ILLINOIS POLLUTION CONTROL BOARD
November 21, 1984
COLUMBIA TOOL STEEL COMPANY,
)
Petitioner,
)
v.
)
PCB 84—144
)
tLLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent0
)
OPINION AND ORDER OF THE BOARD
(by B0 Forcade):
On September
17, 1984, Columbia Tool Steel Company
(“Columbia”)
filed a petition for variance,
for one year,
from
l3oard regulations establishing effluent limitations for Iron
(35
Iii. Mm.
Code 304,124) and effluent limitations in Columbia’s
NPDES permit implementing that regulation0
On October 24,
1984,
the Illinois Environmental Protection Agency
(“Agency11)
filed
a
recommendation that variance be granted for one year,
subject to
certain conditions.
No objections were received, no hearing was
held.
Columbia owns and operates a steel
fabrication facility in
Chicago Heights, Illinois which employs approximately 115
individuals.
The facility produces tool and die steels by
melting,
casting, forging and annealing carbon steel and steel
alloys.
In the past, Columbia used water from two sources, the
City of Chicago Heights potable water supply and Columbia’s own
water well, for non—contact cooling purposes within the plant.
The cooling water is discharged through
Columbia’s only outfall
(numbered 005) to Columbia’s storm sewer which discharges to
Thorn Creek via the State Street storm sewer
(Pet,,
¶ 1—5).
Columbia asserts that
it
has been unable to consistently
meet the 2.0 mg/i Iron discharge
limitation of
35
Iii. Mm. Code
304.124 because of high background concentrations of
Iron in
Columbia’s water supply.
In December,
1983, Columbia switched
all non—contact cooling water to its own well system which
it
felt was lower in Iron;
however, this did not solve the problem.
~nalytica1 values
for Iron from the two supply sources and
Columbia’s effluent are as
follows
(Pet,
¶
6
& Ex,
1;
Rec.,
p.
3):
2
Iron Values in mg/i
3/13/80
9/83
10/83
10/83
11/83
12/83
1/84
2/84
3/84
4/84
5/84
6/84
7/84
7/3/84
7/5/84
7/6/84
7/9/84
7/10/84
7/11/84
7/12/84
7/13
7/16/84
7/17/84
7/18/84
7/19/84
7/20/84
7/23/84
8/84
Chicago Heights
Public ~ater Supply
11
5.1
6.7
3,7
6.0
11
6.7
21
8.0
6.3
7.2
10
12
13
19
1.8
28
1.8
24
22
13
2.6
2.7
1.8
1.5
1.3
1.1
0.59
2,8
302
2.15
0.8
1.7
2,4
2.93
3,7
2.02
2.2
0.74
Eff1nent
1-~.
3.8
5,0
3,3
1,9
2.3
4.1
4.7
8.2
2.5
3,8
1,0
240
1.3
0.12
,23
3.2
0.33
0.6~
The nearest water quality monitoring station on Thorn Creek
is about
8 stream miles downstream of Columbia,
The 1982 data
from that station shows water quality was above the 1,0 mg/i
Iron
standard in 5 out of
9 samples, with a high value of 6.5 mg/i
(Rec,,
p. 3).
The Agency believes other diechargers could con-
tribute to these water quality violations, and it is not aware of
any problems or complaints regarding high Iron levels
in Thorn
Creek,
or any adverse effect on the aquatic community.
Since the high Iron levels come from the water supply Columbia
has taken steps to reduce the amount of water discharged, hoping
to reduce the problems.
As of September,
1984, the only discharges
from outfall 005 are from the rolling mill cooling water when the
rolling mill, operates.
This amounts to about 30—40,000 gallons
per day (Pet,, ¶9),
The only method for Columbia to ensure
compliance with the discharge limitations would be to construct
a
treatment system for approximately $100,000.
Columbia asserts,
and the Agency agrees,
that this would impose an arbitrary and
unreasonable hardship on Columbia, especially since it would be
to treat only non—contact cooling water.
Date
Columbia’s
Well
l2~7
4.0
Columbia’s
30 day Avg.
2.5
3,5
1.0
5,0
61~206
3
For its compliance plan,
Columbia intends to conduct studies
to demonstrate that Iron concentrations in excess of
2.0 mg/i
result entirely from water supply contamination within the meaning
of
35
Ill. Mm. Code 304.103, which would allow the Agency under
Section 304.141(b)
to increase the NPDES permit effluent limitation
for Iron in Columbia’s permit.
This study and the demonstration
to the Agency are expected to take one year.
The Board finds that immediate compliance with the 2.0 mg/i
Iron effluent limitation would impose an arbitrary and unreasonable
hardship on Columbia.
Consequently, the Board will grant Columbia
approximately a one—year variance with conditions requested by
the Agency.
The Agency recommends
a variance from the Iron water quality
standards of Sectin 302.208.
Based on the limited information
in
this record,
the Board will deny that recommendation leaving the
question open if any future and more concrete dispute should
arise.
This Opinion constitutes the Board’s findings of fact and
conclusions of law on this matter.
ORDER
The Columbia Tool Steel Company is hereby granted a variance
from the
Iron. limitations of
35
Iii. Mm. Code 304.124(a) for its
Chicago Heights facility
(Outfall 005), subject to the following
conditions:
1.
This variance shall expire on December 31,
1985.
2.
During the term of this variance, Columbia’s effluent
shall meet a daily maximum value for Iron of 10.0 mg/i.
3.
Columbia shall continue to monitor and report Iron
concentrations as stated in its NPDES permit.
4.
By October
1, 1985, Columbia shall complete its report
correlating well water Iron levels with effluent Iron
levels and submit the report to the Agency by November
1,
1985.
5.
Within 45 days of the date of this Order, Columbia Tool
Steel Company shall execute a Certification of Acceptance
and Agreement to be bound to all terms and conditions
of this variance.
Said Certification shall be submitted
to the Agency at 2200 Churchill Road, Springfield,
Illinois 62706.
The 45—day period shall be held in
abeyance during any period that this matter is being
appealed.
The form of said Certification shall
be as
follows:
4
CERITFICATION
I,
(We)
,
hereby
accept and agree to be
bound
by all terms
and
conditions of the
Order of the Pollution Control Board in PCB 84—144, November 21,
1984.
Authorized Agent
I,
Dorothy M.
Gunn,
Clerk of the Illinois Pollution Control
Board, hereby certify that the above Opinion and Order was adopted
on the
~j~24-’
day of
_________________,
1984 by a vote
of
.
Petitioner
Title
Date
IT
IS SO ORDERED.
2K7
~
Control Board
01
1)r~c,