ILLINOIS POLLUTION CONTROL BOARD
July 23,
1981
CITY OF ROCK ISLAND,
Petitioner,
V.
)
PCB 80—212
ILLINOIS ENVIRON~4ENTALPROTECTION AGENCY,
Respondent.
OPINION AND ORDER OF THE BOARD
(by J.
Anderson):
This matter comes before the Board upon the petition for
variance filed by the City of Rock Island
(City) November 17,
1980
as amended February
19, 1981.
Variance is sought from Rule 601(a)
and 602(b)
of Chapter
3:
Water Pollution
(Chapter 3) in relation
to certain surcharging sewers,
lift station overflow events, and
an emergency drain system.
Relief is also sought from Rule 501(c)
of Chapter
3 as it relates to sampling of fecal coliforrn and
chlorine residual.
The Illinois Environmental Protection Agency
(Agency) recommends that variance be granted in part and denied in
part in its filings of January
26 and March
19,
1981.
Hearing was
waived and none has been held.
The City of Rock Island, Rock Island County, owns and
operates two sewage treatment plants.
The Main plant and its
tributary sewer system is the subject of this petition.
Of the
approximately 170 miles of sewer in the Main plant service area,
it is estimated that 40
consists of combined sewers and 60
separate sanitary and storm sewers.
Two combined interceptor
sewers deliver flows to the Main plant;
specifically, the problems
related to the South Slope Interceptor are the concerns of this
petition.
Surcharging Sewers
One of the lift stations pumping into the South Slope
Interceptor is the Blackhawk State Park Lift Station.
Three man-
holes along the 30 inch gravity sewer immediately upstream of this
lift station surcharge ordinary domestic sewage during wet weather
periods.
The north manhole overflows first and most frequently,
the west* manhole overflows less frequently, during extremely
severe thunderstorms, and the middle manhole overflows infrequently.
*The November 17 petition referred to this as the
usouthfl
manhole, the February 19 petition referred to this as the “west~’
manhole, and the Agency referred to this as the “downstream”
manhole.
43—67
2
(The Agency estimates that surcharge incidents occur approximately
6—8 times a year).
The north and middle manholes are located
immediately adjacent to a creek flowing into the Rock River, so
that overflows “would probably flow directly
into the creek”.
The
west manhole
is located approximately 80 feet from the creek, and
as •the area surrounding the manhole is mostly flat ground with
uncut swamp grass and depressed areas,
it is likely that overflow
would pond and hold sewage solids in the vicinity of this manhole.
The City alleges that the 40 year old,
30 inch gravity sewer
on which these manholes are located is subject to unusually high
infiltration and inflow,
as it passes under the creek and through
“swampy—like draw areas”.
This 30—inch sewer discharges
to the
lift station, which in turn discharges through a 12—inch forcemain
to a 30—inch sanitary sewer downstream.
The Park lift station, installed in 1970,
is equipped with
two pumps with a pumping capacity of 2250 gallons per minute.
The
pumps were designed to operate at variable speeds, but have not
due
to gear failure, which is the subject of a dispute between the
City and the pumps’ manufacturer.
The City believes that these overflow problems will be
corrected upon completion of a $7.5 to
$8 million sewer and plant
rehabilitation project,
for which the City has begun planning with
the assistance of Step
1 federal construction grant funding.
How-
ever, the City states that
it does not have the financial capability
of completing this project without the assistance of federal or
state grant assistance.
The Agency reports that given the City’s current project
Priority Number 1054,
Steps
2 and
3 funding are presently
unavailable.
During the pendency of this petition for variance,
the Agency and the City’s consulting engineer have discussed means
by which the surcharge problem could be mitigated short of the
above—described construction project.
The Agency recommends that
variance with several conditions be granted until December
31,
1983, the date scheduled for Agency approval of the City’s Step
1
facilities plan,
The first is that the west manhole be raised,
and that if surcharging still occurs, that the City initiate and
continue a program of filling,
grading, mowing and cleaning the
area surrounding the manhole.
Concerning the lift station itself,
it is suggested that siphon bar screens be cleaned daily, flow
measuring equipment be installed,
and that the pumps be tested
for capacity.
The Board finds that denial of variance, and the resulting
major financial compliance burden would impose an arbitrary or
unreasonable hardship on the City.
Variance from Rules 601(a)
and 602(b)
is granted.
As the measures suggested by the Agency
and the City seem reasonably calculated to control
the number and
effects of surcharge events,
they are included as conditions
in
the attached Order.
43—68
3
30th Street Lift Station Overflow
The 30th Street Lift Station, one of three tributary to the
South Slope Interceptor,
overflows approximately
3 or
4 times a
year as a result of power failures and/or pump malfunctions.
The
high level overflow line discharges sewage into an 18—inch sewer
tributary to the Rock River.
The station has a high water alarm
system, but no standby facilities for emergency pumping or storage!
detention.
The City has rejected the option of simply plugging the
overflow line,
as
it believes that such action could result in
basement backup problems.
The other option would be use of
portable pumping equipment,
which the City has on hand, after
installation of a forcemain riser with a quick connect coupling
and appropriate valving.
Cost of implementing this option would
be $4,200, with $800 to he added for grant application work.
The
City would plan to include this work in the aforementioned r-~ajor
rehabilitation package, or to apply
for a separate grant in 1981.
The Agency observes that it has not approved funding for
this minor project, and speculates that even
if approval had been
obtained,
funds could be unavailable for an indefinite period.
As the cost of this project is relatively minor, and the City has
not alleged financial inability to complete
it, the Agency believes
that variance should be denied.
The Board notes that the Agency’s initial Recommendation of
January
26 suggested denial of variance on the above grounds,
and
also that the City did not address this issue in its amended
petition of February
19.
Under these circumstances, variance fror~
Rules
601(a) and 602(b)
is denied for failure to prove that
the
burden of compliance rises to the level of
imposing an arbitrary
or unreasonable hardship.
STP Drainage System
The City seeks variance for use of a 12—inch “emergency”
drain to accept raw plant sewage from
a grit chamber and partially
treated
(30
reduction)
effluent from the primary
tanks.
This
drain would be used during shut downs of the grit chamber or
primary settling tanks for maintenance,
as a replacement for
2
6—inch drains which are being plugged.
This drain would discharge
into the plant’s effluent box
(outfall sewer) discharging into
ttie
Mississippi River.
Eventual compliance will involve pumping the drained sewage
back to the head of the treatment process,
and plugging of the
drain.
Cost of this option includes $9,100 for a pump,
$1400 in
fees for engineering and drain plugging,
and $500 for grant appli-
cation work.
Again, the City would prefer to include this in the
major work package,
or to apply
for separate grant funding.
43—69
4
The Agency recommends denial
for much the same reasons given
relative to the 30th Street Station.
As the City has a portable
pump on hand,
and since maintenance can be scheduled to some extent,
the Agency believes purchase of
a new pump may not be necessary.
The Board agrees with the Agency’s conclusion, to which the
City in this instance also made no objection.
Variance from Rules
601(a) and 602(b)
is denied, for failure to prove an arbitrary or
unreasonable hardship.
Fecal Coliform and Chlorine Residual Monitoring and Sampling
Variance is lastly sought from Rule 501(c), which requires
NPDES permit holders to monitor and sample effluent in accordance
with schedules established by the Agency and included in the
permit.
The City’s permit requires it to monitor chlorine
residual by means of daily grab samples,
and fecal coliform by
means of grab samples taken five times per week.
The City’s sampling point for these two parameters
is located
500 feet from the head of the aforementioned plant effluent box
or outfall sewer, which extends for another 300 feet before its
discharge into the Mississippi River.
During high river stages,
the sewer is surcharged, with the result that the required,
representative grab samples cannot be taken.
Such stages usually
occur in the spring,
although samples also could not he taken on
many days in June and September,
1980.
Although the City has not estimated the costs
of compliance,
the Agency recommends grant of variance.
It believes that immediatr~
compliance would involve substantial modifications to the plant,
including installation of a new chlorinator.
The Agency further
remarks that should the Board delete the Rule 405 fecal coliform
limitation as proposed in the still—pending R77—12, Docket
1)
proceeding,
sampling for the chlorine residual and fecal coliform
Count would no longer be required.
It
is therefore recommended
that variance be granted for five years or until the Board
reaches a decision in R77—12,
Docket D, whichever occurs
first.
The Agency correctly notes that mere pendericy of the R77—12,
Docket D proceeding is,
alone,
insufficient support for grant of
variance.
The Board finds that the petition,
read as
a whole,
provides sufficient information concerning financial hardship to
justify variance from Rule 501(c), particularly given the Board’s
denial of variance as related to the 30th Street Station and the
STP drainage system.
For the administrative convenience of all
parties, variance is granted until December 31,
1983 or until
decision is reached in R77—12,
Docket
D, whichever first occurs.
This Opinion constitutes the Board’s findings of fact and
conclusions of law
in this matter.
43—70
ORDER
1.
Petitioner,
the City of Rock Island is hereby granted
variance from Rules 601(a) and 602(b) of Chapter
3:
Water
Pollution,
as they relate to surcharging of sewers in Blackhawk
State Park,
until December 31,
1983,
subject to the following
conditions:
a.
Within
45 days of the date of this Order,
Petitioner shall raise the west manhole.
b.
If this raised manhole overflows at any time
during the period of this variance, Petitioner shall
immediately begin a program of filling,
grading, mowing
and cleaning the affected area.
These landscaping
measures shall be maintained for the duration of the
variance period.
c.
Petitioner shall clean the siphon bar screens
daily, bring the screenings to ground surface and
dispose of them properly.
d.
Petitioner shall make all reasonable efforts
to obtain the repair or replacement of the pumps at
the
Blackhawk State Park lift station,
so as to obtain a
variable speed drive system.
e.
Petitioner shall provide flow measuring
equipment at the Blackhawk State Park lift station.
This includes,
at a minimum, pump time clocks.
f.
Petitioner shall promptly perform a pump test
at the Blackhawk State Park lift station in order
to
determine the present capacity of the pumps and shall
study whether increasing the hydraulic capacity would
be feasible and cost effective.
The results of this
test and study shall be reported
to
the Agency at the
address given in
(g), below.
g.
Petitioner shall report to the Agency in
writing each time an overflow event occurs.
The report
shall
include, at a minimum:
date(s), duration, amount
(if possible),
impact of the event,
and specific man-
holes overflowing.
If the overflow is from the raised
manhole,
Petitioner should also include in this report
a description of the measures taken to clean up the
overflow.
Notice shall be sent to the following address
within five days of the event:
Illinois Environmental Protection Agency
Division of Water Pollution Control
Compliance Assurance Section
2200 Churchill Road
Springfield, Illinois
62706
43—7 1
6
2.
Petitioner is also granted variance from Rule 501(c) of
Chapter
3 as it relates to chlorine residual and fecal coliform
monitoring and reporting schedules contained in its NPDES permit.
This variance shall terminate on December 31,
1983 or on the date
of the Board’s final decision in R77—12, Docket D, whichever first
occurs.
3.
Variance from Rules 601(a) and 602(b) of Chapter 3 are
denied as they relate to overflows from the 30th Street Lift
Station and a proposed
“emergency” drain for the Main treat;nertt
plant.
4.
Within forty—five days of the date of this Order,
Petitioner
shall execute and forward to the Illinois Environmental
Protection Agency, 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 dayperiod shall be held
in abeyance for any period
this matter
is being appealed.
The form of certificate shall
te
as
follows:
CERTIFICATE
I,
(We),
_________________________________,
having cead
the Order of the Illinois Pollution Cotnrol Board in PCB 80-212,
dated __________________________,
understand and accept the said
Order, realizing that such acceptance renders all terms and
conditions thereto binding and enforceable.
Petitioner
By:
Authorized Agent
~TE1e
*
-
Date
IT IS SO ORDERED.
I, Christan L.
Moffett, Clerk of the Illinois Pollution
Control Board, hery
certify that the above Opinion and Order was
adopted on the ~“day
of
~
,
1981 by a vote
.9
)
43—72