ILLINOIS POLLUTION CONTROL BOARD
In the Matter of:
~R70—3
MISSISSIPPI
RIVER
TREATMENT
DATES
Oninion
o.f the Board
(by ~Mr.Kissel)
On August
12,
1970,
the Environmental Protection Agency
filed
two reaulation prc•nosals with
the Illinois Pollution Control Board.
One pronosal
recTuested that the Pollution Control Board amend Sanitary
Water Board Regulation, SWB~12, to specify that secondary treatment
be nrovided by
the nersons named in SWB-l2 by December 31,
1973,
instead of the dates nrescrihed
in said regulation.
The other
nronosal requested that
the ~oilution
Control Board
amend Sanitary
Water
Board
Regulation,
SWB-13,
to
specify
that
secondary
treatment
be
provided
by
the
persons
named
in
SWB-13
b
December
31,
1975,
instead
of
the
dates
orescribed
in
said
requlation.
SWB-l2
is
a
set
of
regulations
oromulgated
by
the
Sanitary
Water
Board
covering
the
interstate
waters
of
the
Mississinpi
River which
forms
a common boundary between Illinois
and Iowa.
The
oriqinal water ciuality criteria which eventually became SWB-l2 were
adooted by
the Sanitary Water Board
Ofl
March
7,
1967.
The imulementa-
tion
olan
was
submitted
to
the
Department
of
the
Interior
on
September
1,
1967.
The
Sanitary
Water
Board re-approved the
modified
water
quality standards on March
6,
1968,
and placed them on
file with the
Secretary
of State of
the State of Illinois.
The original
1977 and 1979 dates
~or the upper Mississipoi
were
edtablished
after
consultation
with
the
Federal Water Qvalit~’
Administration
Regional
Office,
Chicago,
and
in
accord
vith
the
Davartment
of
the
Interior
guidelines
that
all
oun~cina1ities
orovide
a
minimum
of
secondary
treatment
within
a
sneci
~
tine.
1i~~::.
The
time
schedule
was
incoroorated
in
ST’IB-12
as
kule
~T7
Item
7.
Subsecuently,
the State oi Iowa indicated
to rue Federal
Government
t.hat
it
would
not
require
secondary
treatment
on
the
Missis~inpi
River.
On Anril 8and
9,
1969,
the
U.S.
Deuartment
of
the
Interior
Federal
Water
°ollution
Control
Administration
called
a
hearing
to
consider
the
establishment
of
water
quality
standards
for
the
Iowa
nortion
of
the
Mississinpi
River.
This
resuited
in
the
promulgation
of
a
Federal
standard
against
Iowa
reauirir.a
its
municinalities
and
industries
t~orovide
secondary
treatment
of
their
sewage
by
December
31,
973.
Iowa
is
presently
seeking
a
hearing
on
the
Federal
standard
by
a
soecial
nanel.
The Illinois Sanitary Water Board had indicated
its intent
to
amend the existing Illinois standard to conform to
the
earlier Iowa
date and
in deference
to the request of the Department
of the
Interior.
On
May
2,
1970, such
a motion and resolution was proposed
to
the
Sanitary
Water
Board, but action was deferred pending
confirmation
by
the
Department
of
the
Interior.
SWB—l3 covers the
Mississinni
River
which
forms
a common
boundary between Illinois
and Missouri and was originally adopted by
the Sanitary Water Board on February
8,
1967.
The
Imolementation
plan and the
criteria were submitted
to
the Department of the Interior
on September
1,
1967.
The
Sanitary Water Board re-approved
a modified
plan on August
8,
1968,
and filed that with
the Secretary
of State.
Both SWB-l2 and SWB-l3 imposed
the condition on municipalities
and industries
to
provide secondary treatment of wastes.
SWB—l2
required that
level of treatment when existing primary facilities
approach design capacity or obsolescence,
or by
the end of
1977
for
those facilities of
a Population Equivalent
(P.E.)
of 10,000 or more
and by
the end of
1979 where the P.E, was
less than
10,000.
SWB-l3
imposed
a secondary treatment reeuirement when
the existing orimary
treatment
facilities approached design capacity or obsolescence or
by
the end of
1982,
The specific types
of secondary treatment were
covered in those regulations
and said regulations
also stated that
industries were required
to provide
a degree of treatment or control
that
is equivalent
to that required of municipalities.
Based on the provision of
the Federal Water Quality Act of 1965
requiring that municipalities nrovide
a minimum of secondary treatment
within
a specific time
limit,
the Washington office of the Federal
Water Quality Administration reached an agreement that Missouri
municipalities would provide secondary treatment by December
31,
1982.
The 1982 completion date was subsequently written into
the Illinois
standard since Illinois had been working in concert with Missouri
to
obtain compatible standards.
In early
1969,
the Department of the
Interior requested Missouri
to amend
its secondary treatment deadline
to
an earlier date.
To comply with
the federal directive,
the Missouri
Water Pollution Control Board
set
a date of December 31,
1975,
On
July
30,
1970, the Secretary of the Interior announced his acceptance
of
the
Missouri
timetable.
The Illinois Sanitary Water Board had earlier indicated its intent
to amend SWB-l3 to include the
1975 date.
Though
a motion and resôlu-
tion to this effect was submitted May
2,
1970,
to the Sanitary Water
Board,
action was deferred pending confirmation of the
1975 date by
the Department of the Interior.
On July
1,
1970,
the Environmental Protection Act became effective
and
established
the
Pollution
Control
Board
and
its
sister
agencies.
The
Board
authority
to
adopt
secondary
treatment
deadlines
derives
from sections
12(a),
(b),
(c),
13(b),
(c),
27,
and 49(c)
of the Act,
which gives the Board Power to amend
the regulation of the old Sanitary
Water
Board.
Section
13(b)
in
particular
authorizes
the
Board
to
prescribe
effluent
standards
soecifying
maximum
amounts
or
concentra-
tions
of
contaminants
that
may
be
discharged
into
the
waters
of
Illinois,
The
Board
published
notice
of
the
scheduled
hearings
and
sent
a
copy
of the
amendments
proposed
by
the
Agency
to
all
those
munici-
palities situated on or near
the Mississippi River.
The Hearing
Officer held three days
of public hearings,
two in Rock
Island,
one
in Edwardsvi1le~’and received either
oral
or
written
testimony
from
over thirty municipalities,
These hearings, we believe, establish
the necessity,
the technical feasibility and economic
reasonableness
for establishing December
31,
1973,
as
the deadline
for requiring
secondary treatment
to all
wastes
discharged to
the Mississippi
River, which discharge sources are presently covered
in SWB—l2 and
SWB—l3.
The necessity for requiring secondary treatment by
the December
31,
1973,
date was established most granhically by Dr.
Rosen, Chief
of the Water Quality Section,
Federal Water Quality Administration.
Dr.
Rosen, whose qualifications are second
to none in the field of
the effect of waste
treatment, testified
at
a hearing in Edwardsville,
Illinois,
on October
28,
1970.
He stated that conventional
secondary
treatment of municipal waste accomplishes
one
or
more of the following
purposes:
u(l)
Reduce disease—producing and other enteric bacteria and
viruses;
(2)
Reduce depletion of oxygen in the ~receivinq water by
oxidizing nearly completely the substances that consume
oxygen;
(3)
Reduce visible and otherwise aesthetically disagreeable
sewage materials;
(4)
Reduce seecific substances
in municipal wastes,
by physical
and chemical change,
that otherwise will be dangerous
to
humans,
animals or fish exposed
to the contaminated
water.
(R. B 91—92)
While
Dr.
Rosen admitted that not all of the above reasons were
applicable
to
the
Mississippi
River,
he felt that there were still
reasons
for requiring secondary treatment of wastes which were
discharged into
that River.
As
an example, secondary treatment aids
in the disinfection
of effluent, even though primary treatment with
chlorination
is adequate
to destroy some bacteria and viruses.
With
primary treatment,
the effluent
is
so heavy in oxidizable organic
material
that large amounts
of chlorine must be consumed to obtain
*The page references from the transcript from the Oct.
9 hearing will
be prefixed by an
A;
those from the last two days,
by
a
B.
a similar degree of reduction in bacteria and viruses.
Further,
primary effluent contains
a greater amount of fine waste particles
which can shelter bacteria and viruses, making disinfection more
difficult.
(R. B
92)
Efficient secondary treatment can readily remove approximately
90
of five-day biochemical-oxygen demand
(BOD5)
in several hours.
But, without secondary treatment,
the
same purification must be sought
in the receiving stream.
By removal of the BOD
at the sewage treat-
ment plant,
therefore,
the entire stream can be saved that degree of
degradation that necessarily results from the presence of raw or only
partially—reduced sewage substances.
(R.
B
93)
As the Environmental
Protection Agency pointed out, secondary treatment
is
the first step
toward the removal of nitrogenous materials,
a major contributor
to
stream eutrophication.
Further,
the development of acclimated bacteria
capable of reducing bacteria and viruses
is accomplished more
consistently and effectively in the sewage treatment plant than
in
the receiving stream,
(R.
B
94)
The discharge of Primary effluent
not only contributes
to the degradation of the stream,
but,
due
to
its greater odor potential,
increases
the likelihood of downstream
odor problems
and may,
through absorption,
impair the
taste of
fish,
(P..
B
94)
Secondary treatment is necessary not only
to minimize stream
degradation, but also to obtain any substantial reduction in
the
commercial and industrial wastes which our contemporary technology
dictates
be discharged by individuals and corporations alike,
Grease, fatty acids, proteins,
amino acids, detergents,
natural and
synthetic
hormones,
hydrogen
sulfide,
and
mercaotans,
.though
not
removed
by
primary
treatment,
are
readily
oxidized
in
secondary
treatment,
usually
in
amounts
proportionate
to
the
BOD
removal.
SecQ~ndarytreatment also aids
in the removal of
color—oroducing
parti-
cles.
(R.
B
96)
Such substances
as phenols, chloroohenols,
alcohols,
acids
and
ketones
survive
primary treatment, but
crc effectivey
oxi-
dized in secondary treatment
(R.
B
97)
The same reduction
is
true
for
petroleum,
oils,
pesticides
and
synthetic
chemicals.
(R.
B
9~)
The need for
secondary
treatment
of
wastes
discharged
to
the
Mississippi was demonstrated in the Conference
to consider the
“Establishment of Water Quality Standards for
the Mississiooi River
Basin
Interstate
Waters
State
of
Iowa”
which
was
called
by
th’~.
Federal
Water
Quality
Administration and held on April
8-9,
1969.
in
Davenport,
Iowa,
The
record
of
that
Conference
was
made
an
exh~bt
in
this
proceeding
by
the
hearing
officer
on
October
9,
1970,
To
quote
from
a
rather
extensive
record
is
sometimes
dangerous,
but
there
is
one sentence
in the above conference
report
which
is
wor~hy
of
serious
concern,
On
Page
25
of
the
conference
report
the
following
appears:
Figure
1 shows
that there has been
a definite deteriora-
tion
in dissolved oxygen content
at Dubuque with measurements
falling below the 8—hour minimum approved Iowa standard of
4 mg/l
on many occasions
from 1964 through 1967.
.
.
Low
oxygen levels are an indication of the presence of amounts
of
oxygen—demanding organic wastes.”
Since oxygen-demanding wastes are contained
in the influent of all
municloal. and industrial olants,
and since secondary treatment of
those wastes reduce significantly
the amount
of such oxygen-demanding
wastes,
it
is
logical
to assume that if all wastes,
including
those
from our sister state,
Iowa, discharged into
the Mississioni River
were given secondary
treatment,
the problem alluded to by
the Federal
reoort cited above would be greatly reduced if not eliminated.
Perhaps the most interesting connection between
the present
condition of the River and the need for secondary treatment and
chlorination
is the
“slime oroblem.”
On
the second day
of the Rock
Island hearing, October
23,
1970,
a
local newspaper carried
a story
which detailed the
problems
that local fishermen were having
with
a
slime which
had develoned on the
River.
This story was alluded
to
in the record by
Mr.
Waller.
CR.
B23, Oct.
23,
1970)
Interestingly
enough,
in the hearing
in Edwardsville,
Dr.
Rosen postulated
that
this would occur as
a result of the
lack of secondary
treatment.
For examole,
in this exchange with
Mr.
Dumelle:
“MR.
DUMELLE:
.
.
.
Did you talk anything about sugars
or corn
wastes,
as
such,
and what secondary treatment does to them?
I
am
thinking
of the regrowth
that happens.
DR.
ROSEN:
I
didn’t
deal
on
that
subject,
but,.
yes,
the
point—-
and
it
has
been
documented--that
i,f we disinfect waste, whether
it
is
an industrial--that
is whether
the nutrient orqanic
material
comes
from
a food waste or from domestic sewage——but
if we
do not destroy the nutrient,
the
organic food for bacteria-—
but let’s assume
we kill
the bacteria by coronation
(sic)
.
It
has been demonstrated and been stated quite clearly that if this
waste
is
discharged,
and
if there
are
any other sources
of the
same organism reachinc
the stream alive,
that
the organisms will,
then,
muitie.iy because cf
the nutrient supplied by
the disinfected,
but notoxiclized waste.
.
MR.
DUMELLE:
This
leads
to
the
slime growths which foul
nets
and things
DR. ROSEN:
This
olus
the
growth
of
even coliforms.
.
.
.“
CR.
B
100—101)
Phil
S.nith of the
Ill:Lr:ois Natural History Survey indicated he
was
sure
the
fishery business
on the
Mississippi
had
deteriorated
and
had
heard
that fishermen
working
the
River
below
Metropolitan
St.
Louis ccmoiained bitterly about the
odor of their catch.
(R.
Bl49)
To orotect
the Mississiepi’s still abundant fish fauna and preserve
their
environment
he recommended
that we
do
tee utmost
to
cease
1
*
~91
dumping pollutants
into th~River,
CR.
P146)
Dr. Rosen,
in speaking
to
the
question
of
human
encounter
with
the
River
waters,
stated
that
it
would
be
“unsafe”
to
use
for
body
contact
sports
those
waters
downstream
from
a
primary
discharge,
even
though
the
effluent
had
been chlorinated or otherwise disinfected.
(R.
B99)
Without
secondary
treatment, potential pathogenic organisms are not sufficiently
destroyed as to render the river water safe
for swimming or boating.
(R.
P100)
As Dr.
Rosen concluded,
“The obvious degradation that occurs
from discharging primary effluent
and the large number of specific
deleterious substances removed or reduced by secondary treatment
make it clear that no treatment less than secondary can be acceptable
in preventing pollution.
On large streams efficient secondary
treat—j
ment may remain an adequate measure into
the foreseeable
future.”
(P..
B98,99)
Perhaps the most interesting testimony concerning
the present
state of the River came from local citizens.
Although these people
did not come
to deplore the sorry state of the River
(in fact most
came
to say that municipalities they represented needed financial aid
to meet the proposed date
for
secondary
treatment), their testimony
graphically outlined what the River must look
like today.
It
was not
pleasant testimony because many of those testifying would not use
the River for recreation,
even though such
a use is designated by
SWB-l2 and
13.
One witness, Don Waller of Milan, remembered that
“it
isn’t the river that
I recall
as
a boy.. ,the banks are covered with
debris.. .the slime
is
a great problem.”
CR.
P22-3)
Homer Sherrill, Mayor of Hamilton, recollected that “when
I was
a little fellow,
I used to go down swimming, but
I wouldn’t
attempt
it
now.
.
.it
is more muddy-looking,
(more)
roiled up than
it used to
be.”
(P..
P82)
One long time resident of
the
area testified
this
way:
“ACTING CHAIRMAN KISSEL:
How long have you lived
in
this
area?
A
long time?
MR.
SCHROEDER:
I
have
lived
in
this
area
for
22
years
and
I’ve
been
in
Andalusia
for
just
a
little
over
seven
years.
ACTING
CHAIRMAN KISSEL:
And in your
22 years
in
this
area,
have
you seen
a difference
in the use
of. the Mississippi,
any differ-
ence in
the river, itself?
MR.
SCHROEDER:
Even in the last five or six years,
I have seen
a great difference
in it.
Ten
or
fifteen
years
ago,
you
wouldn’t
mind swimming in~it.
Seven years
ago, when
I moved to Andalusia,
I bought
a nice boat
and
I
kept
it
just
a
year
and
a
half
and
I
sold
it.
1
*
192
ACTING
CHAIRMAN
KISSEL:
How
come?
MR. SCHROEDER:
You could not imagine the pollution in the
water.
In fact,
if
I did go fishing,
I would be afraid to eat
the fish.
It is terrible.
ACTING CHAIRMAN KISSEL:
Where
do
you
think this
comes
from?
MR. SCHROEDER:
I would say
just dispoaal plants
of every
description.
It seems
like there is more solid waste on the top
of the water and
It
actually
is
turbid.
Well, we noticed this more possibly in Andalusia because we
have an island about ten miles
long that breaks the Mississippi
channel proper
from Andalusia,
And we have
a nice boat harbor
there.
But just walk down to that harbor where the water
is
not moving too rapidly, actually
it
is sickening.
ACTING CHAIRMAN KISSEL:
The odor?
MR.
SCHROEDER:
Yes,
ACTING CHAIRMAN KISSEL:
Any algae,
any green algae?
MR.
SCHROEDER:
Lots
of it,
lots of it.
ACTING CHAIRMAN KISSEL:
I take
it it
has increased over the
years?
MR~ SCHROEDER:
Very much
so.
I could
see
this coming.
And
my
wife,
she
wou1dn~t
even
get
in
the
boat any more.
She says,
“If
that’s
what
we
have to ride in, forget
it.”
ACTING CHAIRMAN KISSEL:
Don~tyou think one of the ways
to cure
this is to have municipalities do something about their wastes?
MR.
SCHROEDER:
I certainly
do.
I agree with you.
ACTING CHAIRMAN KISSEL:
Thank you very much,
MR.
SCHROEDER:
Thank you.”
(R. B34-6)
What more can be said as justification for requiring
secondary
treat-
ment of wastes discharged into
the River.
Perhaps,
Mr. Schroeder can,
in
his
lifetime,
use
the
River
as
he
used
it
years
ago.
As to the question of technical feasibility,
there is no question
as
to
the
ready
commercial
availability
of
sewage
treatment
units
capable
of attaining the 85 and
90
removal
which
the
new
regulation
1
—
193
insists
upon.
Rather,
the
only
technical
question
is whether complete
installation of the necessary facilities
can be completed by December
31,
1973,
William
Busch,
of
the State of Illinois Environmental Protection
Agency,
testified
that
the municipalities were physically capable of
meeting
the
1973
date.
This testimony was corroborated by several
representatives
of
the
municipalities.
Rock Island’s consulting
engineer
stated
that
if the standard were passed in early 1971
this
would
be
sufficient
time
within
which
to
complete
installation by
December
31,
1973,
CR.
A23—4)
Moline
indicated
that its
schedule would
meet
the
1973
date.
(R.
Bl5)
The Sanitary Engineer from the City of
Savanna
spoke
of
a
three-year
period
f~rominception
to
completion
on
the more complex municipal waste treatment
situation;
on
this
basis,
he stated that Savanna could be
in compliance by
the
proposed
deadline.
(R.
P44)
Similarly testifying were the municipalities
of
Cordova, Andalusia, Hamilton,
and Albany,
CR,
B78,
P64)
Though
opposition to the advancement of the deadline was expressed by
several municipalities on the Lower Mississiopi
the evidence was
overwhelming that the
1973 date was eminently technically feasible.
Much of the testimony in the hearings centered around
the ability
of
the
municipalities
and
sanitary
districts
to
pay
for
the
added
facilities,
which testimony raises the question of whether
the advance-
ment of the date for secondary treatment
is “economically reasonable,”
as
provided
in
Section
27 of
the
Environmental
Protection
Act.
In
determining whether such an advancement is
“economically reasonable,”
we
must
take into consideration
the
actual
costs
to
be expended by
the persons in complying with
the proposed regulation.versus the
benefit to be obtained by
the people of
the State of Illinois
if
such
costs are expended,
The testimony proves rather conclusively
that
secondary
treatment
of
the
wastes
discharged
into
the
River
is
needed,
all that is at
issue
is whether the date by which that degree
of
treatment is required should be advanced,
Therefore,
in determining
“economic
reasonableness”
we
need
not
balance
the
total
cost
of
secondary
treatment against the benefits
to
be
obtained
by
the
people
of the State of Illinois, but rather whether the additional cost,
if
any, which may be incurred as
a result of the advancement of the
date
by which said treatment is required
is reasonable
as compared against
the benefits
to be derived in having secondarily treated waste
discharged into the River at the earlier date.
When the question
is
so phrased,
there is no difficulty
in determining that the “sooner
the better”
as far as the public
is concerned,
In fact,
delaying
the time when secondary treatment
is required
may
increase
the cost
since construction costs
are
generally
on
the
rise,
Thus,
on
balance
there would
be
little,
if
any, increase in
the
cost
to
those
who
will
be required to pay for the secondary treatment, yet,
if the regulation
is’complied with the people of the State of Illinois will have
a
cleaner River at
a much earlier date.
Simply put,
the cost is worth
it to the people of the State.
In addition,
the
funds from the
recently
passed
bond
issue
will
be
available
to alleviate the
burden
of
the
local
citizens
of
the
affected
municipality
or
sanitary
district
in
paying
the
total
cost
of
any
facilities
needed
for
meeting
the
requirement
of
secondary treatment.
The
Regulation
which
was
adopted
by
the
Pollution
Control
Board
on
January
6,
1971,
and
which
this
opinion
supports
provides,
essentially
as follows:
(1)
all oxygen-demanding wastes and wastes containing suspended
solids shall receive secondary treatment,
at a minimum, by
December
31,
1973;
(2)
for sewage works with
a Population Equivalent
(P.E.) of
10,000 or more,
secondary treatment
shall mean 90
removal
of BOD5 and suspended solids,
and no more
than
20 mg/l of
POD5 and
25 mg/l of suspended solids;
(3)
for sewage works with
a P,E. of less than 10,000, secondary
treatment shall mean 85
removal of POD5
and suspended
solids and no
more
than
30
mg/l
of
POD5
and
37 mg/l of
suspended solids;
and
(4)
disinfection shall be provided
for effluents
to reduce
fecal coliforms
as
follows:
(a)
400 per 100
ml
in
primary
contact~waters, and
(b)
2000’ per 100 ml
in all other waters.
The regulation
is different than
what
requirements
existed
in
SWP-l2
and
SWP~-’l3.
The obvious difference
is, of course,
the advancement
of
the date by which secondary treatment facilities
are required.
The regulation makes uniform throughout
the Mississippi River the
date by which
such treatment is required.
It does
not,
as did SWB-l2
as compared
to SWP-l3, discriminate between that section of the River
which forms
a common boundary between Illinois and Iowa and that
section which
forms
a common boundary between Illinois
and Missouri.
All
those who intend to use that River as the outlet for their discharges
shall be bound by the
same requirement.
We
can only hope that the
states of Iowa and Missouri will adopt consistent standards so that
discrimination does
not exist between those on one side of the River
and those on the other.
The new regulation refers to all waste discharges, thereby
not
giving specific reference
to municipal discharges
as did paragraphs
7 of Rule 1,07 of SWP-l2 and of Rule
3,01 of SWP-l3.
Paragraph
8 of
both SWP-l2 and SWP-l3 insisted that industry furnish that degree of
treatment “equivalent”
to that furnished by the municipalities.
Further,
the Agency has informed us that the intent of
the proposed
regulation was that it apply to industry
and municipality
alike.
To
1
—
195
avoid
any
ambiguity
in
this
regard
we
have
therefore
phrased
the
new
regulation
in
terms of
“all waste
discharges.”
We
have
included
under
that term of
“discharges,”
both
oxygen-demanding
discharges
and
those
containing suspended solids.
The regulation therefore covers those
industries which may discharge waste non-organic in nature.
We have also incorporated
a r~iinimum-sizeexclusion into the new
regulation.
Those
sewage works receiving
a waste discharge equal
to
or
greater than
10,000
population
equivalents
(P.E.) must attain a
90
reduction in
POD5
those less
than
10,000
P.E,
need only
reach
an
85
reduction.
The basis
for such
a differentiation lies
in the
type of secondary treatment facilities employed.
With the activated-
sludge process,
a 90
reduction
rate
is
attainable;
with
the trickling
filter method, however,
only
85
is generally possible.
The trickling
filter,
though,
is
a more suitable method of treatment
for smaller
plants since it does
not demand the extensive testing,
the constant
overseeing,
or the highly-trained personnel that an activated sludge
plant would require.
In addition, the activated sludge
process
is
more expensive
to install.
The federal government has suggested a
90
reduction rate all along
the River; we do not believe that the
5
difference
in efficiency
for waste water discharge from the smaller
plants along the Mississippi will cause an appreciable difference in
the water .quality of the River.
We have
also repealed paragraphs
11(a)
and
(b)
of Rule
1,07
and
of
SWP—l2
and of Rule
3.01 of SWP-l3,
The effluent standard
for
fecal coliform reduction
to
400
per
100
ml
or
less
before
discharge
to
any
waters
‘designated for primary contact and the requirement for
bypass
flows in excess of sewage
works
capacity
have
been
retained
in the amended regulation.
We have added the requirement that
disinfection reduce fecal coliforms
to
2000
per
100
ml
before
discharge to any waters other than those designated
for primary con-
tact,
Further,
the
wording in the new regulation removes any doubt
as
to
whether
the
bacteria
standard
is
in fact an effluent standard.
In all other aspects,
the numbers have been transposed
to the new
regulation
and
a
constant
proportion has been maintained
in
the
numerical value of the reduction demanded.
A special note should be given that both the effluent standard
and
the
reduction
percentage must be met by all waste dischargers,
This
is especially applicable
to industrial wastes.
Thus,
an
industry with greater than 10,000 ~
must attain
a
90
reduction
in suspended solids and POD
and an effluent which contains
no more
than
25 mg/i of suspended solids
and. no more than 20 mg/I of POD,
1-196
In summary, ample basis has been established with the criteria
established
by
the Environmental Protection Act for the promulgation
of
the
following
regulation.
Adequate notice was served and the
necessity of such
a deadline was firmly proved.
The regulation
forms
a vital portion of the Board’s dedication
to the principle of
non-degradation
of
the
waters
of Illinois.
The State legislature
has directed the Board to act as expediently as possible
in ,the area
of water pollution and this regulation imposing
a December
31,
1973
deadline
is drawn in that sPirit.
/
/
I
I co~Icur4’
r~
/1
~
I
dissent:
/
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/
__________________________
‘I
~
/~
~
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—
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(~
-—
—4.’—-—
Li
February.
3,
1971
I,
Regina
E.
Ryan,
do
certify
that
the Board has adopted the
above opinion this
3rd day of February,
1971,
(7-))
~
Re’~j4.aE.
~yan
f/
CXe~kof the Boà.~d
I
—
187
