IN THE MATTER OF
:
)
SITE SPECIFIC PETITION OF
)
)
MOBIL OIL CORPORATION FOR
)
RELIEF FROM 35 ILL. ADM. CODE
304.122,
)
AMMONIA NITROGEN EFFLUENT STANDARDS
)
DATE: August 25, 1997
Illinois Environmental Protection Agency
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
217/782-5544
THIS FILING IS SUBMITTED ON RECYCLED PAPER
NOTICE
See Attached Service List
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the Pollution
Control Board the ILLINOIS ENVIRONMENTAL PROTECTION AGENCY'S COMMENTS
for the Illinois Environmental Protection Agency, a copy of which is herewith served upon you
.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By :
et P. Howard
Assistant Counsel
Division of Legal Counsel
RECEIVED
CLERK'S OFFICE
AUG 2 9 1997
STATE OF ILLINOIS
POLLUTION CONTROL BOARD
R97-28
(Water - Regulatory)
BEFORE THE ILLINOIS POLLUTION CONTROL BOA
IN THE MATTER OF :
)
SITE SPECIFIC PETITION OF
MOBIL OIL CORPORATION FOR
RELIEF FROM 35 ILL. ADM
. CODE 304 .122,
AMMONIA NITROGEN EFFLUENT STANDARDS
R97-28
(Water - Regulatory)
COMMENTS OF THE
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
NOW COMES the Illinois Environmental Protection Agency ("Illinois EPA") by its attorney,
Margaret P . Howard, and files its Comments in regard to Comments filed by the Office of the Illinois
Attorney General ("IAGO") on August 6, 1997 .
In its comments, the IAGO suggested that Mobil Oil Corporation ("Mobil") design and
implement a breakpoint chlorination and de-chlorination system
. (Comments of the Attorney
General's Office, p .4) The Illinois EPA cannot support this suggestion
. The Illinois EPA has been
concerned about breakpoint chlorination over the past twenty-five years due to the formulation of
trihalomethanes during the process
. Trihalomethanes are toxic and, when found in public water
supplies, are considered to be carcinogenic to humans
. For this reason, the Illinois EPA has, as a
general practice, disallowed the process
. The Illinois EPA has only permitted the process at one or
two facilities in the state
. In addition to this general advisory about the potential formation of
trihalomethanes in the breakpoint chlorination process, the risk of such formation in a refinery
effluent where unknown hydrocarbon materials created by the biological treatment process may
exist, is also a concern that must be considered
. The Metcalf and Eddy reference, included with the
IAGO'S comments as Attachment A, lists the formation of the trihalomethanes as
one of several
disadvantages of breakpoint chlorination
. Other disadvantages include : the potential to produce high
chlorine residuals which are toxic to aquatic organisms, the process' pH sensitivity and the elevation
RECEIVED
CLERK'S OFFICE
AUG 2 9 1997
STATE OF ILLINOIS
POLLUTION CONTROL BOArr.'
of dissolved solids concentrations in effluent . (Comments of the Attorney General's Office,
Attachment A)
WHEREFORE, the Illinois EPA recommends that breakpoint chlorination not be utilized at
the Mobil Oil facility . Mobil detailed its consideration of alternative technologies in its petition for
Site-Specific Relief from 35 I11. Adm. Code 304.122. Ammonia Nitroeen Effluent Standards
("Petition") on pages 13-14 . The Illinois EPA reviewed the Petition, as well as the testimony and
exhibits entered at the hearing held on July 2, 1997
. In addition, the Illinois EPA has been involved
with the issues raised by Mobil, that has led to the filing of the Petition, since the spring of 1996 .
(T. at 12) All of the possible alternatives have been considered and, as stated at the hearing, the
Illinois EPA maintains that the site specific relief requested by Mobil should be granted . (T. at 12)
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By:
arg
/(
et P. Howard~~
Assistant Counsel
Dated
: August 25, 1997
2200 Churchill Rd .
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
THIS FILING SUBMITTED ON RECYCLED PAPER
G :\WP5I\HOWARD\Mobil OiI\COMMENTS
STATE OF ILLINOIS
)
COUNTY OF SANGAMON
)
SUBSCRIBED AND SWORN TO BEFORE ME
this 12th day of August, 1997.
PROOF OF SERVICE,,
I, the undersigned, on oath state that I have served the attached
ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY'S COMMENTS
upon the person to whom they
are directed, by placing a copy of each in an envelope addressed to
:
See Attached Service List
and mailing them from Springfield, Illinois on August 25, 1997 with sufficient postage, as indicated
.
?7t
&J1tGc..
OFFICIAL
SEAL
CYNTHIA L
. WOLFE
L
NOTARY PUBLIC
. STATE OF ILLINOIS
MY COMMISSION EXPIRES 52.99
THIS FILING IS SUBMITTED ON RECYCLED PAPER
Linda Brand
Department of Commerce and
Community Affairs
Small Business Office
620 East Adams
Springfield, Illinois 62701
Matthew J . Dunn
Division Chief
Environmental Enforcement/Asbestos
Litigation Division
Office of the Attorney General
100 West Randolph Street
Chicago, Illinois 60601
Lee Erchull
CITGO Petroleum Corporation
Lemont Refinery
135th Street and New Avenue
Lemont, Illinois 60439
Albert Ettinger
Environmental Law Policy Center
203 North LaSalle #1390
Chicago, Illinois 60601
Dorothy Gunn, Clerk
Pollution Control Board
James R. Thompson Center
100 W
. Randolph, Suite 11-500
Chicago, Illinois 60601
Alyssa Fron, Assistant Attorney General
Office of the Attorney General
100 West Randolph Street, 11th Floor
Chicago, Illinois 60601
97-28
MOBIL SITE SPECIFIC RULEMAKING
SERVICE LIST
Audrey Lozuk-Lawless
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 62706
G. Brent Manning, Director
Department of Natural Resources
524 South Second Street, #400
Springfield, Illinois 62706
Ross & Hardies
David Rieser, Esq.
James Harrington, Esq.
David Piech, Esq .
150 North Michigan Avenue #2500
Chicago, Illinois 60601
