ILLINOIS POLLUTION CONTROL BOARD
June 16,
1983
In the matter of:
)
PROPOSED WATER QUALITY AND
EFFLUENT STANDARDS FOR
)
R81-29
SCHOENBERGER
CREEK
(PFIZER,
EAST
ST.
LOUIS)
FINAL ORDER.
ADOPTED RULE
OPINION
OF
THE
BOARD
(by D. Anderson):
On
December 3, 1981 Pfizer, Inc.
ipfizer),
a
Delaware
corporation, filed a proposal for site specific water quality
and
effluent
rules which would allow the direct discharge
of
non-contact cooling water to Schoenberger Creek in East
St. Louis,
St. Clair County.
The proposal was in codified
form, modified at the request of the Board from an earlier
version filed September 22, 1980,
but never authorized for
hearing
(Order of October 30,
1980).
On February 10,
1983
the Board sent a proposal to first notice
(7
Ill.
Reg.
2270,
February 25,
1983).
On March 10,
1983 the Board adopted a
Proposed Opinion for public comment.
During the first
notice period the Board received comments only from the
Illinois State Library and the Illinois Environmental
Protection Agency, Division of Water Pollution Control.
On April
21, 1983 the Board sent the matter to second
notice with no changc~in the
proposed
language.
The
bLa.Ei.
of
the Joint Committee on Administrative Rules recommended
the
addition to Section 304.204 of a cross-reference to
Section 304.124,
In a separate Order the Board has
adopted
the proposed language with the recommended changes.
This
Opinion is the Proposed Opinion as modified in response to
comments.
The following provisions are involved in this rulemakinq,
utilizing the numbers of the first notice Order:
35
Ill.
Adm.
Code
Description
302.208
General use water quality standard of 1,0
mg,~1
iron
(total)
52-421
—2—
303.353
Proposed site specific water quality standard
of 20 mg/i iron
(total)
304.124
Effluent standards of 2.0 mg/l iron
(total)
and 15.0 mg/i total suspended solids
304.204
Proposed effluent standards of 20 mg/i iron
(total)
and 37 mg/i total suspended solids
On May 21, 1982 the Board held
a public hearing on the
proposal at Belleville.
Consultants and employees of Pfizer
testified in favor of the proposal,
as did representatives
from the City of East St. Louis.
Representatives of the
Illinois Environmental Protection Agency
(Agency) appeared
at the hearing and questioned Pfizer’s witnesses,
but offered
no testimony or exhibits.
There was no other public partici--
pation,
aside from a newspaper reporter.
The Board received
a public comment from the City of East St. Louis supporting
the proposal.
At the hearing Pfizer requested that the Department of
Energy and Natural Resources
(DENR)
give a “negative declara-
tion”
instead of an economic impact study
(R. 42).
In
letters dated November 10
and 16, 1982, DENR informed the
Board that a negative declaration had been made instead of a
study.
On December 7,
1982, the hearing officer closed the
record except for final comments.
At the hearing, the Agency was granted leave to request
additional information from Pfizer concerning any wastewater
treatment contract between Pfizer and the City of East
St.
Louis, projected charges by the American Bottoms Regional
Plant and costs of treatment facilities
(R.
176,
208,
213).
The Agency asked its questions in
a letter dated July 6,
1982.
Pfizer responded in a letter dated January 7, 1983.
Although there is considerable argument in the final comments
concerning these matters, neither party requested that the
record be reopened for additional hearings.
The letters of
July
6, 1982 and January
7,
1983 are therefore incorporated
into the record.
FACILITY DESCRIPTION
The plant in question is situated inside the City of
East St. Louis in T2N, R9W of the 3rd P.M.,
St. Clair County.
The location is at 2001 Lynch Avenue, which is about one
mile east of the intersection of Interstate 55 and 70 with
52-422
—3—
Interstate
64.
The plant is
in an industrial area bounded
on the west by the Southern Railroad and on the east by the
Terminal Railroad.
There are residential areas to the west
and east of the tracks
(R.
76, Ex.
10,
11,
12).
The plant
employs 375 people with an annual payroll of about $9,000,000.
The plant produces two lines of products,
one based on
barium sulfate,
the other iron oxides.
The barium sulfate
is used as a metal undercoating in appliance steels.
The
iron oxide products are used for coatings and magnetic tape.
The plant precipitates “synthetic” iron oxides from liquors
made from scrap iron, and grinds both natural and synthetic
oxides into powders
(R.
161).
There appear to be three wastewater streams at the
plant:
stormwater,
process water and non-contact cooling
water.
Stormwater
is contaminated with iron oxides in the
form of suspended solids which are picked up from the plant
grounds
(R. 136,
164).
This is accumulated in a settling
pond and discharged to the East St. Louis sewer system
(R.
136).
Process water is subjected to pretreatment con-
sisting of pH adjustment and settling before it is discharged
to the City’s sewer system
(R.
167).
Non-contact cooling
water
is presently discharged directly to the City sewer.
Process water is purchased from the Illinois American
Water Company, while cooling water comes from wells on the
plant property.
Process and cooling water each ~mount to
about
2 million gallons per day
(2 MGD, 7.6 x
10
liters per
day) (R.
168)
Cooling processes include boiler cooling tubes, but are
primarily tube and shell heat exchangers used to
COOl
products
(R.
169,
183,
193).
A typical application seems to be
cooling batches to crystallize a product
(R.
217).
The cooling water enters at
540
F and exits at 56°F
(R. 173,
183).
Some processes are designed around having a
large flow of cooling water at this temperature to produce a
precipitate with the right color or magnetic properties
(R.
217).
This imposes
a constraint on alternatives such as
refrigeration or other water sources.
Pfizer’s proposal is intended to allow direct discharge
of the non—contact cooling water.
The proposed discharge
would be to an existing, but unused, storm sewer which runs
under the Terminal Railroad tracks at the northeast edge of
the plant property.
The storm sewer
flows about four blocks
through
a residential area before discharging to Schoenberger
Creek just north of Morris Avenue
(R.
80,
82,
Ex. 10).
Pfizer has an NPDES permit to discharge to the storm sewer,
but has never done
so because it could not meet the permit
conditions
(R. 143).
52-423
—4—
The iron and suspended solids
in the discharge are
naturally occurring background in the well water,
They do
not come from the processes, although they are contaminants
which would be expected in the process water.
The cooling
system is protected from leaks since it
is at a higher
pressure than the processes.
When it goes to direct discharge,
Pfizer will monitor pH and turbidity in the cooling water
for indications of leaks,
and will provide for emergency
diversion to the City sewer system
(R.
i8l).
The well water contains dissolved iron and suspended
solids.
The dissolved iron is mostly ferrous
iron,
since at
neutral pH ferric iron precipitates as ferric hydroxide or
ferric oxide.
On exposure to the atmosphere ferrous iron is
oxidized to the ferric state, at which time it precipitates
forming suspended solids
(R.
132).
The Board at one time regulated dissolved iron.
This
was repealed in R76-2l at about the same time this proposal
was filed
(35 Ill. Adm. Code 304.124,
6 Ill. Reg.
563,
effective December 24,
1981).
Iron is now regulated as
total iron,
which includes both ferrous and ferric.
The
total iron is included in suspended solids to the extent it
is in suspended form.
Analysis of well water and cooling water reveal the
following average levels of contaminants
(Ex.
13,
14,
l5~:
Average Concentration
kg/day
Parameter
or Range
at
2 MGD
Iron
(total)
14.1 mg/i
110
Iron
(dissolved)
1.5 mg/i
11
Total Suspended Solids
32
mg/i
240
Total Dissolved Solids
637
mg/i
4830
pH
6.84 to 7.58
DIRECT DISCHARGE AND ALTERNATIVES
Pfizer has several alternatives, including the foi~-
lowing:
1.
Deep well injection;
2.
Use of City water for cooling;
3.
Recycle of cooling water with mechanical chilling;
52-424
—5—
4.
Treatment of well water prior to use;
5.
Treatment prior to direct discharge;
6.
Continued discharge to the City sewer system;
7.
Direct discharge of untreated cooling water, as
requested.
Reinjection of non—contact cooling water into the
aquifer from which it was drawn may be permitted as
a Class
V well under the underground injection control program
(35
Ill. Adm. Code 704.124 and 730.105;
6 Ill. Reg.
12,479),
However, there appears to be a problem with plugging of the
aquifer unless suspended solids are removed prior to reinjec—
tion
(R.
204,
215),
City water is too warm for Pfizer to use in the summer
(R.
202).
Cooling towers will not produce cold enough water
during periods of high humidity
(R.
203).
Mechanical chilling
of recycled water would cost about $1,105,000 to build and
$210,000 per year to operate
(Ex.
17).
Two other options include treatment of well water prior
to use or prior to discharge.
These would involve essentially
the same treatment.
Because Pfizer experiences no difficul-
ties from operations with the untreated cooling water
it
would gain nothing by treatment prior to use.
There may
also be difficulties with temperature increases during
treatment
(R.
148).
Pfizer’s treatment proposal involves aeration, alkali
addition, pH control and clarification with polymer addition
(R.
199,
209,
217),
Pfizer first estimated that this would
cost about $1,588,000 to build and $75,000 per year to
operate
(Ex. 17).
In the post-hearing submissions the Agency estimated
that the cost of the clarifier would be $187,000, much less
than the $800,000 used in Pfizer’s estimate
(letter of July
6.~ 1982).
In its response Pfizer indicated that a 60-foot
clarifier would cost around $250,000, again less than the
$800,000 estimated.
However, Pfizer also indicated that it
had decided the 60 foot clarifier would not be large enough
to assure compliance with the
2 mg/i iron (total)
standard.
Pfizer indicated that it would “stand with the $1,638,000
estimated cost”
(Attachment to letter of January
7,
1983).
In the cover letter the cost was quoted as $1,688,000.
These are both different from the $1,588,000 originally
quoted
(Ex. 11).
The construction cost estimates therefore
range from $975,000, with the Agency’s clarifier estimate,
to $1,688,000, which could have been a typographical error
intended to be $1,588,000.
52-425
—6—
The treatment scheme
is intended to meet the
2 mg/i
effluent standard for iron and 15 mg/i standard for suspended
solids.
Pfizer has considerable experience in treating for
iron,
including its process water pretreatment plant at the
facility.
The problem is that the iron is so dilute that a
fine precipitate will form on aeration.
It would require
polymer addition and unreasonably long settling times
to
achieve compliance with the standards.
The cost estimates for treatment may be overstated for
other reasons,
Pfizer’s witness admitted that alkali addition
and pH control might not be necessary.
A much simpler
treatment scheme consisting only of aeration and detention
might be capable of meeting intermediate standards for iron
and suspended solids at a reasonable cost
(R.
217).
Such a
scheme would at least lessen the oxygen demand of the waste-
stream which is discussed below.
However, the record is not
sufficient to fix a suitable compromise.
Pfizer presently discharges to the East St. Louis sewer
system.
The City’s treatment plant receives a dry weather
flow of 10 to 14 MGD.
The
2 MGD of non-contact cooling
water thus represents 14
to 20
of dry weather flow
(R.
46).
East St. Louis estimates that elimination of this flow will
increase retention time and increase suspended solids removal
efficiency by
5 to 8
(R.
47).
The City will also save from
decreased wear on equipment and decreased utility bills from
reduced pumping
(R.
49).
At the time of the hearing Pfizer paid a flat rate of
$80,000 per year to the City for sewer service
(R.
174),
The Agency questioned whether the City would gain if this
contribution were lowered.
Pfizer indicated that the rate
would be increased regardless of whether the cooling water
discharge continued
(R.
175).
The East
St. Louis plant will soon be replaced by the
American Bottoms Regional Plant.
Pfizer will pay a rate
based on flow with a surcharge for solids
(R.
176).
The
estimated charge by American Bottoms would be $708,435 per
year for the cooling water
(R.
177, Ex.
18;
letter of Janu—
ary 7, 1983).
The discharge of relatively clean wastewater to the
American Bottoms plant is
itself objectionable.
An increase
in flow to a well operated plant will not change the concen-
trations of the contaminants discharged.
An increase in
flow entering the plant, even of distilled water, would
result in an increase in the discharge flow and an increase
in the mass of all contaminants discharged.
Even though the
52-426
—7—
plant would still comply with concentration limits,
a larger
mass of contaminants would be washed through it.
The direct discharge of cooling water, the alternative
requested by Pfizer, will require changes in piping costing
$560,000, with annual operating costs of $15,000.
STREAM
DESCRIPTION
Schoenberger Creek arises to the east of East St.
Louis
(Ex.
11).
It flows as an intermittent stream in a north-
westerly direction through the residential neighborhood to
the east of the plant
(Ex.
10).
From about two blocks
before the proposed discharge from the storm sewer,
it flows
alongside the Penn Central and Baltimore and Ohio tracks.
Immediately after the proposed discharge point it turns
north and flows under the tracks into an uninhabited, marshy
area.
Near here it loses the name “Schoenberger Creek” and
becomes an unnamed tributary of the Cahokia Canal.
About
1000 feet north of the tracks,
it turns west and flows under
an interchange on Interstate
55 and 77.
Beyond
the
inter-
change it turns northwest and receives an Illinois Department
of Transportation
(IDOT)
discharge which will be discussed
below
(R.
80).
Beyond this discharge, the unnamed tributary
is
a perennial stream
(R.
88,
Ex.
16).
The unnamed tributary joins the Cahokia Canal about
2 miles northwest of the plant, still in the marshy area
north of the railroad tracks.
The canal
flows west and
southwest to join the Mississippi about
2 1/2 miles west of
the plant.
Prior to that, the canal flows under the levee
formod by the tracks and into an area consisting of railroad
yards and the National City Stockyards.
There are some
residences in this area.
The entire route from the discharge point to the Missis-
sippi has been channelized and leveed to a high degree.
The
canal disappears underground at several points in the stock-
yards and railyards.
The marshy area through which it first
flows is subject to flooding from the Mississippi
(R.
83).
IDOT operates a series of 42 wells near the interchange
to lower the water table to protect the roadbed
(R.
88).
In
1978,
during a period of drought, these wells pumped
6 MGD
(R.
91).
This is drawn from the same source
as Pfizer’s
cooling water.
The flow enters the unnamed tributary near
the interchange.
As a general rule the Board does not consider non-
complying discharges in mitigation of the effects of other
discharges.
However,
the IDOT discharge is operated by
a
52-427
—8—
State agency as an integral part of a large capital improve—
ment, the Interstate highway.
For purposes of this decision,
the Board will accept the IDOT discharge as a fundamental,
irreversible change in the stream.
The Pfizer discharge should have no adverse effect
downstream of the IDOT discharge.
The segment which is
subject to degradation is the stretch
from the discharge
point to the interchange,
a span of 2000 to 3000 feet through
an uninhabited, marshy area.
This intermittent stream
contains pools of stagnant water during times of low flow
(R.
83).
These pools are often contaminated with raw sewage
from illegal sanitary discharges to the creek upstream in
the residential areas
(R.
97, 127).
The bottom consists of
sludge deposits up to one meter thick
(Ex.
16).
WATER OUALITY
Environment Energy Consultants
took stream samples for
Pfizer on two dates
in March and April,
1981
(Ex.
14 and
15).
Samples taken near the proposed discharge point and
just upstream of the IDOT discharge showed the following
average contaminant levels:
Parameter
Average Concentration or Range
Iron
(total)
0.77 mg/i
Iron
(dissolved)
0.11 mg/i
Total Suspended Solids
13 mg/i
Dissolved oxygen
15 mg/i
(10 to
11
a.rn.,
10°C.)
Fecal coliform
4300 counts/100 ml
pH
7.37
to
8.26
Below the IDOT discharge,
iron,
suspended solids and pH
changed to levels comparable to Pfizer’s well water, which
is summarized above.
Fecal coliform fell to about 23 counts!
100 ml.
Dissolved oxygen fell to about 8.8 mg/i,
still well
in excess of the minimum levels required by Section 302.206.
The increased flow of relatively clean water from the
Pfizer dishcarge will improve the water quality in the
stretch prior to the IDOT discharge in a manner similar to
the improvement downstream of the discharge.
However, this
is more because of the illegal sewage discharges
to the
Creek than the absolute quality of Pfizer’s discharge.
52-428
—9—
The adverse impacts expected from the proposed dis-
charge primarily center on the oxidation of ferrous iron and
precipitation of ferric oxide or hydroxide.
Essentially the
same process will occur in the stream as would be employed
in the treatment for iron.
The ferrous iron will exert a
chemical oxygen demand on the stream, and ferric iron will
coat the bottom of the stream, destroying habitat.
Fine
suspensions of iron can be toxic to fish by coating gills
(R76-21,
Economic Impact Study on deletion of dissolved iron
standard).
Downstream of the IDOT discharge there
is a
depression of oxygen levels and an orange deposit in the
stream bed
(R.
114,
129,
136).
it
is
reasonable to anticipate that similar effects
will be noted downstream of the Pfizer discharge.
However,
Pfizer has not requested modification of the dissolved
oxygen or unnatural sludge provisions
(Sections 302.206 and
302.203).
Pfizer has even denied that such effects will
occur.
Should such problems arise,
Pfizer will be expected
to solve them.
Aeration prior to entry into the storm
sewer could alleviate these problems.
The entire watershed downstream of the discharge has
been dedicated to storm drainage and flood control.
The
channelization and leveeing limit habitat availability
so
that
it will never approach a natural backwater area.
rhe
existing IDOT discharge seems to be
a positive factor in the
stream.
The Pfizer discharge will further improve the stream
water quality, and will be fully consistent with the primary
use for storm drainage,
The increased flow and lower contami-
nant levels could increase utilization of this stream reach.
REGFLEX
Pursuant to Section 4.03 of the Administrative Procedure
Act, the Board gave notice of the hearing to the Small Business
Office of the Department of Commerce and Community Affairs.
Pfizer is not a small business, and no one came forward with
any
small business impacts
(R,
262)
IMPACT OF FEDERAL REGULATIONS
Federal regulation of water quality is through USEPA
review of the State’s water quality management plan.
The
revised water quality standards may require incorporation
into the plan and USEPA approval.
This
is handled by the
Agency, which has given no indication that
it anticipates
any difficulties
in obtaining any necessary federal approvals.
52-429
—10—
Federal
regulation
of
effluents
is
through
incorpora-
tion
of
federal
effluent
regulations
from
40
CFR
400
et
seq.
into
NPDES
permits.
This
is
done
by
the
Agency,
which
issues
the
permits.
If
the
federal
regulation
of
this
effluent
is
more
stringent
than
the
site
specific
effluent
standard,
the
Agency
will
impose
the
federal
effluent
standard
in the permit.
However, there
is no indication that this
will be
a problem.
PROPOSED ACTION
On February 10,
1983 the Board sent a proposed rule to
first notice.
The proposal differed from Pfizer’s proposal
to the Board only
in minor respects.
The Board has limited
the effluent standard so that it applies only
to discharges
from “an existing facility owned by Pfizer, Inc.”
This is
intended to bring the matter back before the Board should a
new facility, built by Pfizer or anyone else,
seek to make a
similar discharge.
The phrase “owned by Pfizer”
is intended
to identify the facility as of the time of adoption of the
rule,
and
is not intended to terminate the rule in the event
the plant
is sold to someone else.
The Board has made other editorial changes in the
proposal, the most important of which is specification of
“St. Clair County” rather than “Madison County”
(Ex. 11).
This apparently was
a typographical error in Pfizer’s proposal.
This Opinion supports the Board’s Order of this date.
I, Christian L. Moffett,
Clerk of the Illinois Pollution
Control Board, hereby certify thpt the above Opinion was
adopted on the
_______
day ~
1983 by a vote of
Illinois
Pollution
Board
52-430
