ILLINOIS POLLUTION CONTROL BOARD
October
9,
1975
GRANITE CITY
STEEL,
division of
)
National Steel
Corporation,
Petitioner,
V.
)
PCB 75-58
ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
Mrs.
Leah Hamilton and Mr. Douglas
C.
Nohigren, Jenner
&
Block, appeared on behalf of Petitioner,
Mr. James Burngarner
appeared on
behalf of the
Respondent.
OPINION AND ORDER OF THE BOARD
(by
Mr.
Goodman):
This matter comes before
the
Pollution Control
Board
(Board)
upon Granite City
Steel~s
(Granite) August
1,
1975,
Amended Petition for
Variance
from Rule
203(c)
and Rule
402,
with respect to~Rule~203(c)
for phosphorus,
of the Water
Regulations.
An unsigned stipulation was admitted at the
August 18,
1975,
hearing.
Granite employs 5000 persons in producing flat
rolled
steel at its Madison County plant.
The
Petitioner~s3,5
million dollar wastewater plant is located adjacent to
Horseshoe Lake
in Nameoki Township.
The treatment system
includes three oil—water separation units
(1.75
acres)
,
one
isolation basin
(9 acres),
and a two—cell biological
oxidation
stabilization basin
(350
acres).
Most of the water used by Granite is drawn from the
Mississippi River,
After several recyciings and treatment,
this water
is discharged throuc~har
~,.
11 into Horseshoe
Lake at a rate of
62 mgd.
Horseshrc Lake discharges
to
the
Cahokia Canal,
the water eventually returning to the
Mississippi.
Horseshoe Lake
is an
~ox bow~
with a surface area
of 2107
acres,
a shoreline
of 11.2 miles and a volume of
8429.2 acre
feet.
It has a naturally high turbidity due to wind
conditions
and the lak&s
shallowness.
This turbidity limits
available
light and thereby limits algae growth
(R37-8).
Although Granite
uses
no phosphorus in its
manufacturing
processes,
its intake from the Mississippi River
does contain
phosphorus.
The
phosphorus
content of
Petitioner~seffluent
is lower than that of its
intake.
The
difference in phosphorus
concentration levels
is due to natural chemical and
biological
precipitates.
The average phosphorus level
of Granite~s
effluent is
.07 mg/l or
37 pounds per day.
Rule
203(c)
requires effluent to contain no more than .05 mg/I.
19
—7
—2—
The testimony at
the hearing
corfirmed
that, practically,
neither
biological nor chemical treatment would result in
lowering the
phosphorus
level
to
.05 mg/l
(R.83-87).
Indeed,
the biological
treatment would raise BOD from less than 10
to 250 mg/l
(R,87),
The parties also explored the use of
ion exchange,
selective ion exchange, and reverse osmosis
methods.
These methods
are not only
impractically
expensive,
but also
have never been shown to be operable at 62 mgd.
They
also
create a concentrated effluent
which
must be
disposed
separately.
In addition,
it
is not
thought that
these methods would reduce the phosphorus
level
to 0.05
(R.88—98).
The
cost of operation of a
facility using
reverse
osmosis or ion exchange
would be anywhere from $5,000,000
to
$11,000,000.
The Board finds
that,
at present,
the
necessary
technology needed
to reduce the
phosphorus
to 0.05 mg/i
is
not practically
available.
The purpose
of
the Water Quality Standard as
it pertains
to phosphorus
is to
reduce the
possibility of algae
blooms.
No nuisance algal growth
was found by
Dr. Covich in
Horseshoe
Lake
(R.37).
His testimony
would
have been supported
by
various Agency
witnesses
(Stip. par.
27 through
32).
The cost of treatment
being
prohibitive and resulting
in negligible difference
in phosphorus content coupled
with
the fact that the water returns
to the Mississippi with a
lower phosphorus content than when it was removed,
leads the
Board to the opinion that Petitioner has met its burden and
has shown that it would be arbitrary and unreasonable
to
deny its variance petition.
This
is especially
true,
here,
where the reason for the water quality standard is to
prevent algae blooms and such blooms do not exist
in Horseshoe
Lake.
Therefore,
the board will grant Petitioner~sVariance
from Rules
203(c) and 402
of
the Water Regulations until
October
1,
1976,
This Opinion constitutes the t~ndingsof fact and
conclusions of law of the Board in
‘~
s matter.
It is the Order of the Pollution Control Board
that:
1)
Petitioner Granite City Steel
be, and hereby is,
granted Variance from Rule 203(c)
phosphorus and
Rule
402 as
applied to 203(c) of the Water Regulations for
its
effluent
into Horseshoe Lake until October
1,
1976;
and
2)
That during the period of the Variance,
Granite
City Steel shall not discharge concentrations
of phosphorus
into Horseshoe Lake in excess of the phosphorus
concentration
of Granite City Steel~s intake water as
it is
withdrawn from
its reservoir; and
19—
8
—3—
3)
That within 28 days
of the ~option
of this
Order,
the Petitioner
shall execute and forward
to both the Illinois
Environmental Protection
Agency, Manager, Variance Section,
Division of Water Pollution
Control, 2200 Churchill Road,
Springfield,
Illinois
62706 and the
Pollution
Control Board
a Certification of
Acceptance and
agreement to
be bound to
all terms and conditions of
this Variance.
The form of said
certification shall
be
as follows:
CERTIFICATION
I
(We), ________________________ having read and fully
understanding the Order of the Illinois Pollution Control
Board in PCB
75-58 hereby
accept
said Order and agree to
be
bound by all of the terms and conditions thereof.
Signed ________________________
Title _________________________
Date ___________________________
I,
Christan L.
Moffett, Clerk of the Illinois Pollution
Control Board, hereby cert~ifythe above Opiniop apd Order
were adopted on the
9
~“
day of
1975 by a vote of
3-o
19 —9