ILLINOIS POLLUTION CONTROL BOARD
June 5,
1981
OLIN CORPORATION
(Joliet),
Petitioner,
v.
)
PCB
81—40
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
Respondent.
MR.
GEORGE
H.
PAIN,
ATTORNEY
AT
LAW,
APPEARED
ON
BEHALF
OF
THE
PETITIONER.
MR.
DONALD
L.
GIMBEL,
ATTORNEY
AT
LAW,
APPEARED
ON
BEHALF
OF
THE
RESPONDENT.
OPINION
AND
ORDER
OF
THE
BOARD
(by
D. Satchell):
This matter comes before the Board upon a petition for vari-
ance filed March 12,
1981 by Olin Corporation (Olin).
The petition
requests
a variance from the total dissolved solids
(TDS)
effluent
limitation of Rule 408(b)
in connection with Outfall 001 from its
sodium phosphate factory
in Will County.
On April 22, 1981 the
Illinois Environmental Protection Agency
(Agency)
recommended that
the
variance
be
granted
with conditions.
This recommendation was
amended
on
May
26,
1981.
On
March
23,
1981
Olin
filed
a
motion for expedited ruling.
This
was
denied
by
the
Board on April 16,
1981
after
an
objection
was
received
from
Margaret
and
Robert
Whitler.
A
public
hearing
was held May 22,
1981
in
Joliet.
Olin
presented
oral and written
testimony and Robert Whitler made a statement objecting to the
variance.
On June 1, 1981 Olin again moved for expedited considera-
tion stating that total retention pond number
1
(TRP 1), which is
the source of Outfall 001, was within two and one-half inches of
overflowing.
The motion for expedited consideration is granted.
Olin owns and operates
a plant located at the junction of
Patterson and Laraway Roads
in Joliet Township, Will County.
The
plant produces industrial sodium phosphates.
Products include
monosodium,
disodium and trisodiuin phosphate,
trisodium chlorinated
phosphates, sodium tripolyphosphate, tetrasodium pyrophosphate,
sodium acid phosphate, sodium hexametaphosphate,
sodium silica
fluoride and sodium fluoride.
Sodium phosphates are produced from
phosphate rock using the wet acid process.
Phosphoric acid is pro-
duced from phosphate rock and sulfuric acid.
This serves as raw
material for the other processes.
42—59
—2—
The plant has three water recycle loops.
This variance
focuses on one recycle loop which includes
TRP
1.
Wastewater from
the sodium fluoride manufacturing process is discharged to
TPP
1.
Suspended solids are removed and the clarified water is returned
to the sodium fluoride process.
TRP
1 has a net filling rate of
ten gallons per minute when the sodium fluoride process is in op-
eration, plus additions from rainfall.
TRP
1 water cannot be used
as process water for operations other than the sodium fluoride
process,
although Olin is experimenting with such use.
Up to
sixty gallons per minute of
TRP
1 water can currently be pumped
to the stormwater process water system and discharged to the Des
Plaines River under existing permit conditions.
This quantity,
however, depends on the rate of discharge from other ponds.
Olin discharges by Outfall 001 to the Des Plaines River pursu-
ant to NPDES permit No. IL0002020.
This permit includes an efflu-
ent limitation of 3500 mg/l based on the requirements of Rule
408(b)
of Chapter 3:
Water Pollution.
Olin requires
a variance
from Rule 408(b)
in order to allow it to increase the drawdown
rate on TRP
1 from sixty to about 250 gallons per minute for a
period of one year.
This should bring the water level in
TRP
1
down about twenty inches to a safe level.
The increased rate of
drawdown will result in TDS effluent concentrations of no more
than 7000 mg/l.
Olin believes that once
TRP
1 is brought down to
a safe level, the existing water balance system could be carefully
managed
and TRP
1 water could be treated at
a rate consistent with
permit requirements.
Petitioner and Agency note that the Board has proposed to
delete the Rule 408(b) TDS effluent limitation
(R76-2l, Proposed
Rule, First Notice, February 19, 1981;
5
Iii. Reg.
2629, March 13,
1981).
Evidence in that proceeding indicates that there is no
technologically feasible method to lower TDS levels.
The available
methods, including reverse osmosis and distillation, require con-
sumption of large amounts of energy and result in the production
of brine which is difficult to dispose of in an environmentally
sound manner.
TDS levels in the Des Plaines River average about
500 to 550
mg/l with a maximum of 810 mg/i, under the 1000 mg/i water quality
standard of Rule 203(f).
Under low flow conditions the increase
from 3500 to 7000 mg/i would increase levels in the receiving
stream from 810 to 818 mg/i TDS.
The public comment at the hearing expressed concern for water
quality and suspended solids levels in the river.
Olin will not be
authorized to violate water quality standards or to violate the
effluent standards for individual constituents other than TDS.
42—60
—3—
The Agency has recommended the grant of the variance for a
period of one year or until deletion of Rule 408(b)
in R76-2l.
The Agency recommended a maximum level of 7000 mg/i as an interim
standard.
In its amended recommendation the Agency asked that Olin
be required to report to it every two months on results of its addi-
tional experimentation with reuse
as process water of TRP
1 water
after treatment and dilution.
The Board will include this condi-
tion.
The Board finds that it would impose arbitrary or unreasonable
hardship to require Olin to meet the Rule 408(b)
TDS standard
during the pendency of the proposal to delete the standard.
The
variance will be granted with conditions.
This Opinion constitutes the Board’s findings of fact and con-
clusions of law in this matter.
ORDER
Olin Corporation is granted a variance from Rule 408(b)
of
Chapter
3:
Water Pollution for discharge 001 from its sodium
phosphate facility in Will County,
subject to the following con-
ditions:
1.
This variance will expire one year from the date of this Order
or upon the effective date of deletion of the TDS effluent
standard from Rule 408(b)
in R76-2l, whichever occurs
first.
2.
Effluent from Outfall 001 shall not exceed 7000 mg/i total
dissolved solids.
3.
Commencing June
30, 1981 and every two months thereafter,
Olin
Corporation shall submit to the Illinois
Environmental Protec-
tion Agency a report concerning the progress of its study to
reuse the water from
TRP
1 in its other production processes
until such time as the study is concluded.
Olin shall also
submit a report as to the final determination of this study.
4.
The Agency shall modify NPDES permit No.
1L0002020 consistent
with the conditions of this variance.
5.
Within forty-five days of the date of this Order, Petitioner
shall execute and forward to the Illinois Environmental Protec-
tion Agency, Variance Section, 2200 Churchill Road, Springfield,
Illinois 62706,
a Certificate of Acceptance and Agreement to be
bound to all terms and conditions of this variance.
This forty--
five day period shall be held in abeyance for any period this
matter is being appealed.
The form of the Certificate shall
be as follows:
42—61
—4—
CERTIFICATION
I,
(We),
_______________________________,
having
read
and fully undei~standingthe Order in PCB 81-40, hereby accept
that Order and agree to be bound by all of its terms and con-
ditions.
SIGNED
__________________________
TITLE
____________________________
DATE
____________________________
IT IS SO ORDERED.
I,
Christan
L. Moffett,
Clerk
of the Illinois Pollution
Control Board, hereby certify that the above Opinion and Order
were adopted on the
~
day ~
,
1981 by a vote of ~
a
~
rk
Illinois Polluti
‘Control Board
4 2—62