ILLINOIS POLLUTION CONTROL BOARD
June 28, 1977
REVERE COPPER AND BRASS, INC.,
)
Petitioner,
v.
) PCB 76—246
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
OPINION AND ORDER OF THE BOARD (by Dr. Satchell):
Revere Copper and Brass, Incorporated, filed on Septem-
ber 20, 1976 a petition for variance. A variance is sought
from Rule 203(f) of the Chapter 3: Water Pollution Regula-
tions (Chapter 3) as applied to copper. An alternative
request is that the Board reclassify Revere Ditch, pursuant
to Rule 302(k) of Chapter 3 as a secondary contact water.
An Agency recommendation was filed on November 29, 1976.
After the filing of the recommendation the Petitioner and
the Agency entered into negotiations which resulted in an
amended recommendation and a stipulation filed on March 31,
1977.
Petitioner’s alternative request to reclassify Revere
Ditch as secondary contact water must be denied. The Board
has previously ruled that in order for a water of the State
of Illinois to be so classified the Board’s regulatory process
with the requisite public notice must be pursued, Olin Corpor-
ation v. E.P.A., PCB 73-509, PCB 73-510 (Consolidated) (June 3,
1976).
Petitioner is engaged in the production of seamless
copper tube, stainless steel utensils and fabricated metal
products in two separate plants both located in Clinton,
DeitJitt County, Illinois. The Tube Mill Plant produces the
seamless copper tubing and the Manufacturing Plant produces
the stainless steel utensils and the fabricated metal products.
Operations at the tube mill include:
(I) Cathode and high quality copper scrap; melt; cast
into billets (standby Ajax electric furnace and
casting unit available); production, about 4 x io6
pounds per month.
(2) Oil-fired furnace reheats billets for piercing into
seamless shells; quench26
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in water; pickle in 10 H2S04
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rinse; draw, anneal, saw, pack, etc. to
customer’ s specifications.
Copper is put into the water in the following ways:
(Pet. Dwg. #EV-S-201-A).
Quantity of Water Used
Copper Added
Operation
(Gals. per day)
SuFpended Dissolved
Billet Quench &
40,000
49.2 ppm 0.17 ppm
Piercer
16.4 lbs/ 0.057 lbs/day
day
Pickle Rinse
2,500
134.8 ppm 613.00 ppm
2.81 lbs/ 12.76 lbs/day
day
Continuous Cast
182,100
0.13 ppm 0.0 ppm
Furnace
0.20 lbs/ 0.0 lbs/day
day
Ajax Electric
20,000
3.99 ppm 0.5 ppm
Furnace (Standby)
0.67 lbs/ 0.08 lbs/day
day
Two private inter-connected ponds of about 3 x 106 gallon
capacity which are fed by field tiles and storm runoff furnish
water for all non-contact cooling and contact cooling for static
casting, hot piercing and shell quenching. Pond water is also
used for rinsing and flushing the pierced and pickled shells.
City water is used for contact cooling of cast billets and
for sanitary purposes, these waters are discharged respectively,
into the ponds and to the Clinton Sanitary District Sewer. Water
usage is about 387,500 gpd from the ponds and 182,100 gpd from
the city. The present effluent from the ponds consists of
569,600 gpd of water containing 0.57 ppm ~2.7l lbs/day) sus-
pended copper and 0.81 ppm (3.85 lbs/day) dissolved copper
(Pet. Dwg. *EV-S-20l-A).
The manufacturing plant (Plant) has two separate depart-
ments: (1) Stainless steel utensils and (2) Fabricated metal
products. The Utensils Department press draws about 4 x 106 lbs.
of stainless steel circles per year into various bodies and covers
for kitchen utensils. Some of the bodies are copper plated. The
Fabricated Products Department fabricates about 2.5 x 106 lbs. of
coil and strip stock of various metals into a wide variety of
products, including knobs, handles, brackets and studs for the
Utensils Department.
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Only city water is used in the Plant. The 160,000 gpd
usage is divided into about: (1) 35 non-contact cooling,
(2) 7 boiler make up, (3) 7 sanitary and (4) process waters
for pickling, cleanin and plating operations. All effluents
presently a~edischarged to the city sewer system.
“ReverE. Ditch” carries the overflow from the afore-
mentioned ponds for a distance of several thousand feet and
discharges into Coon Creek. During extended drought periods
the upstream sources dry up and the only flow is equal to or
less than Revere’s city water input of 231,000 gpd.* The
seven-day ten year low flow of Coon Creek at the junction with
Revere Ditch is understood to be zero (Pet. 18). Since Revere
contributes ~95 or more to the total ditch flow, essentially
their effluent must comply, not with the effluent standards of
1.0 mg/l but with stream standards of 0.02 ppm copper. Peti-
tioner states that this is an unreasonable burden as no practical
treatment technology is currently available to achieve this level
(Pet~. 10). Revere discussed three alternatives to enable them
to comply with Illinois stream standards:
A. Use of T?~aterRecirculation and Treatment System. Dis-
solved and suspended solids must be controlled so as
not to leave deposits
-
100 recirculation would not
work. The minimum required 10 bleed-off would be
200,030 gpd which when lowered by best practical
treatment would contain 0.5 ppm of copper (Pet. 11)
and when
mixed
with an average of 387,500 gpd of
upstream water would contain 0.17 ppm of copper. To
reach the 0.02 ppm required only 0.8 (16,146 gpd)
bleed-off wculd he permitted. About 294,100 gpd of
process and contact water is required which if placed
in a closed lam with 10 bleed-off would yield 82
more treated water (29,410 gpd) than permitted
(16r146
gpd) to achieve compliance. Estimated costs:
$1,965,600
capital; $106,000 per year operational.
B. Eliminate All Effluent by Recirculation and Evaporation.
As in “A’~ except evaporate bleed-off from contact and
process waters. Estimated costs: Capital $210354600;
$351,091 ~er year operational. The 98,111,800 ft~of
natural gas per year is not available; the #2 fuel oil
(170,884 gallons per year) is on allocation. Petitioner
concludes this expensive and energy intensive process
would yield a highly unfavorable cost/benefit ratio
(Pet, 15)
*This listed as 231,000 gpm (Pet. 9)
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C.
Dilute Tube Mill Pond Water to Achieve Stream
Standards. The pond outfall (001) after treat-
ment (See “A”) is expected to have a flow rate of
618,600 gpd containing 0.43 ppm copper. Copper
free water required to dilute to stream standards
would be 12,681,300 gpd. This water is proposed
to be drawn by nine six-inch diameter wells drilled
into the same water aquifer that serves the city of
Clinton. This amount of water is about ten times
greater than that used by Clinton (Pet. 17) and
would be expected to affect Clinton’s water supply.
The stream bed below the dam does, not have the
capacity to carry this additional water and it is
extremely questionable whether sufficient ground
water is available (Pet. 17). Estimated Costs:
Capital, $1,443,400; $553,164 per year operational.
The Agency recommendation filed November 29, 1976 confirms
most of Revere’s general facts as stated in their petition. In
addition, analysis of ten grab samples of the pond effluent
taken almost monthly from 11/17/75 to 9/21/76 shows an average
copper content of 1.95 mg/l (Range 0.11 to 4.79) and TSS average
19 mg/l (Range 1 to 53). Analysis of samples of wastewater
from the plant to the Clinton Sanitary Sewer System
(six sam-
pies) show the following:
Copper, Ave. 17.6 (Range 1.81 to 66) mg/l
Cr~3, Ave. 2.23 (Range 0.7 to 4.7) mg/i
Cr~6, Ave. 0.73 (Range 0.0 to 2.9) mg/l and
Zinc, Ave. 2.1 (Range 0.9 to 6.0) mg/l (Ag. Rec. ¶11).
The Agency states Revere proposes to isolate and collect
the mill’s pickle rinse water and the plant’s copper plating
rinses, the pickle and bright dip rinses, and the chrome plat-
ing rinses and to treat these waters in an acid neutralizing
and metal hydrate removal system (Ag. Rec. ¶12). Petitioner
predicts the average copper concentration in waters so treated
will be 0.5 my/I. On September 27, 1976 Petitioner submitted
a permit application for the construction of a removal system.
The design maximum flow in the proposed system is 144,000 gpd.
The aforementioned wastes would be subjected to chromium reduc-
tion, brought to a pH of about 8.5, passed through a Lameila
Gravity Settler and centrifuged to de-water the sludge. This
treatment is expected to effect the following changes: (Ag.
Rec. ¶13).
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Treated Effluent (mg/l)
Parameter
Raw Waste (mg/l)
~.
Max.
Chromium (total
5.34
0.5
1.0
hexavalent)
Copper
126.0
0.5
1.0
Iron (total)
5.0
1.0
2.0
pH
2.5 to 6.0
8.0
8.5
TSS
14.5
5.0
6.0
Zinc
5.0
0.5
1.0
Petitioner predicts that the above system would give a pond
effluent of 618,000 apd containing 0.43 rng/l copper or a daily
discharge
of~2.22 lbs. copper per day. During periods of
ex-
tended drought (only city water discharged) Petitioner states
the decrease in flow would theoretically produce 0.97 mg/i
suspended copper and 0.19 mg/i dissolved copper; however, the
increased pond retention time is stated to increase settling
of suspended copper so that Petitioner could still meet its
NPDES point source limitation of 1.0 ppm.
Petitioner states construction of the system could be
completed in eleven months after receipt of the Agency permit.
The Agency is prohibited from granting the permit by Rule 962(a)
of Chapter 3: in that the proposed construction will not
achieve compliance.
The Agency concurs that meeting the 0.02 mg/l copper stream
standard places a hardship on Revere, but believes Petitioner
had not presented adequate data as to why a lower concentration
of copper could not be achieved in the Tube Mill pond effluent.
Petitioner’s proposed plan did not include treating the 40,000
gpd effluent from the billet piercer and quenching operation
(49.37 mg/i copper; 16.47 lbs. copper per day), as well as the
Ajax Furnace (only used during emergency periods) effluent
(20,000 gpd, 4.49 mg/i
copper,
0.7 lbs. copper/day)
.
The sys-
tem as J)rOpOSed would treat only 81,600 qpd. ‘iddition of both
of the above ~treams
would cause the systc’iu Lo operate at
144,100 gpd--only 100 gallons per day over the present
design
maximum. About
17 pounds of copper per day would be eliminated
from the Tube Mill pond (Ag. Rec. ¶21).
The Agency discusses copper removal technology stating at
least four major types of treatment are available: (a) precip-
itation, (b) evaporative recovery, (c) ion exchange and
(d) electrolytic recovery. Processes b, c, and d appear
economically feasible only when conditions are favorable for
recovery.
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Mention of a promising copper
removal research program is
incorporated in the record of Olin Corporation v. EPA, PCB
75-369, regarding Dr. R. E. Wing’s Agriculture Research Service,
United States Department of Agriculture investigation of the
use of starch xanthate with a polyelectrolyte. The Agency con-
tacted Dr. Wing who was of the opinion that addition of an
anionic polyelectrolyte following lime addition could reduce
copper concentrations to about 0.2 to 0.3 mg/i. Starch xanthate
is not yet economically available (Ag. Rec. ¶23).
The Agency cited several sources on the effect of copper
on aquatic life showing again the sensitivity of phyto-and
zooplankton to micrograms/l concentrations of copper.
The Agency’s amended recommendation filed March 31, 1977
recommended the grant of the variance subject to certain con-
ditions. These conditions became the basis for a stipulation
entered into by and between the Petitioner and Respondent.
The Board finds Petitioner, Revere Copper and Brass, Inc.,
would be subject to an unreasonable hardship if compelled to
meet the stream quality standards of Rule 203(f) of Chapter 3
as it pertains to copper in the effluent from its facilities.
The conditions imposed and accepted by stipulation represent
an equitable balance between protection of the subject receiving
stream and reasonable effort and good faith of the Petitioner.
The Board will grant the requested variance subject to the
conditions set forth in the Board’s order.
This opinion constitutes the Board’s findings of fact and
conclusions of law in this matter.
ORDER
It is the Order of the Pollution Control Board that Peti-
tioner, Revere Copper and Brass, Inc., be granted variance
from Rule 203(f) of Chapter 3: Water Pollution as it pertains
to copper in the effluents from their works located near the
city of Clinton, DeWitt County, Illinois for the period of
five (5) years subject to the following conditions:
1. Petitioner will construct its wastewater treatment
system as set forth in its Petition for Variance with
modifications listed below. Petitioner will construct
said system pursuant to the schedule as set forth in
its Petition for Variance, Part V.
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2. Petitioner shall tie in the discharge from the
Tube
Mill plant’s billet piercing and quenching operation
to the proposed acid neutralization and metal hydrate
system; the tie-in of the discharge for the Ajax Fur-
nace is unnecessary as it is used only on a stand-by
or emergency basis and the tie—in would have a minimal
effect on the ultimate effluent quality.
3. Petitioner shall add the necessary equipment to its
proposed treatment system to enable the addition of
a polyelectrolyte to the waste water for copper
removal, conduct tests regarding the results of such
addition and report the findings to Respondent.
4. Petitioner shall continue to investigate means of
controlling its effluent discharge of copper; Peti-
tioner’s investigation shall consist of monitoring
the state of the art of copper removal from industrial
waste—waters as disclosed in literature which is gen-
erally available and other information which may be
available to Petitioner by reason of its copper
fabricating activities, and evaluating the technical
and economic feasibility of the application of any
developments which may occur to Petitioner’s facility.
5. Petitioner shall submit quarterly progress reports
regarding its investigation to the Manager of Respon-
dent’s Variance Section
—
Division of Water Pollution
Control. Such progress reports shall describe any
developments which have occurred during the reporting
period and the results of Petitioner’s evaluation thereof.
6. Within ninety (90) days after starch xanthate becomes
commercially available, Petitioner shall report in
writing to the Board and Respondent on the technical
and economic feasibility of using starch xanthate at
its facility.
7. In the event of the discovery of a technically and
economically feasible method of treatment to reduce
the copper content of Petitioner’s discharges to the
limit of .02 mg/i, Respondent shall determine whether,
under all of the
facts and circumstances in effect and
the law and regulations existing at the time of such
discovery, Petitioner shall be required to initiate
and complete a program to implement such discovery.
If Respondent determines that the implementation of
such discovery is required, it shall so notify Petitioner
and Petitioner shall immediately initiate and promptly
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complete a program to upgrade effluent quality in
accordance with such discovery, provided, however,
that Respondent’s determination may be contested
in good faith by Petitioner on such grounds and by
such judicial or administrative proceedings, legal
or equitable, as may exist at the time of such
determination.
8. Within twenty-eight days after the date of the Board’s
order granting said variance, Petitioner shall execute
and forward to Respondent a Certificate of Acceptance
and Agreement in the following form:
CERTIFICATE
I (We), _________________________________ having
read and fully understanding the Order of the Illinois
Pollution Control Board in PCB 76-246, hereby accept
said Order and agree to be bound by all of the terms
and conditions thereof.
Signed ___________________________
Title __________________________
Date ____________________________
9. Petitioner’s request for reclassification pursuant to
Rule 302(k) of Chapter 3 is dismissed.
I, Christan L. Moffett, Clerk of the Illinois Pollution
Control Board hereby certify the above Opinion and Order
were adoptec~on the
~QY~
day of
~lj1,~7~ ,
1977 by a
vote of
q_~’) .
Christan L. Moffe?t~Clerk
Illinois Pollution Control Board
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