ILLINOIS POLLUTION CONTROL

BOARD

December 18,

1980

OLIN CORPORATION,

(East

Alton),

Petitioner,

v.

)

PCB

80—170

ILLINOIS ENVIRONI”IENTAL PROTECTION

)

AGENCY,

Respondent.

OPINION

~½ND

ORDER OF

THE BOARD

(by D. Satchell):

This matter comes before the Board upon a petition for

variance filed September 24,

1980 by Olin Corporation, a Virginia

corporation

(Olin).

The petition requests an extension of a

variance previously granted from Rule 203(f)

of Chapter

3:

Water

Pollution, which establishes

a water quality level of 0.02 mg/i

copper

(total).

On November 17, 1980 the Illinois Environmental

Protection Agency

(Agency)

filed a recommendation and a motion to

file.

The Agency recommended grant of the variance subject to

conditions.

On November 21, 1980 Olin amended the petition by

waiving hearing.

The Board has received no public comment.

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.

Olin has two wastewater

treatment facilities which are involved in this variance.

These

are referred to as

“Zone 6” and “Zone 17.”

The discharges are

identified as outfalls 001 and 015 in NPDES permit IL0000230

(Rec,

2,

4)

.

Wastewater from Olin~sZones

1,

2,

4 and

7 are treated at

Zone

6.

Zones

1 and

7 involve manufacture of brass strip

and

fabricated products, metallic and shot shell ammunition.

There

are also a steam generating plant and a potable water treatment

plant.

At Zone

2 Olin manufactures wads for use in shot shells.

At Zone

4 Olin manufactures shot shell ammunition and primer

explosives.

At Zone 17 Olin conducts a brass casting operation and manu-

factures copper

and

copper based alloy slabs and copper alloy

tubing.

Wastewater from Zone 17 is treated at the Zone 17 waste-

water treatment facility.

Both the Zone

6 and Zone 17 treatment facilities employ lime

precipitation and polymer coagulation and flocculation process.

Sludge is dewatered by means of vacuum filters.

Olin has pre-

sented a summary of its discharge monitoring report

(DMR)

data’

40—

137

---

including 1979 averages and

its averages for the first half of

1980

(Pet.

3;

Pet.

Ex. E-1,

13-2).

Its copper concentrations are

as follows

Concentrations, mg/i

Flow

1979

1980

Mi/day1

MGD2

Zone

6

0.24

0.28

10.2

2.7

Zone 17

0.27

0,22

2.0

0.52

3-Megaliters per day

)

Million gallons per day

Based on

the above figures, Olin

is discharging daily 2.4

to 2.9 kg of copper from Zone

6

and 0.44 to 0~54kg from Zone 17.

Rule

408(a)

of Chapter

3

sets an effluent limitation of 1.0

mg/l for copper

(total).

Olin~slong

term average is well within

this level,

However, Rule 402 of Chapter 3 provides that no ef-

fluent shall

alone or in combination with other sources cause

a

violation of any applicable water quality standard,

Rule 203(f)

sets a water quality

standard

for copper

(total)

of 0.02 mg/i.

In this proceeding Olin requests an extension of a previous

variance from Rule 203(f).

Effluent from Zone

6 discharges to the East Fork of

Wood

River and effluent from

Zone

17 to Wood River, 1200 and 6000 feet

above the confluence

of

Wood

River

with

the

Mississippi River.

Since Wood River has a 7-day,

10-year low flow

of

zero the ef-

fluent limitations

of Olin~sNPDES permit 1L0000230

are based on

water quality standards~ The lower reaches of Wood River are

within a dense municipal and industrial area.

The river has been

channelized and

flood

control levees constructed.

There is

a low

water

dam

across

the

mouth of Wood River to protect the levees

and prevent

erosion of the channels.

Olin~sfacility and the re-

ceiving stream are more thoroughly discussed

in the Board~s

pre-

vious Opinions

(

çor oration v.

IEPA,

PCB 73-484,

14 PCB 689,

December 19,

1974;

PCB 75—369,

19 PCB 404, December

4, 1975; PCB

73-509,

-510,

22

PC3 3, June

3,

1976; Olin Corporation

v.

IEPA

and IPCB,

54 Ill.

App.

3d 480,

370 NE 2d

3, 5th Dist., October

20,

1977.

As a condition of the 1976 variance Olin was required to

investigate means

of controlling its effluent discharge of copper

and to submit quarterly progress reports.

Olin was to report in

40—138

---

the event the starch xanthate process for controlling copper be-

came

commercially available.

Olin has provided the quarterly

re-

ports

as

required.

The starch xanthate process is

in use at

several

small facilities.

These have reported effluent copper

concentrations ranging from 0.05 to 0.68 mg/i.

The largest of

these facilities treats only 150 gallons per minute

(0,2 MGD).

Olin

states that none of the users of starch xanthate are treat-

ing

waste streams like Olin’s, that none have flows approaching

Olin’s

and that none have achieved effluent copper concentrations

of

0.02

mg/i

(Pet. Ex.

C).

The Zone

6 discharge has a high flow and many sources of

wastewater.

The Zone 17 discharge appears to be

an ordinary metal

finishing waste stream with a discharge only slightly larger than

those

for which the starch xanthate process has been employed,

0.52 MGD or

360 gallons per minute.

Olin has not pointed

out any

particular problem with treating the Zone 17 wastestream with

starch xanthate.

As noted above, Olin is discharging

about 440—540 grams of

copper

per

day from the Zone 17.

If the 2.0 Ml/day were treated

to

0.05 mg/i, the lower reported limit for the starch xanthate

process,

this discharge would be reduced to about

100 grams per

day.

Although the minimum reported concentration is still two and

one—half times the water quality standard, there is

a potential

for

a reduction in the mass discharge of three to four hundred

grams per day.

The facts alleged in the petition are insufficient to justify

the award of a five year variance for the Zone 17 discharge.

I-low—

ever, the facts

are also insufficient to cause the Board to re-

quire the employment of the starch xanthate

process

at this time.

The Zone 17 variance will be limited to eighteen months.

Within

twelve months Olin shall present to the Agency

a detailed study

of

the starch xanthate process

as applied to the Zone 17 discharge.

This study shall include cost estimates, including

a comparison to

the

cost

Olin incurs in treating the Zone 17 discharge.

Any peti-

tion for variance renewal shall include an updated study of the

effect of the copper discharge on the receiving stream.

The June

3, 1976 variance contained a condition that the dis-

charge not exceed 0.5 mg/I copper.

Olin has sometimes exceeded

this level and has reported this to the Agency

(Rec.

3).

Olin has

reported

levels as high as 1.33 mg/I.

It is not clear whether

these

are grab samples.

The Agency has requested a condition that

the levels not exceed 0,5 mg/I “at any time.”

This could be con-

strued

as requiring grab samples to be less than this value.

To

allow

for variability, the Board will specify an averaging rule

in the Order.

Olin has met

a long term average, based on annual

40—139

---

and

biennial

results

~i 0~3ro

1

Pet,

Dx

B~2),

The Board

will

require this

on

a thirty day average,

The daily average

shall

not exceed

0,6 mg/i

with no grab samples over 1,5 mg/i.

On

September

2~

1980 O1~npro3o’e~ a ~‘itespecific

water

quality

standard

for tIe lover reacles ‘~tWood Piver,

On October

30, 1980

the Board

refused to autro

~zc ~ie proposal

for a hearing

and requested

editorial changec in the pLoposed

language

(R80~-

).

The Board

expects

Olin

to

31

v Lursue ~ts efforts

at obtain~-

ing a rule

change,

For

the reasons

discussed above and in the previous

Opinions

and Orders,

the Board finds thaL

Ollit Corl

ration would

suffer

arbitrary or

unre~sonaoieba~’d~

it

if der~eda variance from

the

water

quality

stard~x3t~r

~p

t-i~

~i’ii

~aiiance will be

granted

with the

conditions d~

c

apae~r~

0

This Opinion

cors

~tute

~

3

rr3~sfindings of

fact and

conclusions

of law ~n U

s

a~sr

Petitioner,

Ollr

or ora~

0r~ntU tot outfalls 001

and

015 for

Zones

6 mcd I

~ var

~r

1~c~th~rater quality

standard

for copper

found U

PrU

~ I

f ~

ll

3’

Water Pollution

subject to

the foil w~ngccr~r ~

1.

The variance

fr oath

I 0~

Zoo

6

will expire

December

18

1985 o~

n ilopton br the Board of a

modified

water quality ~ ard~rdfor copper

in Wood

River,

abiche~mcacci~sr~

2,

The

variance Lot 3u~hi:

or~U

will expire

June

18

l98’~

3.

Petitioner shaLl

met

Uie

~

~owirg Ufluent standards

for

copper for abe

~is~ argmc covered by this

variance,

Rule

408 of CU’~t~r3,

a ~r P

ilut:jn twtwithstanding:

t’oriliil av r

qe

3

mg/I

rally a~’er1gu

C,6

mg/n

5 i~/l

4~

On or

before

~e crnomc U,

~98l Our

shall forward

to

the

Agency a ~e~~Ld

id: o~ ~re tmoiementation of

the starch

xantiatc prc~s

to o~tfall015

(Zone

l7)~

This

study snail inc1uda

ost estimates and

comparison

with

the costs

0 mc

is incurring

in treating

the

Zone

17

discharge,

---

5.

The motion for leave to file recommendation is granted.

6.

The

Agency,

pursuant

to

Rule

914 of Chapter 3, shall

modify NPDES permit 1L0000230 consistent

Order.

7.

Within forty—five days of the date of this Order, Peti-

tioner shall execute and forward to the Illinois En-

vironmental Protection Agency, Variance Section, 2200

Churchill Road, Springfield, Illinois 62706, a Certifi-

cate 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 Certifi-

CERTIFICATION

I,

(We), ______________________

_____,

having read

and fully unde~r

ingte

rerinPCBSO—170,

hereby

accept that Order and agree

to be bound by all of its

SIGNED _________________________

TITLE

___________________________

DATE

____________________________

IT

IS SO

ORDERED.

I, Christan

L.

Moffett, Clerk

of

the

Illinois

Pollution

Control

Board,

hereby

ce:çtify

that

the

~bove

Opinion

and

Order

were

adopted

on

the

1~

day

of

~

1980

by

a vote of

~/-o

(~\~j

/

1

7~)

~tL:

Christan

L.

Mo~f~,

Clerk

Illinois

Pollutiôii

Control Board

40—141