ILLINOIS POLLUTION CONTROL BOARD

February 9,

1984

CITY OF CENTRALIA,

)

Petitioner,

v.

)

PCB 83—103

TLLTNOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

Respondent.

OPINION AND ORDER OF THE BOARD

(by B. Forcade):

This

matter

comes before the Board upon a petition for

variance

filed July

29,

1963,

by

the

City

of

Centralia

(“Centralia”),

seeking

relief

from

Conditions

2

and

3 of the

Boardvs Order

in ç~y~f Centralia v. EPA,

(PCB

82—98,

October

27,

1982,

49 PCB 237).

The following

is a summary

of the regulations involved:

35

Iii,

Adm, Code

302.209

203(g)

Fecal coliform water quality

standard of 200 counts/100 ml

304.120

404(c)

Effluent standard of

10/12

mg/i,

BOD/TSS

304,121

405

Fecal coliform effluent standard

of 400 counts/i00 ml

On September

8,

1983,

the Board struck specific portions

of

the

July

29,

1983,

petition and also ordered Centralia to

file

an

amended

petition.

On October

17,

1983, Centralia

filed

an

amended

petition,

but without the requisite affidavit,

as

noted

in

a Board Order of October 19,

1983.

On November 21,

1983, Centralia filed a second amended petition for variance.

December

30,

1983,

the Illinois Environmental Protection Agency

(“Agency”)

filed a recommendation that variance be granted

subject to certain conditions.

On January 13,

1984, Centralia

filed

a response to the Agency recommendation.

The Agency

filed an Amended Recommendation on January

27,

1984. No hearing

was held and the Board has received no public comment.

56-131

---

2

Centralia operates a wastewater treatment plant serving

16,000 persons and

some

industry.

It

has

a design average

flow of 3.0 million gallons

per day

(‘MGD”).

It discharges

pursuant to NPDES permit IL 0027979 to Sewer Creek, a tributary

of Grand Point

Creek,

Crooked Creek

and

the Kaskaskia River.

This permit has continued in force beyond its expiration

date because of a timely reapplication.

The Plant was upgraded under the federal construction

grants program in 1977 and 1980.

The current plant includes

grit removal, grease removal, an activated sludge unit,

clarification, chemical addition, filtration and disinfection

(Rec.

2 11).

In 1978, the Agency tested five rounds of stream samples

taken downstream from Centralia.

These samples showed

violations of water quality standards for iron,

ammonia

nitrogen and dissolved oxygen,

as well as fecal coliform.

Sediments contained increased levels of chlorinated pesticides,

organics,

and

lead

(Rec. ¶ 12).

As

recently

as

September

1983,

an

Agency

biological

and

chemical

survey

of both Sewer and

Grand

Point

Creeks

showed

a

significant

degradation

of

over

five

miles

of

the downstream

water.

Inspecttons showed water that was turbid with a

strong sewage odor.

Black sludge deposits were present

about 200 yards downstream of the discharge

(Rec. 1 14).

About

three

weeks after initial start—up of the upgraded

plant, in May1

1.980,

the underdrains in one of three tertiary

sand filters failed.

During backwashing, filter media

lodged in nozzle caps.

This caused a pressure buildup which

led to uplifting of a concrete stab in the filter cell.

After this failure, the other two filters were

removed

from

Service.

Since the plant had no provision for by-passing

the filters to the chlorinator,

it was also taken out of

service.

The plant is thus discharging an unchiorinated,

secondary effluent.

Besides the non—use of sand filters,

the stream degradation

may

be caused in part by occasional

by—passes due to excessive infiltration and inflow, and pump

failures.

Centralia is in the process of upgrading to

reduce infiltration

and

inflow,

and

is “negotiating” the

rehabilitation of the lift station which causes overflows

(Rec. ¶ 26).

A report prepared by an independent consulting

firm

determined that failure of the sand filters was due to

design error.

Action against the designer

and

manufacturer

was initiated in February, 1982.

As of this date, no settlement

has been reached.

Centralia has indicated that in order to

preserve evidence,

it does not wish to repair the sand

filters pending completion of litigation.

The Board rejects

56-132

---

3

Centralia

b

ciaL.b

4

Jar

stio

arising

from

possible

destruction of evidence throigh repair of the sand filters.

As

operator

Ce.ttalia

s

primary

responsibility

is

to

meet

the

effluent

staricta. Is

anG

avoid

pollution

of

the

waters

of

the

State.

Centralia

In

a~sccr luded that the original design

of

the

sand

ILl ten

tas

rot

ccapatible with its proposed,

upgraded plant.

Centr~liaprefers to upgrade the sand

filters at a cost of $250,000 to $400,000.

Because of the

unexpected f~..a.re

c~!the san?~fiLters, and Centralta’s

decision to upgrade their aesign, the Board will grant

additional

time

for construction.

In

this

proceeding

Centralia

requested

variance

from

Conditions

2

and

3

of

DC3

82-98.

Those

conditions

involve

interim

effluent

limitations

and a

construction schedule to

achiev,

al.ure

e

cosçsiarce

with

applicable

Board

regulatiors

flc

Into

conditions

will

be

discussed

sepa

it

i’

‘I V tL’1

L’k P

~3

.M

LIMITATIONS

~

~ ~

,~.a.d~ Order in

N2B

82—98 states

that Centraic s el

fleet

‘te

following interim effluent

liintati

is

-

-

uosU.e

Grab Sanple

BO)

45 mg/l

cu

45 t1~9/1

Central ta pr poses to nodify this condition so

that

its

effluent

aal..

we~.

the fc’Jlos.tng limitations:

.,ODay_Average

7

Day

Average

SOD

30 mg/l

45

mg/l

TS5

30 rcg/l

45 ng/l

The

5e:.

agre.s

iti

.entralia

but

requests a monthly

average raiser

ta~.a 30 day average

(Rec.

¶

9).

The

Board

agrees

.hat ~iedtate ~ompliancewithout repair of the sand

filter?

ou1l

rpne

an arbitrary or unreasonable hardship.

The

Board

does

old

res°rvat ~r1is

regarding

this

variance

and,

this

wi

1. a.a conditions to address Centralia’s

delinquency

ia

dcala.ng

;

h

ss’eral

chronic

problems.

Centralia’s cILl.uent,

s.r4ce July,

1982,

has not

consistently

met even a

30/30 mg/l limitation

based. upon a

30

day average

flit.

Pet., p.3p. In July of 1982, after a

shutdown

period,

lol tywood

Brands

Candy

Company

(9Tol

lywood),

56-133

---

wu

‘~

C)

r

•‘

n

‘lollywood’s

sl

j

di

r..

artial

y

responsible

Ion

.1

i

Rec

t6).

Asof

tt~

I

-

it

it

‘alia’s

Phase

I

Pr..

r

.

Ic

lj

ood

problem,

had

r

~‘

ermit originally

re

Un’

19

,

Certralia’s

Cn~

I

it t’ed

o

a completion

dat.

grt of the pervasive

ti’s

.

sssystemthe

30

rc

I

i.velopnent

and

orojra~

)

-

LtUL~

r

1

•)rd

°CB82—98 states

tiut

.

~h

lloc3ng

schedule

for

~

c

20

30~ 120(c)

and

-

1~3

,

er’e

0,

1985

.,

1

1)35

C

-

*

C nstniction

cc

-.

t

E

p~

TheAgency

agrea

flese proposed

rc cd

y

‘pecific treatment

-‘

ar

~ schedules

‘C,-’

‘.

t

‘~hedule

.

te

•

Since

October,

3

1-i

t~chmustbe

-

C

a

flea

tncreased.

-

.

if

‘tenecessary

Is

Tic.

U

--

1

c

e

-

;

ae

al

areas:

(1.

e

t

~t

t

di

g

facilities,

‘1

‘

1

e.

tiacling, and

C,

1

CC

I

-

a

rehabilitation

ard

c

r

-

ate

on—system

ovtrf

.

Ct

usy

1)83

the

Agency

con.

0

‘t

r

nuance

34

---

by

USF~P~.Y

fl~n

work

is

complete and permitted

WPC

Pern~

~

1~aptemher 23, i983)~

However,

certificatt

~ed

intl

Centralia

acquires

the

necess~iry

~

~,

-~

),

Althonc

system,

it

w.

treatmert

~

Therefore

1.

completion

ci

by

Central~c~

alleviate

problems

in the sewer

tesr

it

L~

flo

‘~

to

the

~n

exc-~ss

of

plant capacity

R3a~d wilt

adopt

a

separate

schedule

for the

is

e~z

~low

holding

facility

as

requested

2.

Fil~r

ticn

SiruF

t

s

Oct~ber

27,

1932,

Order

the

USEPA

in-

formed

the

e

y

ccc

~cnnrilia

by

a letter dated September

7,

1983,

th~

~

~c~s

~ociated

with

repair,

replacement

or

reconLtrrc~

i

:~

n

teftiary

sand

filters

are

ineligible

for

graiL

~

pati n

Th ~s is based upon the

certification

by

Centra3io

ct

the

tacility

as

sized

at

the

time

of

the

grant

ra

rt~.

~or

the

entire

planning

period

(Rec.

91

31).

Cent:~

las ag~cedtiat reconstruction

can

proceed

as

a

separate

r iect,

In light of Centralia~s

decision to

undertake

~

n

ce~ts

h-i

tIe

ovstem

which

wilL result in

better

~.

ul

~-

h~rd

will

jract

a

schedule

beyond the

time

re~

~r

i.

~

fi1tecs.

However,

for merely

repairing

-.

~o~eed

period

will

apply.

Wat-r

n~

values

in

exce~

in

perror~c~

at

lerect~

flow

~‘)

will

ir

~

nitrifi~-

L~

4,

SLicic

i

Urc

it

Lince 1978

has shown

d

s’~ionized

ammonia considerably

Li

u

saLty

standard.

Improvement

3

a

Li

labe

suirmer of

1983 were

v~rv

dry

period,

which caused

t

~

reduced,

This variance

-‘

a

schedule

for construction of

A

I

ut*

~c

~g~-itior

continues

to

be

of

critical

importance

a

~-

e

on

sauce

Li

the

Centralia

plant.

In

L

9

‘u. ~n~ha

snur

c Lied

a

Facilities

Plan

which

called

Lir

~

Liacenent

f

the

activated

sludge

facilities,

then

under

co

Liu~tror

wLtt

rotating

biological

contactor

(~RBCs~).lnits

consisting

of

2C

shafts.

The

Plan

claimed

that

this

was

Lie

cost

cost

effective

method

to

achieve

36~135

---

CCII

198

..n September

4,

plan

then

adi

t~~’(

Co

i

a

.i.

Lent

alia’s

-

J

te

agency

-i-.

.‘.

had

to

be

2

¶1

r

mit

‘dl

hand)

.

a

an

aj

ce:j

-

(~Cgut#

c.

1?

Board

to

deter-

..

-

li/ga

~

t

tc

rpo

ate

ff’wever,

‘lulge

ha idling

•r

ri

t’4:~ va/rice.

5

c.

t.~c.

sc-re

to1

a

eq”

C4tJJt

t

io

t

-‘

va.

to

X?j~1

-

I

1._

1_

•(

I.

3

~u

st~rvsceat

it

dati

At.

.,

the

-e

ie?t

c

we

due

I

~

~iO?.,

C’

le4ieve

the

cSs

a

jr

‘-

emo,al.

is

for

~

2

and

:

oL

I.

fOl1CWt~

-

a

a

~by

granted

-

i.~e

tron

Conditions

8

98

sub’ect to the

C.

C

—

t

m.athis

~

.

oec,

build

~bseqi.

ent

-

~,.e1.ional.

a is

ce

be

...t

1.,,~

c.-...taxn

construction

e

..

agrees

a0

c

t’e

~ -t the Board may

‘-

a.

years

t

n

not

date

•

c.

r

qusred

‘-

c.

•on

Ec..

‘

act

ad

---

1

1.

This

varian,e

wtll

expire

on

December

31,

2.

Centralia

~!tall

meat

the

following

interim

effluert

i.nL~acao-s

‘lont.niy

Coirposite

Sample

Type

7

Day

Avq.

BOD

(5

day)

30

nj/I

Daily

Composite

45

mg/l

TSS

30

~g/l

Daily

Composite

45

mg/l

A.

Centra~ia-tall continue to study and

evalua’e mit mdifications and process

~rtro1

cha.ges

in order to achieve the best

quality efruent and to implement such

~hangesand ~odificationsnecessary to

achieve t c best quality effluent.

Centralia

lall

it

q a terly reports to the Agency

:aq~il1.t

n) d

,~

after signing the

certi..~cs

ia1

nailing its efforts.

Cmtral’a

a

act”ely enforce any

eisting aetn

1

a

ordinance and promptly

I

3ke

C

er

pr~rticab1eremedial action to

~revwt

taG

~i’’hargeof wastewater from

any

nduscy

Ce’traia sewers in slug or batch

anounts.

C.

Ceritralid ~

41

,iuamit its Phase I Pretreatment

°tudyt

the

p.

“y no Later than April

1,

1984

.‘4

.eil

Ke

all

steps

necessary

to

ue’plement at

etective

pretreatment

program

as expeditiously

Q5

possible.

3.

Centn.l a shal

r.*t

trte

foliowing schedule:

A.

Ccmp~ete

wcrl.

on ~he sewer rehabilitation

and rel.ef

‘ewer proect

)PC Pernit V9t-IA—2188 issued by the Agency

cr Septenee

2:,

1983, as follows

-

tcny 1?.

.~

t~s~

tnt

acquisition

—

within

~0 cays t.ter signing the certification.

2.

Awarc

cot struction

contract

—

August 15,

3.

Commence construction

—

September

15,

1984

56-137

---

I

a

ri

icr -September15,

B.

(‘orma

-

‘

.

ork to rehabilitate,

~o

‘

-

Dad

reration, the

exir

‘

3

al

filters by June 1,

13J4

.-

colt tng construction

ache

r

ig

tie

filtration

capac’

lila

Açrtl 1, 1984

-

‘f

:

fly’

1984

•~ d

it:

.1.

June 1, l~84

C

•

ution—

Tulyl,

1984

c

~.t:

Janiary

1,

1985

Feoruary

1,

1985

C

o

rc,

o4k

ri

excess flow

1

1

~:

it.

on facilities,

•

C

i

~.

es witch will

b

‘

Cc

-

alia a treatment

psait

.a

‘

u

ra~sce

with all applicable

I nd

a

cr

uiVty

standards

ani

a

i

a

i

c

design criteria in

c.

-

I

c

owiig scnedule:

•

iOta

acaiity planning

ooc

e

t’

it

it

30

days

after signing

E

1

~tor,

-

.

-

ins ana specifications,

re

itrd

I

r issua ice of construction

-

—

J

r~

S85

Jire

1,

1985

~

n

October

1,

1985

C

~p

~

‘

a

-

October

1,

1986

4.

Centra

at

I

A

omplete

work

in

order t

~

£

t

aca_ 3rit and grease

remov~

?yc

1

r

-i

r

ly

June 1,

1984, to

be

operate.

t

t..r

a

c

wth

paragraph

5

of

the

Agency’s Arent-d

or endation.

56-138

---

9

5.

Beginning on Juij 1

1984 rid continuing thereafter

on

a

montily

basis

Cent

alia

shall

submit a report

with its DMR detailing the results and progress of

constcuc”i:n d-i~in~

tl~e

~recading

month.

6

•

Centralia

ste

1

•nair

-ii

the

pumps

at the terminal

shift staticn in wori’ g ordcr.

7.

Centralia

shall

provtAe

the

best

practicable

degree

of operation

avid nauttenance

both

at the waste-

water treatnc.nt plar.t

md

on

tho

sewer

system in

order to keep the poiLnant load to the receiving

stream

at

a

ninimtrr

8.

Withi.i forty-’ive days

or the date of this Order,

Centralia shad axecute

and

forward

to

the

Illinois

Envi:oniietta

1ro4-ec.~orAqency, Variance Section,

2200 Chi~l’7

-

~

,pra.gfield, Illinois

62706,

a

Certif~E’

c

.c’cr.

tx

ce and Agreement to be

bound by all U ye aii conditions of this variance.

This fcrt3

is,’.

‘lay

orind shall be held in abeyance

fOfr

any parid t4

b ma-ter

is

being

appealed.

The

forn

of

t

~ C.rtiicatc’ atall be as follows:

!fll

‘flON

I

(‘pe,_~

,having

read

and

t..

~c

•cti1nr.j

the Order in PCB

83-103

‘tcrcb

a

tot

“at

Order

and

agree

to

be

bound

l-y

e.t

:

.a

t~rt?.

and conditions.

~

_______________

Vt

V.

______

____

_____

I

___________________

IT

IS

SO

ORD~R.D

I,

~hrt°

ti

‘

‘o

C1nk

Ca.

the

Illinois

Pollution

Control Boarj, set eoj

rtr

£

vu.

t’ e

ye

Opinion

and

Order was adqptcd

On

~.

3:

Gay

of

-

,

1984

by

a vote of

~j~-_

-

Jh4gc~.

I

~nristan L. Moffstjtlerk

I

tinois Poltution’Control Board

56-139