

testing of

effluent as

it relates to DOD.

e. Remove last aerator

and

diversion curtain;

f.

Cut

dikes on lagoon 2

-

Dewater

sludge using

swap

pumps;

and

g

•

Remove

any

remaining sludge

from bottom

of

lagoon

2 and deposit in 33,

S. By

December

31, 1984 Georgia—Pacific shall:

a. Dewater

N3

•

using drain pits in

the

dikes. The

supernatan~is to be pumped

over

an established

grassed area;

b.

Cover

6. Georgia—Pacific shall immediately submit to

the Agency, if it has

not

already

done so,

any

permit

applications needed to authorize

any actions contained in

this variance including,

but

not limited to, the reloca-

tion or removal of aerators and

the

construction of a

temporary distribution

system for

flows from the dewater-

ing system;

7.

Georgia—Pacific shall establish a correlation

between

the discharge of chemical oxygen demand and

five day

biochemical oxygen demand such

that discharges

of DOD

from lagoon 2 are maintained within the effluent

limitations incorporated in

PCB

8.

Within 45 days of the date of this Order, the

Georgia—Pacific Corporation shall

execute a

Certificate of Acceptance and

Agreement

which

shall be

sent to: Illinois thvironmental

Protection Agency, Division of Water Pollution

Control, Compliance Assurance Section,

2200

Churchill Road, Springfield, Illinois

62706.

This certification shall have the follow-

57-855

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CE RTI FIC ATI ON

I, (We),

____________________________, having

read the Order of the Illinois Pollution Control~~á~din

PCB 83~179,dated April 5,

1984,

understand 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, Christan L, Moffett, Clerk of the Illinois Pollution

Control Board, hereby certify that the above Opinion and Order

bias adopted on the

______

day of

1984 by a vote of

_________

Christan L. Moffett, c~rk

Illinois Pollution Control Board

~57-356