ILLINOIS POLLUTION CONTROL BOARD
June 22, 1978
IN
THE
MATTER
OF:
FINAL
ORDER
)
AMENDMENT TO CHAPTER
3,
WATER POLLUTION REGULATIONS;
)
R77--6
Rule 402.1, an Exception to
Rule
402
for Certain Ammonia
Nitrogen Sources
)
OPINION AND ORDER OF THE BOARD
(by Mr.
Young):
(FINAL ORDER)
On March
28,
1977, the Pollution Control Board authorized
public hearings on an Environmental Protection Agency proposal
designated
as R77-6 to amend Chapter
3 of the Board~sWater
Pollution Regulations by the addition of a proposed Rule 402.1.
The Rule 402.1 would establish
an exception
to Rule
402 until
December 31,
1978,
or at a date established by NPDES permit,
for
ammonia
nitrogen discharges from small facilities having
limited influent ammonia loading and for larger sources,
allow
the
discharge
of
effluent
containing
a
concentration
of no more than 4.0 mg/l of ammonia nitrogen during the months
of November through March.
The exemption provided by proposed
Rule 402.1 would terminate June 30,
1981.
Notice
of
the
Agency
proposal
was
published in the Environ-
mental Register #145 on April 11,
1977.
Public hearings pur-
suant to Section 28 of the Environmental Protection Act were
held
in
the
following
locations:
May
10,
1977
Sprinyfielcl,
Illinois
May 13, 1977
Chicago,
Illinois
In accordance with Section
6 of the Environmental Protection
Act,
the
Illinois
Institute
for
Environmental
Quality
filed
with
the Board on June
27, 1977,
the final version of IIEQ Document
No,
77/18 Economic Impact of a Proposed Change in Ammonia
Effluent Standards,
R77—6.
30-579
As required
by Section
27(b)
of the Act,
economic impact
hearings were
held on the proposal at the following
locations:
September
9,
1977
Chicago, Illinois
September
13, 1977
Springfield,
Illinois
At the final hearing, the Hearing Officer ordered the
record
closed
fifteen days after the filing of the final
transcript;
final
transcript was
filed hovember 17,
1977,
the
record was
closed
December
5,
l9~,7.
The ~:were
two
principal
additions made to the record after the f~ralhearing.
On
October
21,
1977,
the Illinois State Water Survey submitted
a pre-publication copy of a report ISWS~77thI85entitled
Acute Toxicity
sidual Chlorthe and Ammonia to Some
Native
Illinois Fishes by Donald P~Rosebocrn and Dorothy
L.
Richey
(hereinafter referred to as Roseboom and Richey).
The Agency
submitted operating data in the form of NPDES
discharge monitoring
reports from the MSDGC John B.
Eqan
water
reclamAtion
plant on October
25,
1977,
On
March
30, 1978,
the Board adopted a proposed final
opinion and order and authorized that the proposed
final
order
be submitted to the Secretary of State for publication in
the Illinois Register to meet~noticerequirements
and to
initiate a 45-day public comment period as required by the
Illinois
Administrative Procedure Act (1ll.Rev.Stat.
Ch.
127,
~100l
et
seq.)~
Notice of the proposed final order was also
published
in full for comment in the Board~sEnvironmental
Register #169 of April
7,
1978.
The proposed final order
was published
in Volume
2,
Issue
15 of the Illinois
Register
of April
14,
1978, pages
30 through
33.
During
public comment period
(April 14 through May 29,
1978)
,
the
Board received a single response;
that from Mr.
Carl Blomgren,
Executive Director, Hinsda?e Sanitary District,
Hinsdale,
Illinois,
in full support of the proposed published
order.
On
May
5,
1978,
the Joint Committee on Administrative
Rules
pursuant
to the Illinois Administrative
Procedure
Act
(supra)
reviewed
the proposed final opinion and order without
objection or comment~
Since there has been no adverse comment
to
this proposed regulation,
the Board will adopt the
proposed
order as
a final order for the reasons
set forth in this opinion.
30-580
—3—
THE PROPOSED RULE
The language of the Agency’s proposed rule change filed
with the Board on
May
3,
1977
(Exh.
2),
is as follows:
“Rule 402.1
Exceptions to Rule 402 (Ammonia
Nitrogen)
a)
Rule 402 shall not apply to that portioi~
of Rule
203(f)
pertaining
to
ammonia
nitrogen for any effluent from sources
in existence on April
1, l977~which
sources have an untreated ammonia load
not exceeding 60 pounds per day and
which sources
do not require upgrading
to meet other provisions of this Chapter.
b)
Rule 402 shall not apply
to that portion
of Rule 203(f) pertaining
~o ammonia
nitrogen for any effluent daring the months
of November through March.
During that
period no effluent which alone or in
combination with other sources might cause
a violation of that portion of Rule
203(f)
pertaining to ammonia nit.tc.gen shall ex-
ceed 4.0 mg/l of ammonia nitro~en.
c)
Compliance with the provisions of Rule
402 as it applies to ammonia nitrogen
shall be achieved by December
31,
1978,
or such other date set forth
in an Agency
approved NPDES comoliance program.
d)
After July
1,
1981, the exemptions pro-
vided in this Section 402.1 shall terminate.
James
B. Park,
P.E.,
Supervisor of the Standards Unit, Divi-
sion of Water Pollution Control, presented testimony describing
and explaining the basic elements of Rule 402.1 and the considera-
tions underlying the Agency proposal
(R.
9-11;
59-61).
(*See Note.)
*Note
There were four hearing transcripts taken in this proceeding.
In the transcripts of the first two
(May
10 and 13,
1977)
hearings,
the pages
are consecutively numbered
1 through
169.
The pages
of the third transcript taken September
9,
1977,
are numbered 75
through 118;
in the fourth transcript
(September
12, 1977)
the
pages are numbered 40 through 74.
To avoid confusion, citations
to the May 10 and May 13 transcripts will be prefixed by
R,
followed by the page number.
The page numbers of the transcrints
of September
9 and September 12 will be preceded by an
S and T,
respectively; hence a citation
S.
—
will refer
to the record
taken September
9 and T._
—
—
to September
12.
30—581
—4—
The proposed rule would establish, where none now exists,
an
interim
ammonia
nitrogen
effluent
limitation
until
July
1,
1981,
of 1.5 mg/I April through October and 4.0 mg/i November
through March for sources having an influent ammonia nitrogen
loading
in excess
of 60 pounds per day, or for any source, not
in existence on April
1,
1977, irrespective of loading.
Com-
pliance with the interim effluent limitations is proposed to be
achieved by December
31, 1978,
or such other date as established
by NPDES
(National Pollutant Discharge Elimination System)
permit.
An exemption until July
1,
1981,
is prcuosed for sources having
a daily influent ammonia nitrogen loadinq of less than 60 pounds
if the source was in existence on or bef ~re April
1,
1977, pro-
vided that such source does not require
lacilities upgrading
to meet any other requirement of Chapter
III.
Existing sources subject to Rule 406, which limits ammonia
nitrogen discharges
to 2.5 mg/I April through
October
and
4.0
mg/I November through March for domestic
wastewater
sources
and
to
3.0 mg/l for other sources discharging
to
the
waters
named
therein, are not included in the prooosed. rule.
No discharges
which
are
or~may
be
subject
to
the
limitations
of
Rule
406
are
or
are
intended
to
be
affected
by
the
adoption
or
the
termination
of
the
proposedRule
402.1.
The
proposal
does
not
and
is
not
intended to supercede or alter Rule 203(f) or Rule 206(c) which
establish ammonia nitrogen water quality standards in General
Use Waters and Lake Michigan.
PEGULATORY BACKGROUND
Ammonia Nitrogen Water Quality Stand~irdswere added
to the
Board’s Water Pollution Regulations on tT:rch 7,
1972
(3 PCB 755)
at which time the Board stated:
“In large part today’s draft is simply a
codification of existing water quality
standards and associated provisions
that
are now scattered throughout
a number of
separate
regulations
that we inherited
from the Sanitary Water Board.”
Rule 203(f) established
a general water quality standard,
not to be exceeded,
for ammonia nitrogen
(as N)
of 1.5 mg/l,
Rule
206 established a water quality standard for Lake Michigan
for ammonia nitrogen of 0.02 mg/I.
In adopting Rule
203(f)
the Board said
(at 3 PCB
759) re-
garding ammonia nitrogen:
“The present SWB-8 standard is 2.5 mq/l which
the Green Book
(supra)
says
is acutely toxic
to
fish.
The earlier
1.0 proposal was based
30-582
—5—
upon
a
Minnesota
standard.
While
the
toxicity
of ammonia is pH dependent, the Green Book
recommends a limit of 1.5 mg/l, and that is
here
adopted.”
In regard to the Lake Michigan ammonia nitrogen standard of
0.02 mg/i established by Rule 206 the Board only stated
(at
3
PCB 764)
that:
“Certain parameters
taken from existing standards
are preserved to require this high quality lake
to
remain
especially
clean
for
esthetic
and
recreational
purposes,
in
accordance
with
the
important
non-degradation
policy.”
The
existing
standard
referred to above, Rule
1.01 of SWB-7,
established
a
Lake Michigan open water ammonia nitrogen standard
of
0.02
rng/l
annual
average
not
to
exceed
a
daily
average
of
0.05
mg/l;
Rule
1.02
of
SWB-7
set
a
Lake
Michigan shore water standard
of
0.05
mg/i
annual
average
not
to
exceed
a
daily
average of 0.12
mg/i.
Since-~the
standard
of
SWB-7
in
Rule
1.01
was
an
annual
average,
the
Lake
Michigan
standard
established
by
Rule
206
would
appear
considerably
more
than
a
preservation
of
the
SWB
standard.
The
relationship
between
the
water
quality
standards
and
effluent
limitations
of
Chapter
III
is established by Rule 402,
adopted January
6,
1972,
which
reads
as
follows:
“In addition
to
the
other requirements of
this Part,
no effluent shall, alone or in
combination
with
other
sources,
cause
a
violation of any applicable water quality
standard.
When
the
Agency
finds
that a
discharae that would comply with effluent
standards
contained
in
this
Chapter
would
cause or is causing
a violation of water
quality standards,
the Agency shall take
appropriate action under Section
31
or
Section 39 of the Act to require the dis-
charge
to meet whatever effluent limits are
necessary
to
ensure
compliance
with
the
water
quality standards.
When such a viola-
tion is caused by the cumulative effect of
more than one source, several sources may be
joined in an enforcement or variance proceeding,
and measures for necessary effluent reductions
will be determined on the basis of technical
feasibility, economic reasonableness,
and
fairness
to all dischargers.”
In
the
adopting
Opinion,
the Board said
(at
3
PCB
405):
“402
Violation
of
Water
Quality
Standards.
The
numerical
effluent
standards
adopted
today
are
30-583
—6—
intended as basic requirements that should be
met everywhere
as representing ordinary
good
practice in keeping potentially harmful
materials
out of the waters.
In some cases, because of
the low volume of the receiving stream or the
large quantities of treated wasted discharged,
meetino these standards may not suffice to
assure that the stream complies with water
quality standards set on the basis of what is
necessary to support various water uses.
In
such cases the very nature of water quality
~tandards
requires that additional measures
be taken beyond those required by ordinary
good
practice to reduce further the discharge of
contaminants
to the stream.
This would
not
be so if effluents were all required
to be
as clean as the receiving stream, but in
recognition of economic hardship we have
refrained from imposing such a requirement
across the board.
What additional measures
are required can be determined only on the
basis of more detailed consideration of each
stream in accordance with the statutory re-
quirement that different needs may dictate
different standards.
Rule 402 states the
principle that discthrges causing
violations
of the water quality standards are forbidden,
as was the case under the earlier regulations,
and states basic considerations for determining
which of a number of contributors
to an over-
loaded stream must take measures to abate the
problem.
At the Agency’s request
an additional
sentence has been added to spell out the
Agency’s
responsibility.”
Rule
406, which was adopted January 6,
1972,
established
an
ammonia nitrogen effluent limitation for discharges
to the
Illinois River,
the DesPlaines River downstream of its
confluence
with the Chicago River System, the Chicago River System,
and the
Calumet River System.
Rule 406 provides that discharges
to
those
waters named above by sources having an untreated ammonia
waste
load of more than 50,000 P.E,
shall not contain more
than 2.5
mg/i of ammonia nitrogen
(as N)
April through October
or
4
mg/i
at other times.
No other ammonia nitrogen effluent limitation
has been established for waters other than those listed in Rule
406 and none were established for sources having an influent
ammonia nitrogen waste load of less than 50,000 P.E.
In the Opinion
(3 PCB 401)
adopting the rule,
the
following
comments appear beginning
on
page
406:
“406
Nitrogen.
The evidence is clear that for
too long the oxygen demand exerted by ammonia
in domestic wastes had been overlooked in the
30~58L1~
—7—
emphasis
on
reduction
of five-day BOD,
The
State Water Survey has conclusively shown that
reduction
of ammonia from the larger sources
feeding the Illinois River is necessary if
existing standards
for dissolved oxygen,
essential
to
an adequate fish population,
are
to
be
met.
This
is exactly the sort of
testimony that
is
required,
as discussed in
connection
with
Rule
402 above, in order to
assure
that
the
water
quality standards
are
complied
with.
There
was extensive
testimony
as
to
the
availability
of methods for
reducing
ammonia
in
effluents,
and although several
witnesses believed the technology was not
sufficiently proven in actual operation, we
are convinced that nitrification can be
satisfactorily accomplished for a reasonable
price by a second stage of biological treat-
ment.
The testimony of Edwin Barth and of
Dr. Clair Sawyer, both of whom are intimately
familiar with actual facilities
for nitrifica-
tion,
is particularly effective on this point.
The Metropolitan Sanitary District, which
is
principally affected by our proposal,
is
committed to employing nitrification.
Al-
though Dr. Sawyer’s testimony establishes
that
an
effluent
of
2.5
mg/l
can
be
achieved
even in winter by constructing
a large enough
tank,
we
have
accepted
the
Sanitary
District’s
suggestion of a slightly relaxed winter standard
in order to save costs in light of the Water
Survey’s assurance that such an effluent will
not jeopardize oxygen levels
in the Illinois
River.
We do not in this record have sufficient in-
formation to enable us
to set ammonia effluent
standards for other waters,
athouqh
the
possibility of setting them on the basis
of
dilution ratios,
as in the case of DOD,
is
worth exploring in future hearings.
It is
likely
that
ammonia reductions elsewhere will
prove necessary in order to meet stream
standards either for oxygen or for ammonia
itself, which in relatively low concentrations
may be toxic
to
fish,
The Agency should of
course consider such questions in passing on
individual permit applications.
But we think
it appropriate not to delay adoption of the
standards we know to be necessary in the Illinois
River while determining what standards are
necessary elsewhere.”
30—585
Rule 406 was amended on June 28,
1973,
in R72-4 by adding
the provision that sources discharging to any of the waters
listed in 406 and having an untreated waste load which could
not be computed on
a population equivalent basis and discharging
ammonia nitrogen in excess of 100 pounds per day,
could not dis-
charge an effluent containing more than 3.0 mg/i of ammonia
nitrogen after December 31, 1974.
This amendment did nothing
more than provide an additional clarification of the definition
of a source subject to the effluent limitations of Rule
406;
for
either case,
the threshold
for applicability of the rule
is
established by a discharge of
100
pounds per day of ammonia
nitrogen, however calculated,
NEED FOR THE PROPOSED REGULATION
Through the operation of Rule 402, domestic wastewater treat-
ment facilities not subject to Rule 406 and discharging to inter-
mittent or low flow streams must be designed to provide for ammonia
nitrogen reduction to 1.5 mg/i
to preclude violation of the water
quality standard of Rule 203(f),
The Agency has identified at
least 1479 sources which require ammonia nitrogen reduction under
the presenthregulations
(Exh,
lA3).
Of this total of 1479 sources,
976 are facilities designed to serve fewer than 1000 P.E. and 214
serve fewer than 2500 P.E.
(Exh.
lAlO, Table
3).
In all instances,
in order to insure compliance with the water quality standard,
breakpoint chlorination of the effluent
is required,
a practice
which the Agency believes is beyond operational feasibility at the
small facilities, unreasonably expensive,
and environmentally un-
sound
(Exh. 1A6~l2; R.
135).
Table 3~3of Exhibit
7 provides
a breakdown by discharger type
of 1489* sources which require further ammonia nitrogen reduction:
~h~gerT~oe
Number
Municipalities
647
Schools
221
State Parks
&
Campgrounds
64
Service Statlons
11
Trailer Parks
142
Commercial
45
Recreational Facilities
101
Nursing Homes
34
Agricultural
11
Municipal Facilities
55
State Highway Dept.
23
Motels
19
Residential
58
Miscellaneous
58
TOTAL
1489
*Note:
There is an unexplained difference of 10 between the Agency
total o~1479 and the total of 1489 reported in Exhibit
7.
The
discrepancy occurs in Category #2, Schools
& Other.
30—586
—9—
Table
3 of Exhibit lA breaks the 1479 sources into two
categories,
category
#1
-
Municipalities and category #2
-
Schools
&
Other,
by
plant
design
capability
in
population
equivalents
(P.E.).
Plant
Design
Category
#1
Category
#2
P.E.
Municip~4ties
Schools
&
Other
less
than
1000
179
797
1000—2499
196
18
2500—4999
100
6
5000—9999
70
7
10000—99999
86
4
more
than
100,000
16
_______
647
832
Based
upon
this
information,
approximately
1190
of
these
1479
facilities
will
not
receive a daily average influent loading
of
60
pounds
of
ammonia
nitrogen.
AMMONIA REMOVAL
Ammonia is a colorless gas consisting of nitrogen and hydro-
gen which reacts with water to form an aqueous solution of ammonium
hydroxide.
When sufficient ammonia is dissolved in water, a
chemical equilibrium results which contains un-ionized ammonia,
and ammonium and hydroxide ions.
A simplified expression of the
equilibrium is:
NH3
+
H2O
NH3
1120
~
NH4~
+
0H
where NH3
_H20 represents the un—ionized ammonia;
NH4
,
ammonium
ion;
and
OH
,
hydroxide ion.
For the purpose of this opinion,~
NH3
will
be
used
to
indicate
dissolved
un-ionized
ammonia,
NH4
to designate the ammonium ion and the sum of the two as
total
ammonia or ammonia nitrogen.
Ammonia
can
he
found
as
a
natural
constituent
in
most
waters,
usually
as
a
decomposition
product
of
organic
material
containing
nitrogen.
Ammonia
is
a
common
constituent
of
domestic
sewage;
sources
of
ammonia
may
also
include rain and dust fall as well
as
anthropogenic
activity
such
as
agriculture
and
industry.
Much
of
the
ammonia
present
in
surface
waters
results
from
the
effluent
discharged
from
wastewater
treatment
facilities.
In
its
several
states,
and
as
a
source
of
nitrogen,
ammonia
can
be
toxic,
may
cause
excessive
growth
of
algae,
reduce
dissolved
oxygen
and
may
react
with
other
elements
to
form
other
undesirable
or toxic com-
pounds
in water.
The nitrogen in ammonia can be substantially re-
moved during wastewater treatment by biologic or physical—chemical
processes or combinations thereof.
Biologic treatment of domestic wastewater
is virtually
universally practiced and it has been demonstrated that cost—
effective biological treatment processes,
such as activated sludge,
30-587
trickling filters, recirculating intermittent sand filters
and
natural
or aerated stabilization ponds,
can be designed
which are capable of nitrifying
the
wastewater and thereby
reducing effluent ammonia nitrogen concentrations
to levels
of 1.5 mg/i during warm weather,
The process of nitrification,
however,
is temoerature dependent;
the rate of nitrification
decreases as the temperature decreases.
It is not cost—effective
to design biological processes capable of removing ammonia
nitrogen to 1.5 mg/I from very cold domestic wastewater.
In
Illinois,
facilities
treating domestic wastewater utilizing the
types of biologic processes which yield effluent concentration
of 1.5 mg/i during the warm months are usually incapable of
consistently reducing ammonia nitrogen concentrations below
4.0 mg/i during cold weather
(Exh,
lA4;
R.
23, 45-46, 66-67,
72—73,
120—123, 240—241;
Exh.
3 1—13).
As mentioned above,
there are physicaHchemical processes
for nitrogen removal;
the three candidate physical—chemical
processes suggested are ammonia stripping,
selective ion ex-
change and breakpoint chlorination.
Conceptually at least,
these processes are initially attractive because they remove
the ammonia directly, are not subject to the biologic upset
and operational uncertainty of the biologic-treatment processes
and require less tankage and hence
less space than biologic
processes
(Ext.
1H,
1).
Ammonia stripping and selective ion exchange are not
suitable or cost—effective processes for ammonia removal
in
Illinois.
Ammonia stripping is more sensitive to cold tempera-
tures than the biologic-treatment processes.
Both ammonia
stripping and ion exchange are energy intensive, both require
sophisticated automated process control
for effective operation;
neither process has been demonstrated over a range of treatment
applications, and there is a question whether or not either could
consistently meet a 1.5 mg/l standard without a polishing opera-
tion following the process
(Exh~ lA,
5-6;
Exh.
lH,
21; Exh,
7,
32;
R.
26,
104).
BREAKPOINT
CHLORINATION
The breakpoint chlorination process
for removal of ammonia
nitrogen from water, very generally stated, proceeds
as
follows:
As chlorine,
as chlorine gas
(Cl2) or as sodium hypochlorite
(NaOCl),
is added to water, hypochlorous acid
(Hod)
and
hypochlorite ion
(OCI
)
are formed~
If the water contains
ammonia nitrogen, as
is the case with domestic wastewater,
the
ammonia reacts with the hypochiorous acid to form monochloramine
(NH2C1), dichloramine
(NHC12)
and nitrogen trichloride or
trichioramine (NCl3)~depending upon the amount of chlorine
added and pH, with the monochloramine the most usual formation
in domestic wastewater treatment.
As additional chlorine
is
added,
the chloramines are converted to nitrogen gas; maximum
30~588
—
-a-
conversion
is achieved,
and ammonia removed, when the total
chlorine residual is at minimum, or breakpoint;
hence
the
process
name, breakpoint chlorination.
The term total
residual chlorine is used to describe the sum
of
free
chlorine
(chlorine,
hypochlorous acid and hypochlorite ions)
and
com-
bined residual chlorine
(chioramines)
in water.
Chloramines
are believed to be slightly less toxic to fish than free
chlorine, however, the difference
is apparently
slight
and
water quality criteria,
such as the U.S.
Environmental Pro-
tection
Agency’s Quality Criteria for Water, EPA-440/9-76-023,
(the “Red Book”),
suggest a water quality criterion
of
10.0
micrograms per liter for total residual chlorine.
The Illinois
State Water Survey Report ISWS-77~RI85, Roseboom
& Richey, p19,
concluded that for the protection of the fish investigated
(bluegill,
largemouth bass,
channel catfish)
residual
chlorine
should not be detectable in Illinois streams;
the permissible
concentration for residual chlorine for the protection
of
channel catfish determined by them was about
9 micrograms per
liter which closely corresponds to the Red Book
criterion.
A simpLified description of the breakpoint chlorination
process,
together with some functional disadvantages of the
process were introduced into the record by the Agency in
Group Exhibit 1
(Exh.
1,
4-6):
1.
Chlorine,
either in the form of chlorine gas
or sodium hypochlorite,
is introduced into
and thoroughly mixed with ammonia
containing
wastewater.
2.
The chlorine reacts with the ammonia and
pro-
duces, under different dosages and pH
con-
ditions,
the end products of monochloramine,
dichloramine, nitrogen trichlor±de,hydro-
chloric acid, and free nitrogen.
3.
The acid produced by these reactions
reacts
with the carbonate alkalinity normally
present
in domestic wastewater and
is neutralized.
4.
Because chloramines are toxic to aquatic life,
and because nitrogen trichloride produces un-
pleasant odors, it is necessary to dose with
chlorine at fairly high rates
in order to
cause the ammonia to be converted completely
to nitrogen gas.
5,
It is necessary to carefully control the
dosage
rate and the pH
of
the wastewater in order
to
cause the reaction to go to completion.
30-589
—12—
6.
Since it is necessary to overdose with chlorine
in excess of the stoichiometric ratio to drive
the chemical reaction,
a substantial chlorine
residual exists after breakpoint chlorination.
This residual is high enough to be toxic to
aquatic life.
7.
Dechlorination is most practically accomplished
by sulfur dioxide feeding in a suitable reactor,
but it has the disadvantage of producing sul-
furic acid, usually requiring pH correction by
feeding in a base to neutralize the acid.
8.
The functional disadvantages of the breakpoint
chlorination/dechlorination process are as
follows:
a)
The process requires the use of
sophisticated automated chemical
feed
equipment
to
assure
reasonable
control.
b)
Failure of
any
part of this system
may cause the production of chemical
byproducts which are more toxic than
the initial
‘ammonia
concentrations.
c)
The process must be manned and monitored
on a 24-hour a day basis in order to
assure day-in day—out process reliability.
d)
The process is inherently energy intensive.
In amplification of the disadvantages summarized it paragraph
8
above,
the
Agency
concluded
that
control
of
the
breakpoint
chlorination
process
for
ammonia
reduction
is
not
operationally
feasible at most of the 1479 treatment plants in categories 1
and 2 as described on page 8 above.
In support of this conclu-
sion, the Agency cited the following:
a)
natural fluctuations of diurnal flow and
of
the
chlorine
demand
make
it
necessary
to install intricate automated flow
measurement devices with automated re-
sponsive
chlorine
feed
controls
to
corn—
pensate
for
pH,
chlorine
residual and
ammonia
concentrations;
b)
lack
of
demonstrated
reliability
for
such
automated
equipment
under
field
conditions
is
expected
to
be
a
major
problem,
including
downtime
and
cdsts;
30-590
—13—
c)
the toxicity of residual chlorine
from
the
process
requires
installation of
automated sulfur dioxide feed equipment
to
assure
adequate
dechlorination;
d)
the
dechlorination
process
requires precise
automated
monitoring
to prevent
the
occurrence
of conditions toxic to fish from excess sul-
fur dioxide;
and,
e)
maintenance
and
operation
of
equipment for
ammonia
nitrogen
reduction
by
breakpoint
chlorination
(and
subsequent
dechlorination)
is
beyond
the
capability
of currently available
çlant
operating
personnel
because of the pre-
ponderance of small, low-operating budget faci-
lities
typified
by
plants
having
a capacity of
less
than 0.25
million
gallons
per day which
comprise
more
than
90
of the total treatment
facilities in the State
(Exh,
lA,
12;
R.
25—31,
85—91,
96—98).
Other potential disadvantages of the breakpoint chlorination
process revealed by the record are the substantial increase in
total dissolved solids which is inherent in the process;
the
potentially very hazardous halbgenated organic compounds
(organochiorarnines)
which can be formed during the process;
and the depression of dissolved oxygen in the wastewater
as
a
result of dechlorination using sulfur dioxide
(Exh.
lA,
7;
Exh.
lE,
ito; Exh.
IF,
2—5;
10—13;
44—49; Exh.
IH,
17—21).
The Agency presented,
in Exhibits IA and lB, estimates of
the capital expenditures and operation and maintenance costs
which would result from the use of breakpoint chlorination
as
a backup process
to biologic ammonia removal.
These costs were
estimated utilizing the USEPA publication,
“A Guide
to the
Selection of Cost-Effective Wastewater Treatment Systems,” July
1975,
for
the
479
installations
In
TTU
nois
(oxcludincj
MSDGC
and
industrial)
requiring
ammonia
nitrogen reduction.
Capital
costs
to
provIde
the
backup
breakpoint chlorination for the 1479
installations
were
estimated
by
the
Agency
to
total $185.6 million,
The
Agency
estimate
of
annual
operation
and maintenance
costs
(excluding
capital
amortization)
of the backup processes
is
approximately
$8.8
million,
exclusive
of
MSDGC
and
industrial
plants,
which
they
estimate
would
result in unit costs ranging
from
$1.40
per
connection
per
month
for a plant of 600 P.E,
(200
connections)
to
$1.18
per connection per month for a 10,000 P.E.
plant
(3333
connections).
3O—59~
—14—
The breakdown of the costs estimated by discharger category
taken from Exhibits
IA,
8 and lA,
10 are as follows:
CAPITAL COST OF BREAKPOINT CHLORINATION
FOR BACKUP AMMONIA NITROGEN REMOVAL
Plant Design
P
.
E.
Unit Plant
Capital Costs
$1000’
s
Category
#1
-
No.
Plants
Municipalities
Capital
Costs
Millions
$
Less than
1000
1000—2499
2500—4999
5000—9999
10000—99999
100,000
+
60,0*
95.87
187.
35
290.97
439,59
1,561, 58
179
197
100
70
86
16
647
10.74
18.79
18.73
20. 30
37.80
24.98
$131.32
Plant Design
P,E.
Unit Plant
Capital Costs
$1000’
s
Category
#2
-
Schools
& Other
No. Plants
Capital Costs
Millions
$
797
-L
b
-7
4
0
______
Total Capital cost for Categories
#1 and #2
=
$185.6 million
*Scaled down by factor of
0.628
From Exh.
lA,
8
-
Table
2
TOTAL
—
Category #1
Less than 1000
1000—2499
2500—4999
5000—9999
10000—99999
100,000
+
60,0*
95,87
187.35
290.97
439,59
1,
561.58
To’rAL
—
Catecory #2
47.8
1.7
1.1
2.0
1.7
$54.3
832
30-592
—15--
OPERATION AND MAINTENANCE COST OF
BREAKPOINT CHLORINATION FOR AMMONIA NITROGEN
(4 months of operation per year)
REMOVAL
Plant Design
P.E.
Unit Plant
Annual 0
& M
$l000’s (~—4)
Category
#1
No. Plants
—
Municipalities
0
&
M
Costs
Millions
$
Less than 1000
1000—2499
2500—4999
5000—9999
10000—99999
100,000
+
10,17*
12.79
19.68
20.
78
47.32
323.57
179
196
100
70
86
16
.6
.83
.65
.69
1.36
1.72
TOTAL
-
Category #1
647
$5.85
Plant Design
P.E.
Unit Plant
Annual 0
& M
$l000’s (---4)
10.17*
12.79
19
.
68
20. 78
47.32
323.
57
Category #2
-
Schools
& Other
No. Plants
0
&
M
Costs
Millions
$
797
18
6
7
4
2.7
.08
.04
.07
.06
$2.95
Less than 1000
1000—2499
2500—4999
5000—9999
10000—99999
100,000
+
TOTAL
-
Category #2
832
Total
0
& M cost for Categories
#1
and
#2
=
$8.8
million
*Scaled
down
using
a
factor
of
0.628
From Exh.
lA,
10
-
Table
3
ECONOMIC IMPACT
The Illinois Institute for Environmental Quality performed
a study on the economic impact of the proposed regulation pursuant
to ~6(d) of the Act,
This study, “Economic Impact of a Proposed
Change in Ammonia Effluent Standards, R77-6,”
IIEQ Doc
No. 77/18,
was filed with the Board on June
27,
1977,
and was introduced
into
evidence as Exhibit
7
at
the
September
9,
1977,
hearing
in
Chicago.
30—593
—16—
In
addition,
Exhibit
7A,
“Points
for
Consideration,”
was
intro-
duced
at
the
September
12,
1977,
hearing
and
makes
certain
corrections
to
Exhibit
7.
(*See
Note.)
By
the
Act,
the
Economic
Technical
Advisory
Committee
reviewed
the
economic
impact
study
prior
to
the
filing
of
the
study
with
the
Board
and,
on
review,
found
the
report
to
be
generally
responsive
to
the
requirements
of
Section
6
of
the
Act.
Ms. Linda L. Huff, BS Ch.E, MBA,
the economic impact study
contractor for IIEQ study, summarized the study (8.81-98) and
concluded:
“On the basis of the economic impact and benefit
cost analysis of the proposed IEPA exception to
the existing effluent standards, adoption of
this proposal is justified.
The severe economic
impact on small commercial operations, schools,
and municipalities
with
little
gained
in
terms
of
environmental
improvement
suggests
an
exemption
for
dischargers
less
than
2500
PEis
a
cost
effective
po~.icy.
Additional
time for the compliance of
larger
facilities
removes
the
potential
loss
of
federal
and
state
funds
for
municipal
construction
and
provides
for
technological
development.
The
benefits foregone by granting this exception to
regulation are less ‘than the costs
incurred
by
society
and the dischargers.
Therefore, the
proposed
regulatory
exception
is
an
economically
acceptable
plan.
*Noth
Certain
arithmetic
errors
exist
in
Exhibit
7A,
2.
The
product listed in the first
row
should be $2,440,000 and the
product listed in the third
row
should be $712,800.
Hence the
sum
of the products should be $8,049,700.
Tables 2-2 and 5-8
of
Exhibit
7
should
be
corrected,
as
p.
1
of
Exhibit
7A
suggests,
but
corrected
using
proper
values
•
The
values
in
parentheses
in
the
“Annual
Costs”
column
of
these
tables
should
be
$26.2
for
row
1
(biological nitrification, $18.2; breakpoint chlorination,
$8.0)
and $13.9 for rows 2 and 3 (biological nitrification,
$9.3;
breakpoint chlorination, $4.6).
The above renders the cost
columns of Tables 2-3 and 5-9, “Present Value of Benefits
and
Costs” less useful; the present values have not been recomputed
since
(1), the regulation self-destructs in four years and
(2),
twenty years is
a
totally
arbitrary
time
period.
30~5911
—17—
In
fact,
it
appears
that
a
stronger
proposal
may be warranted.
Unless a water quality
standard
modification
for
intermittent
streams
is
contemplated, the smaller dischargers will
be severely impacted in 1981.
The incremental
costs associated with their compliance far
exceed the incremental gains achieved.
For
larger
treatment
plants
it
may
be
difficult
to
initiate
and
complete
treatment
facilities
within
the
time
frame
outlined by IEPA.
Cer-
tainly the exception proposed will alleviate
immediate compliance and funding problems.
Consideration of the practical logistics in
obtaining
such
significant
auxiliary
treatment
facilities
is important in the final analysis
of the economic impact.”
(S.92—93;
Exh.
7,
13)
Review of the economic impact study
(Exh.
7;
Exh,
7A),
the
economic analysis presented by the Agency
(Exh.
1A,
7—:L1; Exh.
lB,
1—8)
and the testimony in the record (S.81—206;
T.67-69)
reveals
nothing in cpntradiction to the conclusions of the economic
impact study and the economic impact study supports the cost
figures estimated by the Agency.
It should be noted that the
costs developed were for the cost of providing breakpoint chlori-
nation only
as
a backup to biological removal of ammonia.
The
cost of ammonia removal by biOlogic treatment was not compared
to the cost of ammonia removal by breakpoint chlorination either
by the economic impact study contractor or by the Agency.
Nor
is it necessary since the regulation proposed does not require
a
judgment
as
to
the
relative
economic
performance
of
either
system.
In
view
of
the
large
number
of small plants within the
lagoon
exemption
of
Rule
404(c)
and the fact that some
90
of
the
treatment
facilities
in
the state are designed to serve a
capacity
of
less
than
0.25
MGD,
there
is
little
question
that
biologic
treatment
as the primary means for ammonia nitrogen re--
moval will continue.
Dr. Thomas
E. Wilson,
who
participated
in
the EPA technology transfer program on nitrogen control and has
published
a
number
of
papers
on
nitrogen control, stated that
the state of the art for nitrogen control
is biological
nitrifi—
cation
(B.
70).
In consideration of the economic impact of the proposal,
the Board notes differences between the estimate provided by
Dr. Thomas
E. Wilson of Greeley
& Hansen
(Exh.
7, Appendix B,
83)
and the estimate provided by the Agency
(Exh.
1B,
6,
Table
4)
of the cost of breakpoint chlorination/dechlorination
as a
backup for ammonia nitrogen removal; the differences were utilized
in the economic impact study
to provide
a range of costs and the
conclusions reached are valid using either estimate of costs,,
30—595
—
1~8-’
WATER QUALITY CONSIDERATIONS
The
present
Rule
203(f)
water
quality
standard
of
1.5
rng/l
was based,
as indicated previously,
on the recommended limit of
the Green Book
(3 PCB 759).
The “Green Book,” published in 1968
by
the
Federal
Water
Pollution
Control
Administration,
U.
S.
Department
of the Interior,
has been superceded by the “Red Book”
published by the U.
S.
Environmental
Protection
Agency
and
titled
Quality Criteria for Water.
The water quality criterion for
ammonia
set
forth
on
page
16 of the Red Book
is 0.02 mg/i
(as
un—ionized
ammonia) for freshwater aquatic
life.
The Red Book
(at
page
21)
concludes
that:
“Levels of un—ionized ammonia
in the range of
0.20
to
2 mg/l have been shown to be toxic
to
some
species
of
freshwater
aquatic
life.
To
provide
safety for those life forms not examined,
1/10th
of
the
lower
value
of
this
toxic
effect
range
results
in
a
criterion
of
0.020
mg/i
of
un-ionized ammonia.
This criterion is slightly
lower than that recommended for European inland
fisheries
(El FAC,
1970)
for temperatures above
5°Cand pH values below 8.5.
Measurement of
values
of
total
ammonia
for
calculation
of
values
in
the
range
of
0.020
mg/i
NH3
is
well
within
current
analytical
capability.”
The
philosophy
of
the
Red
Book
is
that
the
criteria
presented
therein, appropriately modified
to
take
account
of
local
conditions,
form a basis for judgment in establishing water quality standards.
The local conditions
to be considered include actual and projected
uses of the water, natural background levels of particular con-
stituents,
the presence or absence of sensitive important species,
characteristics of the local biological community,
temperature and
weather,
flow characteristics,
and synergistic or antagonistic
effects
of
combination
of
pollutants
(Exh.
8,
7).
The
Consulting
Engineers
Council
of
Illinois,
through
the
testimony
and
exhibits
presented
by
Mr.
M.D.R.
Riddeil
and
Dr.
T.E.
Wilson, both of Greeley
& hansen,
urged the
adoption
of
a
variable
concentration
ammonia
water
quality
standard
such
as
recommended
for
European
inland
fisheries
which
is
discussed
in
the
Red
Book
and
which
the
Consulting Engineers Council of Illinois had urged
in
1973
in
R73-3
and
73-4
and
which
CEC/I
had submitted
to the
Board
in
November,
1972
(R.
77;
Exh.
3,
3,
10—15,
20,
22—26).
There is wide-spread agreement that the dissolved un—ionized
ammonia
(NH3)
is the toxic constituent in aqueous solutions of
ammonia and that the percentage of NH3 increases with increasing
temperature and alkalinity.
Estimates of the percentage or con-
centration of NH3 and NH4~can be computed if pH and temperature
are known.
Some calculated percentages of un—ionized ammonia in
an aqueous ammonia solution of zero salinity against varying pH
value and temperature
is presented in the following tabulation:
30—596
(1)
Percent Un-ionized Ammonia
(NH3)
in
Aqueous
A~onia
Solutions
Temperature
__________
_________
pH
________
____
______
Degrees
Centigrade
6.5
7.0
7.5
8.0
8,5
9.0
20
0.13
0. 40
1. 2
3.8
11.
28.
25
0,18
0. 57
1.
8
5.4
15.
36.
30
0.25
0. 80
2.
5
7.5
20.
45.
(1)
From:
Emerson,
Russo,
Lund
&
Thurston
“Aqueous
Ammonia
Equilibrium
Calculations,
Effect
of
pH
and
Temperature,”
J.
Fish.
Res.
Board Can.
32
(12)
2379—2383
(1975).
(Exh.
lE,
8
-
Bibliography Reference
24)
The IlLinois State Water Survey Report ISWS-77-R185, Rose-
boom and Rich~y,p30,
concluded,
after applying
a factor of 1/10
to
the
96-hour
TL
50
observed
in
their
study,
that bluegill,
largernouth bass and channel catfish would be protected in Illinois
streams when NH3
(un—ionized ammonia) does not exceed 0.04 mg/i.
Their tabulation of concentrations
of total ammonia which
will produce 0.04 mg/i of NH3 at various pH and temperature
values
is
as
follows:
_____________
_________
pH
_________
________
____
TEMP.
(°C)
6.5
7.0
7.5
8.0
8.5
9.0
mg/i
mg/l
mg/i
~g/1
~i~7F
T~7TY~
5
127.4
36.0
11.4
3.60
1.18
0,40
10
76.3
24.1
7.66
2.45
0.80
0.28
15
52.08
16.5
5.24
1.69
0.56
0,20
20
35.7
11.3
3.60
1.17
0.40
0,15
25
25.0
7.95
2.55
0.83
0.29
0.12
30
17.62
5.60
1.80
0.60
0.22
0.10
From Roseboom
& Richey
-
Table
11
In
Exhibit
iC,
the Agency presented data concerning water
quality ammonia violations for samples exceeding 1.5 mg/i for
years
1973 through 1976 and detailed reported fish kills caused
by ammonia in 1976, none of which resulted from treatment plant
discharges.
Dr. David
J.
Schaeffer,
Science Advisor to the
Manager, Division of Water Pollution Control,
IEPA,
testified
30—597
—20—
concerning the
significance
of
the
number
of
stations
exceeding
1.5 mg/i.
He stated that the exhibit indicated that about 10
percent of the stations
(about
55) exceed the 1.5 mg/i standard
monthly;
that the number of stations which violate the standard
is
small;
that a small fraction of the total data collected shows
water quality violations;
and that the percentage of violation
over
the
standard
is
relatively
small
(R.
163)
.
Mr.
Park
testified
that while these discharges may have localized impacts,
their
impact
on
water
quality
in
general
will
be small
(R.
61).
Mr.
Leonard
C.
Crawford,
of
Crawford,
Murphy
&
Tilly,
Inc.,
Consulting
Engineers,
who
has
practiced
as
a
professional
consulting
engineer
for
about
35
years,
gave
testimony concerning the localized impact
of
the discharge of ammonia nitrogen
(T,
47-49).
The Agency stated
that the experienced frequency of ammonia nitrogen water quality
violations will
be
steadily
decreased
as the over 200 treatment
plant projects
currently
under
construction
are
completed
and
placed
in operation
(Exh.
lA,
13—14).
Exhibit 1-I is Chapter
3
(p46-62) excerpted from a report of
May,
1976,
entitled
“A
Critical
Evaluation
of
Current
Performance
of Some Activated Sludge and Lagoon Systems
in
Illinois”
by
l3harat Mathur,
P.E.
and Carol Houston, both of the Division of
Water Pollution Control,
Illinois Environmental Protection Agency.
Table 11 of Exhibit
1-I,
is a summary of ammonia nitrogen in lagoon
effluents
in Illinois,
as
follows:
AMMONIA NITROGEN IN LAGOON EFFLUENTS*
Average
NH 3-N
Concentration in mg/i
Three Cell Waste Stabilization Ponds
2.3
Three Cell Aerated Lagoons
2.1
Three Cell Waste Stabilization Ponds Performance by Month
January
6.3
(27)**
February
3.1
(28)
March
3.6
(21)
April
2.4
(29)
May
1.7
(33)
June
1.43
(21)
July
0.38
(24)
August
0.76
(18)
September
1.4
(29)
October
2.3
(36)
November
2.3
(24)
December
2.1
(26)
30-598
—21—
AMMONIA
NITROGEN
IN
LAGOON
EFFLUENTS*
(continued)
Average NH3—N
Concentration in mg/i
Three
Cell
Waste Stabilization Ponds
Plants
North
of
fl~qhwav
~16
2,6
(14)
Plants
Between
iTS
and
Ui
.50
1.4
(96)
Plants
South
of
ii
50
2.8
(216)
*(Exh,
~
50)
**Va’ue5
(
)
indicate
number
o:T
sour?
Based
upon
this
report,
it
can
be
concluded
that
existing
three
cell
u~ste
stabilization
c~’-ids and
aerated
lagoons
should
not
violate
a
1.5 mg/i limitation June
through
September.
During
other
times
of the
year,
the
amount cf flow in the receiving
streams
will control
compliance rith the 1,5 mg1’I
limitation
October
through
May.
The effect
of discharges
from three cell
natural
and
aerated waste stabilization ponds
on
water
auaiity
during
the
winter months
is expected to he minimal considering
the
data
concerning
the
decreasing
toxicity
of
ammonia
as
tempera-
ture
fails
(Exh.
1—1,
49—51;
1A,
10).
Exhibit
l-D
presented
by
the
Agency
is
a
summary
of
informa-
tion
relativi
to
existing
regulations
in
several
other
states
re-
garding ammonIa
nitrogen
standards
and.
practices;
Mr.
Park
testified
that
of
the
six
states
surveyed,
only
Pennsylvania
(1.5
mg/l
summer,
4.5 mg/i winter)
and Wisconsin
(controlled discharge) had standards
for intermittent streams
(R. 130—133).
UO
(21JAN05
IN
WATER QUAL is:
v
SPiN
)A1t
The
Agency
has
not proposed that
tie
existing
ammonaa
nitrogen
water
quality
standard be changed at
this
time.
Mr. Park testified
(R.
9,
21-22,
35)
that
the
Agency
will
propose
an
appropriate
un—ionized ammonia water quality standard as soon
as
valid toxicity
data
for
Illinois
waters
can
he
developed
to
support
a
revision
to
the
current
standard.
The
Illinois
State Water
Survey
and
the
Illinois
Natural
History
Survey
are
both
doin
bioassay
work
on
ammonia
toxicity to identify water quality needs specifically
for
aquatic
species
present
in
Illinois
waters,
The
Agency,
in
con-
junction
with their work,
is attempting to
tailor
water
quality
requirements
more
closely to the existing and anticipated uses of
given
water
segments
(R.
13—14).
30-599
—22—
SUPPORT FOR
THE
PROPOSED
CHANGE
In
the
hearing
of
May 10,
1977,
Mr.
0.
W. Henderson,
Superintendent
of
the
Galesburg Sanitary District, presented
a
statement
prepared
by
the
Board
of Trustees and signed by
their
President
requesting a change of regulations.
Mr.
Henderson
testified
that
the
ammonia
levels
in
the
effluent
from
their
treatment
works vary from
above
I
mg/I in warm
weather
to
as
high
as
5
or
6
during
December,
January
and
February
when
temperatures
ranged
between
zero
to
20 degrees
below
(F.
45Y~
He
further
testified
that
since the effluent
maintains
the
flow
in
the receiving
stream,
the effluent must
meet
the
ammonia
nitrogen
water
quality
standard
CR.
43)
and
that
the
cost
of
meeting
the
standard
had
been estimated
at
$4.75
million
CR.
38).
The Consulting Engineers Council
of
Illinois,
through
the
testimony
of
Mr.
Riddeli
and
Dr.
Wilson
and
in a statement entered
into
the
record
as Exhibit
3,
concurred
the
Agency
exemption
of
small sources and require the minimum use of breakpoint chlorina-
tion but stated that the proposal fell short of adequacy in that
it
did
not
include
an un—ionized
ammonia
water
quality
standard
(Exh.
3,
4—5)
A
letter
of
agreement
with
the
proposed regulation,
dated
May
6,
1977,
and
signed
by
Bart
T.
Lynam, General Superintendent
of
the
Metropolitan
Sanitary District of Greater Chicago was
placed
into
the
record as Exhibit
6.
Mr.
Allen
Panek,
Superintendent
of
the
Water Supply and
Reclamation
Division
of the City of
Napervilie,
testified
in
support
of
the
proposal and stated
that
they
were achieving an
effluent
concentration
of 1.5
mg/i
during summer months but
that
the
wintertime
limitation of 4.0 mg/i might not be realistic
based
on
their
experience
(R.
110-114).
Mr.
L.
K.
Crawford,
of Crawford, Murphy
& Tilly,
Inc.,
Springfield,
testified
in behalf
of
the
proposed
requlation
and
recommended
in
addition
that
the
Board delete ammonia nitrogen
concentrations
requirements
for
discharges
to
intermittent
streams
or
ditches
until
there
was
a
showing
that
ammonia
nitrogen
re-
duction
was
necessary
to
protect
the
streams
or
aquatic
life
and
that
technology
was
available
to
safely
provide
the
reduction
necessary.
Mr.
Crawford
expressed
concern
that by adhering to
current
requirements
or
even
the
proposed
rule
change
that
a
number
of
~white,e1ephantsu
could
be constructed which are not
required
from
an
environmental
standpoint
CT.
44-65).
Mr.
A.
Paul
Troemper, Executive Director of the Springfield
Sanitary
District,
concurred
in
full with the conclusions presented
by
Mr.
Crawford
in
a letter dated September 20,
1977,
in which
he
stated
that
no
distress situation had been noted
in fish below
30-600
—23—
their Sugar
Creek
Plant even though the 1.5 mg/i standard had
been exceeded during periods of extreme low flow.
An earlier
letter dated June
1,
1977,
from Mr. Troemper included weekly
readings of ammonia nitrogen from January, 1975,
through May,
1977,
taken
in Sugar
Creek
downstream
of
the treatment plant
noting that
no
adverse
affect had been noted on the fish life
in
the
stream.
He
further
stated
that in his opinion chlorine
carryover in the effluent
had adversely affected fish life.
Mr. John Treuthart, District Engineer of the DeKaib Sanitary
District, submitted a
letter
dated
May
23,
1977,
requesting
favorable consideration of
the
proposal.
Mr.
Treuthart
stated
that the rotating biological contactors being installed in
their upgraded facilities would provide ammonia nitrogen removal
to 1.5 mg/i except during the coldest months and that the
effluent
discharged
during
the
winter
would
have
no
detrimental
effect.
Letters
in
support
of
the
proposed
regulation
were
also
received
from
the
Illinois
Association
of
Sanitary
Districts
on
May
17,
19,77,
and
the
Southwestern
Illinois
Metropolitan
and
Regional
Planning
Commission
on
June
9,
1977.
There
was
no
testimony
or
comment
submitted
in
opposition
to
the
proposed
rule
except the testimony noted above which
suggested
that the Agency
proposal
does not go far enough.
FINDINGS AND CONCLUSIONS
The
Board
has
reviewed the record in this proceeding and
finds
that
the
procedural
requirements
of
the
statute and
regulations
regarding
the
adoption
of
regulations
have
been
fulfilled.
The
proposal
was originally submitted as a variance petition
by
the
Agency
which
the
Board
construed
as
a
regulatory
proposal
believing that such a variance
petition
by
the Agency was beyond
the
contemplation
of
the
Act.
The
Board
finds
merit in the re-
quest
for
an
interim
exception
for
the
existing
small
sources,
not otherwise requiring
upgrading,
pending the gathering of
appropriate bioassay data
to
either
verify
the
existing
standard
established by Rule 203(f)
or to establish a more appropriate
one.
It
does
not
appear
from
the
record
that
existing
water
quality
will
be
degraded
during
the
period of the proposed ex-
ception
to
Rule
402
because
they
will
be
required
by
permit
to
provide
ammonia
reduction consistent with their existing works
and process.
It
appears
most
likely
that
water
quality
will
show
constant improvement as
new
and
upgraded
treatment
plants
begin
operation
during
the
period
and
the
effluent
limitations
proposed
by
402.1(b),
where none now exist, are implemented.
The Board is
persuaded
that
the
use
of
breakpoint
chlorination
as
a
backup
to
30-60~
—24—
biological
processes
may
well
cause
a
more significant problem
in
the
aquatic
environment
than
the
remaining
fraction
of
the
ammonia
nitrogen
removed
by
the
breakpoint
chlorination,
at
least
to
the extent
that
wide-spread
implementation
of
break-
point chlorination be deferred pending a thorough investigation
into the necessity
for the use of such a process.
The
language
of
the Agency proposal has been slightly
modified in
an
attempt
to
insure
clarity.
Rule
402.1(a)
ex-
cepts the small sources
if
they:
(I)
have
an
ammonia nitrogen infiuent loading
of
less
than
60
pounds
per
day;
and
(2)
were
in
existence on
April
1,
1977;
and
(3)
do
not
require upgrading to meet any
other
requirement
of Chapter
III.
If
a
source
does not meet each one of these three criteria,
it
must
comply
with
the requirement of 402.1(b) and
(c) which
provide
that
such
source
meet an effluent discharge limitation
of
4.0
mg/I
November
through
March
beginning March
31,
1979,
or
as
otherwise
required
by permit condition or order of
the Board
in
a
variance
or
enforcement
proceeding.
The
compliance
date
is
established to allow for facilities now planned or under con-
struction to he completed and to achieve compliance in accordance
with the realities of the biological processes employed.
The
provision for other dates
will
allow for earlier dates of com-
pliance because facilities
are already under construction or
operational or because unusual circumstance, such as grant pro-
gram delays,
dictate later compliance.
The termination date
for Rule
402,1
is
established as July
1, 1982, which the Board
believes
is
the
practical minimum in which to collect the detailed
data
to support any
necessary regulatory change
and to allow for
proper
hearing
and
consideration by the Board.
FINAL_ORDER
Proposed
Rule
402.1
Exceptions
to
Rule
402
(Ammonia
Nitrogen)
a)
Rule
402
shall
not
apply
to that portion of
Rule
203(f)
pertaining to ammonia nitrogen for any
effluent
from a source in existence on April 1,
1977,
having
an untreated ammonia influent
loadin
not
exceeding
60
pounds
per
day
and
not otherwise
needing
upgrading to meet the
requirements
of
this
Chapter.
30-602
b)
Rule
402
shall
rot
arpl~
o
chat
port~on
of
Rule
203(f)
pertaininu
to
ai~ccia
nitrogen
for
any
source during
the
month~’ o~ Novemoer
through
March;
except
that
duria~
she
months
of
November
through
March
no
sour~o.
~t
exempt
ardor
432.1(a),
shall discharge an efli n-
S con:alning a concentra-
tion of ammonia nitroge~ a ea~u than 4.0 mg/I
if
the
discharge,
alone
or
~r
cony
natic~
with
other
discharges
causes
or
r
:ib1~
yy
to
a
~Tiolation
of
that
portion
of
Rule
~)
pe~aining
to
ammo~a
nitrogen.
c)
Compliance
with
the
mm
sicns
~
tub
402.1(b)
shall be
achieved
by
~
31
9~9,
or
such
other
date as require~
~°‘DLE
permit,
or
as
ordered by
the
Board
u
Sitle
VIII
or
TItle
IX
of
the
Environmentai
Prcte
if~~ Act.
d)
After
July
1,
1982,
the
exemptl’~ns
prourded
in
this
Rule
402.1 shall
tar
u~nate.
I, Christan L.
Moffett,
ClerK
of
tth
Illinois
Pollutjon
Control Board,
herebyA certify
the
aocve
Cpinion
and
Other
ucra
adopted on
the
~
day
of
~
,
979
by
a
vote ~
Board
30-603
