ILLINOIS
POLLUTION
CONTROL
BOARD
December
20,
1984
REILLY TAR & CHEMICAL
CORPORATION
and THE CITY OF GRANITE
CITY,
Petitioners,
)
PCB
84~82
ILLINOIS ENVIRONMENTAL
)
PROTECTION
AGENCY,
Respondent~
OPINION
AND
ORDER
OF
THE
BOLRD
(by
3.
D,
Dumelle):
This
matter
comes
before
the
Board
upon
a
June
27,
1984
petition
and
an
August
31,
1984
amended
petition
filed
on
behalf
of
the
Reilly
Tar
& Chemical Corporation
(Reilly)
and
the
City
of
Granite City
requesting variance from 35
Ill.
Adm. Code 307.103
as it relates to
Reil1y~smercury discharge to
Granite City~s
sewer system until
August 31,
1988,
The Illinois
Environmental
Protection Agency
(Agency)
filed a recommendation
on October 26,
1984,
that variance be
granted subject to certain
conditions.
Hearing was waived
and
none was
held,
Reilly
owns
and
operates
a
coal
tar
refinery
in
Granite
City
which
produces
coal
tar
pitch,
creosote
oil
and
pipeline
enamel.
It
processes
l2~l5
million
gallons
of
coal
tar
per
year
through
distillation
and discharges
about
25,000
gallons
per
day
(gpd)
of
wastewater
with
a
potential discharge of 40,000 gpd. This
water
consists of
storm water, water
of decantation, and process
water
which was historically
treated
in
an
aerated
lagoon on Reilly’s
property
to
reduce
the
phenol
content
and
then
disposed of by
spray irrigation
on its property~ The past practice
indicates
that
whatever
mercury
was
in
the
treated
wastewater
is
now
on
Reilly’s property
or in its on~sitelagoons
Groundwater
monitoring
of the site has
revealed
significant
concentrations
of
contaminants
other
than
mercury
and a
formal
groundwater
assessment
is
in
progress.
For several
years,
Rei~ly has
been
working
on
a
system to
treat
its
wastewater
in above ground tanks to
produce
an
effluent
capable
of meeting
Granite
City~spretreatment
requirements for
discharge
to
its
sewage
system.
Reilly’s
system
consists
of
two
collecting
and
primary/oil
water
separating
tanks,
two
secondary
A.P.I.
type
oil
waste
separators with surface skimmers,
one
equalizing
tank,
three 250,000 gallon digesters,
and
two
clarifiers
with
associated
aerators,
pumps, piping and monitoring
equipment.
wastewater
is
collected
and
pumped
to
tanks,
where
the
creosote
oil
is
allowed
to
settle,
and
then
is
transferred through
the
A. P. I.
type
separators
where
residual
traces
of
oil
are
removed.
The water
is then
pumped to the equalizing
tank
and
to
the
250,000
gallon digesters
for
final
treatment. consisting
of
bio—oxidation
of the phenol.
Discharge
from
the
digesters
flows
through
a
clarifier
tank
which,
if
variance
Is
qranted,
will
be
discharged
to the sanitary
sewer
systenn.
C~ January
7,
1983,
Reilly was
granted
a temporary
permit
to
construct
and operate
the
wastewater
pretreatment
plant.
In
April
1983
final
drawings
were
completed
and bids
requested
for
construction
The
first construction bids
were
let
in
April
and
construction
commenced May 6,
1983.
On
August
16,
1983,
wastewater
was
intu: oduced
into
the
system.
On
August
26,
1983,
the
first
effluent
exited
the
system
and
testing
commenced.
Data
obtained
to
date
indicate
the
system
is
satisfactorily
meeting
all
required
pretreatment
standards
with
the
exception
of
mercury,
and
in
fact
is
performing
:rnore
efficiently
than
pilot
work
indicated.
Tests
for
total
mercury
levels
in
Rei1ly~s
wastewater
have
been
inconclusive
as
to the
exact
concentrations
of
mercury;
however,
data
indicate
:Lnfluent
:Levels
of
approximately
100
ppb
with
effluent
level
s
of
approximately
40
ppb.
The
s~irce
of
the
mercury
has
been
traced
to
the
coal
tar,
which
is
a
by-product
from
the
carbonization
of coal,
Mercury
has
been
found
in
all
sources
of
Reilly~s
coal
tar,
and
is
known
to
occur
naturally
in
coal.
Reilly
argues
that
this
prevents
the
possibility
of
elim-
inating
it
by
using
selective
sources
or
by changing
Reilly’
s
manufacturing
process.
Granite
City
discharges
from
6~5 to
15
million
gpd
with
an
estimated
average
of
7.~5millios
end
of
treated
waste
with
a
mercury
content
rar~inq
t~urn
C
n
49
h
pu~
The
to)
lowing
values
have
been
reported
for
the
Granite
City
discharge:
Date
~er232r~fb)
June
14~~l5,
1984
Janu
ary
I 7~1
8
,
19 8
4
July
13,
1983
December
9,
1982
0,5
June
29,
1982
1.2
June
8,
1982
49.6
January
5,
1982
0,7
October
7,
1981
0.1
The
Board
effluent
standard
for
mercury
is
0.0005
mg/i
(0.5
ppb)
pirsuant
to
35
111.
l~dm. Code
:304.i26~
Under
the
averaging
provisions
of
35
iii,
Adm~ Code
3~4~:i04(a)(2)
a
daily
composite
may
not
exceed
1.0
ppb.
The
Board
notes
that
the
discharge
data
from
the
Granite
City
plant
indinetes
probable
violations
of
the
mercury efflue
standard*~
However, neither Granite City
nor
Reilly
requests
variance
from
that
standard and the record
does
not include
sufficient
informatior
for the Board to make any
decision on that
question
P~I
~v
and
Granite City
requests
a
variance from
35 IlL
Adm~ Code
3O7~lO3in order to be
allowed to
discharge
mercury at a
concentration
of O~O35mg/l
(35
ppb) to
the Granite City sewer
system,
and
that is the sole request
that
the
Board
will
address in
this
riatter,
According to
the
Agency,
Reilly
has the following
alterna—
tives:
maintenance
of
the
status
ti~io
with continual accumulation
of mercury
and
er
contamir
t
i
~ its on~-sitelagoon;
deep
well
injectior
placerre~t
~et scrubbers,
or plant closure
with attendant
e
of
emplo
However, no estimate
of costs
for
these alte
ives excep*
sure
has been given by
Reilly
Neither contin
on-site
lag
~.
d sposal nor plant closure
is
recommended
by
Agenc~y,an
~tates that the feasibility
of
deep well
injec
is
sl
g’~.
c~ienan approximate cost
of
$1,000,000
for
ew
welL
t
co
s
however,
recommend
that
wet
scrubber
replac
nt
and
storm
water
diversion
should
be
considered
as
part
of
the
pliance
plan
Reilly
has
eviewed
treatment
systems for mercury removal
including
biological
systems,
precipitation
and
complexation,
ion
exchange, activated
carbon
adsorption,
solvent extraction,
chemical
displacement,
electrolytic,
reverse
osmosis, synthetic
polymeric
absorbents,
agriculture
products
and
ground
up
rubber0
It
deter—
mined,
and
the
Agency
does
not
disagree,
that
these
methods
are
very
expensive
and
are
unproved
ard
unreliable
at
the
1~ercury
concentrations
with
which
Reilly
is
working0
It
has,
however,
set forth
a
proposed
sequential
c
mpliance plan which
may
cost
as
much
as $6G,000, but whic
Llieves will result in compliance
by
the
summer
of
‘988
If Reili
a
~
to discharge 25,000
gpd
at
35
ppd (0.035 ac~
~t cc~1
311.96 mg/day (0,0073
lbs/day)
of
mercury
to
ie
~~rite
~
t
At
69
removal
by the
activated
sluda
s~a
t it would increas~the
mercury
content
I
£
0
6 ~1 mg/day (0.0026
lbs/day)
and
increase
t~
~ar
~e
sludge
by
2285.25
mg/day
(0,005
lbs/day
~hi~ l026.IL
c
i~
when diluted by the
28.482
million
1/day
(7.
i!l~o~igpd
s
iiiated average discharge
at
the Granite
City plant
would r~su
in
an increase of
the effluent
mercury of
0,00004 mg/I
(0
4 ovb
.~*
*The 49.6
ppb
fig ire
is
aa~.tic
larly
disturbing,
especially
since
it is
unexplairi
d.
~
,
this
sample
was
taken
at
a
time
when
Reilly was
not
dzscharq
‘~‘
the sewer system,
**The Boa
te5
tiat.
of
the
Agency~s
conversions
in
its recommend~
are
x~
and
corrected
by
the
Board.
4
Based upon
these
discharge
levels,
the
existing
mercury
concentration
in
Granite
City’ s
plant
and
its
fluctuations,
the
Agency
concludes
that
the
addition
of
Reilly’ s
effluent
to
Granite
City’s
sewer
system
would
not
significantly
impact
the
environment.
The
Board
agrees
with
the
Agency
that
immediate
compliance
by
Reilly
would
constitute
an
unreasonable
hardship,
given
the
lack
of
probable
environmental
impact
and
the
necessity
of
pre-
venting
further
groundwater
pollution
from
the
existing
lagoon.
In
order
to
afford
Reilly
complete
relief
in
this
proceeding,
Granite
City
ziust
also
be
granted
variance
from
Section
307.103
since
Granite
City
would
be
in
violation
of
that
rule
if
it
allowed
Reilly
to
discharge
mercury
at
a
concentration
of
greater
than
5
ppb
to
its
sewer
system.
The
Agency
contends
that
it
may
be
possible
for
Reilly
to
reduce
or
eliminate
mercury
in
the
wastewater
by
changing
its
manufacturing
processes.
It
alleges
that
creosote
oil
particulates,
as
with
most
oily
vapors,
can
be
controlled
without
water
scrubbing
by
means
of
filters
which
condense
the
vapor
and
still
recwer
the
product.
Likewise,
storm
water
can
be
diverted
if
it
is
not
contaminated.
The
Board
will,
therefore,
include
as
a condition
of
variance
that
Reily
consider
these
possibilities.
The
Board
will
also
regaire
Reilly
to
apply
for
renewal
of
its
operating
permit,
to
proceed
with
its
proposed
program
to
reduce
mercury
concentrations
in
its
discharge,
and to
sibmit
qaarterly
progress
reports,
all
as
recommended
by
the
Agency.
This
Opinion
constitutes
the
Board’ s
findings
of
tact
and
conclusions
of
law
in
this
matter.
ORDER
Reilly Tar and
Chemical
Corporation
and
Granite
City
is
hereby
granted
variance
from
35
Ill.
Mm.
Code
307.103,
as
it
applies
to
Reilly’s
discharge,
until
August
31,
1988,
aibject
to
the
following
conditions:
1.
Reilly
Tar
and
Chemical
shall
not
discharge
mercury
at a concentration greater than 0.035 mg/l,
sibject to
the averaging rule of 35
Ill.
Adm.
Code 304.104(a), to
the
Granite
City
sewer
system, nor shall Granite City
allow
Reilly
Tar
and Chemical
to
discharge
mercury
at
a
concentration
greater
than
that
level.
2.
Reilly
Tar
and
Chemical
shall
make
prompt
application
for
renewal of its Operating Permit No. 1984-EO-0557;
3.
Reilly Tar and Chemical
shall conduct a
program
to
reduce
the
mercury
concentration
in
its
effluent
as
outlined
in
paragraph
10
(pp.
14—19)
of
its
amended
petition:
62-10
5
4.
Reilly
Tar
and
Chemical
shall
submit
quarterly
progress
reports
(on
the
last day of December, March,
June and
September)
during
each
year
of
the
variance
period
to
the:
Illinois Environmental Protection Agency
Division
of
Water
Pollution
Control
Compliance Assurance Section
2200 Chirchill Road
Springfield,
Illinois 62706;
5.
Reilly
Tar
and Chemical
shall
include in the March
1985
progress
report an analysis of the quantity of
wastewater
p:~::nduced
by its wet scrubber(s),
stormwater,
and
decanta-
tiun;
the
mercury concentration
in each wastewater
source
and
the approximate cost to replace
scrubber
equipment
or
divert storm water
to reduce wastewater
production;
and
6.
Reilly Tar
and
Chemical
and
Granite City shall execute
a Certificate of Acceptance
in the following
form
and
submit it to the Agency
at the address in condition
(4),
above:
CERTIFICATION
We, Reilly Tar and Chemical
and City of Granite City,
hereby
accept and agree to be bound by all
terms and conditions of the
Order
of the
Pollution
Control Board
in PCB 84—82,
dated December
20,
1984.
Reilly
Tar
and
Chemical
City
of
Granite
City
Authorized Agent
Authorized Agent
Title
Title
Date
Date
6241
6
IT
IS
SO
ORDERED~.
I,
Dorothy
M.
Gunri,
Clerk
of
the
Illinois
Pollution
Control
Board,
hereby
certif~
that
the
above
Order was adopted on the
~rQ
day
of
~
,
1984
by
a
vote of
4-~
7,
Dorothy ~4,Gu/in,
Clerk
Illinois Pollution Control
Board
8242