ILLINOIS
POLLUTION
CONTROL
BOARD
March
~L6~
1978
IN
THE MATTER
OF:
THE PROPOSED
AMENDMENTS
TO
)
R76-18
RULE 203.1 OF
THE
WATER
POLLUTION
REGULATIONS
PROPOSED
OPINION
AND
ORDER
OF
THE
BOARD
(by
Dr.
Satchell):
This
matter
conce rue
a
proposed
amendment to Rule
203.1
of
the
Chapter
3
Water
Pollution
Regulations.
The
proponent
Illinois
Power
Compeny
(iPc)
requests
that.
an
exception
be
made
to
the
boron
water
quail
by
standard
for
a
certain
portion
of
an
unnamed
tributary
to
Wood
RIver
Creek
and
Wood
River
Creek
itself
below
1PC
s
generating
plant
known
as
Wood
River
Station.
“Wood
River”
and
~Wood
River
Creek”
are
used
inter-
changeably
throughout.
these
proceedings
to
designate
the
stream
into
which
the
unnamed tributary flows and which
empties
into
the
Mississippi
River.
The language proposed
is
as
follows:
(b)
The boron limitation
in Rule 203 (f)
sha:L1
be
inamlicable
in
the unnamed
tributary
of Wood River Creek
which
enters Wood
River
Creek 4700 feet above the confluence
of
Wood River Creek with the Mississippi
River
from a point 450 feet above the confluence
of
the unnamed
tributary and Wood River Creek to
said
continence,
and
in Wood River Creek
from
said
confluence to the confluence of Wood
River Creek and
the
Mississippi
River,
and
in
lieu of the Limitation
in
Ru:Le
203(f),
the boron
limitation
nha:Ll he 25 mg/i
in the
aforesaid
waterways,
This proposal
was filed with the
Board on September
13,
1976
and published
in Environmental Register
#135 on October
21,
1976.
As
this matter is slnw specific only two
hearings were held.
The first
hearinq was on January
25,
1977
.in Edwardsville,
Illinois.
The second hearinci which was
a
joint merit
and
economic impact hoa:ciny
was held
in
Alton,
Illinois on
August
29,
1977.
This
particular
problem
has
been
before
the
Board
on
several
occasions.
In POE 74~9, 12 FOB 31
(1974)
and
PCB
74—423,
15
PCB
261
(1975)
IPC was granted
research
variances
to
deal
with
their
boron
problem.
This
research
proved unsuccessful
and
IPC
received
an additional
variance
PCB
75-221,
19 PCB 489
(1976)
,
until
March
15,
1976.
Currently
IPC
has a variance,
PCB
76-74,
22 POE 53
(1976)
pending the resolution of
this
regulatory
proceeding.
29
—
395
Prior to discussing the merits of
this
regulatory
change
the Board must rule
on two motions still
pending in this
proceeding.
The first motion
filed
by
I:Liinois
Power is to
make several corrections to the transcript of the August
29,
1977 hearing.
No objections were
filed, the
motion will be
allowed
and thereby made a part
of the
record,
The second motion
was by the Illinois Environmental Protection Agency
(Agency).
This motion requests the incorporation
of pages
32—414 of PCB
73—509 and 73~5l0 (consolidated)
into the
record of this
pro-
ceeding.
These pages include the testimony of
Dr. Donald
McDonald,
William Tucker and Robert
.Hite
concerning the
bio-
logical condition of Wood River Creek, including the portion
of said
river downstream from IPC~sash pond
discharge.
IPC
had
no objections
provided the Agency admit the
following facts:
1.
That Dr.
McDona1d’~s
references
to
the “Ash
Pond
Discharge”
or
similar
terms
(see,
for
example,
pages 99
and 160
of the transcript)
in
fact
refer
to the point of confluence of the
unnamed
tributary
referred to
in the present
proceeding
and Wood River Creek
and do
not
refer
to the out-
fall of
Petitioner’s
ash
pond
into
said unnamed
tributary.
2.
That said unnamed tributary,
in addition
to
receiving the discharge from Petitioner’s
ash
pond also receives other industrial, commercial
or municipal discharges
as well as surface
run—off.
3.
That the areas studied by Messrs.
Tucker
and
Hite
and referred to
in
their
testimony
are all
above
or
upstream of the point of confluence
of the
unnamed tributary referred
to
in the
present
proceeding and Wood River Creek.
The Agency admitted all the requested facts.
The
Board will
allow the incorporation of
pages
32-414 of the earlier
proceeding,
PCB 73—509, 73—510,
into
this record.
The facility
in
question
is
a.
fossil—fueled
electric
generating
plant
known
as
the
Wood
River
Station.
The
two
largest
units
representing
62
of
the
maximum
plant
capacity
burn
coal;
the
remaining
three
units burn
oil,
As
part
of
the
operation of the plant, 1PC operates
an
ash
lagoon system to
treat the
fly
ash
and
the
bottom
ash sluice waters,
Water
is
withdrawn
from
the
Mississippi
to
sluice
the
ash
to the lagoon
for
settling
suspended
solids.
After
the
settling
of
the
solids,
the
excess
water
is
discharged
from
the
lagoon
to
the
unnamed
tributary to Wood River
and
through
Wood
River
back to the
Mississippi.
During the sluicing and settling process
in the ash lagoon,
soluble boron is dissolved from the
ash
and discharged,
generally
in excess of the present standard for
boron
in Rule 203(f) of
29
—
396
Chapter
3.
IPC intends to construct a new ash lagoon because
the retention time in the existing lagoon has been reduced by
bhe accumulation
of ash so that there will not be sufficient
retention time to adequately treat the suspended solids and pH.
Under the Board’s current regulations
if the current ash
lagoon discharge went directly into the Mississippi River the
boron standard would be met because
of
the much larger dilu-
tion factor,
As it now exists the IPC discharge frequently
exceeds the applicable standard for boron for the unnamed trib-
utary and for the
segment
of Wood River Creek
(Pet.
at
2,
R.
10).
The new lagoon
is being designed to discharge to the unnamed
tributary of Wood River Creek just as
the
existing
lagoon does
and it is anticipated that the effluent will continue to
exceed the boron standard.
IPC originally explored a
number of different alternatives
to the boron problem.
Because of costs
(ranging from $461,971
to $2,440,221)
and apparent lack of environmental degradation
of Wood River, IPC chose to pursue the alternative route that
would require this regulatory change
(Ex.
1,
R.
12,
13).
Illinois Power believed that there was inadequate environmental
justification for imposing
the
additional costs of the other
alternatives on its customers
(R.
13).
illinois
Power retained
James A. Cox,
C.
David Schmulbach, Donald
R. Tindall and
Walter E.
Schmid, all PhD’s
at Southern Illinois University at
Carbondale
(SIU-C), to investigate this matter
(R.
13).
The latter
three gentlemen all testified at the hearings.
Drs. Schmulhach
and
Cox conducted research studies
for IPC to find an economically and technically feasible method
to reduce or remove boron concentrations in the coal ash pond
effluent.
Their
final
report
(Ex.
2)
covered the period
March
15,
1974 to June 30,
1975.
Dr. Schmuibach testified
that:
(1)
Unfired coal contained 170 ppm boron,
(2)
Bottom
ash contained 960 ppm B, and
(3)
Fly ash contained 1900 ppm B.
In the aforementioned report
(Ex.
2)
,
samples of southern
Illinois coal used at
this
plant upon analysis showed boron
contents from 118
t.o 170
ppm B, which was stated to be typical
of Eastern Interior Province
(96 ppm B
ave.)
and Northern Great
Plains Province
(116
ppm B ave.)
.
Appalachian coal was stated
to contain 25 ppm B.
Exhibit 14
(The Economic Impact Study,
IIEQ Doc.
No.
77/19)
stated that IPC
burned :Ellinois
#6 coal
until June 1975 from the Streamline Mine,
This coal con-
tained 168-170 ppm B and the ash contained about 1900 ppm B.
Various coals were burned
from
July 1975 through September 1976
at which time low sulfur coal supplied by Energy Fuels Corporation
of Colorado became the only coal
source,
This coal, reported
to be from the Fishcreek and Wadge Seams, contained about
136 ppm B and produced ash with from 440 to 1400 ppm B
depending on the ashing techniques used
(Ex.
14 at
7,
8).
As
mentioned
in Exhibit No.
2, one method of boron concentration
29
--
397
control would be to burn coal with a low boron content
(Ex,
2
at
10).
It
is noted that IPC in their selection of
a low
sulfur
coal also acquired a coal lower in boron content.
The values given from the above study
for boron
content in
the
coal and in the ash indicate that boron in coal
is
not
in
volatile forms
(R.
40).
Much of the boron in fly ash
(about
50)
is readily water soluble; while bottom ash contains a
much
lower concentration of leachable boron
CR.
40, 41).
Methods
tested to reduce boron concentrations Included:
(1)
High
temperature firing of fly ash,
(2)
Boron adsorption
on lime-
stone
and clays,
(3)
Dialysis through ion-exchange
membranes,
and
(4)
Adsorption on a boron specific, ion—selective,
bead—
type resin
(R,
40-43).
None of these methods were
deemed to
present a treatment both economically and technologically
feasible.
Analysis
of the water before contact with the ash
showed a boron content of 0.35 ppm.
This was increased to
3.30 ppm at the hopper discharge and to 5.00 ppm at the
Sluice
Pond overflow to Wood River.
Studies indicated that boron
was
solubilized within
5 minutes over a pH range of 4-10
(Ex.
2
at
4).
Utilizing the data from the study,
the researchers stated
they
calculated the theoretical maximum concentration of boron
that
could be contained in the effluent.
Using worst case
assumptions,
they concluded the maximum concentration could be 23,7
ppm B
(R.
44)
Based on a limited literature review on the toxic
effects
of boron and data available on the stretch of Wood River af-
fected, Dr. Schmulbach concluded that the boron discharged
would
present no threat to microinvertebrate and fish populations
CR.
45)
He recommended a professional botanist conduct a
detailed
survey of aquatic and terrestrial flora in the Wood River Creek
Area to determine if boron damage had occurred
CR. 46)n
Drs.
Donald
R. Tindall and Walter
E.
Schmid,
professors
in
the Department of Botany, SIP-C, were retained to conduct
the
survey.
~Dr. Tindall specializes in phycology and aquatic
vascular plants;
Dr. Scbmid specializes in plant
physiology
and
particularly in the area of micronutrient element uptake and
translocation in higher plants
(R.
57).
While the survey was conducted on a single day
(July
14,
1976),
CR.
58) boron has been discharged into the system for
about 25 years
CR.
94).
Samples of periphyton and phyto-
plankton from the water were taken.
Terrestrial and aquatic
vegetation was observed for species diversity and abundance and
for evidence of boron toxicity.
At nine separate
locations
selected to be representative of possible affected and non—
affected sites, detailed species identification of both terrestrial
and aquatic plants were made
(Exhibits
3,
4,
5),
The results
of the study can be summarized very briefly by the following
quote:
“We can conclude that the boron concentration present
in IPC~sdischarge
has
not had any discernible adverse effect
—5—
on the observed terrestrial and aquatic community, which
is
typical in constituents, maturity, quantity and in all other
respects to those found in this region.
In our opinion the
continuation of this discharge will not produce any adverse ef-
fects on the ecosystem of the unnamed tributary and Wood River
Creek”
(R.
63,
64).
Water samples taken the next two days
(July
15 and 16) upon
analysis showed
the following boron contents
(highest
value only)
(1)
ash pond,
4.4 ppm B,
(2)
unnamed tributary,
3.3 ppm B,
(3)
at confluence
(in
the mixing zone)
in Wood River,
2.8 ppm B,
(4)
upstream from confluence mixing zone in Wood River, 0.7 ppm B,
and
(5)
downstream from mixing zone,
2.1 ppm B,
(Ex.
6)
Mr.
Cecil
A.
Longwisch, representing the Madison County
Environmental Committee,
spoke against granting the exception
without a full year study on the effects of boron on the stream
biota.
His major concern was the food chain culminating with
fish.
His concern included
a fish kill for unknown reasons that
apparently occurred in the spring of 1976
(R.
89).
The Agency submitted supplemental data
(Ex.
7)
concerning
boron in the environment.
This statement was included;
“Several studies have shown that for fresh water fish the
toxic
level of boron is 2000
+
950 mg/i as boron.”
The Agency’s
statement included quotes from specific studies showing boron
to be toxic, teratogenic or mutagenic, when present in high
concentrations particularily during the very early developmental
stages of some species.
In Exhibit
12 submitted by the
Agency one document reviewed indicated some posthatch injury,
one percent mortality
(LC1),
to rainbow trout, channel catfish,
and goldfish at concentrations less than
1 ppm B.
However, the
concentrations necessary to achieve a mortality of
50 per cent
(LC5O)
ranged from 22 to 155 ppm
B in this study for these
same species.
Such large differences
in lethal concentrations
(LC) from a one percent
to
a 50 percent concentration cast
some doubt on the accuracy of the difficult-to-determine LC1
concentrations.
IPC’s aquatic biologist, James A.
Smithson,
also testified concerning the fish kill and the very high boron
levels reported
in
the literature needed for lethal concen-
trations
to
fish.
For example, he cited Turnbull who reported
a 24—hour TLm for bluegill, to be 2,400 ppm B, when supplied
as boron trifluoride
(R.
146)
.
The term “median tolerance
limit”
(TLm)
is essentially equal to LC50 and when coupled
with the time of exposure
(often 96 hours)
is the usual method
of expression
in fish toxicity studies.
With respect to the aforementioned fish kill the previous
spring on Wood River Mr. Smithson reported:
(1)
That he per-
sonally noted dead gizzard shad more than one-half mile upstream from
IPC’s discharge and
(2)
That Mr.
Rudy Stinauer, Region IV
Fisheries Manager, Department of Conservation, had investigated
the fish kill and had sent him a letter
(Ex.
10)
stating that he
29
—
399
—6—
had observed dead gizzard at a point more
than one mile upstream
of
IPC~s discharge
point
(R,
146),
Mr.
Smithson
testified that
he conducted
a biological survey in Wood
River Creek upstream
and downstream
from the confluence of the
unnamed tributary, the
unnamed
tributary
itself,
and
the
Illinois
Power
discharge
ditch.
Fish
were sampled with a seine,
and the
benthic com-
munity was sampled with a Ponar dredge,
No
fish
were found in
Wood River Creek.
IPC~seffluent ditch yielded
70 green
sun-
fish and the greatest diversity and abundance
of benthic
organ-
isms.
The population structure of the sunfish
suggests they
are reproducing in the ditch and have done
so for
more than one
year.
“The greater diversity and number in
the
Illinois Power
ditch,
and the lack of such in the Wood River
Creek, suggest the
Illinois Power effluent not only does no
harm
to
the aquatic
community but in fact supports a better community
of aquatic
organisms than the Wood River Creek”
(R.
148,
149).
As
previously noted a
portion of the record from
PCB
73-509
and 73—510 was referenced into these proceedings,
In discussing
the lower portion of Wood River,
Dr.
D.
B,
McDonald,
a limnologist
and
witness for Olin stated they found it had a
very
low
pro-
ductivity.
“The habitat variety was very
limited, very
very
limited in this area.
In other words,
I would
say this
is a
very poor habitat for the propagation of fish.
It
is
not a
desirable spawning or nursery area because of the
limited
habitat types.
It supports neither a variety,
nor a real
abundance of organisms in general.”
(PCB
73-509 and 73-510,
at
100).
“...The low head dam and the channelization
together,
and,
of
course, to
a lesser extent, the levee all
contribute
to the
fact
that this stream is very different
than the typical
un-
modified
midwestern stream”
(Id. at 101).
“I
would say that
from what I worked on other midwestern streams,
that the fish
community of the upper sections of Wood River
is very typical
of
a small midwestern prairie stream.
.
.Now,
to
go to the
other end of the fish community in the stream,
the section in-
fluenced
by the dam is composed of carp,
shad, and a few gar.
This
is
the
area
where the ponding occurs,
where there is very
little
current,
where you have
this
very
silty bottom”
(Id,
at
114,
115).
Dr. McDonald
tated that many river fish
utilize smaller
tributaries
to spawn and to feed in,
In this
case such fish
were not found above the dam suggesting the
dam restricted
fish movement from the Mississippi up Wood River
(Id.
at 116).
He further stated that,
“I see no evidence to
believe that
Wood
River does or
is capable of supporting fishery of
sport
or
com-
mercial significance”
(Id.
at 120).
Water samples were taken for chemical
analyses.
Although
the water contained several regulated elements in
concentrations
above those specified in the water quality
regulations,
no con-
sistent relationship was shown between
chemical content and
biota assay.
Dr. McDonald stated,
“It is
my opinion
that
the
29
—
400
major
factor
influencing
Lte
coripus~tint
I
the.
~ijta,.
the
number
of species
present,
tue
major
l:rnrnano
ctnrs
if
you
will,
are
the
morphometric
factors,
~h~ni
~5Ct
non,
the
low head
dam”
(Id.
at
273)
Agency
aquatic
biologist~• ~i~ihan 0
ho
rid
Robert
L.
Hite
,
conducted
surveys
on
Wool diver
0
t ated
“So
in
sunmiary,
the
iiisis~itions
to
tta
agueri
n~
~‘c:her
than
habitat
limitations,
and
in
my
pin ion
r
ludlaty
limitations”
(Id.
at
35b
The Agency ~sd no’. taxe
water
samples
for
chemica~
analysis
to
coinpinmoon
tdia
saclogical
surveys.
Nor
were
samplings
or
surve’
s
mdc
in
tue
lower
reaches
of Wood River
(Id.
at 388,
392)
Since the exhinits to
~o.c
~Lpan
Own
~
Ir nnsnripts
were
not
incorporated
into
this
pocotedin;,
‘~
till
:nu,Lt
to
folLow
exactly
what.
portions
fall
:nt
t.
~
olassification
of
pollutedd
balanced~
etc..
Howeve.~
no
:1’
the
Agency
sampled
areas
apparent1~i
were
upstrnc:m
0.
~oa
being
con-
sidered,
the
Board
is
disposed
to
ants
o~~l.
-~.
~‘cOonald
in
that
Wood
River
would
present
a
very
pmw
hol
or
icr
armatoc
organisms
from the ash pond. effluent on
tt~
~cw
bead
dart’,
From
the
studios
dnct
.m’r”or
~.
a
or’
I
specific
segment
of
Wood.
River
and
th~
unnemoc
on
~no
Board
concludes
that
environmental
effects
o
J
or ow
c elsased
by
IPC
in
the
past
have
been
minimal.
The
31.
on
1
~cnIitions
presented
at
this
location
are
particularly
uninic
,
The
scream
segment
is
placed
in
a
highly
developed
induorwor
~rc.a
——
Ihus
there
is
little
or
no
possibility
of
water
nun
1~t
‘or
~‘
in
or
Irrigational
purposes
,
(2)
The
morphooqy
~‘
I
ohs
S ‘tin!
LIiE~
law
head”
dam,
silty
or
ssndy
shifting Loft
‘0
or
;li
zution——
destroying
protec
tine
pool
s”
prar ti.
r
~n’:
~cir
the
presence
of
the
boron—sensitive
early
d~vc’lu1ri1~
of
us
h
re-
production
and
(3)
The
sti
LaS)
eIrt.-or
I
r
~
:~LLs:3issippi
River,
causing
high
dilution
Lheraby
N~or’Te
‘or
soy
downstream
concerns.
IPO’
s
anaJys~u•;
for.
DO~Oflprior
I
ore,
at
best,
subject
to
questscr.
‘lie
methed
n~~”
-,
“
i~u-n.’
:Ls
suitable
for
concentrati
ons
u~ so
nn~
B
‘I
or
v’~:
r’ ‘~ron
concentration
at
their
ash
lasoun
cs~vta1l
was
nor
mu
or
“born
this
one
of
their
tanrinicans
htartlnq
ri
‘nç
ais:.t!y
routinely
made
a
1:10
dilution
but
neqLect~d
00
‘n.”den
this
or:
his
final
analytical
results
(Ex.
9
at
3).
fn
ci
I
“or
r.
r
single
standard
solution
of
0.5
:ag
B/i.
was
tine i
~vei.
~
or
~.:t
on
recalibrate
their
spectrophotcmeten.
Gr,~atori: e.
or”c
near
the
limits
of
detection
(upper
arid
ioweiO.
host
-~
no.~anI
rnenhods
require
systematic
daily
checks
of
the
ctandrrci
or’
to,
osnure
accuracy
(Ex.
13
at
4)
.
In
July
19~/6
,
iPc
staor:re
cii
orting
samples
with
ARDL
Lab
in
Mount
Vernco.
.
Tney
~r’’nd
nhcnr
Baldwin
Lab
results
ran
about
40
lower
that,
ARD’L
‘hor
!i
correction
was
applied
to
the
48
samples
flow
the
B~T,dwis
‘toboratory
(Ex.
9
at
5)
—8—
The
amended
IPC
Boron
analyses
shown
in
Exhibit
14
(Appendix
B—l)
reveal values
from
o.:L
to
17 mg boron per liter.
Values
greater
than
10 mg B/i
during
1974
and
1975,
a period during which some
reported values were multiplied by 10,
are
somewhat suspect
since such
values
would
have
exceeded
the
working range of the
method even after
the
10-fold dilution.
The Board
re relic the absence
of
dependable
analyses during
the
period IPC
was
utilizing
Illinois
Coal
as these values would
have
been helpful
in
a
selection
of
an
appropriate standard.
Dr.
Schmulbach
testified
that utilizing
worst
case conditions a
maximum
concentration
of
23,7 mg B/I
could
ensue
(R.
44).
The
methods of
calculation
are
shown
as
“Exhibit
1” appended to
Exhibit 11.
The
values given
therein
are
23,3 for high sulfur
coal
(Illinois)
and 10.0 for low sulfur
(Colorado)
coal.
Drs.
Muchmore and
O’Brien
also
calculated this value and found 20.9
mg B/i for
Illinois coal
compared to 8.9 rag B/i for Colorado
coal
(Ex.
14 at
13).
It
is realized high
rates of evaporation
with long retention
times
in the ash pond could yield concentra-
tions
greater
than
these,,
IPC is presumed to
have
arrived
at
their proposed
25
mg
B/i
concentration based on Dr. Schmulbach’s
calculations,
The Agency states the
use
of IPC’s analytical data prior
to September 1976 to establish historical discharge
levels is
extremely inappropriate.
They would therefore
use
only
data
collected by
1PC after
September
1976.
Agency
data for 1976 in-
dicated a maximum
value
of 5,0 mg/l
and a medium value of 3.1
mg/I.
IPC data
(DMR)
from September
1,
1976 through
April
31,
1977
showed
an
average
value
of
3.0
mg/l
and
a
maximum value of
4.2 mg B/i
(Ex.
12
at 3).
The
Agency
recommends
a
concentration
standard
of
5
mg B/i~.
Mr. Larry L.
Idiema:ri
Director
of
Environmental
Affairs
with
IPC,
testified
that several
developments were under way
that
could
permit,
or
even
require,
the use of some Illinois coal.
IPC has supported
research
on the Allis-Chalmers KILnGAS low
btu coal
gasification
process
and one of the five demonstration
power plant
locations
‘order
consideration
would utilize the
Wood
River
oil—fired
units.
If
selected,
the
coal ash from the
gasification
process
would
go
to
IPC”s
ash
lagoon
(R.
156).
The
sulfur content
of the
Colorado
coal
might
permit
some blending
with
Illinois
coal
if
aporopriate
equipment
were added to the
plant.
In addition,
evergy
legislation may require
retrofitting
the present three
oil-fired
furnaces
to burn coal
(R.
157).
The Board
finds
that the
risk of environmental harm in this
very unique
situation
does
not
justify placing the boron standard
so
low
that IPC
may
be
precluded
from
using
Illinois
coal.
With
present
operations
and
Colorado
coal
during 1976 the Agency
shows
a maximum
concentration
value of
5
mg/i.
Drs. Schmulbach
and
Cox calculated
this
coal
could
give
a maximum value of
10
mg/i and Drs.
Muchmore
and O’Brien in
similar
calculations
report a value of
8.9
mg
B/i.
The above researchers calculated
values of 23.3 and 20,9,respectively,
if
Illinois coal data were
used in the calculations,
29
—
402
According
to these calculations,
the Illinois coal
could
give
values
about
2
1/3
times
higher
than the Colorado coal
or
concentration
values
of
about
12
mg B/i under normal
operations
could
be
expected.
IPC
reported
values up to 17 mg
B/i
during
1974 and 1975
while
burning
Illinois coal; however,
the
highest
average
value was
12,95 mg B/i
(Ex.
14 at Appendix B-i).
While
the
Board
realizes
IPC”s analyses
at that time were of
dubious
accuracy,
they
are the best estimates
available and are
rea-
sonably in
accord
with values
expected when the differences
in
boron content
of
the fuels are
considered.
The following
conclusions were
reached
in the economic
study
by
Drs.
Muchmore and O’Brien:
a.
Should
the proposed change
be denied additional
estimated
costs of
$272,000 capital and
$8,300
annual operating
would
be required by IPC for
the
next
least
cost
alternative,
No significant effect
wouldbe
anticipated
on
the
availability of
goods
and services, and
the
availability of employment.
b.
No
discernible effect would be
anticipated on
Illinois
agriculture or local
government.
c.
The
direct
economic impact of
the
proposed
rule
change on commerce and industry would be minuscule.
The
secondary
effect,
in
terms of
attraction
of
new
industry,
is difficult to
evaluate on a quantitative
basis but
should be
given careful consideration.
Actions
on any proposed
rule change affecting
industrial
operations
would be
expected to influence
the
at-
titude of
industries
contemplating expansion
in
Illinois.
In
summary,
it should be
noted that the proposed
rule
change would
preserve the status quo.
Should the
rule
change be granted
and evidence of environmental
damage
be disclosed
at some future date, the
cost
of
backfitting
a
pump-transfer
inc system to the
ash
pond
discharge
should not
(except
for
inflation)
be
significantly
greater
than
today’s
cost
(R.
258-259).
In
conclusion the Board finds that a boron
concentration
of
15
mg.
boron
per
liter
as a water quality
standard
in
the
streams
(the
unnamed
tributary and
Wood
River Creek)
below
IPC’s
ash
pond
discharge
point
would have a
minimal environmental
impact on aquatic
and
terrestrial
flora and fauna in
and
associated
with
these streams,
A~lowing
this concentration will
also pro-
vide IPC with
an
economical
route
to the Mississippi
and in
light of current
energy concerns provide
enough flexibility that
Illinois coal
could be used.
29
—
403
ORDER
It is the Order of the Pollution Control Board that an
addition be made to Rule 203.1
of
the Chapter
2:
Water Pollution
Control Regulations.
A new subsection
(b)
shall be added to
read as follows:
(b)
The boron
limitation
in
Rule
203(f)
shall be
inapplicable in
the
unnamed tributary of Wood
River Creek
which
enters
Wood
River Creek 4700
feet above the confluence of Wood River Creek
with
the
Mississippi
River from a point 450 feet
above
the
confluence of the unnamed tributary and
Wood River
Creek
to said
confluence,
and
in
Wood River Creek
from
said confluence to
the
confluence of Wood
River Creek and the
Mississippi
River, and
in lieu of the limitation
in Rule 203
(f), the boron limitation shall be
15 mg/i in the aforesaid waterways,
I,
Christan L. Moffett, Clerk of the Illinois Pollution
Control Board, hereby certify
the
above
Opinign and Order
were adopte
on
the
J~,,,,,
day of ~
1978 by
avoteof
..~
,
/
~
Illinois Pollutio
ontrol Board
29
—
404
