ILLINOIS POLLUTION CONTROL BOARD
    January
    16,
    1975
    ILLINOIS POWER COMPANY,
    Wood
    River Station,
    Petitioner,
    PUB 74-~423
    ENVIRONMENTAL PROTECTION AGENU~,
    Respondent.
    Sheldon
    A, Zabel, attorney for Illinois
    Power Company.
    Henry
    3.
    Handzel, Jr.,
    attorney for the
    Environmental Protection
    Agency.
    OPINION AND ORDER OF THE BOARD (by Dr. Odeil)
    On November 15, 1974. the Illinois Pollution Control
    Board (Board) received from Illinois Power Company a Petition
    for Variance from the 1.0 mg/i boron standard in Rule 203(f) of
    Chapter 3 from December 31, 1974, to June 30, 1975, to complete
    their research on boron control.
    Petitioner owns and operates a fossil-fuel fired electric
    power generating station, referred to as the Wood River Station,
    near East Alton, Madison County, Illinois. The Wood River Station
    consists of five steam elect.ric generating units. Units 1 through
    3, which are fired with No~~2 distillate oil, have a combined
    capacity of 155 MW. Units 4 and 5 are coal—fired with capacities
    of 103 MW and 320 MW, respectively at the present time.
    After coal and oil are burned to generate electricity,
    the ash (mostly from coal) is sluiced with water to the ash lagoon.
    It is retained there to permit the settling of suspended solids.
    Longer retention in the lagoon increases settling of suspended
    solids, but this also increases the leaching of boron out of the
    fly ash. The ash lagoon effluent, which is the subject of this
    variance request, is discharged into and flows about 200 feet in
    an unnamed tributary of Wood River Creek, and then flows approxi-
    mately 3,500 feet in Wood River Creek to the Mississippi River.
    The Wood River Station is located at the confluence of Wood River
    Creek and the Mississippi River. Since the ash lagoon effluent
    is discharged to Wood River Creek, which is an intermittent stream,
    the effluent plus limited stream flow must meet the Rule 203(f)
    water quality standard of 1.0 mg/i boron. If the effluent dis-
    charged directly to the Mississippi River, Rule 408 of Chapter 3
    would apply,
    which
    includes no limitation for boron.
    15—261

    —2—
    In response to Petitioner’s previous variance request in
    PCB 74-9, 12 PCB 81 (April 18, 1974), the Board granted Petitioner
    a Variance from Rule 408 of Chapter 3, as it pertained to suspended
    solids, until May 30, 1974; from Rule 1002 (project completion
    schedule for control of suspended solids); and from Rule 203(f), as
    it pertained to boron, until December 31, 1974. The Variance that
    was granted from Rule 203(f) for boron in PCB 74-9 was subject to
    the following conditions:
    “(a) Petitioner’s discharges shall not exceed 16 mg/i
    boron in any 24-hour composite sample;
    “(b) Petitioner shall submit quarterly reports to the
    Agency beginning July 1, 1974. Such reports
    shall contain ~information relating to all pro-
    gress or lack of progress in research conducted
    by Southern Illinois University relating to the
    removal of boron from ash lagoon effluent;
    “(c) Petitioner shall submit with any request for an
    extension of variance an engineering feasibility
    report on the diversion of the ash lagoon waste
    to the Mississippi River;
    “Cd) Petitioner shall submit comments on the feasi-
    bility of its boron removal as per its research
    program with any request for an extension of this
    variance.
    On May 29, 1974, Petitioner completed the ash lagoon
    extension, which increases the retention time of the effluent and
    reduces suspended solids in the effluent. Since May 29, 1974,
    total suspended solids have averaged 8 mg/i, which is within the
    15 mg/i limit in Rule 408.
    Research on boron removal, which was the basis for the
    Variance from Rule 203(f) that was granted in PCB 74—9, is still
    in progress with Messrs C. David Schmulbach and James A. Cox of
    the Department of Chemistry and Biochemistry at Southern Illinois
    University, Carbondale. This research lasts until June 1, 1975.
    The first and second quarterly research reports from Messrs
    Schmulbach and Cox accompanied Petitioner’s current Petition for
    Variance. These two reports include the following results:
    1. The major source of boron in the lagoon effluent
    is the fly ash, The rate of boron removal from
    fly ash is very rapid and increases with increas—
    ing acidity from pH 10-8 to pH 6-4. “Approximately
    50 percent of the boron in fly ash is removed in
    the first 15 minutes of contact with the water.
    • .
    Boron in bottom ash appears to exist in an
    inert, non-leachable form.
    . . .
    The percentage
    removal of boron from fly ash varied from approxi-
    mately 55 percent in acid buffered solution to
    about 35 percent in basic solution.”
    15
    262

    —3—
    2. Boron content in the ash lagoon sediment increases
    from 450 ppm at the ash sluice inlet to 2,300 ppm
    at the lagoon outlet, Therefore, the boron needs
    to be removed or be made chemically insoluble be-
    fore or soon after it enters the ash lagoon. Boron
    is not removed to any significant extent from water
    by adsorption on limestone or glauconite.
    3. Exposure of fly ash to temperatures of 1,200°Cfor
    periods as short as 1 minute causes most of the
    boron in the fly ash to be converted to a non-
    leachable form, but exposure to fly ash to 800°C
    does not convert the boron to a non—leachable form.
    “Mixing limestone, CaCO3, with fly ash improves the
    extent of conversion of boron to a non-leachable
    form at a given temperature and firing time.
    CaCO3 added to fly ash to give a weight ratio of 75:1
    (fly ash:CaCO3) and fired (at l,2000C) for 1 minute,
    or a blend of 100:1 fired for 5 minutes, are optimum.”
    4. Limited tests indicate that “boron is fixed when a
    coal sample is fired with CaCO3 at 1,200°C.”
    5. Research is in progress to evaluate ion exchange
    membranes as devices for the removal of boron from
    the effluent.
    A Recommendation was received from the Environmental
    Protection Agency (Agency) on December 6, 1974. They reported that
    Petitioner has complied with conditions (a), (b), and (d) of the
    boron portion of the Variance granted from Rule 203(f) in PCB 74—9
    (quoted above), but the data submitted in regards to condition Cc)
    are inadequate as an engineering feasibility report on the diversion
    of the ash lagoon waste to the Mississippi River. A sample taken
    by the Agency on October 1, 1974, from the discharge of the ash
    lagoon contained 10 mg/i boron. This is within the limit of 16
    mg/i boron listed in condition (a) of PCB 74-9.
    “The Agency believes that Petitibner’s discharge has no
    adverse effect on the present condition of the unnamed tributary
    of Wood River Creek which received Petitioner’s effluent. Boron is
    not harmful to aquatic life in moderate concentrations. Studies have
    indicated that the minimum lethal dose of boron affecting minnows
    is a concentration in excess of 19,000 mg/i. The waterway in
    question here is not a public water supply nor is it used for
    irrigation.” The 1.0 mg/i boron level was established in 1972
    primarily on evidence that higher levels can harm irrigated crops
    (3 PCB 412 and 760); but this water is not used for irrigation.
    Effective methods of boron removal from aqueous solutions
    are unknown at the present time, It is hoped that the current re-
    search at Southern Illinois University that is being done in
    cooperation with Petitioner will develop a suitable process for
    boron removal. If so, it would be valuable to Petitioner and
    other dischargers with similar problems. In view of ,Petitioner’s
    15 —263

    —4-.
    efforts to investigate technology for removal of boron from
    aqueous solutions, the Agency recommends that Petitioner be
    granted a Variance from Chapter 3, Rule 203(f) as it pertains
    to boron, from December 31, 1974, to June 1, 1975. The Agency
    mentioned a six-month variance, but then recommended one for only
    five months. Since the research is to be completed by June 1,
    1975, the Board will grant a Variance to June 30, 1975, to complete
    the research and provide more time for Petitioner to finalize future
    plans based on the research results.
    If a viable boron removal method is developed, a test
    facility will be established at the Wood River Station to test the
    most promising possibilities on Petitioner’s effluent.
    If this research does not result in a suitable
    method for
    boron removal from the effluent, Petitioner plans to use one of
    several other alternatives for controlling
    the
    boron discharge
    problem. These include dry collection of the fly ash, direct dis-
    charge of ash lagoon effluent to the Mississippi River, and rerouting
    the effluent to a “borrow pit” northwest of the plant and then through
    twin 60-inch culverts in the levee to the Mississippi River. Any
    planning for this latter alternative should insure that the existing
    impoundment problem behind the Mississippi River levee is not
    aggravated at any time. EEPA v. Alton Box Board Company PCB 73—61,
    74—5 and 74-51 (August 29, 1974); and EPA v. Laclede Steel Company
    PCJ3 72—425 and 72—505 (November 22, 1974)).
    ORDER
    IT IS THE ORDER of the Pollution Control Board that
    Petitioner is granted a Variance from Chapter 3, Rule 203(f) as
    it pertains to boron, from December 31, 1974, to June 30, 1975,
    subject to the following conditions:
    (a) Petitioner’s discharge shall not exceed 16 mg/l
    boron in any 24—hour composite sample;
    (b) Petitioner shall continue to submit quarterly
    reports to the Agency which were begun July 1,
    1974. Such reports shall contain information
    relating to all progress or lack of progress
    in research conducted by Southern Illinois
    University relating to the removal of boron
    from ash lagoon effluent;
    Cc) Petitioner shall, within 90 days of the grant
    of this Variance, submit an Engineering
    Feasibility Report on alternative means of
    disposal of fly ash, i.e. dry storage of all
    ash or diversion of the ash lagoon effluent to
    the Mississippi River;
    15
    264

    —5—
    (d) Any proposals which Petitioner develops to solve
    its boron problem should receive review by the
    appropriate permitting engineers.
    I,
    Christan L. Moffett, Clerk of the Illinois Pollution Control
    Board, hereby certify that the above Opinion and Order was adopted
    on the
    /(d~~
    day ~
    ,
    1975, by a vote of
    ~/
    to ~
    15—
    265

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