ILLINOIS POLLUTION CONTROL BOARD

June 7, 1973

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OLIN CORPORATION

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v.

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PUB 73-82

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ENVIRONMENTAL PROTECTION AGENCY

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SUPPLEMENTAL STATEMENT (by Mr.

Dumelle)

While I

concurred in the 4-0 grant of this variance I wish to

point out two points of consideration in future proceedings at this

same plant.

First, it is my opinion that Olin did not carry its burden in

proving

it needed a variance for lead. The record shows that Olin’s

“analytical technique is such that we cannot reach down below three-

tenths of a part per million” referring to heavy metals including

lead (R.81). Yet the sensitivity for lead analyses is not 0.3 ppm

but 0.05 ppm. Thus it is not clear why an industry in the chemical

business could not measure its lead discharges to a finer degree.

If interferences exist because of other heavy metals, then Olin

should have gone to the exact procedure of neutron activation.

Also the lead data are as of January 1, 1972 or 16 months

before the hearing was held. O1in should have made an up-to-date

(and accurate) analysis for the instant proceeding.

Second, the “uncertain market” argument is one that any other

industry can bring. A steel mill can talk of Japanese imports of

steel and an automobile plant can point to the foreign car imports.

So long as we have a competitive economy so the market uncertainty

will exist. If we accept a market argument for Olin how do we not

accept it for any other industry which is in competition? I would

rather base the grant of this variance on the points that (1) the

fluoride discharge presents no water quality problem after mixing

and (2) progress toward abatement to State effluent standards is

being made.

/

_____________________

,/

Jacob D. ~umel1e, Board Member

I, Christan L. Moffett, Cl~zkof the Illinois Pollution Control

Board, hereby certify the above Supplemental Statement was submitted

on the /c.~”of June, 1973.

~

Illinois Pollution Control Board

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