ILLINOIS POLLUTION CONTROL BOARD

December 19,

1974

OLIN CORPORATION

Petitioner,

v.

)

PCB 73-484

ENVIRONMENTAL PROTECTION AGENCY

Respondent,

MR. RANDALL ROBERTSON, ESQ.,

LUEDERS, ROBERTSON,

AND

KONZEN

appeared on behalf of the Petitioner;

MR. HENRY

J. HANDZEL, JR., ESQ.,

and MR.

RICHARD BARDELAN, ESQ.,

appeared on behalf of the Environmental Protection Agency;

OPINION

AND

ORDER OF THE BOARD (by Mr. Dumelie):

This petition was filed with the Pollution Control Board on

November 14,

1973 and requests variance from provisions of

Section 12(a)

of the Environmental Protection Act

(Act),

that

portion of Section 203(f), Part II, Chapter

3 of the Illinois

Pollution Control Board’s Rules

and Regulations Governing Water

Pollution Control which establish a maximum water quality

concentration level of 0.02 mg/l for copper and from Section

404(f)

of the Rules and Regulations,

also in Chapter

3.

Amendment to Petition was filed on April

30,

1974, striking

request from variance from Section 12(a) of the Act.

Olin Corporation,

a Virginia corporation authorized

to

do business

in the State of Illinois, operates a plant consisting

of an area of approximately 1732 acres at East Alton,

Illinois.

In its Zone

17 it conducts

a brass casting operation and manufactures

copper, copper base alloy slabs

and copper alloy tubing;

in its

Zones

1 and

7,

it manufactures brass strip and fabricated products,

metallic and shot shell ammunition,

and operates

a steam generating

plant and potable water treatment plant; and in Zone

4,

it

manufactures shot shell ammunition and primer explosives. Approxi-

mately 5700 workers are employed at Petitioner’s East Alton

location.

Testimony was presented stating that the annual

payroll was $60,000,000, property taxes were $1,000,000 per year,

and the

local purchases

(Madison Co.) for supplies and services

were $2,000,000 annually

(R.

24).

14— 689

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-2-

The federal government has designated

the area from which

Petitioner hires

as

a labor

surplus area,

and Petitioner has an

approved plan to employ disadvantaged individuals

from this

area

(Pet.

5).

Petitioner’s wastewater effluent enters the Wood River

through two separate outfalls.

These are located

at

6000 feet

and 1200 feet from the confluence of the Wood River and

Mississippi

River, (Olin Ex. V).

The Wood River

is

a low flow,

non-navigable stream and has

a seven-day ten-year low flow of

zero at the Zone

6 WWTF discharge.

Since the dilution ratio

is

less than 1:1, Petitioner must meet the water quality standards

of 4 mg/i BOD,

5 mg/i S.S. and 0.02 mg/i for copper

(Rule 404(f)

Part IV-Effluent Standards).

Petitioner has

two wastewater treatment facilities

(WWTF)

designated as Zone

6 WWTF,

and Zone

17

WWTF.

The raw materials

processed in the area discharging to Zone

17 plant

consist of

1,401,000 lbs/day of virgin and scrap brass, copper, nickel,

zinc, lead and tin.

The raw materials processed in the area

discharging to the Zone

6 plant consist of 1,349,000 lbs/day

of brass, aluminum, lead and plastics

(Pet.

Ex.

F).

Petitioner engaged the consulting firm of Ryckman, Edgerley,

Tomlinson and Associates

(RETA)

in 1966 to study volume and

characterization of the wastewater from the plant.

As

a result

of extensive study, RETA recommended, and Olin accepted,

a Lime

Precipitation and Polymer Coagulation and Flocculation Process.

Engineering was started in 1970 and was completed in 1971.

Con-

struction started in November 1971 and was completed in December,

1973, when the plant

(Zone

6) was placed in service.

The design criteria were as follows:

Flow

-

6.25 mgd

Effluent BOD

-

10 mg/l

Suspended Solids

-

12 mg/i

Copper Concentration

-

1 mg/i

In March of 1972,

the Board adopted Rules 203 and 404.

This had the effect of requiring an effluent having

a BOD

of

4 mg/l,

S.S.

of

5 mg/I and copper concentration of 0.02 mg/i,

since

there would be

a dilution ratio of less than 1:1 when

discharged to the Wood River.

Zone

17 plant, with a process similar to Zone

6 plant

but with

a design flow of .86 MGD, was started up

in February,

1974.

The design criteria were the same as for Zone

6 plant.

14—690

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-3-

Both plants have improved on the design criteria as to BOB,

S.S. and copper.

However,

the Water Pollution Regulations have not

been met.

The copper concentrations have gone below 0.5 mg/l

and the BODs and suspended solids have been held well below

the design of

10 and

12 mg/i but have frequently exceeded the

4 and

5.

Petitioner requests

a variance for copper concentrations

to be allowed not to exceed 0.5 mg/i for both Zone

6 and Zone 17

plants,

and for BOD and S.S.

for Zone

6 plant from the

4 and 5

mg/l.

Petitioner has engaged RETA to study the possibility of reducing

the copper concentration to water quality standards.

The recommen-

dation was made to recirculate the effluent through the treatment

process.

This was carefully studied and the conclusion is

that

no improvement could be effected by this method.

Four other systems were also studied.

These are 1) Sulphide

precipitation, and multi-media filters,

2) Recarbonation, multi-

media filters and carbon absorption,

3) Recarbonation, multi-

media filters and ion exchange, and

4) Recarbonation, multi-media

filters and reverse osmosis.

The technical

feasibility of all of

these

is doubtful since

they have never been tried on Olin’s type of wastewater, or on

so

large

a scale.

The costs would also be inordinately high

(Olin Exhibit 1-1,

J,

K); about $500,000

to $2,760,000 per annum.

Petitioner alleges, and the EPA concurs, that the Wood

River, from the Zone

6 discharge to its confluence with the

Mississippi River

is not used by the public for any beneficial

purpose and further,.since it

is bordered exclusively by industry,

its public accessibility is minimal

(Pet.

6)(R.

13,

14).

Sampling by both the Agency and Olin indicate that no physical

degradation of the Wood River has taken place as

a result of

Olin’s discharge,

(Olin Ex. H-i, and EPA Ex.

1).

We conclude that Olin should be granted a variance from

the copper standard of 0.02

nig/l to be allowed

a discharge of

0.5 mg/l,

on the basis that they have diligently pursued several

avenues

of possible compliance and that there will be minimal

public harm.

Because we are granting a variance from Rule 203(f)

as

to copper,

a variance from Rule 404(f)(ii)(A)

is not necessary.

We

are not granting variance for BOD and suspended solids

because the Agency has indicated Petitioner should qualify for

a

“Pfeffer” exemption under Rule 404(f) (ii) with the granting of

the variance for copper from Rule 203(f).

This Opinion constitutes

the Board’s findings of fact and

conclusions of law.

14—691

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-4-

ORDER

It

is the Order of the Illinois Pollution Control Board that;

1.

Petitioner be granted a variance from Rule 203(f)

of Chapter

3

solely for the discharge of copper,

for a period of one year from

the date of this Order upon the following conditions:

(a)

That Petitioner’s discharges from Zones

6 and 17 wastewater

treatment facilities not exceed 0.5 mg/i of copper.

(b)

That Petitioner continue

to investigate additional

means of controlling its effluent discharges

of copper.

(c)

That Petitioner submit quarterly progress reports

to

the Agency on its investigations.

2.

All requests for variances from other provisions

of Chapter

3

of the rules are denied.

I, Christan L. Moffett, Clerk of the Illinois Pollution

Control Board, hereby~certify the above Opinion and Order were

adopted on the

j~7M

day of December,

1974 by a vote of

U—

0

I

j

~

7

1

~

Christan

L. Moffett, Cii~rk

Illinois Pollution Control Board