ILLINOIS POLLUTION CONTROL BOARD
    April
    8,
    1976
    CITY OF RED BUD,
    Petitioner,
    PCB 75—458
    ENVIRONMENTAL PROTECTION AGENCY,
    Respondent.
    OPINION AND ORDER OF THE BOARD
    (by Mr. Young):
    This matter comes before the Board on the amended
    variance petition filed January
    22,
    1976 by the City of
    Red Bud seeking relief
    from the chlorination and the
    finished water quality requirements as
    established
    by
    the
    Board in Rules
    305
    and 304(b)
    of Chapter
    6:
    Public Water
    Supplies,
    and from Section 18 of the Act.
    An Agency Recom-
    mendation was filed with the Board on March
    12,
    1976.
    The City of Red Bud, with
    a population of 2900 people,
    owns
    and operates a public water system which presently
    consists of ten wells,
    two elevated storage tanks, and
    a
    distribution system.
    The only treatment currently being
    provided the water
    is fluoridation.
    Seven of the wells are
    active;
    one
    is
    retired;
    and two
    (wells
    #9 and #10) have not
    yet been put into service.
    Because of the future needs
    of Red Bud, Petitioner now plans
    to abandon the present well
    system after constructing new wells on the Kaskaskia River
    and transmitting the finished water some five miles
    to the
    City.
    Petitioner estimates that the new
    system
    will not be
    operational until September 30, 1978.
    Petitioner was made aware of the inadequacy of the
    existing water supply sources
    to supply future requirements
    in December of 1972
    when the Southwestern Illinois Metro-
    politan Area Planning Commission released its reports de-
    tailing improvements that Red Bud and other municipalities
    in the area
    should make
    in
    order to meet future population
    needs.
    In addition to this report,
    the Illinois State Water
    Survey released studies which emphasized that this particular
    area of the State was subject to limited water resources.
    The City of Red Bud funded several studies directed toward lo-
    cating adequate future water sources,
    the last one being com-
    pleted
    in December of
    1975.
    After careful consideration of
    these studies and reports, Petitioner has decided to construct
    21—91

    —2—
    a well system on the Kaskaskia River.
    The City’s consultant
    estimates that it will cost $1,700,000 for this system,
    which includes
    a one million gallon per day treatment plant
    and pumping facility, two wells,
    five miles of transmission
    line,
    and an elevated storage facility.
    In order to presently meet the chlorination requirements
    of Rule 305, Petitioner alleges that it would be necessary
    to treat each of its existing wells separately at a capital
    cost per well of $1,500.00.
    Chlorination is not the sole
    problem however.
    Petitioner notes that water from its existing
    wells has measured iron content of 0.6
    to 1.2 mg/i and a manganese
    content up to
    .04 mg/i.
    After January
    1,
    1978 the City is also
    required by Rule 304(b)
    to limit iron concentration to a maxi-
    mum of 0.3 mg/i and manganese concentration to
    a 0.05 mg/i.
    It appears Petitioner would have to provide filtration equip-
    ment at each well in order
    to meet the standards for iron and
    possibly manganese.
    While the iron standards do not have to
    be met until January
    1,
    1978,
    the high iron concentration would
    present a problem if chlorination were undertaken at this time.
    The Petitioner~sconsultant states there
    is a strong possibility
    that the oxidation of the iron in the water may cause serious
    operational and esthetic problems.
    To meet the chlorination
    requirements the Petitioner would be forced to provide for iron
    removal as well.
    Although Petitioner makes no estimate of
    the cost of installing iron and manganese removal equipment,
    the Agency estimates the cost for installing iron removal equip-
    ment would be at least $200,000.00, even
    if
    the
    treatment were
    concentrated at one central point.
    Since
    the present wells
    will not be part of the planned new system, Petitioner claims
    that it will suffer an unreasonable hardship if it is required
    to make these substantial short—term investments to achieve
    compliance.
    The Agency recommends the grant of
    this variance subject
    to several conditions.
    Agency records indicate that well #9
    has had a pattern of bad samples ever since it was drilled.
    While
    the Petitioner has not placed this well on line because
    of the failure to obtain good samples, in addition to the fact
    that the well has been pumping sand;
    the Agency, nonetheless
    recommends that good samples on two consecutive days should be
    required prior to placing the well on line.
    If the well is
    placed on line, bacteriological samples
    should be submitted
    to the Agency for the next six months.
    If any of these samples
    indicate contamination continues to exist in the well, Peti-
    tioner must either take the well off line or provide continuous
    chlorination so long as the well is in line.
    The Agency also recommends that the absence of continuous
    chlorination at the supply for the time period requested makes
    necessary the adoption of an active cross—connection program
    to further assure that contaminants will not inadvertently enter
    into the system.
    21 —92

    —3—
    The various studies and reports that were done recom-
    mended alternative methods
    of updating the water facilities.
    Some of the alternatives considered
    in depth by Petitioner
    were as follows.
    One plan Petitioner considered was the
    purchase of 275 acres of land to be used for the construction
    of reservoirs,
    including solicitation of the existing land-
    owners.
    Another plan involved the purchase of water from
    the Sunixnerfield-Lebanon-Mascoutah water system which was
    discarded when it was determined that although a connection
    with the
    (SLM)
    system would be a quick and easy solution
    to the problem, the water supplied by this means would also
    be the most costly.
    A third plan involved the construction
    of the well system on the Kaskaskia River.
    Other alterna-
    tives were also considered and the final study was completed
    in December of 1975.
    Faced with this important and expensive
    decision, Petitioner thoroughly investigated each alternative
    before choosing the Kaskaskia River well system as the long-
    term solution to its problems.
    Petitioner estimates that
    this system will be completed
    in
    September 1978 and is ex-
    pected
    to serve the community for the next forty to fifty
    years
    at an estimated capital cost of $1,700,000.00.
    In
    consideration of these factors, we find that Petitioner
    has established
    a legitimate and adequate reason for its
    delay.
    Any compliance program chosen by the City naturally
    depended upon
    which
    particular water supply system was
    finally chosen,
    and it would have been irresponsible for
    the Petitioner to proceed in any other fashion.
    The Board
    finds
    the Petitioner has established
    a hardship sufficient
    for a grant of this variance.
    While samples reveal that the iron concentration exceeds
    the standards
    as established by Rule
    304 (b),
    the same
    is not
    true for manganese.
    For this reason it will not be necessary
    to grant a variance from Rule 304(b)
    as it concerns manganese.
    The Board agrees with the Agency that it will not be necessary
    to
    grant
    a
    variance
    from
    the general requirements of Section
    18
    of
    the
    Act
    which
    requires
    that
    owners
    and
    operators
    of
    public
    water
    supplies
    provide
    water
    which
    is
    “assuredly
    safe
    in quality and adequate in quantity.”
    A
    variance
    from
    the
    provisions of Rules
    304(b)
    and 305 is sufficient
    to meet
    Petitioner
    s needs.
    This Opinion constitutes the Board’s findings of fact and
    conclusions of law in this matter.
    ORDER
    1.
    Petitioner, City of Red Bud,
    is granted variance from
    the chlorination requirements of Rule
    305 of Chapter
    6:
    Public
    21—93

    —4—
    Water supplies from December
    21,
    1975 until September
    30,
    1978.
    2.
    Petitioner, City of Red Bud,
    is granted variance
    from the finished water quality standard for iron set by
    Rule 304(b) of Chapter
    6 from January
    1,
    1978 until Septem-
    ber
    30,
    1978.
    3.
    Petitioner, City of Red Bud, shall follow the water
    sampling program for well
    #9
    as detailed in this Opinion.
    4.
    Petitioner,
    City of Red Bud, shall adopt
    a cross—
    connection control program and submit such program to the
    Agency for approval within sixty days of the date of this
    Order.
    5.
    Petitioner, City of Red Bud,
    shall file
    a satis-
    factory project completion schedule with the Agency within 35
    days of this Order and thereafter file bi-monthly progress
    reports with the Agency until completion of the
    facilities.
    6.
    Petitioner, City of Red Bud,
    shall complete and send
    within 35 days of the date of this Order the following certi-
    fication to the following address:
    Environmental Protection Agency
    Division of Public Water Supplies
    2200 Churchill Road
    Springfield, Illinois
    62706
    I,
    (We),
    having read
    the Order of the Illinois Pollution Control Board
    in
    PCB 75-458, understand and accept said Order, realizing
    that such acceptance renders all terms and conditions
    thereto binding and enforceable.
    SIGNED
    TITLE
    DATE
    7.
    Those portions of the petition seeking variance from
    Section
    18 of the Act and Rule 304 (b)
    as it concerns manganese
    are dismissed.
    IT IS SO ORDERED.
    21—94

    —5—
    I, Christan L. Moffett, Clerk of the Illinois Pollution
    Order were
    adopted on the
    ~
    ~
    day of ________________________
    Control Board, he9by certify the a~~~~pinion
    and
    ,
    1976
    by a vote of
    ~
    Christan
    L.
    Illinois Pollution ~a~oi
    Board
    21—95

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