ILLINOIS POLLUTION
CONTROL BOARD
June
8, 1978
E,
I.
DU
PONT
DE
NEMOURS
AND
COMPANY,
Petitioner,
vs.
PCB
76~30
ENVIRONMENTAL
PROTECTION
AGENCY,
Respondent
OPINION
AND
ORDER
OF
THE
BOARD
(by
Dr~ Satchell):
This
matter
comes before the
Board on the variance petition
of
E,
I.
du Pont de Nemours and
Company
(Du Pont)
filed Febru-
ary
2,
1976
seeking
relief
for
their Seneca Plant from
Rule
406
of
Chapter
3:
Water
Pollution
Rules
and Regulations of the
Pollution Control Board which,
in
pertinent part,
restricts
ammonia nitrogen in effluents
discharging into the Illinois
River,
inter alia,
to not more than
3,0 mg/I if the total
dischar~~of
ammonia
nitrogen exceeds
100 pounds per day.
The said Petition was deemed inadequate
by the Board and an
Order,
dated February 11,
1976, requested assurance that
Du Pont would not be in violation of
other regulations
or
rules and more specifically Rules
203(f),
402, and 401(c)
of Chapter
3
and the Board~sProcedural
Rule 401(a)
(6).
A “Supplement to Petition for Variance”
was filed with the
Board on March
29, 1976.
The Petitioner
was asked
in an
Interim Order of the Board, dated
May
6,
1976,
to consider
upgrading weak regenerating ammoniurn
nitrate solutions
to
fertilizer grade.
Du Pont responded
to the Interim Order on
July
12,
1976 and,
in addition, had
submitted to the Environmental
Protection Agency
(Agency)
additional
data which was received
by the Board June 17,
1976.
An open
waiver from Procedural
Rule 408 was received from Du Pont
on May 6,
1976 allowing the
Agency and
the
Board more time to
consider the case,
The Agency
filed its recommendation, dated July
16,
1976,
to deny or
dis-
miss
as inadequate
Lhe instant
peLition.
In
the March
29,
1976
filing
and
again
in a separate August
5,
1976
filing
entitled
“Request
for
Standards
Interpretation~,
Du
Pont
re-
quested
the
Board
determine
the
applicability
of Rule 406 to
Petitioner~s
discharges~
Du
Pont
filed a “Response
to EPA
Recommendation”
on
August
30,
1976.
A
hearing
was
authorized
in
this matter on November 10, 1976
in
response
to
Petitionervs
November
5, 1976 motion for oral
argument or hearing authorization.
A hearing was held
(March 7,
1977)
at Morris,
Illinois in Grundy
County.
Both parties
filed closing statements:
Du Pont
on March 28,
1977, titled
“Hearing
Closing
Statement.”;
the
Agency
on March 29,
1977,
titled
“Agency~s Final
Argument”.
Du Pont~sApril
8,
1977
30
—
353
motion for oral
arument
was
denied
by
the
Board
April
14, 1977,
but filing
of
briefs
was
permitted.
Subsequently
Du Pont
filed
on
May
2,
1977
a
“Concludinq
Statement”
and
the
Agency
filed
a
response
May
5,
1977.
On March
6,
1978 Du Pont filed an
amended
petition
and
rescission
ot
waiver.
The
Agency
filed
its
recommendation
May
2,
1978
to
qraIn~the variance
subject
to
specified conditions.
The Du
Pont plant is located in Grundy
County
near
Seneca,
Illinois
and
discharges
its effinerit.
into
the
Illinois
River.
Products
manufactured incLede:
citric
acid;
ammonium
nitrate
(AN)
prills
for
explosives; Elvace~’
acetate,/ethylene
copolymer
emulsions;
and
Tovex~:easer
gel
explosives
(aqueous
solutions
of
organic
and
inorganic
nit:cates)
Sulfuric
acid
is
purchased
and
residual
acid,
dynamite
blasting
caps,
and
nitro-cellulose
are
transshipped from the
plant.
Vapors from
the
neutralization reaction between anhydrous
ammonia and nitric acid to form AN are scrubbed and constitute
one of the works principal waste flows.
The countercurrent
air in the 200 foot high prillinq tower passes the 95
AN
spray and the very fine droplets
are
carried as particulate
AN out of the tower and then to the grouncL
These emissions
approximate 900 lbs~/day (equivalent to
158
lbs. (NH3-N)/day).
Other waste products are generated primarily
by
leaks,
spills
and cleaning operations.
Du Pont
states there are ahou~: 50
plants
in the U.S.
producing AN with
capacities from
30
to
1,000
tons per day and
that of
the
7
x
l0~tons total product/os one
half was sold as
fertilizers
and
explcs:kTes
accounting
foe
most
of the rest.
In
the
original
etitioc
(Pet.
at
9)
,
Du
Pon~
states
that
the
yet
unpublished
Federal
Puidelines
will
likeit:
allow
the
following
discharges
for
ammonia~N
for
the
Senece
iN plant, nitric acid
plant
and
water
gel
orodnct~on:
Facility
Da~.I~
Avg.
Daily
Max.
/doy
(lbs
.
/day)
AN
p1an
t
400
~
Nitric
acid
10
01~
Water
gels
42
84
These
specs i~I i.vc
1 ~ures
are
of
intoeac
1;,
out
do
not
state
what
actual
dischaec~os
are
bnLnq
made
either
in
extent
or
nature.
‘Petitioner
reoueet~s
.~that he be al owed
so discharge
ammonia—N
at. the
limits
set
be
the
federal
cuidolines
for
ammonium
nitrate.
nitric
ac
d
and
water
gel
r~anufacture,
until
such
time
as
a cennoloqy
has
teen
developed
end
sen
be
instal:Led
which
wi.
1
anab
e
Petitioner
to
ccmpiv
W~
t
Rule
4 Of
in
a
safe
and
econorrically
fossihie
manner.
(Pet.
at
10,
ii)
Using
the
above
f :~
ct
ca ~cula
OCs
tita a
H
ei
i:
J
scharc;t.:
would
increase
ide:
ai~unOn
~s~~seetcation bt
ens
shan
0. 03
me/I
at
the
10—ye
as
fi
0
Di se/O
at normal
flows
of
the
Illinois
River.
—3—
Du Pont submitted
five exhibits with their petition.
Exhibit
I supports the
contention that recycling waste
streams
in the AN plant would subject
Du
Pont
to
unreasonable
risks of
explosions because of impurity
sensitization of AN.
The
Board
is aware of such risks and
agrees
that
recycling
does
not
present a viable abatement
procedure.
Exhibit II
is an
affidavit
from
Clark, Dietz and
Associates-
Engineers,
Inc. stating Du
Pont had engaged them to
study
waste
water treatment at the Seneca
Works
and
that they had
prepared
a preliminary report and
pages
19
and
20 of the report
were
attached.
The two pages
briefly
discuss
three treatment
methods——
overland flow, reverse
osmosis and
ion
exchange,
They
state
that reverse osmosis would
reduce the poLLutant volume
to about
5
of the original flow which
would
be
about 14,000
gallons;
further reduction would require
evaporation.
in the
“overland
flow” method they state the
anticipated
ammonium
nitrate
con~~
centration is 1.33 g/l,
It
was
stated
that based on
rule of
thumb figures of 1/4 inch
water
per
acre
(A)
per dry
day a
minimum of 42 acres would
be
required.
if the
“assimilation
rate”
of the land is considered
to
be
300-600
lbs.N/A/year,
a
minimum of 340 A would be
needed,
Ion
exchange was
recommended
as the system of choice.
The substance of Exhibits
III and IV with the petition is
that the overland flow and
reverse
osmosis
methods
are
not
appropriate methods:
(1)
the
overland
flow would
require, even
with
very heavy loading
(up
to
3400
lbs.AN/acre
per
year),
as
a
minimum 340 acres, and
(2)
available
information
indicates
a
membrane is not available
to
reject AN;
thus, eliminating
reverse
osmosis.
Exhibit V and VI are
authorization,
specification
and
expenditure documents relating to a
proposed ion exchange unit
to be supplied by Chemical Separations
Cove s:ation,
These are
limited to drawings, procurement of
critics
material.
Authorized expenditures include
$l40,00U
roe
“Engineering
and
Design” and $410,000 for
“Cancellation
Charges” or a total
of
$550,000.
Du Pont~sresponse
to
the
Order
of the Board of
February
11,
1976 filed March 29,
1976
requested
clarification
of
interpreta-
tion
for
Rule
406.
The Board notes with interest Mr.
Curri&s
opinion in this matter,
3 PCB
406
(1972)
,
and his specific
reference to the Illinois
River and also Mr. Dume1le~s
opinion,
15 PCB 423
(1975).
In the
record
concerning
“In the
Matter of
Water Quality Standards
Revisions”
PCB
R72-4,
the testimony
of
Mr.
Carl
Blomgren taken September 13, 1972
(R.
21,
22)
includes
the following:
“In keeping with
the Board~ssuggested amendment
to Rule 406, we are concerned with
this on the
basis
by the definition of
population
equivalent,
we can
very easily miss the impact
from
industrial
discharges
30
—
355
and this
computai.
ci
2,5 milligram
per
L
LI
times the five
milL
-
-
i-h.
cut—off of
fifty
tL
tion,
times the
corc
This ends
up
1
-s
per day and we
cone.
as we worded
it, e~c
LI
not discharge
an ~i-
Mr.
Blomgren~s
testimorv
rule
which
is
entitled
-
-
a
limit the amount of ama
to
specific waters.
The
L
-.
La
Rule 406
is likewise exist
a
by
Mr. Dumelle
(R.
26)
c
principally
to industxz
governments which have
and bond issues.
It can readily be
-
Permitted effluens
C
2.5 mg NH3-N/l
(ppm;
Weight of
1 ppm
c-i
Thus:
2,5 ppm x
8.35
x
IL
1 PE
=
100
gal/d~mv,
(20.88
x-
io6~
x
(5 x
In Du Pont~s ~
-
Petitioner contends
and
suspended
sol
Id-
Rule
104 definition
effluents will cont
~.
Rule
406, promulgated
should
and will
be
the
e
-
In Du Pont~s
orijan-
by a senior staff
er.~p1
which
states:
“That both
Clark, t~
treatment methods
£ ~s
land flow
irrigation
biological treatment en
ion exchange
to
oc
capable of aehice
H
by Rule 406.”
And
also,
“That the major effluent
treatment
feature still to
be resolved
is the disposition of the ion
exchanger weak
ammonium nitrate
regenerant
solution.”
Du Pont contracted with
Centec Consultants,
Inc.
of Reston,
Virginia,
to make an
independent
assessment
of
the
feasibility
of preparing
urea-ammonium
nitrate
(UAN)
solutions
from the
regenerant solution.
On page
5 Du Pont states,
“The
use
of
the more dilute 16
AN
solution created by the ion exchange
system instead of the
83
AN solution produced at the AN plant
modifies the water balance
to the point
where
evaporation is
required to produce a
commerciall
acceptable concentration of
the final blended
solution
being produced.”
-
The weak 16
AN
solutions
(5.6N)
that
would
be produced
by ion regeneration
present unique problems
under Du Pont’s
conditions:
(1)
They
are highly corrosive and therefore
difficult to store or
ship;
(2)
They are produced
in too low
a quantity to justify
facilities
to upgrade
to AN, or UAN
direct application grades
or to fertilizer
ammoniating
solutions;
and
(3)
They are produced
in too large a quantity
and too low
a grade to dispose of
locally.
The Board is
convinced
that,
at
this time,
Du Pont cannot
economically
dispose
of
the regenerant
solutions
as fertilizer.
In the Order of
the
Board
dated February
Il,
1976 Du Pont
was asked for assurance
that Rules
203 (f)
,
402
and
401 (c)
of
Chapter
3 would not
be
violated by granting
the
variance.
Du
Pont
stated
that
the
standard for
ammonia-N
of
1.5
mg/I
is
already being exceeded
and
their effluent would result in an
insignificant increase
of about 0.03 mg/I at low flow of the
Illinois River,
This
is
the
same
information
that
was
submitted
in the original
petition
and
appeared
to be
based
on a dis-
charge of 452 lbs.
NH3-N/day,
Later
docuenuts,
filed
with
the
Agency June 17,
1976,
indicate higher d
Large
rates.
Du Pont
calculates the latter
figures would result
in
concentrations
caused by Du Pont’s
effluent
at the edge of
the
mixing zone
as follows:
____
Ammonia-Nitrogen
Condit
i
O±~
__________
Low Flow
Mean Flow
a.
Until July
1,
1976:
1.
Maximum Daily Load
9200
2,2
0,64
2.
Average Daily Load
4300
1.0
0,30
b.
After July
1,
1976,
until
Federal guidelines
achieved:
1.
Maximum Daily
Load
6000
1.4
0.42
2.
Average Daily Load
2500
0,59
0,17
c.
Federal Guidelines
1.
Maximum Daily
Load
980
0,23
0,068
2.
Average Daily
Load
450
0.11
0.031
30
—
357
—6---
Petitioner states that
if
lEb
that at no time, will the
dischaoLje CXC?-$
requested.
Rule 402 would
be
vLLLL
t
level of NH3N already in
the river
nj
merit among other dischargers
as prv ~ed
Apparently Du Pont has
recon
La-
cC
denitrification losses by
overia-~
as evidenced by data submitted
to
Donald M~Parmelee to
r~.
T.
Conno
Report entitled “Program
Develops
0.
R. Buehler and D. M.
Parmelee
properly stress the need
for caL
sity of keeping the salt
content
-
the soil type.
The Agency’s recommendation
tiL~~
that Du Pont had failed to
submai
Is
justify the grant of a
variance,
in
deficiencies
were noted by
the tigen
a
a)
No statement has
been nmd
as
quantity and complete
des—
ii
taminants currently
dIschdi
b)
Insufficient data
has LLei
cating the nature
and e~a
—
failure to meet
Rule 400
c
c)
An inadequate and
incompit-
proposed pollution
contCol
C
presented;
d)
A time schedule
to bring
tIn.
into compliance
has
not
beer-
-
e)
A
detailed
description
or
LI
the entire facility
inL
-
been presented;
f)
Data concerning past
efforts
pliance has not
been
ps~cnt~.
g)
Data concerni,.ng
costs and
te~i-.
-
alternatives has
not
been
sits
h)
The environmental
impact at
—
requested variance
has not LIsi
addressed.
~pest
is granted,
ui-ti- times
the
value
a
use
of the high
abject
to adjust-
I ~is
Rule.
~ssibility
of
anead
irrigation
‘Letter
from
2,
1976 and
Irrigation” by
tflese
reports
trees,
the neces—
~il
solution and
21,
1976, stated
sufficient to
r,
the following
ion
of
has
been
~i-cility
1
-
3
bring
)S not
t- .‘e
corn—
LI
the
.~te1y
The Agency noted that
Du PotiL’s
c-it
utained
floating debris, excess
concentration
cf an
c-via,
cyanide
(in violation of Rule 408(a)),
and total d~~.~lved
solids
ota
1
—on-
audi
-
~ esent
—7—
(in violation of Rule
408(h)).
Attached data from Route
47
Bridge sampling point upstream
of
the.
Seneca
plant and from
Route 170 Bridge sampling point
downstream
disclose a possible
environmental impact from the Seneca plant.
While the samplings
were taken over the same time periods
(1975
to
May
1976)
relatively
few were taken the
samt-
day.
In addition, the Board
was
not
informed
about
other possible
dischargers
between
the
two
sampling
points.
The
following
table
reports
the
ranges
of concentration
(in mg/l)
recorded:
Field
D.
o.
NH3N
NO3-N
Upstream* 7.0 to 12.8 0.26 to
3.8
320
to
:30
1.8
to 7.5
0.26 to 0.8
Down-
stream*
4.5 to 20.9 0.32 to
7.0 320
to 490
2.3 to 7.8
0.35
to 0.65
*Tjpstream,
14
samples;
Downstream
9
sampa-:s.
The Agency also included Du
Pont
monitoring
analyses
from
the lagoon system to the mouth of
Hog Run
Creek
for
the period
June 1975 through February
1976.
Part.
c--i
Nbc
data
is given
below
(in mg/l).
June
July
Aug.
Sept.
0~t.
0ev.
538
592*
552
5-~,
1358
633*
832
60-8
Dec.
Jan.
Feb.
4
10
7
Il
16
13
1
4
4
11
Flow
Ave.
(MGD)
Max.
1.07
0.721
0,767
0,984*0,784
0.714
N.A.
0.811
1.441 1.548
1,542
0.832
0.835
0.891
1.096
1.172
1.172
1.567
*Numbers
barely
legible
and
may
be
in
error.
The Agency stated it believed the
current
state of the record to
be
insufficient
to
justify
favorable
review
of
the
requested
variance
and
recommended
that
the
variance
be
denied
or
dismissed
as
inadequate.
TDS
Total
P
Ave.
4.7
5.0
15
3.5
D.C
HO
Max.
6.0
8.0
31
ilL
14,0
L,O
Ave.
36
19
10
12,1
11,0
Max.
52
38
40
23,*
15,OL
TSS
TDS
Cya
-
nide
Ave.
216
772
Max.
266
1185
12
711
749
385
1221
971
801
Ave.
Max.
1280
1875
3534
4423
3060
4645
2431
3314
2724
4098
2678
3550
3069
4449
3614
7783
1503
3559
AVe.
0.0
0.44
N.A.
.018
.014 0.001
.014
.010
.006
Max.
0.0
1.17
N.A.
,Ø4*
.020 N.A.
.030
.013
.018
30
--
359
—8—
The Board’s decision on its Opinion and Order denying
Petitioner’s request was stayed to grant Du Pont’s motion for a
hearing at the Board’s November 10,
1976 meeting.
The afore-
mentioned hearing was held March 7,
1977 at which time Mr. John
L. Kvochak, plant manager at the Seneca Works, testified that
the works employs about 300 people to produce the previously
mentioned products.
The AN prill plant was stated to be the
major source of NH3-N and that its production capability was
400 million pounds of AN
(R.
15)
assumed
to be annual.
Efforts
over the past three years were stated to have made significant
reductions in NH3—N in plant effluents; so that, recently the
average discharge was less than 1000
lbs../day, but that time was
needed to complete an optimum system including operational
control,
containment and removal by overland flow——a test method
stated to have given encouraging results the previous fall
(R.
18).
The compliance schedule submitted
(Pet.
Ex.
lB)
and
other data indicate the progress made and projection if every-
thing goes well:
Plant Effluent NH-~-N (lbs./day)
Average
Maximum
January 1976
(R.
51)
4700
—
predicted July 1,
1976
2500
6000
March
—
June
(1977)
1500
2500
July 1977
—
December
(1978)
510
1040
After December 1978
Requirements Rule 406
The Board’s understanding of the overland flow system as
used at the Seneca works
is briefly:
The system applies the weak
ammonium nitrate solution to gently sloping, relatively imper-
vious
soil which supports a stand of cool season grasses.
In balance,
the system is maintained at a nearly neutral
pH to favor nitrification of the
ammonium
ion to the nitrate
ion.
Application rates are pulsed to achieve aerobic and anaerobic
conditions.
Under anaerobic conditions in the presence of a
readily biodegradable substrate
(in this case
--
grass clippinos)
the nitrate ion is reduced primarily to nitrogen gas which
is
lost to the atmosphere.
Mr. Harold T.
Conner’-,
Jr.
•
liar-f:
Technical
Superintendent,
testified
that
the
presently defined containment and control
programs
are
e:~peeted
lu
rC~UC.
(5
errcr
i C
dnL~-(:l-C)
c c
L~ about
4,000
lbs./day
at
a
cost
of
about
$1,000,000.
“To
date,
we
have
achieved
a
reduction
of
3,100
lbs./day
and
spent
about
$500,000”
(R.
52).
The
expected
reduction
by
overland flow
is
500
lbs.
NH3-N
per operating day.
The experimental eight acre test plot took
four months to install at a cost of about $380,000.
It was
operated for an eight week period
--
September to mid-November
1976
(R. 53).
If data remains favorable, the full 64 acres would
be developed at an estimated cost of $2,000,000
(R.
54).
Dr. Larry L.
Russell, Senior Engineer for James M.
Montgomery Consulting Engineers,
Inc., testified on their report
to Du Pont titled “Axnmonia Treatment Alternatives” which was
admitted as Petitioner’s Exhibit #3 and stated that an additional
report was
in preparation
(R.
81).
The report
(Pet.
Ex.
3)
30
—
360
—9—
discusses
the
biological
and
physical
chemical
alternatives
of
NH3—N
removal
(R.
66)
,
but
does
not
recommend
a
“best”
method
for
Petitioner.
Donald
M.
Parmelee,
President
and
Principal
Scientist,
of
Parraclee,
Inc.
and
Robbin
M.
Ashrnc-ad,
Du
Pont
Environmental
Engineer,
testified
on
the
“overland
flow”
method
arid
results
from
the
eight-acre
test
plots,
respectively.
Robbin
Ashntead
stated
the
ammonia
nitroqthi
removal.r
anqed
from
42
to
88
percent
in
October
and
from
58
to
70
percent
in
November
(R.
121)
.
Maximum
total
nitrogen
loadings
were
11.8
lbs.
N
per
acre
per
day.
Optimum warm weather loading
rates
were
estimated
to
be
as
higb
as
21
pounds
total
N/A/day
with
90
NH3-N
removal
(R.
122).
It
is
estimated
the
system
would
have
135
days
of
down
time
per
year
at
that
location
(R.
123).
Groundwater
monitoring
wells
were
installed
and
were
believed
necessary
in
the
final
installation.
Hcwevcr,
results
to
date
show
no
correlation
between
applied
N
and
groundwater
N
(P~.
124).
It
is estimated,
at this time, that an
impoundment
of
at
least
6.8
millions
gallons
capacity
would
be
required
to
offset
the
135-day
down
time
period
(R.
127).
Mr.
Williem
B.
~Thito,
~Teneca
~1erks
Site
Erviror~irenta1
Cccrdinatc.r,
testified
that
Lu
Pont
expected
to
prcceed.
with
development
of
the
large
scale
facility
by
the second quarter
of
1977
(R.
134)
Dr.
Lloyd
L.
Falk,
Principal
Cc-nsultant
in
the
Enqineering
Department
of
Du
Pont,
reaffirmed
the
effect
of
Du
Pont’s
effluent
NH3—N
on
the
Illinois
Fiver
(Sec
Cp.
at
2,
5).
The
Board
disagrees
with
Mr.
Falk’s
apparent
conclusion
that
Board
rules
do
not
give
a
guideline-
to
ammonia
riltioqen
populaticrL
equlvalency
in
~etit.~ioner’s
situation
(R.
152)
.
Rule
104
and
Rule
406
when
read
together
should
have
clarified
the
Board’s
position
with
regard
to
NH3-N
effluents
to
the
Illinois
River
(See
Op.
at
3,
4).
Edward
L.
Mare-k, Supervisor Region 2A Field Operations
Sec.
DWPC of
TEP/\, presented
surnmn r
I on of:
(1)
TEP1\
i-uirnpi i
nqs
oi
l)u
Pon
L
‘
~
1.
il(JO0fl
)r
Lor
t-o
(Ii
~c1i
ar(je
Lo
IIO(J
k
I
Vt’
L
Creek
(Res.
Ex.
1);
(2)
i)u
Pont’s
DMR’s
(Res.
Ex.
2);
(3)
Sampling
of
Illinois
River
at
Morris
which
is
about
ten
miles
upstream
from
the
plant
(Res.
Ex.
3);
and
(4)
Similar
Illinois
River
samples
taken
at
the
Route
170
Bridge
which
is
about
two
miles
downstream
(Re-s.
Ex.
4).
The
lagoon
samples
show
a
marked
reduction
in
NH3—N:
(Res.
Ex.
1)
Dates:
4/15/76
7/15/76
9/10/76
12/14/76
NH3—N(mg/l)
160
320
29
23
30
—
361
—10—
The discharge monitoring reports
(see Op.
at
7)
show
the
same
desirable trend:
(Re-s.
Ex.
2)
Dates
(1976):
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
NH3-N
(mg/i)
Ave.
437
241
248
272
325
176
132
48
64
36
Max.
749
424
462
611
480
374
256
84
110
62
Water quality samples from the Illinois River
(Re-s.
Ex.
3,
4)
again show
(see Op. at
7) NH3-N levels above the 1.5 mg/l water
quality standard much of the time and DO levels quite low during
the warmer months.
The Board again finds
it difficult to draw
any valid conclusion about the impact of the Seneca plant on
water quality from these samples.
Pleadings subsequent to the hearing restated both party’s
positions and arguments.
On March
6,
1978, Petitioner filed an
amended petition seeking a variance until May
31, 1979.
Based
on results from the experimental program, Du Pont now estimates
an investment of four to five million with operating costs of
$100,000 to $140,000 for commercial facilities
to achieve
Rule 406 compliance.
Du Pont has investigated other methods for
control of NH3-N:
(Amended Pet.
3,
Att.
B)
Estimated Costs of Treatment Facilities
($
million)
Method
Installation Cost
Operating Cost
Overland
Flow
4
—
5
0.1
—
0.14
Double
Effect
Evaporation
2.3
0.04
Caustic
-
Air
Stripping
0.8
0.1
—
0.16
—
Steam
Stripping
0.8
0.1
—
0.16
Single
Effect
Evaporation
1
-
1.4
0.02
-
0.4
During
the
past
two
years,
Du
Pont
has
reduced
its
plant
NH3-N
discharges with a continuing site containment program from about
a daily maximum of
7,200 to less than 1,000 pounds per day and
monthly
averages
from
4,700
to
less
than
500 pounds per day at
a
cost of about
6
1
.
8
rn~..
IT ion.
TliCr(i’
is
one
major
containment
acuity
providing
more
efficient
recovery
of
rail
car
heels
to
come
into
operation
on
June
1,
1978
(additional
cost
$250,000)
Du
Pont
states
if
the railcar heels facilities are fully
successful, compliance with Rule
406
will
be
achieved.
During
the
full
year
alleged
to
be
needed
for
evaluation,
Du
Pont
states
it
will
limit
monthly
average
NH3-N
discharges
to
a
monthly
average
of
350
lbs./day
with
no
one
day
exceeding
700
pounds.
Du
Pont
states
the
contribution
to
NH3-N
in
the
Illinois
River
of this discharge will be
as
follows:
(Amended
Pet.
Att.
C)
30
—
362
—11—
Discharge
NH3-N
Average NH3-N Concentration
(mg/l)
(lbs./day)
Within Mixing Zone
Complete Mixing
Low
Flow
Mean
Flow
Low
Flow
Mean
Flow
700
0.16
0.049
0.042
0.012
350
0.082
0,025
0.021
0.005
100
0.023
0.007
0.006
0.002
In
view
of
the progress Du Pont has made,
it believes a variance
is
warranted
to
evaluate
the
effect
of
its continuing containment
program
on
NH3-N
discharge
before
commitment
to
costly
($1-S
million)
abatement
program(s).
The Agency’s recommendation
is favorable under certain
specified
conditions.
The Board finds that Du Pont would be subjected to arbitrary
and
unreasonable
hardship
if required to make costly expenditures
prior to evaluating its present compliance program and that the
environmental impact of its discharges during the variance
period will be minimal.
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 a
variance is granted to Du Pont for its Seneca Plant works from
Rule
406
of
Chapter
3:
Water
Pollution
Regulations
until
May
31,
1979
subject
to the following conditions:
1.
That Petitioner’s discharge of ammonia—nitrogen
not exceed 350 pounds per day as a monthly average;
2.
That Petitioner’s discharge of
ammonia—nitrogen
not exceed 700 pounds
on
any
given
day;
3
.
That
Pe Li
i
oner
record
cIa I
ly and
rel)or
L
mon
Lii
I
y
to
the
Agency
the
volume
of
flow
generated
in
the
north
prill
ditch
as
runoff
from
the
ammonia-
nitrate production area.
That the report also
contain measurements of the ammonia concentration
of
that
flow;
4.
That Petitioner complete construction of the
railcar heels unloading facilities described
in
the Petition;
5,
That
Petitioner
continue
to operate the experimental
overland flow treatment system.
That Petitioner
shall prepare and submit to the Agency a report during
November of
197,8 summarizing the results of the
overland flow system operation;
30
*
363
—12--
6.
Within 45 days after the date of the Board herein
the Petitioner shall execute and forward to the
Illinois Environmental Protection Agency, Variance
Section,
2200
Churchill
Road,
Springfield,
Illinois
62706,
a
Certification
of
Acceptance
and
Agreement
to
be
bound
to
all
terms
and
conditions
of
the
variance.
This
45 day period shall be held in
abeyance for any period during which this matter
is appealed.
The
form
of
said
Certification
shall
be
as
follows:
CERTIFICATION
I,
(We)
,
___________________________,
having
read
and
fully
understanding
the
Order
of
the
Illinois
Pollution Control Board in PCB 76-30 hereby accept said
Order
and
agree
to
be
bound
by
all
terms
and
conditions
thereof.
Title
Date
***
The Agency, pursuant to Rule
914
of
Chapter
3,
shall
modify
the
Petitioner’s
NPDES
permit
consistent
with the conditions
set forth
in this order including such interim effluent limita-
tions as may reasonably be achieved through the application of
best
practicable
operation
and
maintainance
practices
in
the
existing facility.
I,
Christan
L.
Moffett,
Clerk
of
the
Illinois
Pollution
Control
Board,
hereby
c~rtify
the
above
Opinion
and
Order
were
adopted
on
the
~“
day
of
_____________,
1978
by
a
vote
of
________
:ontrol
Board
30
*
~64
