ILLINOIS POLLUTION CONTROL BOARD

June 26, 1975

THE FLINTKOTE COMPANY,

Petitioner,

v.

)

PCB 74—89

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

Mr. Edward Benecki, Gosnell, Benecki and Borden Ltd., appeared

on behalf of Petitioner.

Mr. Henry J. Handzel, Jr.,

appeared on behalf of the Respondent.

OPINION AND ORDER OF THE BOARD

(by Mr.

Goodman):

This matter comes before the Pollution Control Board

(Board)

upon the March

8,

1974 petition of the Flintkote

Company

(Flintkote) for a variance from section 12(a)

of the

Environmental Protection Act

(Act)

and Rules 203(a),

402,

403,

404(a) (ii)

and 404 (b) (ii), and certain portions of

408(a) of the Water Regulations for its felt mill.

On April

8,

1974, Flintkote filed a motion to amend its

variance petition which was granted.

On May 15,

1974,

Flintkote filed

a “petition for exception to variance period,”

and requested a formal hearing and granted a waiver of the

90-day decision rule on May 28,

1974.

Finally, Petitioner

filed its final amended petition for variance on September

5,

1974.

On April

9 and June 17,

1974,

the Environmental Protection

Agency

(Agency)

respectively filed its recommendation and

amended recommendation.

Each recommendation was replied to

by Flintkote.

A pre-hearing conference was held in Mt. Carmel,

Illinois,

on August 13,

1974,

at which time Flintkote proposed to

amend its petition.

On March

31,

1975,

a hearing was held at which time a

Stipulation and Agreement was submitted to the Board as

a

joint exhibit.

In the case of E.P.A.

v. the Flintkote Company, PCB 72-

152, Flintkote

was

granted a similar variance from corres-

ponding provisions of SWB—9 of the Sanitary Water Board

Regulations and the Water Regulations of the Board until

17 —377

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May 10,

1974.

At that time it was anticipated that Flintkote’s

compliance plan would extend beyond May 10,

1974, and that

Flintkote would have to apply for another variance.

The two

stage compliance plan would eventually result in a zero—

discharge to the Wabash River and two unnamed

ditches tributary

to the Wabash River by Petitioner’s Mount Carmel,

Illinois,

felt plant.

In 1973, Flintkote was discharging between 500,000 and

700,000 gpd containing an

average of 3,600 pounds

of BOD5

effluent at between 500 and 1,000

ppm

and 4,000

pounds of

suspended

solids ranging between 200 and 1,800 ppm in various

grab samples.

In PCB 72-152, Flintkote was assessed a

penalty

of

$8,000 for

its violations which was duly paid by

the Petitioner.

Additionally, Flintkote posted a $150,000

corporate bond

to guarantee performance of its compliance

plan.

Phase

I of the compliance plan was completed and became

operational on or about June

10,

1974.

Pursuant to Phase

I,

a

partial loop was constructed to achieve a 75

reduction in

the daily flow to the Wabash River,

There has been

a signif-

icant reduction in Flintkot&s waste water discharge.

Flintkote now discharges 125,000 gallons per day with up to

500 pounds suspended solids and 3,000 pounds per day BOD5,

Phase II of the plan will be completed by October

5,

1975, and result in a completely closed system.

See “Submission

of

Phase II Engineering Program” PCB 74-89 which is hereby

incorporated by reference as though fully set forth herein.

“The program contemplates the installation of new side

hill screens, white water storage tank,

filter,

shower water

tank,

centrifugal separators,

seal tank and four pumps.

The

purpose of the new equipment is to collect the white water

now being discharged into the river,

to screen and filter

it, and then return it to the process for reuse.

Existing

sunip pumps will pump the white water effluent to the new

side hill screens which will flow by gravity to the existing

shower water chest, which will be converted to a surge

chest.

A new pump will be installed on the existing shower

water chest which will be converted to a surge chest.

Clarified white water will be returned to the process

and)

excess white water from the cylinder vat will be pumped ?d

the stock preparation white water chest by an existing pump.

The demand for white water at the hydrapulper will be met

from the screened white water tank by a new pump

(P—3)

as

determined by the level in the stock preparation white water

chest.

Existing wash-down pumps will be repiped to use

white water from new pump P-3 for wash-down.

“The existing No.

4 shower water pump will be relocated

to supply clarified white water

from the North filter to the

machine

showers,

The new North filter will remove suspended

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378

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solids that might adversely affect the operation of the

machine showers.

These showers will be replacedwith white

water type showers to assure minimum disruption of machine

operation.

“Centrifugal

separators

will

be installed on the suction

sides

of

three

vacuum

pumps

to

remove

the

water

pulled

from

the

sheet

and

felt

in

the

machine

press

section.

This

water

will be collected in a new seal tank and be pumped to the

effluent ditch,

Since this water has been screened by the

felts,

the suspeided solids content should meet the initial

requirements of the State.

“A Parshall flume will be installed in the existing

effluent ditch to measure the effluent flowing to the river.

“Under Phase

I, all cooling water will be picked up in

the white water system,

in the future, with a completely

closed system,

the cooling waters would be collected and

discharged directly to the river.

“The Phase II operation is described in the report as

fallows, reference being made to flow sheets PSI,

FS2 and

r a

“The

mill

presently

discharges

from

500,000

to

700,000

gallons

per

day

to

an

effluent

ditch

that

eventually

flows

to me

sanash Paver

Praor to Thscharge

the mall effluent

is collected and pumped to

a flat screen.

This screen

removes large solids and some fiber prior to discharging to

the effluent ditch,

This ditch has an effluent weir to

furnish manual flow measurements.

“The intent of the proposed system as shown on FS2 and

FS3 is to reduce the mill effluent by screening and settling

waste white water and reusing this water in the process of

producing roofing felt,

“The system recommended for Phase

i is shown on Flow~

sheets 22—l059A~FS2and FS3•~’RecommendedWater Refuse

Flowsheet.’

The system includes the following equipment to

reduce the effluent to the river to 125,000 gallons per day

and to reduce suspended solids

to 1,000 pounds per day.

“The mill effluent will be pumped by the existing sump

pumps to two s~de~hillgravity screens sized to handle 500

gpm each.

These screens will be located in the beater room.

They will discharge through the floor into the existing

shower water chest located in the basement below.

“Screened white water from the side hill screens will

be pumped to a

30

ft. diameter by 14

ft. high straight side,

clarifier tank.

The clarifier rake

mechanism

and

mixing

zone

are

not

included but can be installed at

a

later

date

if required.

17—379

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“The screened white water storage tank will be used to

store the screened white water, thus providing surge capacity

for the high water demand for the hydrapulper operation.

It

will also provide sufficient retention time for gravity

separation of much of the suspended solids in the white

water.

Flocculating aids may be added to improve the settle-

ability of the suspended solids,

“The tank bottom will

be conical in shape to receive

the possible future rake mechanism.

The suction piping of

the new

white~water transfer pump

(P-3)

will be connected to

the center of the conical

bottom,

thus providing a means for

removing settled solids,

The settled solids will be returned

to the process

with white water,

It is an?icipated that

pumping the white water containing

the solids

from the cone

will prevent excessive build-up

of solids in

the storage

tank.

“Since the white water from the press section of the

paper machine will be collected and discharged to the effluent

ditch,

it

is anticipated that there will be no overflow from

“The table below shows the design conditions and process

DESIGN CRITERIA

Average

Flow

(gpm)

465

1000

(lb/l000 gal)

6 lb

126 lb

Percent removal for screens

0—10

90

Suspended solids to screened water storage

tank

(lb/l000 gal)

6

lb

13 lb

Predicted suspended solids in press water to

effluent ditch

(lb/l000 gal)

.5

lb

3 lb

“New pump

(P-2) will supply white water from

the screened

white water storage tank

to

a new North-type gravity filter

that will be installed to

remove suspended solids

from the

paper machine shower water,

The rotating drum of the North

filter will be equipped with

a fine mesh stainless steel

filter screen to filter out

the

suspended

solids contained

in the shower water,

“Three white water type shower pipes will be installed

on the paper machine.

These shower pipes will be equipped

“A chemical feed package as shown on FS3, consisting of

a 300-gallon tank,

a metering pump, and an agitator would be

17

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380

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capable of adding coagulant aids or other clarification aids

if necessary.

It also can add chemical slimicides to control

the growths that will tend to develop in the white water

system.

“A chlorination system as shown on FS3 will be provided.

The effluent during Phase I

(125,000 gpd) will require

chlorination

to insure disinfection

of this discharge.

The

control of microorganisms will depend on the ability of the

chlorination system to feed sufficient quantities

of chlorine

and to maintain a chlorine residual throughout the white

water system.

For design purposes,

a feed rate of

6 parts

per million

(ppm)

is anticipated to maintain a residual of

2

to

3 ppm.

The chlorinator

is sized to be capable of pro-

viding shock doses of chlorine

(10 to

20 ppm)

to each chlor-

ination point.

This shock dosing would last for 10

to 15

minutes, probably not more frequently than once

a shift.

“Four chlorine meters have been provided.

Three of

these are proposed to eject chlorine into the new supply

pumps, P-i and P-3 as well as new effluent pump P-4.

One

additional chlorine meter has been included for ejection at

a slime problem location after start—up.

If extremely

tenacious slimes develop, slimicides would have to be used

to penetrate the slime envelope that protects the organisms.

However,

if chlorine is used properly and dosed frequently

enough, slimicides will not be required.”

(Environmental

Protection Agency v.

Flintkote Company, PCB 72-152, May 10,

l973).h1

The May 10, 1973 Order stated:

IT IS THE ORDER of the Pollution Control Board:

1.

Stipulation entered into between The Flintkote

Company and the Environmental Protection Agency, incor—

porating therein document captioned “Pollution

Abatement Study for The Flintkote Company” by

Rust Engineering Company

is approved and

incorporated therein.

2.

Variance is granted to the Flintkote Company until

May 10,

1974 from the provisions of SWB-9 and the

Water Regulations of the Illinois Pollution Control

Board,

as applicable,

to enable implementation of

Phase I and Phase II of the compliance program

herein provided.

Permits for construction

of the

abatement system shall be applied for within ten

days from the date of this order.

Phase

I shall

be completed within

13 months and 10 days from the

date of this Order and Phase II shall be completed

within 27 months from the date the permits are

issued for construction

of Phase

I.

Variance

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—6—

herein granted may be extended upon application

submitted to the Board no less than 90 days before

the expiration of any variance herein allowed,

which shall be extended only upon a demonstration

that Flintkote is making satisfactory

progress

toward the completion of its

abatement program as

defined herein, requiring substantial compliance

with all time tables for completion of Phase I and

the submission of

a sound engineering program for

implementation of Phase II.

3.

Corporate bond in the amount of $150,000 in form

satisfactory to the Agency shall be posted within

35 days of the date of this Ordbr,

to guarantee

compliance

with

all

of

the

provisions

of

this

Order

and

the

Stipulation

entered

into

between

the

parties.

Upon

completion

of

all

conditions

of

the

bond,

the Agency will execute and deliver

a bond

release to Flintkote,

4,

Flintkote,

during construction

of Phase

I,

shall

submit to the Agency and the Board, periodic

progress reports at 30-day intervals which shall

indicate the status of all design and construction

progress with respect to Phases

I and II.

5,

Penalty in the amount of $8,000 is assesed against

the Flintkote Company for violation of Section

12(a)

of the Environmental Protection Act and SWB-

9,

as alleged in the complaint.

Penalty payment,

by certified check or money order payable to the

State of illinois,

shall be made within

35 days

and sent to:

Fiscal Services Divsion,

illinois

Environmental Protection Agency,

2200 Churchill

Drive, Springfield,

Illinois

62706,

The Board finds that Flintkote has made satisfactory

progress toward completion

of its compliance plan and has

substantially complied with the Board~sOrder of May 10,

1973,

in PCB 72~l52. The assessed penalty was paid,

the

bond posted, permit applications for Phase

I were submitted

on

ti.me, and the required progress reports were timely

submitted.

Phase

I

was

completed

on

schedule

and

Phase

II

commenced

immediately

thereafter

and

has

continued

to

date.

The

expected

reduction

of

suspended

solids

did

not

occur

at

the end of Phase

I and Petitioner admits that on occassion

the 2800 pound per day limitation on the discharge of POD5 has

been exceeded.

The nature of Flintkot&s discharge varies

from day to day,

as indicated by the chart on page

6 of the

Stipulation, due to Petitioners~ raw material feed stock of

wood pulp and paper.

Flintkote has expended considerable sums of money on a

program which is acceptable to both the Agency and the

17

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382

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Board.

To deny this program, when it is so near to completion,

would work a severe hardship on Petitioner.

Completion of the compliance plan

will

result in total

recycle which is to be encouraged as the ultimate treatment.

There having been no showing in the record of adverse citizen

reaction,

together with the continuing reduction in discharges,

the Board finds that Petitioner has

met its burden in proving

lack of environmental harm.

This opinion constitutes the findings of

fact and law

ORDER

1.

Flintkote is hereby granted a variance, until

October

5,

1975,

for

its

discharge of process

waters from Section 12(a)

of the Act, and Rules

203(a),

402,

403, and 404(a)

(ii) and 404(b) (ii)

of

the Water Regulations as they relate to the discharge

of BOD5

and

suspended solids;

and

2.

Flintkote is hereby granted a variance from Rule

408(a)

of the Water Regulations until October

5,

1975,

limited to allowing Flintkote to continue

the discharge of its present quality effluent.

Said variance is granted upon the following conditions:

(a)

Flintkote

shall

not substantially change the

character

and

nature of its raw material

feedstock without giving the Agency and the

Board prior 30-day written notice; and

(b)

Flintkote~seffluent, with the exception of

cyanide and mercury, shall not,

at any time,

exceed

5 times,

on either a grab or composite

sample basis, the numerical standard provided

in Rule 408(a); and

(c)

Flintkote’s discharge of cyanide shall not

exceed 1.0 mg/l at any time;

and

(d)

Flintkot&s discharge of 408(a)

contaminants

shall not cause

a violation of Rules 203(f)

and 402 of the Water Regulations in the

Wabash River; and

(e)

This variance shall not extend to the 1imita~

tions set forth in Rule 408(a)

regarding pH

and mercury, which shall remain in full force

and effect;

and

17 —383

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3.

Flintkote’s waste water discharge during this

variance shall be limited to:

(a)

125,000 gallons per day;

(b)

250 pounds per day of suspended solids as a

monthly average, not to exceed 500 pounds on

any day; and

(c)

2,800 pounds per day of BOD5 and

4.

Flintkote shall take grab samples every six hours

for 24 hour periods each week and mathematically

compute 24 hour composites from same for suspended

solids,

BOD5 and free chlorine.

The results of

said samples shall be included in monthly progress

reports which Flintkote shall continue to submit

to the Agency and the Board, detailing progress on

Phase

II; and

5.

The bond posted

in

PCB 72-152 shall remain in full

force and effect until completion of conditions

of

the bond at which time the Agency shall execute

and deliver

a bond release to Flintkote;

and

6.

Flintkote, during the term of this variance, shall

not use in its compliance plan or in its manu-

facturing processes any of the contaminants listed

in Rule 408 of the Water Regulations except as may

be found to occur in Flintkote’s normal raw material

feed stock of wood pulp and paper as reported in

PCB 71-68 and PCB 72-152;

and

7.

Flintkote shall complete Phase II and cease all

on or before October

5,

IT

IS SO ORDERED.

I, Christan L. Moffett,

Clerk of the Illinois Pollution

Control Board, hereby ce,~tifythe above Opinion and Order

were

~1opted

on the

“day of~,

1975 by a vote

Christan L. Moffett,

~J4rk

Illinois Pollution C&~ol Board

17

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