ILLINOIS POLLUTION CONTROL BOARD
    November 1,
    1973
    )
    MONSANTO COMPANY
    )
    )
    )
    v.
    )
    PCB 73-320
    )
    )
    ENVIRONMENTAL PROTECTION AGENCY
    )
    )
    OPINION AND ORDER OF THE BOARD
    (by Mr. Dumelle):
    Petition for variance from the mercury effluent limits
    (Rule
    408(a))
    was
    filed on August
    6,
    1973.
    No public hearing was held.
    On August 23,
    1973 the Board issued an order requiring additional
    information.
    An amended petition was filed October
    9,
    1973.
    No
    recommendation has been received to
    date from the Environmental Protec-
    tion Agency.
    In previous proceedings
    (PCB 71-110, November
    8,
    1971,
    3PCB9
    and PCB 73-336, October 31,
    1972,
    6PCB117)
    this Board granted variances
    to Monsanto’s Krummrich Plant
    at Sauget to discharge mercury above
    the limit of 0,0005 mg/l.
    The initial variance permitted 0.5
    lbs.
    per day discharge;
    the succeeding one cut this amount to 0.33 lbs.
    per day.
    A materials balance for mercury was also required under
    PCB 72-336 and this was submitted on April
    12,
    1973.
    The data submitted in the amended petition supplemented by the
    report for September 1973 shows
    a six month average
    of 0.256 lbs.
    of mercury discharged
    (April through September,
    1973 inclusive).
    The
    previous six month figure
    (October
    1972 through March
    1973)
    is
    0.315
    lbs.
    of mercury discharged daily.
    Since the most recent data
    (June
    through September,
    1973)
    gave the lowest values recorded in
    the past
    13 months
    (0.21
    lbs. per day)
    we
    think that
    the new variance
    can be both granted and tightened in its allowance.
    We grant the variance for an additional year
    at 0.25
    lbs. per
    day based upon
    a six month moving average not
    to exceed 0.4 lbs.
    in
    any 24-hour period.
    In January 1971 the plant was discharging 7.7
    lbs.
    per day of mercury.
    The reduction from 7.7 to 0.25
    lbs.
    per day is
    96.7
    which
    is an impressive
    and commendable reduction in just
    32
    months
    of effort.
    9
    —
    715
    The effluent standard is 0.5 ppb and Monsanto’s discharge in
    September 1973 averaged 2.0 ppb or 150
    above the standard.
    We
    do not accept
    the petitioner’s statements
    on the effects
    of its
    discharge on the Mississippi River because
    a mixing zone of 25
    is
    assumed.
    The petitioner incorrectly quotes Rule 201(b)
    as permitting
    this computation but the Rule has not yet been changed.
    Furthermore
    Rule 201(a)
    limits mixing zones
    to not exceed in area the size
    of
    a
    circle of 600 ft. radius
    (1,130,000
    sq.
    ft.).
    We also call attention to Monsanto’s unexplained and possibly
    significant mercury losses
    at
    this plant.
    Their materials balance
    estimates daily mercury losses at from 38. 395
    lbs. per day to
    63.455 ibs. per day or 23,100
    lbs. per year
    at the highest
    daily
    figure.
    Monsanto only states “Our measured (mercury)
    losses
    do not
    balance with mercury purchases.,.
    We believe the unaccounted
    for losses are either in the landfill or are lost by theft,”
    But
    we are not given the purchased quantity of mercury and do not know
    in
    this record the “unaccounted for losses.”
    Monsanto should plan to be
    in compliance with the mercury
    standard
    a year from now,
    The Board will want to fully explore
    any reasons
    as
    to why compliance after three
    full years
    cannot
    be
    achieved.
    This
    opinion constitutes the Board’s findings of fact and
    conclusions
    of
    law.
    ORDER
    1,
    Variance is granted from Rule 408(a)
    to discharge mercury
    in
    excess of 0.0005 mg/i until November
    6,
    1974.
    The mercury
    discharged may not exceed 0.25
    lbs. per day based upon
    a six
    month moving average and 0.40 lbs.
    in any 24-hour period.
    2,
    Monsanto shall submit to the Environmental Protection Agency
    monthly reports on the progress
    of
    its mercury abatement
    program.
    3.
    Monsanto shall submit to the Board and Agency within four
    (4)
    months from the date of this opinion an update materials balance
    for mercury for the chior-alkali plant giving the losses and the
    purchases and the unaccounted for amounts.
    IT
    IS SO
    ORDERED.
    1, Christan L. Moffett,
    Clerk of
    the Illinois Pollution Control
    Board, hereby certify the above Opinion and O~derwere adopted on the
    ~+
    day of November, 1973 by
    a vote of _______________________

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