ILLINOIS POLLUTION CONTROL BOARD
June 14, 1973
)
GALESBURG SANITARY DISTRICT
)
)
)
v.
)
PCB73—86
)
)
ENVIRONMENTAL PROTECTION AGENCY
)
)
)
OPINION AND ORDER OF THE BOARD (by Mr. Dumelie)
Petitioner requests a variance from all applicable stream
and effluent standards of the Water Pollution Regulations of
Illinois for a one-year period, to be extended until July 1, 1977.
Implicit in the petition is a request to be exempted from the
Permit and Project Completion Schedule filing requirements of
Rules 921(d) and 1002. Hearing was held on May 2, 1973.
Petitioner owns, operates, and controls a sewage treatment
plant and sewage transport system serving the entire City
of
Gales-
burg and certain surrounding unincorporated areas. The majority
of
the area within the District is served by separate storm and
sanitary sewage systems, though combined sewers still serve certain
areas, The treatment plant provides secondary treatment by means
of the trickling filter process. Chlorinated plant effluent is
discharged to Cedar Fork Creek, which affords a dilution ratio
of less than one to one.
Grab samples of the plant effluent taken by the Agency
during 1972 show BOD at 34, 23, 16, 15, 11 and 10 mg/i; suspended
solids at 14, 10, 23, 1, 6,
and
12 mg/i and ammonia nitrogen at
7.2,
2.5, 2.0, 1.0 and 5.8 mg/I. The District monthly operational
reports for 1972 show BOD ranging between 5 and 29 mg/i and suspended
solids between 12 and 29 mg/i.
The Agency believes that the plant
is well operated and that the effluent has
little or
no adverse
effect on Cedar Fork Creek.
Since Cedar Fork Creek provides a dilution ratio of less than
one to one, Petitioner must comply with the BOD standard of 4 mg/i
and the suspended solids standard of S mg/i by December 31, 1973.
Petitioner anticipates that adequate BOD and suspended solids removal
will be accomplished in conjunction with the process of ammonia re-
moval. The District contends that reduction in effluent ammonia
8— 279.
-2-
concentrations and compliance with the Rule 203(f) standard of 1.5
mg/i will be possible upon construction of proposed upgraded treat-
ment facilities. Ammonia reduction is said to be possible by
supplementing the trickling filter process with an activated sludge
unit (for nitrification) followed by multimedia filtration and break
point chlorination. The District further maintains that a pilot
plant study is an essential prerequisite to insure the proper
physical and economic design of an ammonia removal process. Design
and operation of the proposed pilot plant would require a one-year
period.
In 1967 Petitioner began to expand and upgrade its treatment
plant. The plant was designed to treat to a standard of about
7 mg/i of BOD. During construction the Sanitary Water Board Rules
and Regulations (hereinafter SWB) became effective. Pursuant to
SWB-14, Petitioner was required to meet a standard of 4 mg/i of BOD
and 5mg/i of suspended solids. Late in 1971, the Agency conducted
a sampling program. Samples indicated that the 4/5 standard was
not being met. Petitioner was notified of this inadequacy. Petitioner
thereupon retained new engineering consultants and requested a
report in order to plan further upgrading to meet standards.
During this period of time the Petitioner had also worked
upon its sewer separation project; and by the middle of 1972 the
greater part of this project was completed. Petitioner believed
that separation was necessary in order to evaluate total plant
loading.
The Agency, in its recommendation filed April 26, 1973 points
out that “ignorance of applicable standards cannot justify the grant
of a variance
“
(p.5). SWB-l4, while it contains an ammonia water
quality standard of 2.5 mg/i, applies this only to Public Water
Supply and Food Processing Industry waters (Rule 1.04). There is
no showing that Cedar Fork Creek is used for these purposes. Thus
official notice of the need for ammonia reduction must begin with
the March 1972 enactment by the Board of the 1.5 mg/i ammonia standard.
We have before us a variance filed March 5, 1973 asking for more
time in which to do pilot plant work on ammonia, a year after the
regulation was passed. This delay has not been satisfactorily ex-
plained and thus we cannot grant the ultimate relief desired which
is until July 1, 1977.
On the other hand, we have before us in two regulatory proceedings
the very issues of the ammonia standard itself and its deadline date
and the issue of moving back from December 31, 1973 to December 31, 1974
the due dates for conformance with municipal effluent limits (R 73-3,
8—
-3-
R73-4). Since we have not yet decided these regulatory proceedings
we grant the variances requested until June 14, 1974
only leaving
future Oxtensions to a better showing of prompt pilot work research
initiated between now and then. We grant a variance from Rule 921 (d)
to permit the District to obtain construction permits in the absence
of an approved Project Completion Schedule.
Finally, we note the Agency’s comment in its recommendat2on that
“piant effluent has little or no adverse effect on Cedar Fork Creek”.
The average levels in the effluent for 1972 were 17 mg/i ROD and
18 ing/l suspended solids or almost four times the incipient 4 mg/l
BOD and 5 mg/i suspended solids standard for this stream. We invite
the Agency to propose a new and less stringent effluent standard if
it has proof that “no adverse effect” on low
dilution
streams
will
be
felt.
This opinion constitutes the Board’s findings of fact and con-
clusions of law.
ORDER
1. Variance is granted until June 14, 1974 from Rule 203(f) as
regards ammonia nitrogen.
2. Variance is granted from Rule 921(d) but a Project Completion
Schedule must be submitted before June 14, 1974 showing the
best anticipated date for compliance with the standards.
3. The District shall submit quarterly reports to the Agency
detailing progress in its pilot plant research and in all
other steps toward completion.
4. The sewage treatment plant shall not be operated at effluent
levels to exceed 20 mg/i BOD and 25 mg/i suspended solids on
a monthly average.
5, The District shall diligently pursue correction programs for
sanitary and storm sewer overflows.
6. The District shall apply for an extension to this variance at
least 90 days prior to its expiration.
I, Christan L. Moffett, Clerk of the Illinois Pollution Control
Board, hereby certify the above Opinion and Order were adopted on the
j~day of June, 1973 by a vote of _______________________________
ristan L. Mo~fett,9’l~rk
Illinois Pollution Co~)frolBoard
8— 281