ILLINOIS POLLUTION CONTROL BOARD
    June 28, 1977
    REVERE COPPER AND BRASS, INC.,
    )
    Petitioner,
    v.
    ) PCB 76—246
    ENVIRONMENTAL PROTECTION AGENCY,
    Respondent.
    OPINION AND ORDER OF THE BOARD (by Dr. Satchell):
    Revere Copper and Brass, Incorporated, filed on Septem-
    ber 20, 1976 a petition for variance. A variance is sought
    from Rule 203(f) of the Chapter 3: Water Pollution Regula-
    tions (Chapter 3) as applied to copper. An alternative
    request is that the Board reclassify Revere Ditch, pursuant
    to Rule 302(k) of Chapter 3 as a secondary contact water.
    An Agency recommendation was filed on November 29, 1976.
    After the filing of the recommendation the Petitioner and
    the Agency entered into negotiations which resulted in an
    amended recommendation and a stipulation filed on March 31,
    1977.
    Petitioner’s alternative request to reclassify Revere
    Ditch as secondary contact water must be denied. The Board
    has previously ruled that in order for a water of the State
    of Illinois to be so classified the Board’s regulatory process
    with the requisite public notice must be pursued, Olin Corpor-
    ation v. E.P.A., PCB 73-509, PCB 73-510 (Consolidated) (June 3,
    1976).
    Petitioner is engaged in the production of seamless
    copper tube, stainless steel utensils and fabricated metal
    products in two separate plants both located in Clinton,
    DeitJitt County, Illinois. The Tube Mill Plant produces the
    seamless copper tubing and the Manufacturing Plant produces
    the stainless steel utensils and the fabricated metal products.
    Operations at the tube mill include:
    (I) Cathode and high quality copper scrap; melt; cast
    into billets (standby Ajax electric furnace and
    casting unit available); production, about 4 x io6
    pounds per month.
    (2) Oil-fired furnace reheats billets for piercing into
    seamless shells; quench26
    25
    in water; pickle in 10 H2S04

    —2—
    rinse; draw, anneal, saw, pack, etc. to
    customer’ s specifications.
    Copper is put into the water in the following ways:
    (Pet. Dwg. #EV-S-201-A).
    Quantity of Water Used
    Copper Added
    Operation
    (Gals. per day)
    SuFpended Dissolved
    Billet Quench &
    40,000
    49.2 ppm 0.17 ppm
    Piercer
    16.4 lbs/ 0.057 lbs/day
    day
    Pickle Rinse
    2,500
    134.8 ppm 613.00 ppm
    2.81 lbs/ 12.76 lbs/day
    day
    Continuous Cast
    182,100
    0.13 ppm 0.0 ppm
    Furnace
    0.20 lbs/ 0.0 lbs/day
    day
    Ajax Electric
    20,000
    3.99 ppm 0.5 ppm
    Furnace (Standby)
    0.67 lbs/ 0.08 lbs/day
    day
    Two private inter-connected ponds of about 3 x 106 gallon
    capacity which are fed by field tiles and storm runoff furnish
    water for all non-contact cooling and contact cooling for static
    casting, hot piercing and shell quenching. Pond water is also
    used for rinsing and flushing the pierced and pickled shells.
    City water is used for contact cooling of cast billets and
    for sanitary purposes, these waters are discharged respectively,
    into the ponds and to the Clinton Sanitary District Sewer. Water
    usage is about 387,500 gpd from the ponds and 182,100 gpd from
    the city. The present effluent from the ponds consists of
    569,600 gpd of water containing 0.57 ppm ~2.7l lbs/day) sus-
    pended copper and 0.81 ppm (3.85 lbs/day) dissolved copper
    (Pet. Dwg. *EV-S-20l-A).
    The manufacturing plant (Plant) has two separate depart-
    ments: (1) Stainless steel utensils and (2) Fabricated metal
    products. The Utensils Department press draws about 4 x 106 lbs.
    of stainless steel circles per year into various bodies and covers
    for kitchen utensils. Some of the bodies are copper plated. The
    Fabricated Products Department fabricates about 2.5 x 106 lbs. of
    coil and strip stock of various metals into a wide variety of
    products, including knobs, handles, brackets and studs for the
    Utensils Department.
    26
    26

    —3—
    Only city water is used in the Plant. The 160,000 gpd
    usage is divided into about: (1) 35 non-contact cooling,
    (2) 7 boiler make up, (3) 7 sanitary and (4) process waters
    for pickling, cleanin and plating operations. All effluents
    presently a~edischarged to the city sewer system.
    “ReverE. Ditch” carries the overflow from the afore-
    mentioned ponds for a distance of several thousand feet and
    discharges into Coon Creek. During extended drought periods
    the upstream sources dry up and the only flow is equal to or
    less than Revere’s city water input of 231,000 gpd.* The
    seven-day ten year low flow of Coon Creek at the junction with
    Revere Ditch is understood to be zero (Pet. 18). Since Revere
    contributes ~95 or more to the total ditch flow, essentially
    their effluent must comply, not with the effluent standards of
    1.0 mg/l but with stream standards of 0.02 ppm copper. Peti-
    tioner states that this is an unreasonable burden as no practical
    treatment technology is currently available to achieve this level
    (Pet~. 10). Revere discussed three alternatives to enable them
    to comply with Illinois stream standards:
    A. Use of T?~aterRecirculation and Treatment System. Dis-
    solved and suspended solids must be controlled so as
    not to leave deposits
    -
    100 recirculation would not
    work. The minimum required 10 bleed-off would be
    200,030 gpd which when lowered by best practical
    treatment would contain 0.5 ppm of copper (Pet. 11)
    and when
    mixed
    with an average of 387,500 gpd of
    upstream water would contain 0.17 ppm of copper. To
    reach the 0.02 ppm required only 0.8 (16,146 gpd)
    bleed-off wculd he permitted. About 294,100 gpd of
    process and contact water is required which if placed
    in a closed lam with 10 bleed-off would yield 82
    more treated water (29,410 gpd) than permitted
    (16r146
    gpd) to achieve compliance. Estimated costs:
    $1,965,600
    capital; $106,000 per year operational.
    B. Eliminate All Effluent by Recirculation and Evaporation.
    As in “A’~ except evaporate bleed-off from contact and
    process waters. Estimated costs: Capital $210354600;
    $351,091 ~er year operational. The 98,111,800 ft~of
    natural gas per year is not available; the #2 fuel oil
    (170,884 gallons per year) is on allocation. Petitioner
    concludes this expensive and energy intensive process
    would yield a highly unfavorable cost/benefit ratio
    (Pet, 15)
    *This listed as 231,000 gpm (Pet. 9)
    26
    27

    —4—
    C.
    Dilute Tube Mill Pond Water to Achieve Stream
    Standards. The pond outfall (001) after treat-
    ment (See “A”) is expected to have a flow rate of
    618,600 gpd containing 0.43 ppm copper. Copper
    free water required to dilute to stream standards
    would be 12,681,300 gpd. This water is proposed
    to be drawn by nine six-inch diameter wells drilled
    into the same water aquifer that serves the city of
    Clinton. This amount of water is about ten times
    greater than that used by Clinton (Pet. 17) and
    would be expected to affect Clinton’s water supply.
    The stream bed below the dam does, not have the
    capacity to carry this additional water and it is
    extremely questionable whether sufficient ground
    water is available (Pet. 17). Estimated Costs:
    Capital, $1,443,400; $553,164 per year operational.
    The Agency recommendation filed November 29, 1976 confirms
    most of Revere’s general facts as stated in their petition. In
    addition, analysis of ten grab samples of the pond effluent
    taken almost monthly from 11/17/75 to 9/21/76 shows an average
    copper content of 1.95 mg/l (Range 0.11 to 4.79) and TSS average
    19 mg/l (Range 1 to 53). Analysis of samples of wastewater
    from the plant to the Clinton Sanitary Sewer System
    (six sam-
    pies) show the following:
    Copper, Ave. 17.6 (Range 1.81 to 66) mg/l
    Cr~3, Ave. 2.23 (Range 0.7 to 4.7) mg/i
    Cr~6, Ave. 0.73 (Range 0.0 to 2.9) mg/l and
    Zinc, Ave. 2.1 (Range 0.9 to 6.0) mg/l (Ag. Rec. ¶11).
    The Agency states Revere proposes to isolate and collect
    the mill’s pickle rinse water and the plant’s copper plating
    rinses, the pickle and bright dip rinses, and the chrome plat-
    ing rinses and to treat these waters in an acid neutralizing
    and metal hydrate removal system (Ag. Rec. ¶12). Petitioner
    predicts the average copper concentration in waters so treated
    will be 0.5 my/I. On September 27, 1976 Petitioner submitted
    a permit application for the construction of a removal system.
    The design maximum flow in the proposed system is 144,000 gpd.
    The aforementioned wastes would be subjected to chromium reduc-
    tion, brought to a pH of about 8.5, passed through a Lameila
    Gravity Settler and centrifuged to de-water the sludge. This
    treatment is expected to effect the following changes: (Ag.
    Rec. ¶13).
    26
    28

    —5—
    Treated Effluent (mg/l)
    Parameter
    Raw Waste (mg/l)
    ~.
    Max.
    Chromium (total
    5.34
    0.5
    1.0
    hexavalent)
    Copper
    126.0
    0.5
    1.0
    Iron (total)
    5.0
    1.0
    2.0
    pH
    2.5 to 6.0
    8.0
    8.5
    TSS
    14.5
    5.0
    6.0
    Zinc
    5.0
    0.5
    1.0
    Petitioner predicts that the above system would give a pond
    effluent of 618,000 apd containing 0.43 rng/l copper or a daily
    discharge
    of~2.22 lbs. copper per day. During periods of
    ex-
    tended drought (only city water discharged) Petitioner states
    the decrease in flow would theoretically produce 0.97 mg/i
    suspended copper and 0.19 mg/i dissolved copper; however, the
    increased pond retention time is stated to increase settling
    of suspended copper so that Petitioner could still meet its
    NPDES point source limitation of 1.0 ppm.
    Petitioner states construction of the system could be
    completed in eleven months after receipt of the Agency permit.
    The Agency is prohibited from granting the permit by Rule 962(a)
    of Chapter 3: in that the proposed construction will not
    achieve compliance.
    The Agency concurs that meeting the 0.02 mg/l copper stream
    standard places a hardship on Revere, but believes Petitioner
    had not presented adequate data as to why a lower concentration
    of copper could not be achieved in the Tube Mill pond effluent.
    Petitioner’s proposed plan did not include treating the 40,000
    gpd effluent from the billet piercer and quenching operation
    (49.37 mg/i copper; 16.47 lbs. copper per day), as well as the
    Ajax Furnace (only used during emergency periods) effluent
    (20,000 gpd, 4.49 mg/i
    copper,
    0.7 lbs. copper/day)
    .
    The sys-
    tem as J)rOpOSed would treat only 81,600 qpd. ‘iddition of both
    of the above ~treams
    would cause the systc’iu Lo operate at
    144,100 gpd--only 100 gallons per day over the present
    design
    maximum. About
    17 pounds of copper per day would be eliminated
    from the Tube Mill pond (Ag. Rec. ¶21).
    The Agency discusses copper removal technology stating at
    least four major types of treatment are available: (a) precip-
    itation, (b) evaporative recovery, (c) ion exchange and
    (d) electrolytic recovery. Processes b, c, and d appear
    economically feasible only when conditions are favorable for
    recovery.
    26
    29

    —6—
    Mention of a promising copper
    removal research program is
    incorporated in the record of Olin Corporation v. EPA, PCB
    75-369, regarding Dr. R. E. Wing’s Agriculture Research Service,
    United States Department of Agriculture investigation of the
    use of starch xanthate with a polyelectrolyte. The Agency con-
    tacted Dr. Wing who was of the opinion that addition of an
    anionic polyelectrolyte following lime addition could reduce
    copper concentrations to about 0.2 to 0.3 mg/i. Starch xanthate
    is not yet economically available (Ag. Rec. ¶23).
    The Agency cited several sources on the effect of copper
    on aquatic life showing again the sensitivity of phyto-and
    zooplankton to micrograms/l concentrations of copper.
    The Agency’s amended recommendation filed March 31, 1977
    recommended the grant of the variance subject to certain con-
    ditions. These conditions became the basis for a stipulation
    entered into by and between the Petitioner and Respondent.
    The Board finds Petitioner, Revere Copper and Brass, Inc.,
    would be subject to an unreasonable hardship if compelled to
    meet the stream quality standards of Rule 203(f) of Chapter 3
    as it pertains to copper in the effluent from its facilities.
    The conditions imposed and accepted by stipulation represent
    an equitable balance between protection of the subject receiving
    stream and reasonable effort and good faith of the Petitioner.
    The Board will grant the requested variance subject to the
    conditions set forth in the Board’s order.
    This opinion constitutes the Board’s findings of fact and
    conclusions of law in this matter.
    ORDER
    It is the Order of the Pollution Control Board that Peti-
    tioner, Revere Copper and Brass, Inc., be granted variance
    from Rule 203(f) of Chapter 3: Water Pollution as it pertains
    to copper in the effluents from their works located near the
    city of Clinton, DeWitt County, Illinois for the period of
    five (5) years subject to the following conditions:
    1. Petitioner will construct its wastewater treatment
    system as set forth in its Petition for Variance with
    modifications listed below. Petitioner will construct
    said system pursuant to the schedule as set forth in
    its Petition for Variance, Part V.
    26
    30

    —7—
    2. Petitioner shall tie in the discharge from the
    Tube
    Mill plant’s billet piercing and quenching operation
    to the proposed acid neutralization and metal hydrate
    system; the tie-in of the discharge for the Ajax Fur-
    nace is unnecessary as it is used only on a stand-by
    or emergency basis and the tie—in would have a minimal
    effect on the ultimate effluent quality.
    3. Petitioner shall add the necessary equipment to its
    proposed treatment system to enable the addition of
    a polyelectrolyte to the waste water for copper
    removal, conduct tests regarding the results of such
    addition and report the findings to Respondent.
    4. Petitioner shall continue to investigate means of
    controlling its effluent discharge of copper; Peti-
    tioner’s investigation shall consist of monitoring
    the state of the art of copper removal from industrial
    waste—waters as disclosed in literature which is gen-
    erally available and other information which may be
    available to Petitioner by reason of its copper
    fabricating activities, and evaluating the technical
    and economic feasibility of the application of any
    developments which may occur to Petitioner’s facility.
    5. Petitioner shall submit quarterly progress reports
    regarding its investigation to the Manager of Respon-
    dent’s Variance Section
    Division of Water Pollution
    Control. Such progress reports shall describe any
    developments which have occurred during the reporting
    period and the results of Petitioner’s evaluation thereof.
    6. Within ninety (90) days after starch xanthate becomes
    commercially available, Petitioner shall report in
    writing to the Board and Respondent on the technical
    and economic feasibility of using starch xanthate at
    its facility.
    7. In the event of the discovery of a technically and
    economically feasible method of treatment to reduce
    the copper content of Petitioner’s discharges to the
    limit of .02 mg/i, Respondent shall determine whether,
    under all of the
    facts and circumstances in effect and
    the law and regulations existing at the time of such
    discovery, Petitioner shall be required to initiate
    and complete a program to implement such discovery.
    If Respondent determines that the implementation of
    such discovery is required, it shall so notify Petitioner
    and Petitioner shall immediately initiate and promptly
    26
    —31

    —8—
    complete a program to upgrade effluent quality in
    accordance with such discovery, provided, however,
    that Respondent’s determination may be contested
    in good faith by Petitioner on such grounds and by
    such judicial or administrative proceedings, legal
    or equitable, as may exist at the time of such
    determination.
    8. Within twenty-eight days after the date of the Board’s
    order granting said variance, Petitioner shall execute
    and forward to Respondent a Certificate of Acceptance
    and Agreement in the following form:
    CERTIFICATE
    I (We), _________________________________ having
    read and fully understanding the Order of the Illinois
    Pollution Control Board in PCB 76-246, hereby accept
    said Order and agree to be bound by all of the terms
    and conditions thereof.
    Signed ___________________________
    Title __________________________
    Date ____________________________
    9. Petitioner’s request for reclassification pursuant to
    Rule 302(k) of Chapter 3 is dismissed.
    I, Christan L. Moffett, Clerk of the Illinois Pollution
    Control Board hereby certify the above Opinion and Order
    were adoptec~on the
    ~QY~
    day of
    ~lj1,~7~ ,
    1977 by a
    vote of
    q_~’) .
    Christan L. Moffe?t~Clerk
    Illinois Pollution Control Board
    26
    32

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