ILLINOIS POLLUTION CONTROL BOARD
May 27,
1982
CITY OF ABINGDON,
)
Petitioner,
)
)
PcB 81—107
)
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
)
)
Respondent.
OPINION AND ORDER OF TUE BOARD (by J. Anderson):
This matter comes before the Board on the petition for
variance filed by the City of Abingdon (City) June 23, 1981 as
amended March 26, 1982.
The City seeks variance front the 2.0
mg/i fluoride concentration limit of Rule 304(B)(4) of Chapter
6:
Public Water Supplies (Chapter 6) and front the 15 pCi/i
gross alpha particle activity limitation of Rule 304(3) (4) of
Chapter 6.
On July 8, 1981 the Illinois Environmental Protection
Agency (Agency) filed its Recommendation in support of grant of
variance until January 1, 1984.
Bearing was waived and none has
been held.
The City of Abingdon, located in Knox County, supplies the
water needs of its population of approximately 4,150 (1500 water
users) frote two deep wells (depth unspecified).
The fluoride
and
gross
alpha
levels
of
each
well
have
not
been
provided.
The
City
states
however
that
its
raw water
has
contained
fluoride
levels
ranging
from
a
high
level
of
4.0
mg/l
in
1972
to
a
low
level of 2.33 mg/l in 1979, with the last analysis available
at the time of the petition’s filing showing a 2.42 mg/l level
(December, 1979).
The City also states that gross alpha particle
activity levels in its raw water have ranged from a low level of
16.6 pCi/l in 1975 to 30.2 pCi/l in 1980.
The Agency in its
Recommendation has supplemented this information.
Analysis of
a
composite
of
four
quarterly
distribution
system
samples
taken
between August, 1979
and
September,
1980
and
analyzed
after
correction of Agency analysis procedures, shows a gross alpha
particle activity level of 30.2 ±7.86 pCi/l.
The City’s consulting engineers, Anderson Engineering
Consultants, Ltd
•,
have investigated various compliance options
to solve both problems.
They have concluded that there is not
available to the City an economically feasible alternative surface
water supply of proven quality.
An alternative groundwater source
is also unavailable, as the aquifer underlying Knox, Fulton and
Peoria Counties is recognized as having an elevated flouride
levels, ranging in Knox County from 2.2 mg/l to 8.0 mg/l.
47-135
Treatment alternatives scrutinized were the reverse osmosis
and lime softening methods which accomplish both fluoride and
radioactivity reduction,
and the adsorption method which reduces
fluoride alone~
Lime softening was identified as the least costly
method of reaching both compliance goals.
Total capital costs of
such
a system were estimated to be $379,100, with annual operation,
maintenance, and capital amortization costs of $88,260.
These
costs do not include costs
for the disposal of the system~s
resulting sludge,
a special waste.
The City asserts that immediate compliance would impose an
arbitrary or unreasonable hardship,
Installation of the softening
system would increase a typical water bill from $5.70 to $10.50.
The City,
first,
states that in the 79 years
since the water
supply~sconstruction that no adverse health effects have been
observed, and second,
that it believes that the fluoride in its
water reduces tooth decay and hardens bone structure,
The Agency does not dispute the City~scost figures.
It
asserts its belief that the public health will not be endangered
by grant of variance until January
1,
1984, the deadline date
for exemptions pursuant to §1416 of the federal Safe Drinking
Water Act,
In light of the high cost of compliance, and the apparent
lack of any immediate threat to health of consumption of water
containing fluoride or radioactivity at the levels present in
the Village~swater
(see ylla~~fKirkw2Qdj~IEPA,PCB 81-111,
December
3, 1981 and
~aeofLemgn~.IEPA,
PCB 80—48,
April
30,
1981)
the Board finds that denial of variance would
impose an arbitrary or unreasonable hardship.
Variance is granted
until January
1,
1984,
subject to the conditions outlined in the
attached Order,
Given the apparent rise in gross alpha particle
activity in the City~swater over the years, and the Board~s
continuing uncertainty about the accuracy of test analyses
(see
~~ofD~ae,
PCB 82—24,
May 27,
1982),
it is even more than
usually important that gross alpha testing continue and that radium
testing commence, and the Board will so order,
In addition, the
City would seem not to have considered the feasibility
of blending,
using an auxiliary water source as an alternative to complete
replacement of its current water supply,
and will be ordered to
investigate this option,
This Opinion constitutes the Board~sfindings of fact and
conclusions of law in this matter.
ORDER
1.
Petitioner, the City of Abingdon is granted a variance
from the 2,0 mg/l fluoride limitation of Rule 304(B) (4) and the
15 pCi/l gross alpha particle activity limitation of Rule
304(C)(1)(b)
of Chapter 6:
Public Water Supply until January
1,
1984, subject to the following conditions:
47~136
a.
Petitioner shall,
in consultation with the Agency,
continue its sampling program to determine as accurately as
possible the level
of radioactivity in its wells and finished
water.
Testing for radium 226 and 228 shall he commenced.
b.
Petitioner shall investigate the possibility and
feasibility of achieving compliance by blending water from
its deep wells with water from another source.
As
expeditiously after identification of a feasible compliance
method as
is practicable, but no later than January
1,
1984,
Petitioner shall submit,
to the Agency,
a program (with
increments of progress) for bringing its system into
compliance with radiological quality and fluoride standards.
c.
Petitioner shall take all reasonable measures with
its existing equipment to minimize the level of fluoride and
radioactivity in its water supply.
The fluoride level
shall
not be allowed to exceed an average of 4.0 mg/l,
d.
Pursuant to Rule 313(D) (1)
of Chapter
6,
in its
first set of water bills or within three months after the
date of this Order, whichever occurs first, and every three
months thereafter,
Petitioner will send to each user of its
public water supply a written notice to the effect that
Petitioner has been granted by the Pollution Control Board
a variance from the 2,0 mg/l fluoride standard and 15 pCi/l
maximum gross alpha particle activity standard,
The notice
shall state the average content of gross alpha particle
activity in samples taken since the last notice period
during which samples were taken.
2.
Within forty~fivedays of the date of this Order,
Petitioner shall execute and forward to the Illinois Environmental
Protection Agency, PWS Enforcement Programs,
2200 Churchill Road,
Springfield, Illinois
62706,
a Certificate of Acceptance and
Agreement to be bound to all terms and conditions of this variance.
This forty—five day period shall he held in abeyance for any period
this matter is being appealed.
The form of the certificate shall
be
as follows:
CERTIFICATE
I,
(We),
—
,
having read
the Order of the Illinois Pollution Control Board, in PCB 81-107,
dated _________________________________, understand and accept the
said Order, realizing that such acceptance renders all terms and
conditions thereto binding and enforceable.
Petitioner
By:
Authorized Agent
47-137
4
Title
Date
IT IS SO ORDERED.
Board Member
I,
Goodman abstained.
I, Christan L.
Moffett, Clerk of the Illinois Pollution
Control Board, hereby certify that the above Opinion and Order
was adopted on the
~
day oE
,~
,
1982 by
a vote of
L1_(~
,
Christan
L. Moffett, C~rk
Illinois Pollution Con~rolBoard
47-138