ILLINOIS POLLUTION CONTROL BOARD

October 31, 1972

MONSANTo COMPANY

v.

)

PCB 72-336

ENVIRONMENTAL PROTECTION AGENCY

OPINION AND ORDER OF THE BOARD (by Mr. Dumelle)

On August 10, 1972 the Monsanto Company (Monsanto) filed a petition

requesting an extension for an additional year of their variance to discharge

mercury in quantities greater than the regulation (PCB 71-110, November 8,

1971, 3PCB 9) from the W. G. Krummrich Plant at Sauget.

Without a hearing we grant the variance for an additional year until

November 7, 1973 for the reasons discussed below and subject to the condi-

tions listed.

In our initial variance in this proceeding we set certain conditions upon

Monsanto. The Agency, in a late filed recommendation received by us October 31,

1972 (the date of this decision) agrees that substantial compliance has been

achieved with the original conditions. The only dispute appears over the

amount of mercury to be permitted to be discharged. Monsanto asks to dis-

charge up to 0. 5 lbs. of mercury per day as a daily average’~ (Petition).

The Agency in its recommendation mentions a Federal EPA ~!guideline

of 0. 25 lbs. of mercury per day. No documentation of this ‘guidelin& was

submitted to the Board and we are unable to determine if in fact Monsanto agreed

to meet this lower level of discharge.

Both Monsanto and the Agency point out that actual discharges for the six

months ending July 1972 were 0. 33 lbs. per day. Monsanto’s recital of progress

in reducing mercury discharges convinces us that the most recent discharge

level (0. 33 lbs. per day) can be met as an average based upon a six month

moving average. The instant variance request asks that 0. 5 lbs. per day

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level not to be exceeded in any 24-hour period.

In January 1971 Monsanto was discharging 7. 7 lbs. per day of mercury.

They are now capable of meeting 0. 33 ‘bs. per day for a most commendable

reduction of PS. 8’, from the level of jtst 21 months ago.

Monsanto’s petition states that 0.25 lbs. per day of mercury is lost

from sources other than the chlor-alkali plant (which discharges 0. 04 to

0.06 lbs. ner day). We urge additlonU

study

of

mercury contents

in

all

raw materials used by Monsanto as well as attention ta the removal of mercury

deposits in the plant sewer system joints

and

cracks. And

we

again

call

attention to the mercury materials balance of the chlor-alkall plant which showed

in 1971 an unexplained loss of 32, 000 lbs. of this toxic metal that year. If

these 16 tons of mercury are going to the Sauget atmosphere each year we

should know that and limit that

type

of emission, If this mercury is going out

of the Kruznmrich plant in the form of sodium hydroxide or potassium

hydroxide or in the chlorine gas then we should also know that

and

prevent

envfronmental contamination elsewhere by users of these products.

We will require a verification of the statements in the petition by an

officer of Monsanto to be filed by December 11, 1972 with the Board and

Agency.

The conditions listed in the order replace the conditions of the original

1.

Variance is granted until November 6, 1973 to permit discharge of mercury

up to 0.33 lbs. per day based upon a 6-month moving average but not to

3.

Monsanto shall sample and analyze the mercury-bearing waste water

which is alternately put in one of the two storage tanks prior to release

to the village sewers and treatment plant. If the concentration of mercury

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-3-

4.

Monsanto shall submit to the EPA monthly reports on the progress

of its nier’rurv abatement program. The reports shall include

a listing of the mercury concentration of the waste water storage

tanks before discharge and shall be submitted a reasonable time

after the end of the month.

5.

Monsanto shall submit to the Agency and the Board within six months

from date a report listing the mercury materials balance for the

chior-alkali plant including the amounts which are emitted into the

atmosphere and those which leave the plant contained in the products

manulactured.

6.

Failure to adhere to any of the conditions of this variance shall be grounds

for revocation of the variance.

I, Christan L. Molfett, Clerk of the Illinois Pollution Control B ard,

hereby certify the above Opinion and Order were adopted on the~/~__day

of October, 1972 by a vote of

0

Christan L. Moffett,

k

Illinois Pollution Cont

Board

6

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