ILLINOIS
POLLUTI~ON
CONTROL
BOARD
November
12,
1982
In the matter of:
PROPOSED WATER QUALITY
STANDARD
R81-24
FOR WOOD RIVER (OLIN,
EAST
ALTON)
PROPOSED
RULE.
FIRST
NOTICE
OPINION OF
THE
BOARD
(by
D.
Anderson)
On September 24,
1980 Olin Corp~ (Olin)
filed a proposal
for a site—specific water quality standard for copper in Wood
River Creek, near East Aiton,
in Madison County~
On August 17,
1981 an amended proposal was docketed as R81-24.
On July 30,
1982 Olin filed
a second amended proposal in codified form.
The following provisions are involved in this rulemaking:
35
Ill. Adm. Code
Chapter
3
Description
§302.208
203(f)
General use water quality
standard of 0.02 mg/l copper
(total)
Part
303
203.1
Exceptions
to
Rule
203
standards
§304.105
402
Requirement that effluents not
cause violation of water
quality standards
§304.124
408
Effluent standard of 0.5 mg/i
copper
(total)
§304.203
Codified designation for this
proposal
HEARING
A public hearing was held on December
9,
1981 at Edwards—
yule.
The Illinois Environmental Protection Agency (Agency)
appeared as
a participant.
Representatives
of Granite City
Steel,
the City of East Alton,
and Illinois Power Company
attended the hearing.
There was no public comment, as such,
although East Alton testified for Olin in favor of the proposal.
The record was left open to allow for an economic impact hearing
and possible additional merit hearings~
On February 22,
1982,
the Departnient of Energy and Natural
Resources advised the Board that the Economic Technical Advisory
Committee had voted a “negative dec1aration~pursuant to P.A.
82-548.
This satisfied the economic impact study requirement.
49-307
—2—
On August 2, 1982 Olin and the Agency filed a stipulation
concerning the admission of additional exhibits without the
necessity of conducting a second merit hearing.
On August 19
the Hearing Officer admitted exhibits Z-1 and Z-2 and closed
the record except for comment periods.
PREVIOUS ACTIONS
Copper discharges from Olin’s East Alton facility have
been the topic of several previous Board cases:
PCB
73—484
14 PCB 689
December 19,
1974
75—369
19 PCB 404
December
4,
1975
73—509
73—510
22
P~B
3
June 3,
1976
80—170
40 PCB 137
December 18, 1980
41 PcB 321
May 1, 1981
80—126
45 PCB
389
February 17,
1982
46 PCB
7
April
1, 1982
The Board originally granted Olin a variance from the
water quality standard for copper in 1972.
This was extended
in 1976 and in 1980.
Olin is currently subject to an effluent
limitation
in its variance of 0.3 mg/i copper, based on monthly
averages.
In PCB 73-509,-510 Olin sought a declaration that Wood
River was
a “secondary contact water” and hence not subject to
the general use water quality standards.
The Board held that
such designations must be made only by way of rulemaking
(54 Iii.
App. 3rd 480,
370 NE 2d,
5th District, October 20,
1977).
The secondary contact standards were subsequently
amended to state this result
(Rule
302, Section 303.102,
3 Iii.
Reg. no.
20,
p.
95).
This site—specific proposal is
the result of that holding.
FACILITY DESCRIPTION
Olin operates a manufacturing facility in East Alton,
Madison County.
The facility occupies 1732 acres and employs
4300 workers, with an annual payroll of $86,000,000.
The
facility includes a brass casting operation, manufacture of
copper and copper alloy slabs, strip tubing, fabricated products
and small arms ammunition.
Several operations result in dis-
charge of copper to the plant’s sewage system.
49-308
*
3—
The following table summarizes the discharges and “Zones”
of the facility which are involved in this rulemaking:
Treatment
Plant
Zones
Discharge
Type of Discharge
Zone
6
1—7
015,006
Main outfall
002, 003, 004,
005, 009,
010,
Overflow
discharges
013, 014
007, 008,
011, 012
Stormwater discharges
Zone 17
17
001
Main
outfall
Zone
6 is the older of the two treatment plants.
Both
plants treat for copper, and other heavy metals, by lime precip-
itation with polymer coagulation and flocculation.
The dis-
charges are authorized by NPDES Permit No.
IL 0000230.
Discharge
001 is to Wood River Creek;
015 is upstream on the East Fork.
In R76-2l the Board changed the copper effluent standard
from 1.0 to 0.5 mg/l.
Direct comparison of these numbers is
difficult because at the same time the Board changed the method
of determining the concentration from a daily to a monthly
basis.
In adopting this standard
the
Board found that it was
technologically reasonable to treat copper to a level of 0.5
mg/l
(43 PCB 367, September 24,
1981;
6 IlL
Reg. 563).
As
noted in that Opinion, Olin treats its wastewater to a greater
degree.
Its current variance contains
~t
O~3mg/i limitation,
based on monthly averages.
Olin presented a summary of nearly
1200 daily composites from outfalls 015 and 001 from 1975
through 1981
(R.
146, Ex.
B and C).
The following table is
abstracted from those exhibits:
Cumulative
of daily composites
less than indicated level
Copper
(mg/i)
015
001
0.5
97.6
92.1
1.0
99.6
97.9
The median values for the discharges are
in
the
range
of
0.2 to 0.3 mg/l, with about 98.8
of daily composites being
less than 1.0 mg/l.
Olin has violated the 0~,3mg/i monthly
variance standard only
two
times
since
the
variance
was
granted
(R.
214).
49-309
—4—
The following table
summarizes
average
flows
and mass
discharge data based on the average flow at 0.5 mg/i:
Flow
Mass
at
0.5
mg/i
Discharge
Zone
MGD
Liters x i06
kg7day
015
6
2.7
10
5.0
001
17
0.52
2.0
1.0
TREATMENT ALTERNATIVES
The lime precipitation process which Olin uses is the most
common copper treatment technology.
In R76-21 the Board
identified it as the technology on which the 0,5 mg/i standard
was based,
although Olin’s plants perform better than this.
Olin has considered severai alternative processes which might
reduce copper levels
(R.
152).
These are summarized as follows
for the Zone
6 plant:
Expected
Copper
Process
(mg/l
Zone
Capital
—
Operating
Sulfide precipitation
0.05
6
$
2,650,000
$1,500,000
17
498,000
70,000
Ion Exchange
0.09
6
8,740,000
467,000
17
1,448,000
285,000
Reverse osmosis
0.09
6
19,300,000
8,500,000
17
4~460,000
1,240,000
Starch xanthate
0.05
6
290,000
920,000
17
65,000
102,000
None of the alternatives would be capable of meeting the
0.02 mg/i water quality standard.
Reduction from 0.5 to 0.1
mg/i would reduce the combined Zone
6 and 17 copper discharge
from 6.0 to 1.2 kg/day.
Other treatment alternatives were considered but rejected
without detailed estimates.
These include electrolytic recovery,
cementation, evaporative recovery and sodium borohydrate.
These
either were too expensive, did not perform well enough, or both
CR.
158).
Direct discharge to Mississippi River is too expensive
($2,600,000)
and merely gets the copper to the Mississippi
quicker
(R.
159).
49-310
—5—
WOOD
RIVER CREEK
The lower reaches of Wood River Creek were discussed at
length in a previous site—specific rulemaking concerning boron
discharges from Illinois Power Company’s ash pond, which is
situated downstream from Olin (R76-l8,
29 PCB 395, March 16,
1978;
2 Ill. Reg.
no.
27,
page 221, effective July
5,
1978).
The waterway is referred to as “Wood River”
and
as
“Wood
River Creek”
(R.
27).
The Board will continue with the latter
designation which was followed in R76-18,
Addition of the word
“creek” to the name avoids confusion with the nearby town of
Wood
River.
Furthermore,
the term “river” generally denotes
a larger stream than Wood River Creek, which has
a seven day,
ten year low flow of zero
(R.
141).
Wood River Creek arises above the Mississippi River bluffs.
It has
a maximum length of about 20 miles and watershed of
125 square miles.
The East Fork has
an average flow of
110
million liters per day
(44 cubic feet per second) (R.
42,
173,
Ex.
X,
Z).
The East and West Forks meet between Olin’s dis-
charge points, with the Zone
6 discharge
(015)
upstream on
the East Fork.
The lower reaches of Wood River Creek and the
East Fork have been straightened and leveed.
There is
a dam
across the mouth of the creek, which is less than one mile
below Olin’s discharges.
EXISTING WATER QUALITY
Olin has taken actual water
quality
measurements
in
1975
and in 1980
(Ex. P, W).
Upstream copper levels tend to be
around
0.02
mg/i,
the
general
use
water
quality standard.
Downstream,
grab
samples
have
been
taken which are
in
excess
of
0.5 mg/i, but averages tend to be below 0.1 mg/i
CR.
95, Ex.
P,
W).
Stream modeling
tends
to
indicate
that
levels
in excess
of
0.5 mg/i should occur 19
of the time, but this is not
borne out by the data
(Ex.
Z-l).
ENVIRONMENTAL
IMPACT
The areas surrounding the lower reaches of Wood River Creek
are almost entirely occupied by heavy industry, including Olin,
Illinois Power and a junk yard.
There is
a small area where
residences are close to the levy and where public access
is
possible.
However, the Mayor of East Alton and other testified
that they have never known of any recreational use being made
of the creek.
The area is heavily overgrown and is not access-
ible or attractive from a recreational point of view.
The creek
does not normally have a sufficient flow for usual recreational
activities such as swimming and boating
(R.
32,
127, 163).
49-311
—6--
The physical condition of the creek is the
same
as was
discussed at length in R76-18.
The low head dam cuts the stream
off from the Mississippi most of the time.
This prevents
utilization by river fish.
The ch.annelization,
leveeing and
urbanization, combined with the dam, have eliminated the habitat
diversity
which
is
essential
to
a diverse aquatic population.
The
lack
of
habitat
is
the
principal
limiting
factor,
not
the
chemical
composition
of
the
water.
Olin’s
discharges
keep
water
in
the
stream
even
during
the
dryest
times.
This
increases
species
diversity
by
protecting
fish
which
would
be
unable
to
escape
during
dry
periods.
Copper
is
toxic
material
which
is
also
a
trace
nutrient
at
low
levels.
It
is
used
as
an
algicide
and
piscicide
at
levels ranging from
1
to
10
mg/i
(R.
121).
Toxicity
varies
with
species under consideration, with LC—50’s
ranging from 0.007 to
10 mg/i
CR.
98).
Toxicity also depends
on
hardness of the water.
The
water
in
Wood
River
Creek
is
sufficiently
hard
to
reduce
toxicity
of
copper
(R.
100).
The
species
present,
which
are
determined
by
habitat,
are
generally
tolerant
to
higher
copper
levels.
Olin’s
lixnnologist,
Dr.
Donald
B.
McDonald,
a
professor
of
environmental
engineering
at
the
University
of
Iowa,
examined
the
creek
above
and
below
the
discharge
points
to
determine
whether
there
was
any
change
in
species
or
counts
from
the
discharge.
None
was
found.
Indeed,
the
largest
number
of
species
and
individuals
was
found
in
a
~OOi
below
Olin’s
Zone
6
discharge.
At
the
time
flow
was
sufficient
to
allow
the
fish
to
escape
upstream
to
lower
copper
levels.
The
fish
were
expressing
a
preference
for
the
bettar
habitat
and
larger
flow
below
the
discharge
rather
than
the
lower
copper
levels
upstream
(R.
63,
88).
The
Board
finds
that
the
existing
conditions
of
Wood
River
Creek
near
Olin’s
discharge are dominated by irreversible
changes
in the drainage basin rather than copper levels.
Enforcement of the existing standard, or requiring treatment
to 0..
mg/i, the next level of treatment technology, would
cost money but would not significantly improve environmental
conditions, or increase the aesthetic or recreational value of
Wood River Creek.
The Board will therefore modify the water
quality standard to a level reflecting existing conditions
with Olin’s historical discharges.
PROPOSED ACTION
Olin originally proposed a water quality standard of
0.5 mg/i.
The first modified proposal asked for an effluent
standard of 0.5 mg/i with an exemption from the water quality
49-312
—7—
standards.
In January,
1982 the general effluent
standard
of
Section 304.124 was changed to 0.5 mg/i, mooting the site
specific modification of the effluent standard.
On July 30,
1982, in response to questions raised at the hearing, Olin
returned to a modified water quality standard of 0.5 mg/i.
At
the hearing,
and
in its comments of August 31, 1982,
the Agency
opposed this shift back to a straight water quality standard
revision.
On September 21 Olin indicated that it didzYt care
whether relief was granted by way of modification of
the
water
quality standard or exemption from the water quality standard.
The Board has proposed to adopt Section 304.203, which. would
provide Olin with a site-specific exemption from the requirement
of Section 304.105 that its effluent discharges comply
with
the
water quality standard for copper of Section 302.208.
The
text
of the proposed rule appears in a separate Order.
This Opinion
supports that Order.
I, Christan
L. Moffett, Clerk of the Illinois Pollution
Control Board, hereby certify that the above Opinion wa~adopted
on the
1~1.
1’—
day of
1)
~
1982 by a vote of
~
Illinois Pollution
Board
49-313