ILLINOIS POLLUTION CONTROL BOARD
September 25,
1986
BLOOMINGTON AND NORMAL SANITARY
)
DISTRICT,
)
Petitioner,
v,
)
PCB 86—156
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent.
OPINION AND ORDER OF THE BOARD
(by J.
D.
Dumelle):
This provisional variance extension request comes before the
Board upon
a September 25,
1986 Recommendation of the Illinois
Environmental
Protection Agency (Agency).
On July 31,
1986,
the
Board granted the Petitioner
a 45—day provisional variance
in PCB
86—116 from 35
Ill. Adm. Code 304.120(c) and 35
111. Adm. Code
304.141(a)
to allow the Bloomington and Normal Sanitary District
to exceed
its NPDES Permit effluent biochemical oxygen demand
(BOD)
and total
suspended solids (TSS)
limits during
the
time
period that the tertiary filters are bypassed while
the filters
are out of service
for structural inspection and repair.
(See:
Opinion and Order of July 31,
1986 in PCB 86—116, Bloomington and
Normal Sanitary District
v.
IEPA).
The Agency recommends that
a
45—day extension of the prior variance
in PCB 86—116 be granted
to the Petitioner.
The Bloomington and Normal Sanitary District was previously
granted
a provisional variance
in PCB 85—34 on March
22, 1985 to
allow the rebuilding
and replacement of the tertiary filters’
media and
to allow the construction of some piping changes around
the filters.
(See:
Opinion and Order of March 22,
1985
in
PCB 85—34, Bloomington—Normal Sanitary District
v,
IEPA).
However,
the Petitioner has not yet completely rebuilt and
replaced the media of its tertiary filters because of
unanticipated wastewater treatment plant operating constraints.
(Rec.
1).
The Bloomington and Normal Sanitary District, which serves
approximately 85,000 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
wastewater
facilities
before
their
secondary
effluents
are
combined
for tertiary treatment and disinfection.
(Rec.
1).
Additionally, each facility has the capacity to disinfect its
72-422
—2—
secondary effluent individually
if necessary.
These
three
facilities have
a total design average flow of 16.0 million
gallons per day (mgd),
Effluent from the Petitioner’s wastewater
treatment facilities
is discharged to Sugar
Creek,
tributary
to
Salt Creek,
the Sangamon River, and
the Illinois River.
(Rec.
1).
The Petitioner’s NPDES Permit #1L0027731 provides that its
wastewater treatment facilities must meet tertiary effluent con-
centration limits of 10 milligrams per liter
(mg/i) biochemical
oxygen demand and 12 mg/i
total suspended solids as a monthly
average and 15 mg/i BOD and 18 mg/i TSS as
a 7—day maximum
average plus associated loadings limits.
However, the Petitioner has asked
for effluent limitations
of 25 mg/i for both SOD and TSS
as 30 day averages during the
requested 45—day provisional variance extension period.
As previously indicated in PCB 86—116, the sanitary district
has recently been contending with severe structural problems
associated with
the support floor of the tertiary filter media.
In one of the
16 cells,
the cell
floor has ~b1own up” during
backwash, thereby pulling out the anchors and cracking some of
the media
support plates.
Additionally, substantial movement of
the floor
in other cells has occurred during backwash,
(Rec.
2).
In
an attempt
to rectify the structural problems which have
been encountered,
the Petitioner removed the tertiary filter
from
service on August
5,
1986.
However, because of the lack of
structural integrity of the floor
and anchoring system,
the
tertiary filter cannot now be placed back into service.
According
to the Petitioner’s chief engineer, the problem is more
widespread than originally believed and the sanitary district may
need
to seek a full variance after the proposed provisional
variance extension
in order
for the filter
to be rebuilt.
(Pet.
2).
There are 1328 concrete slabs
(each weighing about
200
pounds)
in the
filter containing 23,840 nozzles.
To allow
further examination of the sub—floor and anchoring system,
the
Petitioner has removed about 40 of the 1328 two—hundred pound
floor slabs
so
far.
Because of the lack of availability of an
appropriate hoist
in central
Illinois, a delay
in the removal of
these slabs occurred.
Even before the
40 slabs were removed, the
Petitioner had to remove about 840 nozzles.
(Pet.
1—2),
The Petitioner’s structural consulting engineers are
currently in the process of making a more comprehensive
structural
inspection of the two cells which
initially failed
and
are performing pull—out testing on floor anchors throughout the
filter.
(Pet,
1;
Rec.
2).
Accordingly, the sanitary district is
requesting
a 45 day extension of
its prior provisional variance
72-423
—3—
in PCB 86—116
in order
to complete
the comprehensive structural
inspection
and
determine
the
appropriate
solution
to
its
engineering
problems.
(Pet.
1;
Rec.
2).
In Table
1 of its variance extension petition, the sanitary
district has delineated secondary effluent data obtained during
the provisional variance granted
in PCB 86—116
as follows:
BLICOMING’iDN AND NORMAL SANITARY DISTRICT
TABLE
I
AUGUST
5—31,
1986
SECONDARY
ThEATMENT
*
FL0~~
11.84
Million
Gallons
Per Day (Average)
17.31 Million Gallons Per Day (Maximum)
SOD
*
16 mg/i Monthly Average Concentration
87.8
Monthly Average Ren~va1Efficiency
SUSPENDED SOLIDS
*
13.3
mg/i
Monthly Average Concentration
90.5
Monthly Average Rerr~va1Efficiency
*
Values
presented
in
Table
represent
flow
proportioned
weighted
averaginy
of
all
3
plants.
PCB
86—116
Variance
Monthly
Average
Effluent
Limits
SOD
25
mg/i
SS
25
mg/i
(Pet.
3).
72-424
Similarly,
Table
II
provides
the following information:
BLOOMINGTON AND NORMAL
SANITARY
DISTRICT
TABLE
II
AUGUST,
1986
SECONDARY TREAThENT
INDIVIDUAL PLANTS
FLOW
Plant No.
1
6.4 Million Gals Per Day (Average)
Plant No.
2
1.7 Million Gals Per Day (Average)
Plant No.
3
3.8 Million Gals Per Day (Average)
SOD
Plant
No.
1
20.5
my/i
Monthly Average Concentration
Plant
No.
2
4.9
mg/i
Monthly
Average
Concentration
Plant
No.
3
3.3
mg/I
Monthly
Average
Concentration
SUSPENDED
SOLIDS
Plant
No.
1
19.0
mg/i
Monthly
Average
Concentration
Plant
No.
2
4.3
mg/i
Monthly
Average
Concentration
Plant
No.
3
5.7
mg/i
Monthly
Average
Concentration
(Pet,
4).
The Agency believes that the data
in Tables
I
and II
indicates that the Petitioner will generally be able to meet the
requested effluent limitations without the tertiary filters
during the time period
that structural
inspections and repairs
are being completed.
(Rec,.
2),
The Petitioner believes that,
at the present time, there
is
no practical alternative
to removing the tertiary filters from
service
in order
to properly evaluate and correct the media
support floor problem.
(Rec.
2).
The Agency has also indicated that,
in view of the need
to
remove
the tertiary filters from service
in order
to resolve the
media support floor problem,
it “agrees with Petitioner’s assess-
ment of the alternatives”.
(Rec.
2).
The sanitary district has stressed
that it anticipates no
adverse environmental impact on the receiving stream during the
time period of the requested provisional variance extension.
72.425
—5—
The Agency agrees with the Petitioner’s environmental
assessment
and believes that “the expected environmental impact
will be minimal because disinfected secondary effluent will be
discharged”.
(Rec.
3).
Additionally, the Agency thinks that any
potentially adverse environmental impact can be readily detected,
and treatment operations appropriately modified by the Petitioner
as capabilities allow, because the sanitary district “has
established its own water quality and biological monitoring
stations downstream of
its discharge”.
(Rec.
3).
The Petitioner has claimed that denial of its requested
provisional variance would cause
an arbitrary or unreasonable
hardship,
The Agency agrees with the Petitioner’s contention in
regard
to such hardship and has indicated that denial of the
requested relief would place an arbitrary or unreasonable
hardship on the sanitary district because the Petitioner
is
expending
substantial
funds
and
is
striving
in good faith to
correct
the problems and “has demonstrated via past data that
it
has the capability
to produce good secondary effluent while
the
tertiary filters are out of service”.
(Rec.
2).
Accordingly, the Agency has concluded that compliance on a
short—term basis
with
the
provisions of
35
Iii.
Adm.
Code 304.120(c)
and 304.141(a) would impose an arbitrary or
unreasonable hardship upon the Petitioner.
The Agency has stated
that there are no Federal regulations which would preclude the
granting of the requested relief and there are no downstream
public water supplies which would be adversely affected by the
granting of the provisional variance.
Therefore, the Agency
recommends that the Board grant the Bloomington and Normal
Sanitary District
a 45—day extension of the previously granted
provisional variance
from Sections 304.120(c)
and 304.141(a)
for
a period of 45 days, subject
to certain conditions.
Pursuant
to Section 36(c) 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 Petitioner,
the Bloomington and Normal Sanitary
District,
is hereby granted a 45—day extension of its provisional
variance from 35 Ill. Adm. Code 304.120(c)
and
35 Ill. Mm.
Code 304.141(a),
subject
to the following conditions:
1,
This provisional variance extension shall begin on
September 20, 1986 and shall continue for 45 days,
or
until
the tertiary filters are returned
to service,
whichever occurs
first.
72-426
—6—
2.
Effluent shall be limited
to 25 mg/i weighted average of
the three secondary effluents for both BOD and TSS as
monthly averages.
Effluent shall be sampled by the
Petitioner according to NPDES Permit #IL002773l as
to
frequency and sample
type.
Analysis results shall be
submitted
to the Agency on the monthly discharge
monitoring report as
30 day averages.
3,
The Petitioner
shall notify Pat Lindsey of the Agency’s
Compliance Assurance Section via telephone at
217/782—9720 when the tertiary filters are returned to
service.
Written confirmation of each telephone
notification shall be submitted within
5 days
to the
Agency at the address given below:
Illinois Environmental Protection Agency
Division of Water Pollution Control
Compliance Assurance Section
2200 Churchill Road
Springfield,
Illinois
62706
Attention:
Pat
Lindsey
4.
The Petitioner shall keep the Agency apprised of the
tertiary filter situation,
especially concerning
necessary corrective measures and estimated time frames
to
implement and complete them.
5.
If the Petitioner
is unable
to return the tertiary
filters
to service prior
to
the end of this provisional
variance extension,
the Petitioner shall
file for
a
standard variance prior
to the expiration of this
provisional variance extension,
6.
The replacement and rebuilding of the tertiary filter
media shall be included as part of the final scheme for
returning the tertiary filters
to service.
7.
The Petitioner shall operate the remainder of the three
treatment facilities
so
as
to produce the best effluent
possible.
8,
Within
10 days of the date of the Board’s Order, the
Petitioner
shall execute a Certification of Acceptance
and Agreement which shall be sent
to Mr. James Frost of
the Agency at the following address:
Mr. James Frost
Illinois Environmental Protection Agency
Division of Water Pollution Control
2200
Churchill
Road
Springfield, Illinois
62706
72-427
—1—
This certification shall have the following
form:
I,
(We), _______________________________,
having read the
Order
of
the Illinois Pollution Control Board
in PCB 86—156 dated
September 25,
1986, understand
and accept
the 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
llinois Pollution Control
Board, hereby certify that the above
pinion and Order was
adopted
on
the
c~’4ZZ’
day of ______________________,
1986 by
a
vote
of
______________
Dorothy
M.
G~?n,
Clerk
Illinois
Po1~Iution Control
Board
72-428