BEFORE THE POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

IN THE MATTER OF:

PROPOSED ADJUSTED STANDARD FOR

AMMONIA NITROGEN DISCHARGE LEVELS

APPLICABLE TO CITGO PETROLEUM

CORPORATION AND PDV MIDWEST

REFINING, L.L.C., PETITIONERS

)

)

)

) AS 08-08

) (Adjusted Standard - Water)

)

)

NOTICE OF FILING

To:

Dorothy Gunn

Clerk

of the Board

Illinois Pollution Control Board

100 West Randolph Street - Suite 11-500

Chicago, IL 60601

Jason

R. Boltz

Illinois EPA

1021 N. Grand Ave. East

Springfield, IL 62794

Bradley Halloran, Hearing Officer

Illinois Pollution Control Board

James

R. Thompson

100

W. Randolph, Suite 11-500

Chicago, IL 60601-3218

Please take notice that on August 1,2008, we filed electronically with the Office

of the

Clerk

of the Illinois Pollution Control Board the attached Pre-filed Testimony of Brigitte Postel,

Jim

Huff and Bob Stein, and accompanying Exhibits, a copy of which is served upon you.

CITGO PETROLEUM CORPORATION, and

PDV MIDWEST, LLC, Petitioners

11

I

~/

By:-Ai1

-~

One of Its Attorneys

Jeffrey

C. Fort

Ariel

J. Tesher

Sonnenschein Nath

&

Rosenthal LLP

7800 Sears Tower

233

S. Wacker Drive

Chicago, IL 60606-6404

Electronic Filing - Received

Clerk's Office

August 1, 2008

---

BEFORE THE POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

IN THE MATTER OF:

PROPOSED ADJUSTED STANDARD FOR

AMMONIA NITROGEN DISCHARGE LEVELS

APPLICABLE TO CITGO PETROLEUM

CORPORATION AND PDV MIDWEST

REFINING, L.L.C., PETITIONERS

)

)

)

) AS 08-08

) (Adjusted Standard - Water)

)

)

I.

BACKGROUND

My name is Brigitte Postel. I have been employed by CITGO Petroleum Corporation

("CITGO") at the Lemont Refinery since October, 2003. At the Lemont Refinery, I have held

the position

of Environmental Engineer, Water Coordinator. I received a Bachelor of Science in

Chemistry from the University

of Illinois, Champaign-Urbana, and a Masters of Science in

Environmental Engineering from Lamar University, Beaumont, Texas. Prior to my time at the

Lemont Refinery, I held various environmental positions in the pharmaceutical, chemical, and

power industries.

,-

II.

TESTIMONY

1.

PDV Midwest Refining, L.L.C. ("The Refinery") owns a petroleum refinery

located on an 860-acre tract in Will County near Lemont, Illinois. The Refinery was formerly

owned and operated by the Union Oil Company

of California ("Union") and then operated by the

UNO-VEN Company. On May

1, 1997, PDV became the owner of the Refinery and CITGO

was contracted to operate the Refinery.

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2.

Despite extensive improvements and other efforts, the Refinery is not able to

consistently meet the ammonia nitrogen effluent limits contained in Section 304. 122(b)

of

Subpart B of Part 304 of Title 35 of the Illinois Administrative Code (ammonia nitrogen rule). I

want to emphasize that "consistently" meeting the rule is the focus

of our Petition. The general

ammonia nitrogen discharge rule would apply to the Refinery, but for site specific rule changes

granted in 1987, 1993 and 1998. Despite steady improvements during the last twenty years,

Petitioner and its predecessors have been unable to consistently achieve the effluent limits

of the

ammonia nitrogen rule. The Refinery has been successful in lowering the ammonia nitrogen

concentration in its effluent and has achieved this success even though the plant throughput has

increased and wastewater usage has decreased. The Refinery

is prepared to continue efforts to

reduce its ammonia nitrogen discharge, but it cannot commit to continuously meet the general

effluent limit in

35 Ill. Admin. Code 304.122(b). Additional information requested by the

Board'shearing officer, Bradley Halloran, may be found in

Exhibit 1

to this testimony.

3.

We have attempted to work with the Agency on this matter and initiated meetings

with the Agency last November. As suggested by the Agency then, we agreed to separate the

Total Dissolved Solids issues from the ammonia nitrogen issues - and further agreed to use the

adjusted standard approach rather than the site-specific rule change - in order to meet the

requirements

ofD.S.EPA in reviewing Illinois'swater quality standards. We are disappointed

that the Agency did not engage in any technical discussions on the content

of our proposal and

filed the Recommendation it has. We disagree with the Agency's statements

in its

Recommendation, which we believe mis-characterize the Petition and are not based on facts.

One thing we could agree with is to continue to improve our existing biological treatment

processes, solids handling processes, and the desalter. Indeed,

as will be shown by other

presented testimony, the Refinery is currently discharging, on an average basis, less ammonia

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nitrogen than is in its raw water supply. Of course, that is because the Refinery is on an "effluent

dominated water," the Chicago Sanitary and Ship Canal, as the Agency has testified to in the

UAA rulemaking proceeding.

4.

The Refinery was constructed during the period 1967 through 1970.

It

became

operational in late fall

of 1969. The Refinery employs approximately 530 people.

5.

Approximately twenty-five different products are produced at the Refinery,

including gasolines, turbine fuels, diesel fuels, furnace oils, petroleum coke and various specialty

naphthas which can be manufactured into many intermediate products, including antifreeze,

dacron, detergent, industrial alcohols, plastics and synthetic rubber. Ninety percent

of the

Refinery's output goes into making gasolines, diesel fuels, home heating oils and turbine fuels

for use in Illinois and throughout the Midwest.

6.

The Refinery currently discharges to the Chicago Sanitary and Ship Canal

("Canal") which is a tributary

of the Illinois River. The discharge is quickly dispersed in the

Canal and assimilated by the receiving stream. The dilution pattern

of the effluent is rapid and

immediate under the criteria

of 35 Ill. Admin. Code Subtitle C, Chapter I, Section 302.1 02.

7.

The primary treatment portion of the current plant consists of four sour water

strippers for ammonia and sulfide removal, oil/water separators for free oil removal, stormwater

impoundment, equalization, and emulsified oil removal using organic polymers.

8.

The effluent from the primary clarifier flows to the Induced Gas Flotation ("IGF")

vessel and then to the secondary treatment portion

of the wastewater plant which consists of a

single stage activated sludge treatment system. The system includes three aeration basins

operated in parallel with a total aeration basin volume

of 1.92 million gallons. Aeration is

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provided by a fine-bubble diffused aeration system. Activated sludge is settled in two 100-ft.

diameter secondary clarifiers. Within the aeration basin, phosphorous is added as a nutrient for

biological organisms. During the winter, steam is injected to the equalization tank to maintain

operating temperatures at a minimum

of 70° F in the aeration basin effluent.

9.

The tertiary system consists of a 16 million gallon polishing lagoon. The purpose

of the lagoon is to remove any carryover solids from the secondary clarifier. The lagoon also

serves as a water supply for fire protection.

10.

The Refinery draws from and discharges to the Canal. The Refinery takes

approximately 5.0 million gallons

of water daily from the Canal, and discharges approximately

4.5 million gallons to the Canal, the difference being cooling tower evaporation and steam

losses. The wastewater effluent contains ammonia as nitrogen derived from compounds present

in crude oil that are removed from the crude by various Refinery operations, as well as the

ammonia already present in the intake water from the Canal.

11.

The Refinery operates under a National Pollutant Discharge Elimination System

("NPDES") permit (No. lL 0001589), issued by the Illinois Environmental Protection Agency

("IEPA," or "the Agency"). The most recent NPDES permit was issued as modified June 22,

2007 and expires July 31, 2011. The NPDES permit includes outfall

001 at the Refinery at river

mile 296.5 on the Canal (Latitude

41 °38'58", Longitude 88°03 '31"). The current NPDES permit

includes ammonia nitrogen limits in the existing

35 lAC 304.213.

12.

The U.S. EPA has established effluent guidelines for wastewater discharges by

industry category. The petroleum refining industry is divided into five subcategories based on

the processes utilized and the products produced. The Refinery is classified as a Subcategory-B

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cracking refinery under the federal regulations. Effluent limits under the federal regulations are

based on production and are computed on a pounds-per-day basis.

13.

U.S. EPA has promulgated categorical limits on various industries, including the

petroleum refining industry. While these regulations, found in 40 CFR 419, do specify limits for

ammonia nitrogen, these are less stringent than the limits in the existing site-specific rule. The

Board has previously found that the wastewater treatment system goes beyond Best Available

Technology ("BAT") requirements.

14.

The Board has adopted Title 35, Section 304.122 to control ammonia discharges

to the Illinois River System, originally Rule 406, adopted Jan

6, 1972. Rule 304.122(b) limits

larger industrial discharges (greater than 100 Ibs/day ammonia) to an effluent discharge

concentration

of 3.0 mg/l NH

3

-N. Historically, the refinery has achieved compliance with the

federal effluent regulations; however, the 3.0 mg/l effluent limit has not been attainable on a

consistent basis.

15.

From 1977 through 1984, Union operated the Refinery under several variances

from the Board for the ammonia nitrogen discharge. In 1982, the Board granted Union a

variance, contingent that by May

of 1984, Union would submit a program to ensure compliance

with Rule 304.122 or prepare a proposal for a site specific rule change. In December

of 1984,

Union petitioned the Board for a site specific rule change. The Board granted Union site specific

effluent limits set at the U.S.

EPA'sbest available technology (BAT) pursuant to 40 CFR 419.23

(1985). This site specific rule change terminated on December 31,1993. In 1993, UNO-VEN

petitioned the Board for a site specific rule change. The Board granted UNO-VEN's request and

set effluent limits for ammonia nitrogen

of9.4 mg/l monthly average and 26.0 mg/l daily

maXImum. By final order dated December

17, 1998, the Board made only two changes to the

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rule as adopted in 1993: a change of the name to reflect the sale to PDV Midwest Refining,

LLC, and an extension of the termination date by 9 years to December 31, 2008.

16.

The Refinery has improved its performance

of ammonia removal despite higher

crude throughput and a decrease in wastewater volume. Wastewater volumes have decreased

since 1984 through the exercise

of sound water management practices. Despite these factors that

would tend to increase ammonia concentration, the Refinery has maintained and improved its

performance in ammonia removal.

17.

The limits for ammonia nitrogen proposed here are based on a statistical analysis

using the 95th percentile of the standard deviation over historical and representative time periods

to calculate the effluent limits. The daily and monthly limit is based on the 95th percentile based

on the last five years

of effluent data. The limits proposed demonstrate the commitment to

improvement in nitrification, a reduction in the daily limit of 59 percent and in the monthly limit

of27 percent. Jim Huff will explain these calculations in his testimony.

18.

Over the last several years, Lemont Refinery has been processing an increased

percentage

of heavy crudes and can expect the trend in feedstocks over the course of this petition

to continue. The uncertainty associated with this issue justifies the Board choosing to set daily

and monthly limits that take into account this uncertainty. Moreover, this analysis indicates that

the proposed limits represent a continued emphasis on improvement in wastewater controls and

achieving nitrification in the wastewater treatment plant even with more difficult wastewater

streams to be treated. Over the last 5 years, on a net basis, the Refinery has exceeded 100

pounds on a monthly daily average for ammonia only 33 percent of the time, and exceeded 200

pounds per day for ammonia only 17 percent of the time.

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19.

At this point, Petitioner and its predecessors have expended significant resources

in improving the wastewater treatment system at the Refinery. Petitioner and its predecessors

have spent nearly $75,000,000 to upgrade and improve the wastewater treatment facilities at the

Refinery; approximately $45,000,000

of that was spent just in the last 10 years. While some of

that was not done for the specific purpose of improving nitrification, approximately one quarter

of that investment had, as a substantial component, improving the ability of the wastewater

treatment process to provide nitrification. Even investments that did not primarily target

nitrification were done to benefit the nitrification process. For example, the Purge Treatment

Unit ("PTU") that was installed as part of the FCC consent decree was required in large part to

ensure consistent ammonia nitrogen removal. The testimony of Bob Stein provides more detail

on this matter.

20.

Under the site specific rule change granted in 1987, the Refinery was required to

continue its efforts to reduce the concentration

of ammonia nitrogen in its wastewaters. The

Refinery met this requirement through continuous upgrades to the wastewater treatment plant.

After petitioning for the 1987 site specific rule change, the Refinery:

•

Added a third aeration basin, increasing the total aeration volume from 1.38

million gallons to 1.92 million gallons;

•

Upgraded the aeration system by replacing the existing mechanical surface

aerators with a fine-bubble diffused aeration system; and

•

Added the second 100-ft. diameter secondary clarifier, doubling the secondary

clarifier capacity.

These improvements were designed to increase ammonia oxidation, increase available

dissolved oxygen and increase hydraulic throughput.

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21.

While the site specific rule change was granted in 1993, the Refinery continued its

efforts to reduce the concentration

of ammonia nitrogen in its wastewaters. From 1992 until

1998, the Refinery:

•

Installed a new chemical feed facility at the WWTP;

•

Eliminated discharge

of process wastewater to the stormwater basin and provided

tankage for equalization/oil separation

of process wastewater;

•

Converted the WWTP control system to new DCS control

•

Modified the sour water stripper charge tanks inlet line for better oil/water

separation;

•

Performed a clean closure

of the stormwater basin; and

•

Utilized

Na1co dried bacteria and conducted nitrifier inhibition testing.

22.

Since 1998, the Refinery has continued to make improvements to its wastewater

treatment system. Those measures have included:

•

In 2000 installed induced gas flotation system with polymer addition;

•

In 2003, added additional strippers in the sour water system for ammonia

removal;

•

Also in 2003, upgraded diffused aerators to improve oxygen transfer;

•

In 2006, upgraded phosphoric acid feed system and the aerators to improve

oxygen transfer;

•

In 2007, installed purge treatment unit to treat the discharge from the FCC

scrubber; and

•

Also in 2007, upgraded diffused aerators to improve oxygen transfer.

The total cost

of these improvements was approximately $45,000,000.

23.

While there has been success in reducing the effluent ammonia nitrogen

concentration, the Refinery is unaware

of proven means to comply with the ammonia nitrogen

rule on a continuous basis. The options available to Lemont are 20-68 times more expensive, on

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a unit cost basis, than other available alternatives for ammonia removal. Therefore, it is possible

to spend millions

of dollars in an attempt to implement unproven strategies for potential

ammonia nitrogen reduction even though: (a) the present level

of wastewater treatment at the

Refinery is better than the United States Environmental Protection Agency's ("U.S. EPA")

effluent guideline

of best available technology ("BAT") economically achievable; and (b) the

ammonia nitrogen discharge for the Refinery has no discernable water quality impact on the

receiving stream.

24.

The requested amendment will allow Lemont Refinery to continue to operate

without spending millions

of dollars on unproven technology in an attempt to accomplish further

ammonia nitrogen reductions with little or no environmental benefit. The Refinery will continue

to optimize its treatment facilities, regardless

of the outcome of this Petition. Indeed, the daily

limit requested here represents a 59 percent reduction, substantially below the level authorized

in

1998.

25.

The Lemont Refinery has investigated the available information on the

performance

of other refineries in Illinois to provide nitrification. The conclusions of that

in,restigation are in the 2007

l~~vlare

report, but can be SUll1.l'11arized as follov/s: (a) the other

refineries were using similar technological approaches as used by the Lemont refinery design,

and none

of them were using the technologies investigated by Aware as possible additions to the

Lemont Refinery; (b) there are site specific variations in how the wastewater treatment systems

are designed and operated, as well as some differences in the crude supply; and (c) there are

some differences in these design specifics which may be worth exploring for potential use and

modifications at the Lemont Refinery to further enhance its nitrification capabilities.

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26.

Based on evaluations and reports that accompany this Petition, the Refinery will

continue to investigate improvements to its existing wastewater treatment system.

It

is believed

that focusing on better solids handling from the desalter holds the greatest promise for achieving

improved wastewater treatment performance on a consistent basis. The options that will be

investigated include: an in situ solid removal system, increased tankage to allow brine

segregation; amine management; and adjusting chemical usage to reduce emulsification in the

primary treatment units.

27.

At this point in time, the total ammonia discharge from the Refinery, on an

average basis over the last 5 years, is less than the allowable discharge

of 3

mgll,

even when

about 25 percent

of that discharge is due to the ammonia nitrogen levels already in the Canal.

Nevertheless, the Refinery will continue to look to improve its treatment for ammonia nitrogen.

28.

Through the first six months

of 2008, the refinery has removed 29 pounds per day

from the Ship Canal, while adding only

17 pounds per day. To date, the 2008 annual average

ammonia concentration is 0.39 mg/L.

29.

This concludes my prepared testimony. Jim

Huff and Bob Stein will provide

further testimony and exhibits in support

of the Petition.

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CERTIFICATE OF SERVICE

The undersigned, an attorney, certifies that I have served upon the individuals named on

the attached Notice

of Filing true and correct copies of the Pre-filed Testimony of Brigitte Postel,

Jim Huff and Bob Stein, and accompanying Exhibits, via electronic mail, on August 1, 2008

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1

12461166

BEFORE THE POLLUTION CONTROL BOARD

OF THE STATE OF ILLINOIS

IN THE MATTER OF:

)

)

PROPOSED ADJUSTED STANDARD FOR

)

AMMONIA NITROGEN DISCHARGE LEVELS

) AS 08-08

APPLICABLE TO CITGO PETROLEUM

) (Adjusted Standard - Water)

CORPORATION AND PDV MIDWEST

)

REFINING, L.L.C., PETITIONERS

)

TESTIMONY OF JAMES E. HUFF

My name is James E. Huff, and I am Vice President and part owner of Huff & Huff, Inc.,

an environmental consulting firm founded in 1979. I received a Bachelor of Science in Chemical

Engineering in 1970 from Purdue University and was awarded a Masters of Science in

Engineering from the Environmental Engineering Department at Purdue University in 1971. I

am a registered Professional Engineer in Illinois.

My work experience includes two years with Mobil Oil as an Advanced Environmental

Engineer during the construction and start-up of the Joliet Refinery. After leaving Mobil in the

fall of 1973, I was employed for three years at IIT Research Institute in the Chemical

Engineering Department, working on advanced wastewater treatment projects including catalytic

oxidation of cyanide in petroleum wastewaters. I then spent four years with the Armak

Company, now called Akzo Nobel Chemicals, where I was the Corporate Manager of

Environmental Affairs responsible for regulatory compliance and engineering design of

environmental systems at nine manufacturing facilities in the United States and Canada. Three

of these chemical plants were fatty amines manufacturers, where ammonia was utilized as a raw

material and was a major component in the wastewater.

For the last 28 years at Huff & Huff, Inc., I have been involved in over 40 environmental

impact studies associated with the impact of wastewater discharges on receiving streams

throughout the United States. Many of these studies have involved ammonia nitrogen impacts,

including those for the City of Lockport, CITGO Lemont Refinery and its predecessors UNO-

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12461166

VEN and Union Oil, ExxonMobil Oil Corporation, the Galesburg Sanitary District, and Modine

Manufacturing. I was Project Manager on a year long Fox River Ammonia Study on behalf of

most of the municipal discharges on the Fox River below the Chain-of-Lakes. I was an active

participant in the ammonia water quality proceedings (R94-1b), on behalf of six communities

and the Indian Refining Corporation. I am currently working on addressing low dissolved

oxygen levels on the East Branch of the Du Page River and Salt Creek on behalf of the Du Page

River/Salt Creek Work Group. In addition, I have been actively involved in the current UAA

proceedings on the Chicago Waterways on behalf of three industrial clients. I have designed

nitrification facilities for both industrial and municipal wastewater treatment plants.

I was retained by CITGO Petroleum Corporation (Lemont Refinery) to evaluate the

environmental impact of the ammonia in the Lemont Refinery’s discharge to the Chicago

Sanitary & Ship Canal. See 2008 report attached as

Exhibit 2

. I have directed previous studies

relating to the same issue for previous site-specific requests for the Lemont Refinery. See 1992

report attached as

Exhibit 3

. A copy of my resume is attached as

Exhibit 4

. In addition,

effluent limits were derived based upon existing effluent quality, BAT, and current water quality

conditions.

Background

The Lemont Refinery is located southwest of Lemont, Illinois, east of Romeoville, along

the east side of the Chicago Sanitary & Ship Canal (Ship Canal), at River Mile 296.5. Water is

withdrawn from the Ship Canal for refinery use, and the treated wastewater effluent is

discharged to the Ship Canal 5.5 miles upstream of the Lockport Lock and Dam and less than

one mile upstream of Midwest Generation’s Romeoville Power Plant.

The wastewater treatment facilities came on line in 1969, the same time the refinery

began processing crude oil. The treatment plant underwent major changes in 1992, including

new process water storage tanks, a new aeration basin, a new clarifier, and fine bubble diffusers.

Over the past decade, the Lemont Refinery has expended an additional $45 million on capital

projects related to ammonia control and reduction. Over the past five years the processing of

heavier crude oils has increased. These heavier crude oils contain more inert solids and create

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3

12461166

more stable emulsions in the desalter unit. The result has been not only a significant increase in

chemical addition to remove oil (break the emulsions) and solids in the process water, but a more

variable influent loading on the activated sludge treatment process.

The Ship Canal is classified as Secondary Contact water under Illinois regulations. There

is no total ammonia water quality standard applicable to the Ship Canal. Un-ionized ammonia,

which is a function of the total ammonia, pH, and temperature, is limited by a not-to-exceed

value of 0.1 mg/L. This water quality standard is to be achieved at the edge of the mixing zone.

The Agency has proposed to amend the ammonia water quality standard on the Secondary

Contact Waterways to be the same standard as in the General Use Standards in R08-09, currently

before the Board.

Influent and Effluent Quality

The Lemont Refinery water intake is located approximately 175 feet upstream of the

outfall and is routinely analyzed for ammonia by the refinery. Ammonia quality in the Ship

Canal has steadily improved over the past two decades, from an annual average of 3.77 mg/L in

1987, to 1.28 mg/L in 1996, to 0.56 mg/L in 2007, as depicted in the attached

Exhibit 5, Figure

1

. This decline is attributed primarily to the reduction in effluent ammonia achieved by the

MWRDGC at its upstream treatment plants over this period of time.

Effluent ammonia quality from the Lemont Refinery is presented in

Exhibit 5, Figure 2

.

From 1995 until 2005 the annual average ammonia concentration was below 3.0 mg/L. In 2005,

with the increase in the processing of the heavier crude oils and resultant higher loading on the

treatment facilities, the effluent ammonia increased to an annual average of 3.63 mg/L. As the

Lemont Refinery has improved its ability to process these heavier crude oils, the effluent

ammonia levels have continued to improve; to 3.50 mg/L in 2006, 2.45 mg/L in 2007, and

through the first six months of 2008 to an all time low 0.39 mg/L. Clearly overall, the Lemont

Refinery has made progress on consistently nitrifying.

Finally,

Exhibit 5, Figure 3

depicts the mass of ammonia removed from the Ship Canal

on an annual average compared to the mass discharged. The net discharge (effluent less influent)

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12461166

over the past decade has averaged less than 43 pounds per day, and for 2008 to date, the Lemont

Refinery has removed 29 pounds per day from the Ship Canal, while only discharging an average

17 pounds per day.

Receiving Water Way Description

As noted previously, the Lemont Refinery discharges into the Ship Canal 5.5 miles

upstream of the Lockport Lock and Dam, at River Mile 296.5. The Ship Canal extends 31.1

miles from its confluence with the Des Plaines River to the Damen Avenue Bridge in Chicago

(CDM, 2007). The Ship Canal is typically 200 to 300 ft. wide with depths ranging from 27 to 50

ft. (CDM, 2007). The construction of the Ship Canal includes vertical walls and steep

embankments. The Ship Canal was erected in approximately 1900, to “transport human waste

and industrial pollutants away from Lake Michigan” (CDM, 2007). As part of the Use

Attainability Analyses (UAA), CDM conducted a recreation and navigation survey for 28 days.

No swimming, skiing, tubing, or wading was observed. A single

canoe, sculling or hand

powered boat

was observed within the 28 days. From my own experience in conducting benthic

surveys on the Ship Canal for both the Lemont Refinery and the MWRDGC, the Ship Canal is

not safe for canoes, sculling or other hand powered boating activities. When barges pass, the

wake creates literally a wave machine bouncing off the vertical walls. Where two waves cross,

the amplitude doubles, and waves get progressively larger reaching wave heights in excess of

five feet before gradually subsiding.

The aquatic habitat of the portion of the Ship Canal where the Lemont Refinery is located

was rated as “poor to very poor” (IEPA, 2006). Overall stream use is designated as

non-support

for fish consumption and aquatic life. The identified causes of impairment were polychlorinated

biphenyls (PCBs), irons, oil and grease, D.O., total nitrogen, and total phosphorus. Sources

included combined sewer overflows, urban runoff/storm sewers, impacts from hydrostructure

flow regulation/modification, municipal point source discharges, and other unknown sources.

Ammonia concentrations were not identified as a source of impairment, due to the monitored

results achieving the water quality standard.

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12461166

In addition to the unique structure, the Ship Canal is home to three coal fired power plants that

provide low cost electricity to the City of Chicago, the remainder of the State of Illinois, and

elsewhere through the electrical power grid. The Ship Canal is effluent dominated with over 70

percent of its flow on an annual bases from municipal effluents (IEPA, 2008). This included

wastewater effluent from the Stickney treatment plant, one of the largest treatment plants in the

world. Essential barge traffic also flows along this critical artery to a wide range of industries

located along the Ship Canal.

Another unique factor on the Ship Canal is the electric barrier installed near the Lockport Locks.

This barrier was installed to prevent invasive bighead carp from migrating into the Great Lakes.

A second electric barrier has been constructed but is yet operational. These electric barriers will

not only prevent the invasive fish from migrating, but will also prevent other fish from migrating

up or down the Ship Canal at Lockport, normally not a desirable outcome, but certainly

necessary in light of the goal to protect the Great Lakes.

The UAA Report (CDM, 2007, page 4-80) notes that habitat ranged from poor to very

poor, and identified the following factors as limiting aquatic potential on the Ship Canal:

Silty substrates

Poor substrate material

Little instream cover

Channelization

No sinuosity

There are no backwater areas or tributary mouths along the Ship Canal. The lack of habitat

diversity along the Ship Canal clearly limits the diversity of the aquatic biota.

As noted in

Exhibit 5, Figure 1

, the total ammonia concentrations in the Ship Canal are

generally low, below 1 mg/L. Un-ionized ammonia levels from 2000 to 2002 at four stations

along the Ship Canal and Des Plaines River are presented in

Table 4-1

of the 2008 report,

Exhibit 2

.

Average un-ionized ammonia concentrations at all four stations have been

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12461166

consistently less than 0.010 mg/L. Not only is the un-ionized ammonia levels in the Ship Canal

less than the current water quality standard, the levels also attain the proposed changes in the un-

ionized ammonia water quality proposed as part of the Use Attainability Analysis (UAA) in R08-

09.

Mixing Zone

In 1992, Huff & Huff, Inc. conducted a mixing zone study on the Lemont Refinery

outfall (see

Exhbit 3

). The outfall design is unique in that it is a 15-inch diameter pipe,

extending vertically downward 15 feet below the surface into the Ship Canal. The result is a

turbulent discharge that is strongly buoyant due to the entrained air from the effluent flowing

over the weir from the Treated Water Basin. The Zone of Initial Dilution (ZID) was measured at

10:1 and only occupies 100 square feet of the Ship Canal. There are only 300 gallons of effluent

within the ZID at any one time, with a mean retention time under 7 seconds.

In 1992 the mixing zone achieved a 40:1 dilution within 60 ft. downstream, occupying

only 0.05 acres, compared to the allowable 26 acres. With the lower 7-day, 10-year low flow

due to the MWRDGC’s loss of discretionary diversion from Lake Michigan and the slightly

higher effluent flow today than in 1992, the mixing zone today achieves a 36.7:1 dilution within

the same 0.05 acres.

Historical Relief Sought

In 1987, the Board granted site-specific relief to the Lemont Refinery, allowing the

Agency to establish limits based on a reasonable measure of actual production at the Refinery.

From that order, the Agency set limits of 749 lb/day ammonia (monthly average) and 1,648

lb/day (daily maximum). No concentration limits were imposed in 1987 but at the refinery’s

design average flow of 5.79 MGD, these mass limits equate to:

Monthly Average:

15.5 mg/L

Daily Maximum:

34.1 mg/L

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The next two rule changes contained the following concentration limits:

Monthly Average:

9.4 mg/L

Daily Maximum:

26.0 mg/L

The current petition is requesting the following concentration limits:

Monthly Average

1

:

6.9 mg/L

Daily Average

2

:

10.6 mg/L

Clearly, the Lemont Refinery has made progress in reducing its effluent ammonia

discharged, and the requested relief continues to make commitments to future progress. It is

important to remember that this requested relief is for a reduction in pollutant loading from the

current permitted level.

Receiving Water Impacts

Exhibit 5, Figure 1

and

Tables 4-1

and

4-2

of

Exhibit 2

present the historical

concentrations of total ammonia and un-ionized ammonia in the Ship Canal. The total ammonia

can be described as relatively low on an annual basis, and the requested relief will further lower

the Lemont Refinery’s contribution to the downstream stations. The permitted monthly average

limit will decline by 27 percent, while the permitted daily maximum will decline by 59 percent.

The un-ionized ammonia in the Ship Canal on an annual basis is less than 10 percent of

the un-ionized water quality standard, and is consistently in compliance with the water quality

standard. This adjusted standard request will further reduce both the total and un-ionized

ammonia levels downstream over the existing conditions.

1

Concentration limits would apply whenever average discharge exceeds 100 lbs/day.

2

Daily maximum would apply only when the daily discharge exceeds 200 lbs/day.

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As ammonia is oxidized in the receiving stream, oxygen is consumed. To the extent the

Lemont Refinery’s ammonia is contributing to lower dissolved oxygen (D.O.) levels, the

requested relief will only improve D.O. from the existing levels, with the more restrictive

ammonia effluent limits proposed. According to the UAA Study (CDM, 2007), the MWRDGC

has recorded D.O. levels below the 4.0 mg/L minimum water quality standard at all seven

stations on the Ship Canal. At Romeoville and Lockport, both downstream of the Lemont

Refinery, 19 percent of the time D.O. levels below 4.0 mg/L were recorded, the same percentage

of time as at the upstream location at Cicero Avenue.

The Agency’s proposal is to change the minimum D.O. to 3.5 mg/L in the Ship Canal. It

is my understanding the Ship Canal does not currently achieve this 3.5 mg/L D.O. level during

wet weather combined sewer overflow events.

In 1992, in support of an earlier petition, Huff & Huff used the MWRDGC’s QUAL 2E

model to predict changes in D.O. from the Lemont Refinery’s contribution. At a discharge rate

of 744 pounds per day of ammonia from the Lemont Refinery, the maximum D.O. decline was

0.03 mg/L (maximum loading at low flow conditions.) With the current requested relief, the

maximum reduction in D.O. will be closer to 0.02 mg/L at maximum loading and low flow. The

minor level of change in D.O. is less than can be accuracy of the D.O. test method for streams

(0.1 mg/L). In essence, no change in D.O. could be measured attributed to the Lemont Refinery.

Illinois EPA Recommendations

The Agency has recommended that the Board deny CITGO’s requested Adjusted

Standard relief. Some responses to the Agency’s technical basis are appropriate.

•

The Agency cites the Board’s 1972 conclusion that a reduction in ammonia is

necessary if the Illinois River is to achieve the D.O. Standard.

While the 36 year old opinion held significant meaning at the time, more recent water

quality data present different stream conditions. The attached

Exhibit 5, Figure 1

shows that

since just 1986, ammonia levels in the Ship Canal have declined from over 3.6 mg/L to between

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0.47 and 0.81 mg/L. There is no longer an ammonia issue on the Illinois River. The Agency

also overlooks the fact that the requested relief will further reduce ammonia concentrations over

existing levels in the Ship Canal.

•

At this point, CITGO is the only refinery discharging to the Ship Canal that has

yet to meet the ammonia nitrogen standard at 35 III. Adm. Code 304.122(b).

This statement is misleading as the Lemont Refinery is the sole refinery on the Ship Canal.

However, the waterway receives effluent from one of the largest municipal wastewater treatment

plants in the world, which contributes significantly more ammonia on a pounds per day basis

than the Lemont Refinery contributes. Over the past four years, the ship canal upstream of the

Lemont Refinery has contained an average 0.66 mg/L total ammonia. Even at the 7-day, 10-year

low flow, this translates into 4,640 pounds per day of ammonia passing by the Lemont Refinery.

The Lemont Refinery over the past decade has contributed an average 43 pounds per day of

ammonia on a net basis, or less than one percent of the overall ammonia loading under low flow

conditions. (The contribution from the Lemont Refinery would be even less at higher Ship Canal

flows.)

•

CITGO further claims that the discharge from the refinery doesn’t pose any threat

to human health or the environment and is not significantly greater than the

environmental impact that the Board was trying to control when it adopted the

ammonia nitrogen rule. Since Section 304.122(b) is a technology based standard,

not a water quality standard, CITGO’s assertion is irrelevant to the issue at hand

as there exist removal technologies that are economically reasonable and

technically feasible.

The economically reasonable and technically feasible determination by the Board was based on

treating municipal wastewater. The Agency has supported since the late 1980s, for both the

Lemont Refinery and Mobil Oil relief from this rule, in part based on the absence of

environmental impact. The Agency’s current response addresses environmental impact,

including citing the Board’s 1972 opinion on the D.O. concern, yet claims such concerns are

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“irrelevant”. The Lemont Refinery continues to make progress in reducing its ammonia

discharge. The requested relief will reduce the permitted daily maximum by 59 percent.

•

Conoco-Phillips Refinery does not have water quality based limits due to its

location on the Mississippi River, however nitrification is known to occur on a

regular basis given the ammonia levels measured in the effluent and the results of

whole effluent toxicity testing.

This statement is also misleading. The Lemont Refinery nitrifies a high percentage of the

time and its effluent also passes the whole effluent toxicity testing. From information in the

Agency files, the following could have been provided to the Board by the Agency:

CONOCOPHILLIPS WOOD RIVER AMMONIA EFFLUENT LEVELS

Year

Maximum Monthly Average,

mg/L

Daily Maximum,

mg/L

2003

2.0

15.2

2004

7.6

7.6

2005

5.8

10.6

2006

2.3

3.0

2007

4.2

4.2

From 2002 to 2007, the ConocoPhillips Wood River Refinery has discharged an average 67

pounds of ammonia per day. As the intake water is groundwater, this 67 pounds per day can be

considered a net discharge, as compared to the Lemont Refinery net 43 pounds per day ammonia

discharged. It would seem that the Agency’s use of this other refinery as an example is totally

consistent with the Lemont Refinery’s performance.

It is clear Conoco-Phillips does not meet a 3.0 mg/L monthly average or a 6.0 mg/L daily

maximum all the time. In fact, the results look very similar to the Lemont Refinery’s

performance. Simply comparing concentrations discharged from petroleum refineries can be

misleading, as water conservation practices vary. The more modern refineries like the Lemont

Refinery discharge less water per barrel of crude processed than older refineries.

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•

By seeking relief from Section 304.122 ammonia standard, CITGO is subjecting a

portion of the Ship Canal to experience much higher ammonia concentrations, 6.9

mg/L as a monthly average and 10.61 mg/L as a daily maximum.

This statement does not offer an accurate representation of the relief sought. The

requested relief will result in lower ammonia concentrations in the Ship Canal than result from

the existed permitted levels, which the Agency supported in the previous site specific rule

change. The Agency also seems to imply that ZIDs and mixing zones are inappropriate. Within

the ZID, where a 10:1 dilution occurs within 7 seconds. Assuming the Lemont Refinery is

discharging at the requested

daily maximum

limit of 10.61 mg/L, the ammonia concentration at

the edge of the ZID will be 1.63 mg/L, and at the edge of the mixing zone, the ammonia

concentration will be 0.91 mg/L. At the 7-day, 10-year low flow, the increase in ammonia will

be from 0.634 mg/L upstream to 0.701 mg/L once complete mixing has occurred when the

refinery is discharging at its proposed daily maximum 10.61 mg/L and its design average flow.

Again, all of these values are reductions from the current permitted levels.

The Lemont Refinery is seeking an adjusted standard from ammonia effluent limits that

were adopted by the Board solely because of the elevated ammonia/low dissolved oxygen in the

Illinois River over 36 years ago. No other large water body in Illinois has effluent ammonia

standards. The conditions that lead to these unique Illinois River Basin effluent standards no

longer exist today.

•

The Ship Canal will thus have an area that is effectively unavailable as habitat for

sensitive forms of aquatic life.

The Agency should identify which “sensitive forms of aquatic life” it is referring to. The

Agency in its pre-filed testimony in R08-09, described the Qualitative Habitat Evaluation Index

on the Ship Canal as “generally below 22, which are to be expected in waters with

very poor to

poor habitual attributions

” (R. Sulski, 2007, page 17, emphasis added). If the habitat is

controlling the aquatic potential, it is misleading to state sensitive forms would enter into the

turbulent ZID and mixing zone. In Adjusted Standard AS96-10, the Board’s opinion noted that

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12461166

the Agency’s opinion was that the costs of installing additional cooling “may not be

economically reasonable

when compared to the likelihood of no improvement in the aquatic

community of the UIW.”

3

(AS96-10, Opinion and Order at page 7). The Agency’s position in

this ammonia proceeding is inconsistent with the position it has taken historically along the

waterway as well as its current position on the limitations of habitat in the UAA proceedings.

•

Adding higher

ammonia discharge levels would only further prevent attainment of

dissolved oxygen standard (emphasis added).

Again, the Agency is confusing the Lemont Refinery’s request, which is a reduction in

ammonia levels over the current permitted levels. Attainment of the dissolved oxygen standard

on the Ship Canal will depend on the elimination of CSO events, not on the Lemont Refinery’s

minor ammonia contribution.

Cost Effectiveness

As presented in

Exhibit 5, Figure 3

, the Lemont Refinery has achieved an average

annual total ammonia effluent level of 75 pounds per day over the past decade while the existing

Site Specific Rule Change was in effect. The ammonia removed from the Ship Canal by the

Lemont Refinery over this same period has averaged 32 pounds per day, so the net contribution

has been 43 pounds per day. Assuming that the lowest cost upgrade identified in the Aware

Report (February 2008) will remove the 43 pounds per day contributed (the refinery becomes

ammonia neutral

to the Ship Canal), the annualized cost would be $3,220,000, or a cost of $205

per additional pound removed.

The Lemont Refinery would also increase its carbon footprint from the additional energy

consumed with the add-on equipment, should the adjusted standard be denied. The operating

horsepower for the added equipment will be 144 HP. Assuming the additional energy consumed

is derived from coal, the additional pounds per year of carbon dioxide emitted will be 1,976,000.

3

UIW-Upper Illinois Waterway

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Or for every additional pound of ammonia oxidized, 126 pounds of carbon dioxide will be

emitted. Remember, that ammonia oxidation occurs naturally within the receiving stream,

without carbon dioxide generation.

The $205 per pound of ammonia removal for the incremental 43 pounds per day can be

compared to the cost for ammonia removal at the Calumet Water Reclamation Plant of

approximately $3.00 per pound, and the addition of five side-stream aeration systems that

provide sufficient oxygen to remove a pound of ammonia at approximately $10.00 per pound.

4

The above unit cost is 68-times higher for the Lemont Refinery than the ammonia removal costs

required for the Calumet Water Reclamation Plant, and is clearly not cost effective.

Derivation of Effluent Limits

The Lemont Refinery is currently operating under a site-specific rule change that expires

on December 31, 2008. The existing limits include both load limits based on Best Available

Treatment under the federal categorical limits and concentration limits. The existing limits are

as follows:

Ammonia Concentration

Monthly Average

9.4 mg/L

Daily Maximum

26.0 mg/L

Using five years of effluent data from June 2002 to May 2007, and the U.S. EPA

Technical Support Document for Water Quality-based Toxics Control (1985) procedure, at the

95

th

percentile the calculated ammonia limits are 6.9 mg/L monthly average and 10.6 mg/L daily

maximum. As noted previously, these are significant reductions from the current limits, 27

percent on the monthly and 59 percent on the daily maximum. However, Section 304.122(b)

only applies to dischargers that discharge more than an average 100 pounds per day on a monthly

average, and 200 pounds per day on a daily basis, and the Lemont Refinery is asking that the

4

See Environmental Assessment of Ammonia Concentrations in the Wastewater Discharge of Union Oil Company, Chicago

Refinery, by L.L. Huff and J.E. Huff, 1983, updated to 2008 dollars and testimony of J. E. Huff in the Matter of Petition of Uno-

Ven to Amend Regulations Pertaining to Water Pollution, R93-8.

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above concentration limits only apply when these mass limits are exceeded. This is particularly

important from a compliance perspective. If nitrification is lost or inhibited, ammonia

concentrations increase, and there is minimal corrective action that can be accomplished in the

short term to lower concentrations. However, the Lemont Refinery does have the ability to limit

the volume of discharge for a period of time, and could reduce its discharge rate during periods

when the nitrification process is upset to stay under the mass limits. From an environmental

perspective, this is a good approach to minimizing any increase in ammonia in the Ship Canal,

and allows for a proactive method for refinery personnel to respond to upsets without violating

an effluent limit.

Summary

The Lemont Refinery has consistently achieved the Best Available Treatment ammonia

limits since 1987. The average net ammonia discharged by the refinery to the Ship Canal since

1999 has been 43 lbs/day, and in 2008 through June the refinery has removed 29 pounds per day

from the Ship Canal, while adding only 17 pounds per day.

The site-specific relief is not required to achieve the calculated BAT limits, but rather for

the unique Illinois River Basin regulations that were based on river conditions that existed in the

early 1970s, but no longer exist today. The Lemont Refinery has been unable to consistently

achieve the ammonia effluent limits due to the complex nature of petroleum refining as well as

the sensitive nature of the nitrification process itself. The Lemont Refinery has expended over

$45,000,000 since 1998, to attempt to further reduce effluent ammonia levels. The increase in the

processing of heavier crude oils in 2005 clearly set back the refinery’s progress. However, the

steady improvement since 2006 and the record low effluent ammonia levels through the first six

months of 2008 suggest that the Lemont Refinery is close to achieving the 3/6 mg/L limits, and a

five year period to fine tune and demonstrate performance is reasonable. The environment will

benefit from the significant reductions in ammonia permitted to be discharge while consumers

may benefit from less expensive petroleum products in Illinois and a reduced carbon footprint

associated with add-on nitrification equipment at the Lemont Refinery.

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Given that the proposed effluent limits are lower than the limits determined from the

water quality-based derivation, the requested effluent limits will be protective of the Ship

Canal’s water quality. The overall declining ammonia loading on the Illinois River System and

the onset of nitrification within the Ship Canal itself (due to higher dissolved oxygen levels) have

virtually eliminated un-ioinized ammonia exceedances downstream of the Lemont Refinery.

Dramatic improvements in the dissolved oxygen level within the Ship Canal have also occurred

over the past twenty years. These factors support the Lemont Refinery’s request for site-specific

relief, as no environmental impacts from the requested relief have been identified.

REFERENCES

CDM,

Chicago Area Waterway System Use Attainability Analysis,

August 2007.

Huff, J. E. and M. A. Panatera,

Environmental Assessment & Effluent Limit Derivation Report

for the Ammonia Discharge from the CITGO Lemont Refinery,

February 2008

.

Illinois EPA, Statement of Reason, R08-09, 2008.

R. Sulski,

Pre-filed Testimony in the Matter of R08-09

, December 21, 2007, page 17.

U. S. EPA,

Technical Support Document for Water Quality-based Toxics Control,

EPA-440/4-

85-032, September 1985.

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TESTIMONY OF ROBERT M. STEIN

My name is Robert M. Stein and I am affiliated with AWARE Environmental Inc. (AEI). I have

been evaluating the Citgo Lemont Refinery’s (Lemont Refinery) wastewater treatment plant with

regard to achieving the State of Illinois ammonia nitrogen discharge limitations for over 30 years.

A summary of the AWARE Environmental Inc. professional capabilities, as well as the vitae for

those persons participating in this evaluation are attached and are designated as follows:

Description of AWARE Environmental Inc.

Exhibit 6

Robert M. Stein Vitae

Exhibit 7

George Tyrian Vitae

Exhibit 8

I have specialized in the area of industrial water pollution control and I have worked with

numerous industries with regard to biological nitrification and nitrogen control. I have consulted

on over 10 refinery and 30 nitrogen control projects. A detailed list of projects is included in the

attached vitae.

I have been a contributing author to one of the standard texts in the environmental engineering

field, have been an adjunct professor at the University of North Carolina-Charlotte, I was

appointed by the North Carolina Environmental Management Commission to serve on the

Champion/Pigeon River Water Quality Variance Review Committee and I was awarded the

TAPPI Roy F. Weston award for outstanding contributions in environmental technology. I have

authored numerous articles on industrial environmental control. A list of publications is included

with my vitae. Several of these were in the area of nitrogen control.

AEI, in addition to extensive experience in refinery and nitrogen removal systems in general, has

a detailed understanding of the Lemont Refinery. The refinery produces gasoline, a variety of

other fuels, coke, and solvents from crude oil. AEI personnel have been working with the

Lemont Refinery treatment system for approximately thirty (30) years.

Process wastewater and stormwater from the refinery are treated in the refinery’s wastewater

treatment facility. The wastewater facility includes oil and solids removal, flow equalization,

clarification, single-stage activated sludge treatment and final polishing.

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The Lemont Refinery has been unable to consistently and reliably meet the State of Illinois

effluent ammonia nitrogen concentration standard of 3.0 mg/L. The Illinois Pollution Control

Board granted the refinery a site specific rule change, effective through December 31, 2008,

which allows the refinery to meet the U.S. EPA Best Available Technology Economically

Achievable (BAT) effluent limitations. The refinery has consistently achieved compliance with

the U.S. EPA BAT effluent limitations.

AWARE Environmental Inc. (AEI) of Charlotte, North Carolina was retained by the Lemont

Refinery to evaluate current conditions and potential alternatives for upgrading the treatment

system to meet a 3 mg/l ammonia nitrogen limit. AEI conducted a conceptual evaluation of the

Lemont Refinery wastewater treatment system, and the available alternatives to achieve

ammonia removal for a refinery wastewater. The details of this evaluation are presented in our

report entitled “Technical Review of Ammonia Treatment at the Wastewater Treatment Plant –

Citgo Petroleum Corporation, Lemont Refinery,” attached to this testimony as

Exhibit 9

. The

primary objectives of this evaluation were to:

1. Determine if the present wastewater treatment system is consistent with U.S. EPA BAT

criteria;

2. Determine if the wastewater treatment system operating conditions are conducive to

biological nitrification; and

3. Evaluate alternative ammonia removal technologies and the cost of those technologies to

determine if changes in the present wastewater treatment system are warranted as part of

a program to achieve compliance with the 3 mg/l ammonia nitrogen criteria.

The results of this evaluation indicate that Lemont Refinery has a wastewater treatment system

which exceeds BAT criteria and which allows the refinery to comply with U.S. EPA refinery

discharge regulations. The long term performance data has demonstrated that the refinery

wastewater treatment facility has achieved compliance with the current mass based limitations

for ammonia nitrogen contained in the NPDES permit, but that the refinery has not been able to

consistently meet a 3.0 mg/l ammonia nitrogen limit as per the Illinois regulations.

A review of the wastewater treatment technologies employed at the other Illinois Refineries was

conducted. These refineries were Conoco-Phillips, Roxana, IL; Exxon-Mobil, Joliet, IL; and

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Marathon, Robinson, IL. The wastewater treatment processes employed by these Refineries are

very similar to those utilized at the Lemont Refinery.

A review of the activated sludge treatment plant was performed with regard to factors which

control the ability of a biological treatment facility to achieve nitrification. These factors include

food to microorganisms ratio (F/M), sludge age, dissolved oxygen concentration, temperature,

pH, and alkalinity. The review indicates that these parameters have been maintained in the

ranges favorable to nitrification. However, in spite of this, the refinery treatment facility has

been unable to meet the 3.0 mg/l ammonia nitrogen standard on a consistent basis.

We found that Lemont Refinery has maintained an ongoing optimization program and this

program has resulted in improved ammonia nitrogen removal. The program has been expanded

to address changes in the petroleum refinery industry. The refinery has spent over $45,000,000

over the last ten years on capital projects related to ammonia control and reduction.

As a result of changes in the crude quality, Lemont refinery has experienced a five-fold increase

in wastewater treatment chemical addition costs over the last 4 years. Lemont refinery has and is

continuing to conduct research which addresses the environmental impacts caused by crude

quality fluctuations. Crude quality fluctuations confirm AEI’s previous analysis which indicated

that the capability of the wastewater treatment system is limited, in large part, due to the inherent

variability of refinery wastewater.

There are a large number of treatment technologies which can be utilized for ammonia removal.

These include biological treatment technologies, land treatment, wetlands polishing, and

physical/chemical treatment. As part of my review of treatment alternatives for upgrade of the

Lemont Refinery wastewater treatment plant to achieve increased ammonia removal I considered

our experience in design and operation of nitrogen technologies along with a detailed review of

published data on technologies for ammonia removal. The most commonly used approach for

ammonia nitrogen removal is biological nitrification.

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Biological nitrification is typically a two step process as follows:

Nitrosomonas

2 NH

4

+ 3O

2

2 NO

2-

+ 4H

+

+ 2 H

2

O

Nitrobacter

2 NO

2-

+ O

2

2NO

3

-

Total Reaction

NH

4

+

+ 2O

2

NO

3

-

+ 2H

+

+ H

2

O

It is in the biological nitrification process where refineries have experienced problems in

providing consistent ammonia nitrogen removal. This is because biological nitrification is a

very sensitive process. The cell growth rate is much lower for the ammonia nitrogen organisms

(nitrifers) than for carbonaceous degradation (COD) organisms. In a typical activated sludge

aeration basin, nitrifies represent only 2-5% of the aeration tank biomass. The nitrification

growth rate is more sensitive to temperature changes than carbonaceous organism and nitrifers

are more susceptible to chemicals discharges. This can occur in a number of ways:

1. Inhibition – Nitrifers continue to grow but at a slower rate

2. Toxicity – Loss of nitrifers

EPA has published a listing of organics and metals which inhibit the organic activated sludge

process and which affect nitrification (EPA-430/9-76-017a). This document indicates there are

significantly more compounds which affect nitrification than carbonaceous organisms and where

a compound affects both it typically affects nitrifers at a much lower dosage (I.E. phenol affects

carbonaceous organisms at 200 mg/l and nitrifers at 4-10 mg/l).

Because of the sensitivity of the nitrifying organisms in the degradation of refinery wastewaters

and the long term variability which has occurred in achieving ammonia removal at the Lemont

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Refinery, process technologies considerations were based on approaches which could minimize

potential upsets and provide the best mechanism for biological nitrogen removal. This included

single stage activated sludge (an increase in the activated sludge aeration basin size or addition

of a media to the existing aeration basin to obtain additional biomass). Some of the media

applications include Kaldnes, Linpor, Hydroxyl or Agar or the addition of supplemental

specialized bacteria to a single stage basin. However, these alternatives were rejected because of

the sensitivity of nitrifers to the refinery wastewater. Since the existing treatment plant has been

experiencing problems with loss of nitrification and the fixed media type organisms are subject

to sluffing, the addition of fixed media or increased retention time does not provide the best

alternative to minimize potential upsets.

An alternative approach could be providing a fixed bed type system ahead of the activated sludge

system as a pretreatment. However, this still presents a problem since the fixed bed bacteria

would be more sensitive to upsets and would not do as good as job of removing the carboneous

materials. There is a very high probability of sluffing of the organisms which could upset the

activated sludge process.

In reviewing alternatives for upgrading a single activated sludge system, we felt that the two

most promising alternatives were a single stage activated sludge with a powered activated carbon

supplement or a single stage activated sludge membrane bioreactor. The powered activated

carbon supplement includes the advantage of the plastic type media in that it provides a location

where additional bacteria can grow however the powdered activated carbon also adsorbs

materials that may be toxic or inhibitory to the nitrifying organisms. This process allows

concentration of trace nutrients at the carbon surface and provides bulk addition to improve

sludge settling properties.

The membrane bioreactor technology is one of the newest approaches for improving biological

nitrification. With the membrane there can be improved solids liquids separation and the

treatment plant is able to operate at significantly higher MLSS levels than in a conventional

treatment plant (typically twice the normal MLSS levels). Specifically this allows:

1) the retention time of the biomass can be increased to create favorable conditions for

normal growth of the nitrifying organisms;

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2) better and more reliable effluent quality as compared to a conventional processes; and

3) easier control and operation of the system since the system would not longer need a

secondary clarifier.

In addition to considering a single stage system we also considered two stage biological

treatment. In a two stage process, carbonaceous removal is achieved in the first stage. This is

normally an activated sludge process. The first stage reduces the concentration of toxic and

inhibitory materials. There are two basic second stage alternatives. One is to have a 2

nd

stage

activated sludge system and the other is use of a fixed media system for the 2

nd

stage. The

reason for selecting a fixed media system for the 2

nd

stage is that the nitrifying organisms tend to

grow slower than carboneous organisms, they do not settle as well and therefore, if the inhibitory

or toxic materials can be reduced in the 1

st

stage than a 2

nd

stage fixed film system provides a

very good mechanism for biological treatment. The poor settling organisms will attach to the

media.

Based on the analysis of all alternatives, four of the most viable alternatives were selected for

preliminary process design and budgetary cost estimates. The four alternatives selected include

powdered activated carbon addition (PACT), a two stage activated sludge fixed media biological

treatment, membrane bioreactors, and breakpoint chlorination. Addition of a fixed media

biological reactor would be the most cost-effective alternative. The fixed media system would

utilize a rotating biological contractor (RBC) and would have an estimated capital cost of

$13,500,000 and an estimated annual operating cost of $1,220,000. The estimated total

annualized cost for the addition of the fixed media reactor system over a ten (10) year period at 8

percent interest is $3,220,000/year.

Even with the ammonia removal upgrades, the ability of the treatment system to consistently

meet the 3.0 mg/l ammonia nitrogen standard is uncertain. Based on the significant cost of

upgrading the system, and the uncertainty that the upgraded system would achieve consistent

compliance with the 3.0 mg/l ammonia nitrogen standard, upgrading the treatment system with

additional treatment technologies for ammonia removal is not justified.

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Our findings indicate that the Lemont refinery has an approach which is properly directed to

improving treatment plant performance, particularly as it relates to ammonia removal. We

recommend that Lemont Refinery continue its ongoing research studies and projects designed to

optimize the existing wastewater treatment system. These efforts should be directed toward

obtaining the maximum possible ammonia removal on a consistent basis. Continued

development of operational data under the varying conditions inherent with refinery wastes will

help to improve the performance of the system, and will allow the maximum ammonia removal

capability of the system to be achieved.

In conjunction with the preparation of testimony I received and reviewed a copy of the June 20,

2008 document entitled “Recommendation of the Illinois Environmental Protection Agency”

related to the Lemont Refinery ammonia standard request. I offer the following comments to

information contained in that document:

1. Item #13 on Page 5. In this section it is indicated that many expenditures which were

credited as improvements to the treatment plant were not directly related to ammonia

nitrogen. I feel that this is not true since many of the items noted were implemented to

improve the overall treatment plant performance and the overall treatment plant

performance improvements allowed the treatment plant to provide increased biological

nitrification. For example, gas floatation pretreats and removes oils and solids prior to

the activated sludge system. Oils can inhibit nitrification and the lower levels of these

materials improves biological nitrification. In addition, the cost of the Purge treatment

unit “PTU”, installed as part of the FCC consent decree, were largely caused by the need

to consistently provide ammonia nitrogen removal. Before installation of the FCC unit,

the Refinery was far below BAT treatment standards. The PTU wastewater treatment

processes would likely not have been needed had the ammonia rule - or the ammonia site

specific rule - not been in effect.

2. Item #15 on Page 7. There is a discussion that when the board adopted the provisions of

the ammonia nitrogen standard there was extensive testimony as to the availability of

methods for reducing ammonia in the effluent and it was determined that nitrification can

be satisfactory accomplished for a reasonable price by a second stage of biological

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treatment. It indicated that the evidence is clear that for too long, oxygen demand exerted

by ammonia in

DOMESTIC

waste has been overlooked.

We feel that there is adequate demonstration that domestic wastewater treatment plants

can achieve biological nitrification but this is not the case for the treatment of refinery

wastewaters. Two documents which justify this finding are the “Development Document

for Effluent Limitation Guidelines in New Source Performance Standards for the

Petroleum Refinery Point Source Category”, April 1974, developed by the US

Environmental Protection Agency and the “Develop Document for Effluent Guidelines

New Source Performance Standards and Pretreatment Standards for the Petroleum

Refinery Point Source Category”, October 1982, developed by the effluent guidelines

division of the US Environmental Protection Agency. In both of these documents, there

is clear indication that the petroleum refinery industry does not have the technology for

economically achieving a 3 mg/l effluent standard on a consistent basis. In 1974, the

EPA data showed that an activated sludge system for an petroleum refinery can expect to

produce an effluent ammonia of 1 to 100 mg/l and in the 1982 development document the

EPA indicated that for direct dischargers in the petroleum refinery industry (Table 6-1)

that the current BPT for ammonia nitrogen is 6.8 mg/l.

These data indicate that although the board may have had extensive testimony on

methods of removing ammonia nitrogen in domestic effluents the technology was

fundamentally different for ammonia nitrogen in the refining industry.

3. Item #15 on Page 7. It is noted that Citgo is the only refinery discharging to the Ship

Canal that has yet to meet the ammonia nitrogen standard in the Illinois administrative

code. I am not aware of any other refineries that discharge to the ship canal.

4. Items #17 and 18 on Page 8. The board specifically states that nitrification can be

satisfactory accomplished at a reasonable price. We question the use of reasonable price

in light of the specific nitrogen reduction which is proposed to be achieved. Table 3-10

of the AWARE report (

Exhibit 9)

shows that the average effluent ammonia from January

2006 through October 2007 was 122 lbs NH

3

-N/day. At an average flow of 7.13 MGD

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and at a 3 mg/l ammonia nitrogen limit, the refinery would be allowed to discharge 178

lbs NH

3

-N/day. Therefore, the long term ammonia discharge is less than the projected

limit. The technical and economic justification to spend an annual cost in excess of

3,000,000 to achieve very little addition nitrogen removal and a level that is not expected

to consistently achieve the 3 mg/l standard is questionable.

5. Item #19 on Page 9. This notes that Citgo is the only Illinois refinery not meeting the

ammonia limit. Based on a review of the available NPDES data, the Conoco Philips

Refinery is only in compliance with the 3 mg/l limit approximately 90% of the time and

the Exxon Mobil Refinery has been in compliance only since 2005.

6. Item #20 on Page 9. The report questions if the refinery has adequate retention time to

comply with the effluent standards. It should be noted that the retention time at the

Conoco Philips is 1.31 days and that refinery, as previously noted, has only been in

compliance approximately 90% of the time. The F/M as noted in the AEI report at the

Citgo Refinery is adequate for biological nitrification and on a long term basis achieves a

very low effluent ammonia concentration. One item noted in the EPA development

document related to refineries are “the effluent from a properly designed and operated

treatment plant changes continually due to the variety of factors. Changes in production

mix, production rate, and reaction chemistry influence the composition of raw wasteload

and therefore, its treatability. Changes in biological factors influence the efficiency of

the treatment process”. Therefore, we feel that there are a number of factors which effect

the performance of a refinery treatment plant to achieve nitrification and that these have a

direct effect on the ability of the treatment plant to consistently achieve nitrification.

7. Item #20 on Page 10. It was noted that Citgo did not consider additional aeration basin or

additional clarifier to provide longer detention time. It should be noted in the AEI report

(in Table 4-6 of

Exhibit 9

) that the overflow rate in the clarification system is lower than

in the Exxon Mobil and Conoco Philips refineries. Therefore additional clarification

would not necessarily make any significant improvement. We looked at additional

detention time in that one of the processes selected (2-stage biological system where we

used a fixed film system as the second stage). This provides additional detention time

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and also provides what we feel is one of the best cases for providing good treatment in

that a 2-stage system provides reduction of toxic and inhibitory materials in the 1

st

stage

and a 2

nd

stage a fixed film type process provides a very good media for growth of

nitrifying organisms.

8. Item #24 on Page 11. The ammonia concentrations in the permit should not affect the

long term average ammonia discharge. As previously noted the long term ammonia

discharge from the refinery in 2006-2007 was 122 lbs/day. This is actually significantly

less on a long term basis than the proposed permitting levels. Therefore, we do not feel

that there is any significant additional effect on aquatic life. This also applies to Item 25

on Page 12 which questions the additional ammonia effecting DO in the ship canal since

on a long term average the ammonia discharge is less than would be permitted under the

3 mg/l regulation.

9. Item #37 on Page 16. The other refineries have not been able to consistently achieve the

3 mg/l level. We disagreed, as previously stated, that the additional ammonia removal

will be cost effective.

I will now summarize our findings which have resulted in these conclusions:

1. COMPARISON OF LEMONT REFINERY WITH U.S. EPA BAT TECHNOLOGY

a) The U.S. EPA has developed a model plant for sour water strippers. The Lemont

Refinery has maintained an on-going program with the objective of improving

stripper performance. The sour water stripper data from the last ten years shows that

ammonia removal efficiencies have been observed in excess of 96.8 percent, and

monthly average efficiencies have been observed in excess of 99 percent. This type

of performance is indicative of the facility’s diligent program of improving

performance. This represents performance well exceeding the U.S. EPA model

refinery objective and continues to show ongoing improvement.

b) The U.S. EPA developed a BAT model for a refinery wastewater treatment system.

Our analysis of the Lemont Refinery wastewater treatment system indicates that it

exceeds the BAT technology for refinery wastewater treatment as presented in the

1982 U.S. EPA “Development Document”. The BAT criteria used as the basis for

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the U.S. EPA effluent limitations guidelines are compared with the refinery

wastewater treatment system in Table 1. As shown in Table 1 the refinery treatment

system contains all of the BAT components outlined in the U.S. EPA. In addition to

complying with the U.S. EPA model technology, the facility has continually made

improvements and upgrades to its wastewater management program to reduce

effluent ammonia and improve the overall performance of the treatment system.

Based on the continued improvement in effluent quality it appears that these

improvements and upgrades have been successful.

c) We have found that the Refinery wastewater treatment system performance is

compliant with the U.S. EPA BAT effluent limits for ammonia. The current NPDES

ammonia limits are 1005.73 lbs/day average and 2212.65 lbs/day maximum based

upon updated production data. An evaluation of the data from January 2006 through

October 2007 shows that the effluent ammonia has consistently been less than BAT

levels with an average ammonia nitrogen discharge over this period of 122 lbs/day.

The refinery produces a better quality effluent ammonia and the U.S. EPA BAT

ammonia effluent limits are achieved 100 percent of the time, even under extreme and

adverse conditions.

2) ANALYSIS OF TREATMENT PROGRAM

A number of parameters have been identified which affect biological nitrification. These

parameters are: F/M (food to mass ratio); sludge age, aeration basin pH, aeration basin

temperature; and aeration basin dissolved oxygen concentration.

Table 2 presents an analysis of normal requirements for nitrification and the operating levels

at the Lemont Refinery. As can be noted, the Lemont Refinery has consistently provided

equal or better capabilities.

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BAT Guidelines

Lemont Refinery System

•

Sour water strippers

•

Sour water strippers provide in excess

96% average ammonia removal

efficiency

•

Flow equalization

•

Two (2) 4.6 MG process wastewater

storage tanks providing approximately

4.2 day equalization capacity in addition

to a 52 MG stormwater capacity which

provide 14 days equalization and a 0.25

MG equalization tank

•

Initial oil and solids removal

•

CPI separators

•

Additional oil and solids removal in the

two 4.6 MG process wastewater storage

tanks

•

Additional oil and solids removal

•

100 ft diameter primary clarifier with

polymer addition

•

Induced gas flotation

•

Biological treatment

•

Single-stage activated sludge system

•

Filtration or other final polishing

•

16 MG final polishing pond

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Parameter

Optimum Range

Operation

(2)

F/M, lb BOD5/lb MLVSS-day

Less than 0.3

0.056 – 0.287

(3)

Sludge Age, days

> 10

13.1 - > 100

D.O., mg/L

2.0

(1)

3.3 – 7.0

pH

7.2 – 9.0

7.0 – 8.2

Temperature, ºF

68 – 100

76 - 97

NOTES:

(1)

Average D.O. should be >

2.0 mg/L.

Minimum D.O. should be >

1.5 mg/L.

(2)

Based on monthly average data.

(3)

F/M exceeded this range in June and July 1994. Overall average F/M over

operating period is approximately 0.150 lb/lb-day.

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3) ANALYSIS OF TECHNOLOGIES UTILIZED AT ILLINOIS REFINERIES

In conjunction with the review of alternative technologies to upgrade the Lemont Refinery, a

review of the treatment technologies in place at other Illinois refineries was conducted. The

refineries included:

Conoco-Phillips

Roxana, IL

Exxon-Mobil

Joliet, IL

Marathon

Robinson, IL

A summary of this analysis is presented in Table 3.

This analysis indicated that the treatment technologies at all the Illinois refineries are very

similar. All have preliminary oil separation followed by an additional oil-water separator

using a gas flotation process. The biological treatment process is activated sludge. The

overflow rates on the secondary clarifiers are similar. The only difference in the treatment

systems appears to be the activated sludge retention time. The Conoco-Phillips and

Marathon refineries have a longer retention time than the Lemont Refinery. The Exxon-

Mobil and Lemont Refinery have similar activated sludge retention times. A review of the

effluent data shows that the Conoco-Phillips Refinery has not been in consistent compliance

with the 3 mg/l ammonia standard. The Exxon-Mobil Refinery exceeded the 3 mg/l limit

prior to 2005.

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System

Exxon

Lemont

Marathon

Initial Oil and Solids Removal

Oil/Water Separator

API Separator

Two-4.6 MG Process

Separation Tanks

API Separator

Additional Oil and Solids Removal

Dissolved Nitrogen

Flotation

Air Flotation

Induced Gas Flotation

Dissolved Nitrogen Flotation

Biological Treatment

Activated sludge with 1.31

days detention time and

450 gpd/ft

2

clarifier

overflow

Activated sludge with 10.9

hrs detention time

(upgrading to 19.4 hrs).

Clarifier overflow 392

gpd/ft

2

Activated sludge with 7.7 hrs

detention time and 382

gpd/ft

2

clarifier overflow

Activated sludge with 1.54

days detention time and 227

gpd/ft

2

clarifier overflow

Tertiary Treatment

Polishing ponds 5.4 mg

Polishing pond 4.9 mg

Polishing in treated water

basin (polishing pond) 16 mg

Final filtration

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4) ADDITIONAL TECHNOLOGIES FOR THE REMOVAL OF AMMONIA

The AEI analysis of the Lemont Refinery treatment facility indicated that the refinery has

been unable to provide consistent biological nitrification. Consequently alternative treatment

technologies or variations of the biological treatment technology were examined to determine

the feasibility of achieving the State of Illinois ammonia limitations of 3 mg/L. The

alternative technologies which were evaluated included:

1. Biological Treatment Technologies/Adaptations

a. Single-stage activated sludge.

b. Single-stage activated sludge with the supplement of specialized bacteria.

c. Single-stage activated sludge with a powdered activated carbon supplement.

d. Single-stage activated sludge membrane bioreactor.

e. Two-stage activated sludge.

f. Two-stage biological treatment using activated sludge for the first stage and a

fixed media system for the second stage.

2. Land Treatment

3. Wetlands Polishing

4. Physical – Chemical Technologies

a. Ion exchange.

b. Air stripping.

c. Steam stripping.

d. Breakpoint chlorination.

Based on a review of available literature, previous studies on Lemont Refinery wastewater, and

our personal experience with similar wastewaters, this list of technologies was reduced to the

four with the greatest potential for achieving the Illinois 3.0 mg/l ammonia nitrogen standard on

a consistent basis. The four technologies selected for consideration at Lemont Refinery are:

1. Activated sludge with powdered activated carbon addition (PACT);

2. Activated sludge with a fixed media system;

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3. Activated sludge with membrane bioreactor; and

4. Activated sludge with breakpoint chlorination and dechlorination.

Each technology was subjected to a rigorous and thorough evaluation to evaluate its potential for

achieving the objective mentioned above.

Our analysis indicated that the least expensive approach for compliance was a second stage fixed

media biological treatment unit. The annualized cost for the fixed media system over 10 years at

percent interest is $3,220,000.

Additional ammonia removal may be achievable by upgrading the treatment plant with

additional treatment steps such as a fixed media biological treatment unit. However, this would

be at significant cost, and it is uncertain that the upgraded system would achieve consistent

compliance with the 3 mg/L ammonia nitrogen standard. Therefore, upgrading the treatment

system with additional treatment technologies for ammonia removal is not justified at this time.

SUMMARY

In summary, an analysis of the Lemont Refinery wastewater collection and treatment system was

conducted to determine if the system continues to be a BAT facility. The results of this analysis

indicate that the refinery has a state-of-the-art wastewater treatment system which exceeds BAT

criteria and allows compliance with all U.S. EPA refinery discharge regulations and with the

current NPDES permit for the facility. The wastewater treatment system has been operated

under conditions which are optimum to achieve biological nitrification. There have been

significant changes in crude supply and the refinery is processing heavier crudes, the wastewater

treatment program has been diligent and has continued to provide excellent performance.

However, the system has been unable to consistently achieve biological nitrification. The data

has demonstrated that the wastewater treatment system is not able to consistently provide

biological nitrification to meet the 3 mg/L ammonia nitrogen standard as required in the Illinois

regulations.

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The Lemont Refinery has continued its program to optimize its treatment system. This appears

to be the proper direction for improving wastewater treatment performance.

Alternative add-on, end-of-pipe treatment technology has been evaluated and will have an

annualized cost of $3,220,000. There is no guarantee that installing this technology will result in

compliance with the 3 mg/L ammonia nitrogen limitation.

Therefore, we recommend that Lemont Refinery continue its ongoing wastewater treatment

improvement programs. These efforts should be directed toward obtaining the maximum

possible ammonia removal on a consistent basis. Continued development of operational data

under the varying conditions inherent with refinery wastes will help to improve the performance

of the system, and will allow the maximum ammonia removal capability of the system to be

achieved.

35606003

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EXHIBIT 1

TO PRE-FILED TESTIMONY IN SUPPORT OF

CITGO’S PETITION FOR AN ADJUSTED STANDARD (AS 2008-008)

12461137

ADDITIONAL INFORMATION REQUESTED BY THE HEARING OFFICER

1a.

What is the Design Average Flow for the Refinery’s discharge?

5.79 MGD (H&H Report, page 9).

1b.

Is the far edge of the mixing zone located in the Chicago Sanitary & Ship Canal?

Citgo discharges into the S&S Canal at River Mile 296.5 (H&H Report page 16). The

maximum permitted mixing zone would carry to River Mile 291.5, which is still in the

Chicago Sanitary & Ship Canal 0.5 miles above the Lockport Lock & Dam (H&H report

page 16).

1c.

What is the projected incremental change in the ammonia concentration at the edge

of the mixing zone when the refinery is discharging 10.61 mg/L? Also, please describe

the incremental changes in terms of un-ionized ammonia.

The 7Q10 for the S&S Canal at Romeoville is 1,315 cfs, or 850 million gallons per day

(MGD) (H&H Report, page 9). The mixing zone would encompass 212.5 MGD at low

flow, so the available dilution would be 212.5 MGD/5.79 MGD or 36.7 to 1. Using a

background of 0.65 mg/L for the average ammonia upstream of the refinery, then when

the refinery is discharging 10.61 mg/L at 5.79 MGD, the incremental increase in

ammonia concentration at the edge of the mixing zone will be 0.27 mg/L. This value

assumes no reduction in concentration due to nitrification or volatilization within the

mixing zone, essentially treating ammonia as a conservative pollutant. It should be noted

that Citgo’s already exists, and so the downstream water quality data presented in the

Huff & Huff Report already reflect this contribution.

With respect to the question on the un-ionized ammonia, the average ammonia at

Lockport was 0.65 mg/L from 2001 to 2002, while the un-ionized ammonia averaged

0.005 mg/L (Tables 4-1 and 4-2 from the H&H Report). Therefore on average, the un-

ionized ammonia represents 0.76% of the total ammonia. So when the Refinery is

discharging at 10.61 mg/L, at the edge of the mixing zone the total ammonia will be 0.27

mg/L higher, and the un-ionized ammonia will increase over the upstream by 0.002

mg/L, assuming again no biological degradation or volatilization. Table 4-2 from the

H&H Report clearly indicates un-ionized ammonia water quality consistently achieves

the standards.

1d.

The 2008 AWARE Report states that “[t]he annual average ammonia discharge to

the Canal over the last 5 years has averaged 102.4 pounds per day…” Pet., Exh. B at

30. Please elaborate on the data used to calculate the average of 102.4 pounds per day

for the last five years.

Aware used the effluent data from 2003 through 2007, inclusive, to compute this average

mass discharge. The specific data was:

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EXHIBIT 1

TO PRE-FILED TESTIMONY IN SUPPORT OF

CITGO’S PETITION FOR AN ADJUSTED STANDARD (AS 2008-008)

12461137

Year

Ammonia(lb/day)

2003

99

2004

62

2005

116

2006

139

2007

96

1e

Does Citgo anticipate an increase in production during the requested 5-year adjusted

standard period?

Citgo continues to carry out projects that make the refinery process more efficient, and

this will continue over the five year period. None of these projects will result in an

increase in the ammonia loading to the wastewater treatment plant. There are currently

no plans to increase the crude oil throughput from the current rated capacity. Citgo does

anticipate it will identify additional projects that will reduce effluent ammonia loadings to

the wastewater treatment plant over the five year period.

2a.

Did the petitioners intend to propose that 6.93 mg/L be the monthly average

limitation and 10.61 mg/L be the daily maximum limitation? Also, please explain the

rationale for proposing effluent limits based upon ammonia loading rates on a monthly

and daily basis.

Citgo did indeed intend to propose the 6.93 mg/L as a monthly average limit and the

10.61 mg/L as the daily maximum limit.

The proposed concentration limits when the mass loadings exceed 100 lbs/day (monthly)

or 200 lbs/day (daily) is based upon Title 35, Section 304.122. The refinery is located on

part of the Illinois River System, which has unique effluent ammonia limits that are

applicable only to dischargers exceeding the above mass limits. Dischargers below these

mass limits currently have no concentration limits. As noted in the next question, Citgo

has not consistently achieved the requested concentration limits. Citgo believes it is

important to continue to show progress toward meeting the Illinois effluent limits, and

therefore committed to the more restrictive concentration limits, when the mass loadings

exceed the regulatory thresholds. This threshold is important in the Refinery’s ability to

comply with the proposed limits. While the Refinery has limited control over ammonia

concentrations on a day-to-day basis, it has significant control on the volume discharged

to the Ship Canal. Therefore, during upsets, Citgo plans to reduce the volume discharge

in the short run in its Treated Water Basin, and if necessary reprocess part of this water

until the concentration limits are achieved. This will require a change in the operational

practices at the wastewater treatment facilities, which Citgo is prepared to make.

2b

Please clarify that the limits of 6.93 mg/L and 10.61 mg/L in the proposed adjusted

standard are attainable as expected by petitioners. Also, please elaborate on reliance

upon the 95

th

percentile and whether exceedences above the limits based on the 95

th

percentile are expected.

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EXHIBIT 1

TO PRE-FILED TESTIMONY IN SUPPORT OF

CITGO’S PETITION FOR AN ADJUSTED STANDARD (AS 2008-008)

12461137

Anytime one relies on a statistical approach, exceedences can be expected based on the

confidence level chosen. Again, Citgo is committed to making reasonable progress

toward compliance with the Illinois effluent limits, and believes it can achieve the

requested levels on a consistent basis, assuming the mass limit applicability is also

adopted. As explained in the response to question 2a, Citgo’s operational strategy will be

to hold back effluent water to stay under the mass thresholds during upset conditions.

3.

Please demonstrate that the unionized ammonia water quality standard of 0.1 mg/L

will be met at the edge of the mixing zone.

The monitoring data presented in the Huff & Huff Report already includes the ammonia

contribution from the Citgo Refinery. This request is not for a new or increased discharge

of ammonia. As described in response to question 1c, the un-ionized ammonia averages

0.76% of the total ammonia. At a discharge of 10.61 mg/L, as derived in response to

question 1c, the incremental increase in ammonia at the edge of the mixing zone will be

0.27 mg/L. Assuming the un-ionized ammonia is 0.76% of this 0.27 mg/L, that yields

0.002 mg/L increase in un-ionized ammonia. Using the highest un-ionized ammonia

recorded at the Lockport Forebay on the Ship Canal (Table 4-2 from H&H Report) of

0.070 mg/L and assuming that Citgo’s existing effluent did not somehow contribute to

this value, then the predicted maximum un-ionized ammonia will be 0.072 mg/L at the

edge of the mixing zone, compared to the water quality standard of 0.100 mg/L. Again, it

is important to note that ammonia is not a conservative pollutant, it will both degrade and

volatilize as it travels downstream.

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