ILLINOIS POLLUTION
CONTROL BOARD
November 18,
1983
In the matter of:
JOHN DEERE THERMAL
)
R81-26
DISCHARGE
(EAST
MOLINE)
FINAL
ORDER.
ADOPTED
RULE
FINAL
OPINION
OF
THE
BOARD
(by
D.
Anderson):
On
October
19,
1981
John
Deere Foundry, Deere
& Company
(Deere),
a Delaware corporation,
filed
a petition to amend
the
water
quality
standards
to
set
a
site—specific
temperature
rule
for
its
discharges
to
Sugar
Creek,
a
direct
tributary
of
the
Mississippi
River
in
Rock
Island
County.
The
proposal
was
amended
to
conform
to
codification
requirements
on
November
13,
1981.
A
second
amended
proposal
was
filed
on
July
23,
1982,
adding
site-specific
proposals
for total
dissolved
solids
(TDS)
and
iron
(total).
The
Board
conducted
a
merit
hearing
on
August
24,
1982
at Rock Island and the proposal was again
amended
on that
same day
(R.
125).
An economic impact study
(EcIS) was
prepared by the Department of Energy and Natural Resources
(DENR) (Ex.
21 and 22).
An economic impact hearing was
conducted February 28,
1983, again at Rock Island.
The Hearing Officer
set
a comment period following the
final hearing
(R.
160),
On March 10,
1983 Deere filed a
comment which suggested alternative language.
On March 21,
1983 the Illinois Environmental Protection Agency
(Agency)
suggested
alternative
language
amending
the
effiuenL standd~ds
of
35
Ill,
Adm.
Code
304,
rather
than
the
water
quality
standards
of
35
Ill.
Adm.
Code
302
and
303.
On
April
8,
1983 Deere indicated that
it
had
no
objection
to
the
Agency’s
suggested language.
On May
5,
1983 the Board entered a proposed rule, first
notice Order which proposed to adopt 35 Iii. Adm. Code
304.205.
The text of the proposal appeared at
7 Ill.
Reg.
6697, May 27,
1983.
The Board received comments only from
the Administrative Code Unit concerning codification require-
ments.
On July 26,
1983
the Board
entered a second notice
Order.
The Joint Committee
on
Administrative Rules
(JCAR)
considered the rules at its September 22,
1983 meeting.
No
objection issued.
On October
6,
1983 the Board adopted the May
5 proposal
without change.
Section 304.205 was filed and became effec-
tive on October
14,
1983.
It
appeared at
7 Iii. Reg.
14515,
October 28,
1983.
54-403
—2—
In
a
related matter,
on October
5,
1982 the Board
granted Deere a variance from the water quality standards
for TDS, iron and temperature pending the outcome of this
rulemaking
(PCB 81-163,
49 PCB 21).
The facility in question
is a nodular iron foundry,
with a potential output of 150,000 tons per year.
It employs
about
1,000 persons and is located northwest of Silvis, on a
145-acre tract bordered by the former Rock Island Railroad
and State Highway 84,
It
is about 1.25 miles southeast of
the Mississippi River
(R.
8,
19,
36,
41).
The foundry draws process and noncontact cooling water
from two private wells into the Jordan aquifer.
It draws up
to 1500 gallons per minute from the wells, and up to 100 gal-
lons per minute process water from the City
(R.
9).
It
discharges, pursuant to NPDES permit IL 0002992, via three
outfalls to two unnamed tributaries of Sugar Creek,
a direct
tributary of the Mississippi River.
The discharge is about
1.9 million gallons per day
(MGD)
dry weather flow
(R.
9,
Ex.
22).
The
plant
has
three
discharges,
as
follows
(R.
18,
Ex.
2):
001
Stormwater and cooling water from air
conditioner
(R.
9,
13,
23,
58).
002
Discharge
from
API
oil
skimmer,
which
receives
process
water,
primarily
from
floor
drains,
cooling
water,
cooling
tower
blowdown
and
emergency
induction furnace cooling water
(R.
9,
13,
18,
20,
32,
58,
109,
112,
115)
003
Discharge
from
clarifier which also receives
cooling water
(R.
9,
22,
32,
58,
109, 112,
115).
003 is passed through a lagoon before final discharge.
Deere has committed itself to transfer of the thermal component
of 002 to 003 before December of 1984
(R.
109,
112,
115).
The plant discharges to tributaries of Sugar Creek,
which is a direct tributary of the Mississippi River ~iitha
6.1 square mile watershed.
The Creek flows
in a westerly
direction from the plant about one mile before joining the
Mississippi.
This lower reach is diked and is often more of
an arm of the Mississippi than a flowing stream.
001 and
002 flow north through a ditch to an underground culvert
along 19th Street into the diked portion;
003 flows through
a lagoon to a ditch running east along 8th Avenue before
turning north to meet Sugar Creek above the diked portion
(Ex.
2).
54-404
—3—
The
drainage
has
been
greatly
altered
by
urbanization
and
agriculture,
as
well
as
flood
control
(R.
41,
64,
84,
130,
Ex.
1,
22).
Under
low
flow
conditions
the
Deere
discharge
is
the
entire flow of the tributary ditches, and most of the
flow
of
the
main
stream
(Ex.
1,
p.
11,
Ex.
22,
p.
15).
This
site—specific
regulation
arises
out
of
a
fish
kill
on
January
21,
1975,
which
was
initially
attributed
to
thermal shock.
Subsequent investigations indicated that the
kill was likely due to natural causes
(R.
10).
Regulations Involved
The following regulations are involved in this rulemaking:
35111. Adm. Code
Description
302.208
Water quality standard of 1.0 mg/i
for iron
(total)
302.208
Water quality standard of 1000 mg/i
for
TDS
302.211(d)
Maximum temperature rise of 5F°
above natural temperature
302.211(e)
General use water quality tempera-
ture standard of 60°F winter,
90°F summer
303.331
Temperature standards for Missis-
sippi River
(North) main
stem
304.105
Requirement
that
effluents
not
cause
violation
of
water
quality
standards
304.124
Effluent
standard
of
2.0
mg/i
iron
(total)
304.205
John
Deere
site
specific
Section
TDS
The
primary
source of TDS
is
the
background
in
Deere’s
well water.
This ranges from 1700
to 1900 mg/l
(R.
29,
36,
55).
TDS is also concentrated in cooling tower blowdown
CR.
46).
The discharge meets the 500 mg/l water quality
standards for chloride and sulfate
(R.
67).
Deere ultimately
concluded that it could guarantee levels below 2200 mg/i TDS
(R.
107,
111).
54-405
—4—
The
Board
has
previously
concluded
that
the
treatment
technologies
available
for
TDS
are
expensive,
consume
a
lot
of
energy
and
result
in
concentrated
brines
still
requiring
ultimate disposal
(R76—21, Opinion of September 24,
1981, 43
PCB 367,
6 Ill.
Reg.
563).
The effluent standard was repealed,
leaving
TDS
to
be
regulated
only
through
the
water
quality
standards
for
TDS,
chloride
and
sulfate.
Iron
Deere’s
discharge
is
generally
below
the
2.0
mg/l
effluent
standard
for
total
iron,
and
often
below
the
1.0
mg/i
water
quality
standard
(R.
38,
56,
67,
Ex.
5,
22).
However,
background levels often exceed the water quality standards,
with concentrations ranging up to
4 mg/i
(Ex.
8,
R.
67).
Such elevated iron levels are common in northwestern Illinois
(Ex.
6,
7).
With elevated levels
in the receiving stream,
there
is no possibility of dilution to meet the water quality
standards.
The proposal to modify the iron standard is a
recognition of natural conditions.
Temperature
The original and most important aspect of the proposal
involves the thermal component of the discharge.
Many
processes contribute to elevation of the effluent temperature.
Among these are air conditioner cooling, cooling tower
blowdown, compressor cooling, transformer cooling and inter-
mittent induction furnace cooling
(Ex.
2,
R.
20).
As noted
above,
all of the discharges are heated somewhat, but Deere
has committed itself to route the thermal discharges to 003,
which discharges through a lagoon system.
The discharges do not often cause violation of the
general use water quality standards of 60°F in the winter
and 90°F in the summer;
however, they often raise the
temperature more than SF° above the natural background
(Ex.
1 and 2).
The rerouting to 003 should lessen the
frequency of these violations,
but will not eliminate them.
The thermal violations are most extreme in the ditches;
there is little likelihood of violations in the diked area
of Sugar Creek and none in the Mississippi
(Ex.
22,
p.
21).
The economic impact study evaluated seven options to
avoid thermal violations
CR.
19,
27,
32,
53,
55,
60,
128,
131, Ex.
22,
p.
56):
1.
Deep well injection.
2.
Direct discharge of 002 and 003 to the Mississippi
via a new pressure sewer.
3.
Direct discharge via an existing water main.
54-406
—5—
4.
Total
recycle
of
discharges
002
and
003.
5.
Brine
chiller
with
direct
discharge
of
002
and
003
to
Sugar
Creek.
6.
Direct
discharge
to
Sugar
Creek.
7.
Reroute
003
to
19th
Street
culvert.
Deep well injection was rejected as unfeasible because
chemicals
added
to
cooling
water
would
bring
the
wells
under
the Underground Injection Control permit system
(40 CFR 122
and
146;
35
Iii.
Adm.
Code
704
and
730).
It was uncertain whether options
6 and
7 would guarantee
compliance with the standards,
It
was also uncertain whether
option 3 was
feasible
because the condition of the existing
water main was uncertain.
The least expensive option evaluated would cost $1.7
million, to build a new 10-inch sewer some 9,000 feet to the
Mississippi.
Options
5 and
4 would cost $10.1 and $16.5
million, respectively.
Environmental Impact
Historically Sugar Creek drained a rolling hardwood
forest and a swamp,
It now drains agricultural land and a
city.
In both,
the drainage has been improved to promote
faster drainage.
The lower reaches of the stream have been
channellized and diked for flood control.
Species diversity
is limited by habitat availability rather than the chemical
and physical properties of the water
(R.
64, Ex.
2,
22).
If
the existing discharge flow were routed from the tributaries,
species diversity would be reduced because there would be an
inadequate flow of relatively clean water
(R.
68,
129).
Pools of stagnant water would become a breeding ground for
biting insects
CR.
139).
With respect to iron,
the proposal just recognizes that
the natural background exceeds the general use water quality
standard.
With respect to TDS, the Agency introduced a study:
“Acute Toxicity of Chlorides,
Sulfates, and Total Dissolved
Solids to Some Fishes
in Illinois”, by Paula Reed and Ralph
Evans of the Illinois State Water Survey
(Ex.
14).
This
study indicates that 96-hour median tolerance limits for TDS
are around 11,000 to 17,500 mg/i for Illinois fish exposed
to TDS
in water with a composition similar to that found in
Illinois.
The maximum level allowed under the proposal
54-407
—6--
would
be
2200
mg/i
discharged
under
zero
flow
conditions.
This
would
be
13
to
20
of
the
96-hour
media
tolerance,
greater
than
the
10
required
by
Section
302.210,
but
pro-
viding an adequate margin of safety for this non—toxic
parameter under
the conditions of this discharge.
With
respect
to
the
thermal
discharge,
temperatures
sometimes
exceed
the
90°
F
summer
maximum,
as
well
as
the
SF° over
ambient
limitation.
It
is
reasonable
to
expect
high
discharge
temperatures
to coincide with low flow
conditions
at
times
when
fish
are
already
under
stress
from
high
temperatures
and
low
dissolved oxygen.
However,
if
the
discharge
were
moved
or
eliminated,
the
reduction
in
discharge
flow
would
certainly
produce lethal conditions during times
of
low
stream
flow.
The
option
of
chilling
the
discharge
would
cost
far
more
than any conceivable benefit to the
stream,
which
is habitat limited anyway.
Furthermore,
the
brine
chiller
would
be
difficult
to control to
avoid
bringing
the
stream
to
a
temperature
lower than
SF° under
ambient
temperatures.
As
noted
previously,
Deere
has
committed
itself
to
move
the
thermal
component
of
002
to
003
and
the
lagoon
so
as
to
damp
out
swings
in
temperature,
thus
avoiding
possible
problems
with
thermal
shock.
The
Board
has
therefore
adopted
Section
304.205,
granting
Deere
the
site
specific
regulation
requested.
The
text
is
that
suggested
by
the
Agency
on
March
21,
1983
with
minor
changes.
Deere
had
originally
requested
a
modified
water
quality
standard.
The
Agency
suggested that
the
Board
set
an
effluent
standard
of
98°
F
and
exempt
Deere
from
the
water
quality
standards
for
temperature,
TDS
and
iron
(total).
The
exemption
from
the
TDS
standard
was
to
have
been
conditioned
on
a
discharge
TDS
level of
2200
mg/i.
As
adopted,
Section
304.205
instead
sets
effluent
standards
for
both
temperature
and
TDS,
and
exempts
the
discharge
from
the
water
quality
standards
for
temperature,
TDS
and
iron,
conditioned on compliance with the site-
specific
effluent
limitations.
This
makes
the
TDS
standard
directly
enforceable
without proof of a water quality violation.
The
water
quality
standards
could
also
be
enforced
if
there
were
a
violation
of
the
site-specific
effluent
standards.
This
Opinion
supports the Board’s Final Order, Adopted
Rule
of
October
6,
1983.
54-408
—7—
Board
Members
B.
Forcade
and
J.
Marlin
abstained.
I,
Christan
L.
Moffett,
Clerk
of
the
Illinois
Pollution
Control
Board,
hereb~y certify
that
the
above
Opinion
was
adopted
o~the
JX1
day
of
~
1983
by
a
vote
of
‘ci’ ~
Christan L. Moff&~(,~
Clerk
Illinois Pollution Control Board
54-409