1. B. CWLP's Adjusted Standard for' Boron
BI:FORE THE ILLINOIS POLLUTION CONTROL BOARD
IN Tf-IE MATTEI{ OF:
PROPOSED SITE SPECIFIC
RULE
FOR CITY OF SPRINGFIELD,
ILLINOIS,
OFFICE OF PUBLIC
UTILITIES,
CITY WATER, LIGHT
AND PO\VER AND SPRINGFIELD
METRO SANITARY DISTRICT
FROM
ILL. ADM.
CODE
SECTION 302.208(g)
)
)
)
)
)
)
)
)
IZ08-
--,-~~-
(Site Specific IZule -- Water)
NOTICE OF FILING
TO:
Mr. John Therriault
Assistant Clerk
the Board
Illinois Pollution Control Board
100
West Randolph
11-500
Chicago, Illinois
I
(VIA ELECTRONIC MAIL)
ILLINOIS,
OF PUBLIC UTILITIES,
CITY
WATER, LIGHT
POWER
SPRINGFIELD METRO SANITARY
DISTRICT,
Date:
nus flUNG SUBMITTED ON RECYCLED PAPER
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
BEFORE '11IE ILLINOIS POLUJTION CONTROL BOARD
TN THE MATTER OF;
PROPOSED SITE SPECIFIC
RULE
FOR CITY OF SPRINGFIELD,
ILLINOIS, OFFICE OF PUBLIC
tJTILITIES,
CITY WATER, LIGHT
AND
POWER AND SPRINGFIELD
METRO SANITARY DISTRICT
FROM
ILL ADM. CODE
SECTION
302.208(g)
)
)
)
)
)
)
)
}
ENTRY OF APPEARANCE OF KATHERINE D. HODGE
Kal11eI'me D. I-lodge, of the law finn HODGE DWYER
L,Ll'nr,l
and hereby enters
appearance in this matter on behalf of City of SpringfIeld, Illinois,
Public IJti
, Light
Springfield, Illinois
(217)
-KDH
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
BEFORE THE ILLINOIS POLUJTION CONTROL BOARD
IN THE MATTEI{ OF:
IJRUPOSED
SITE SPECIFIC
RULE FOR CITY OF SPRINGFIELD,
ILLINOIS,
OF
PUBLIC
UTILITIES, CITY WATER, LIGHT
AND POWER AND SPRINGFIELD
METRO SANITARY DISTRICT
FRDM
ILL. ADM. CODE
SECTION
_?'Jk,
.;"'IU\,
pc,
)
)
)
)
)
)
)
)
R.08-
,~
~_~._.~W.
Specific Rule - Water)
ENTRY OF APPEARANCE OF CHRISTINE G. ZEMAN
NOW
LA.llHl",
of
law
finn
HODGE DWYER LoLl'.•
nl
"PI"'"''
enters her appearance in this 11latter on behalf of City of Springfield, Illinois,
and
2:iprll1gtlelCl Metro
"~ll1lrOln!
Date: rUll"U;:'t.
Christine
I-lODGE DWYER
L,L.IY'!>
31
Roland
Post Office
caz
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
ILLINOIS POLLUTION CONTROL BOARD
IN THE MA'TTER.OF:
PROPOSED
SITE SPECIFIC
RULE FOR CITY OF SPRINGFIELD,
ILLINOIS, OFFICE OF PUBUC
UTILITI
CITy.' WATER, UGFTT
AND POWER AND SPRINGFIELD
METRO SANrrARY DISTRICT
FROM
ILL
ADM. CODE
SECTION
302.208(g)
)
)
)
)
)
)
)
)
R08-
._-"~----~~--,-
(Site Specific Rule - Water)
PETITION FOR SITE SPECIFIC IHiLE
NOW
'-J1Y.ll_'J the
ofSpri
.. .,r,.",., Illinois,
of Public Utilities,
, Light
District
("I)istricC or
tenns
I..
PROPOSEI)
SITl~
SPECIFIC RUI,E
PetltlOIlers arc seel';.ll1(! a
to estilbli:sh an alttTnativc water
quality st'1lllCl'11'(1 for boron fron1 the point ofdischan!c at Outfall
rcaltment Plant ("SDrIlU!
Planf') to the Sarlyarnon
to
,'.r,..
dl. '"''''''''
with the Illinois
in the Illinois
100
Ill.
at SectJon
stmldard
to
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
~~"'-~"
the Board
not adopted an eft1uent standard t()r boron. Similarly, Illinois
Environmentnl Protection
("JEPA" or
not imposed an eftluent
limit for boron
nt Outfall 007 in the District's National. Pollutant Dischnrge Elimination
CNPDES")
PCTlnit
35 Ill.. Adm. Code § 304.1 05.
explained HJOre fully bel.ow, this
Specific rZule tell' an alternative water
quality standard tcn" boron is
to enabl.e the SMSD Spring
Plant
to
a Drc:treate:d industrial effluent stream ll'om CWLP's power statiOl].
Operation of the air
pollution control C\f,'r,"I"'c
:H
plant causes eleyaky! COilcentrati()ns
Plant
p18nt is a critical
supply
boron
in a plant cft1uent stream that is proposed to be translen'eel to the SMSD Spring
the City of
II
1,'p"1111"'1f to
IS nel1ll1er
lpl'!1nlt~"
I>,,",>LU'>,. nor econOlllllc;all
clo
'
,vn:31rc'am of
ctCI11011stl'ate that
to
\v
hich the U IJl U'i';'
Plant etlsctlargcs,
to
in the Illinois
n!tl::rnatl'ves to
Slg.l1ltlcant e,:'OllOlme Imp[u::t on
(((llmlle
Ii
III
waters (Jmvm:tream
clls:char,t~c
or
n,.,,',.;!f"Ut"
""'VA,'!
on
current use
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
proposed, the Site :Sm:cItI.C Rule
'-'"I"V0''-'-'by Petitioners would provide as
:::;e(~tlc)n
303
Springfield Metro Sanitary District Spring
Treatment Plant Boron
The
use water quality standard
boron set forth
in
:::;e(~tlc,n
302.208(g) shall not apply to waters of the state that
,'1"("01\10
Cl'ISCl.JarJ!;C
from Outfall 007 of the Spring Creek Treattnent Plant located at 3017
North
8th
Springfield, Illinois, O\vncd by the Springfield Metn)
Sanitary District Boron levels
in such waters must meet the water quality
standard for boron
as set
tenth
in this
"""Tit''''
1.
11.0
within
River
fran] Outfall 007 to 1 yards doV'mstream it'om the
confluence
with the
River:
in the
"'''''t''''''''''
waters
the
arc eXIJeetcct to
L
STATEIVIEN'r OF FACTS
stations" rc:tcrrect to as
a j)Oltal>le water treatment
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
gCllcrate CleCtrilCHY for the reSlClc:nts
anclIJLI~ant;ss(:s
m Spl'mgti<eld and provide potable
water to Springfield and surround
conl1mmities, Approximately
1
people are
employed at the power gellcnltmlg stations and an additional
19
people are employed at
the \vater treatment plant. The nteilities are '"''1.1-'''tV\lenty-tour hours
day, 7
per
I,
p,
I.)
CWLP's
Dallman Power Station
an electric (f<"1"I""c,h
3
111f'o-:1\V"lfrc: and is comprised of
units were
into
CC"'\T',"p
in
1
Units 31
coal-tired units: (Jnits 31,
and 1
and
The
D~lllman
are
identical, each having
cvc:lorte D()llCrsin Units
31
[\n,~t"lf'",
at
1
to all
111
currentl
y
OJ)lcralCS
dud
the ozone season
1 through Septe'ln!yO'
to
remove ant1rOxnnat
cmISSl'Cl!1S at
Dallman un
The
II
ve~lr-J,'oUIll(l
opi:ral"lOllS in July
to
in control
1, p. 2-1.)
3.
5,
seven ttlrlYHllC
m"nl'.!',',l!'nrc:
7
nre Wc:ntlcal
4
6
\vent
opc;rallon in
I
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
Boiler Turbine 7
operation
in 196.1 Both units operate at 850
and
The
Power Station
will be retired in the near future. (Ex, 1, Pl'. 1,2.)
4.
Total coal consumption at the eWLP facility
"Vf,!·",'r,~"
L I million tons per
The
ash h::mclling practices at eWLp are typical for a coal-fired power plant.
Bottom
ash and fly nsh £iom all
units are sluiced to ash ponds. The raw bke
\\Inter
icing is obtained fi:om
Thrce SCtJarate
once-through cooling water ,'",;"pn,,,
transport ('\le!p,!",,, serve Dallman Units
31
and
3
Dallman l.Jnit
and L(ll''''',)iIU''''.
5.
. I,
p.
{''''''''!'''lh~(
two ash ponds. Typically, the Dallman tly
and
water is pumped to
north
pond, which
is commonly kno\vn as
n"""l'j"-'~
waS\eW,lircr treatment
it into
fi
dl~;cll,ln~cCI
to
west !X)rllCHl
1111scc'll.ane()us \-vater streams
plant
,-,cc"""" mCluClIll,R the
effluent water.
ponds
but
CIC!JCnO jJlnn.(:llJ,\!l
upon
1, p.
6.
reten'ec! to
4 is current!
a
a steanl tnrbme-£!.enerator
a nOlnl11aJ
new
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
technology and the
t~}llowing
air pollution control systerns:
seleCLlve catalytic reduction,
a iitbric
fi
lter, wet nue
desulfurization,
nnd a wet electrostatic precipitator. Dallman
Unit 4 will util
a dry ash handling systenl.
1, p.
.)
7.
CWLP's water trc:all.nent plant has a capacity of 4l:? million gWIl.OI1S
day
("MGD"). A
convcntionallime-sonening/filtration/disinfection
DrClce~)s
is employed to
produce potable water.
in the treatment
''''(',,~p,;.(.
remove
particulate matter from the raw
wnter. Thickened
on,,,.',,.,,", from the
!lIters is
dI.SCIHlI.·g(~(j
to
panels located north
Spaulding Dam. The volume of
and l)a,c!\:\Vm;!l water
(1I~;c11arj:;cc1
to the
pond
is dependent upon production vOlurrlc and raw water Cll:lraetenstlcs.
) is
ttl
IS
.)
impoundment of
"'F',Ll,,", "",
a
Ll.!.!4-;HTe
1',',",",,\''''''
COllstiructed in
I
is
the ,w,n"tj"\! source
and
streams "nHill1O
streams
6
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
the FODS efnuent watc'r, !lows into a clarification pond, which also provides
and
neutralization,
it l11SCI18Irg(;S into Sugar
(Ex,
1,
pp,
B.
CWLP's Adjusted Standard for' Boron
CWLP's NPDES Permit IL00:24767,
5. :2001, reglJlav;:s
16 olltfalls at the CWLP LlCiJity, OuU:l11s 001 through 011 apply to
discharges at
CWLP, Outfalls 012 through 016 apply to St0I111 water runofflhHn
industrial
L?',)'-ll"IF~'-
from Outfnll
all others (/ls,cl1arge
CO[ISlstS mainly
potable water and raw water
Out1:1I1s
004,
016 (ils,cllarge into
collected
\r'\l"">11C' equipment drains, floor drai ns and roof drains at the LlkeSlCle
IS
through an underground
at '-,n'llIlll!
contact
ill
~IC('UnlU!;,lr\(ll1S
llin
to
ni~",nlr
limit
COll1])llaJICC to be
1L)
10.
On
a petition with
an
at
Ut'(:cmbcr 1, 1
an acl \Illst(xl sranoaro
Is
7
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
compliance was reaC!lt:C! with the
H"r',~l'ql
water quality standard of 1,0
Tile
adjusted standard included an alternative water quality standard for boron at a point of
discharge from SMSD's Spring
Plant (Outfall 007) to 100 yards downstream of the
confluence of the
,,,,,,,,,,,v,,,
River with ""'11HT
Thus, an alternative watel'quality
standard
boron already applies
to portions
the 01f1.'j"",O,{.' waters at
this
Petition, as follows:
of Springfield, Office
of Public Utilities,
and
(CWLP) facility which
to
100
downstream of the
tIle
River with
in the Northeast Quarter of Section 10, in Springfield
;-:,arlgamo,n County, is hereby granted a partial adjusted
stancl;:lrC! from
ilL Adm.
304.105.
to this
III
Adm.
304.1
not apply to
from Outfalls
and
"'."'",'(kboron
than or
to:
and
(Ill
1 1
8
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
boron standard in
11.
Historically, CWLP has been able to An,r"""'!", while meeting the adjusted
air pollution control systenls t()r
NOx removal were added to the three Dallman Units in 2003, CWLP
had difficulty
complying with the adjusted standard
boron
in
during the ozone season, from May through SeptemlJer
cOJ.1CentratH)nS 1'1'0111
operation results in
Apparently, trace ammonia
ncrCaf;C(! leaching of boron and/or
'11{'IY';;Ci,,[j boron solubility in the Dallman Ash Pond, 11,("'.,,"'('1
boron
to tbe
clarification pond, The ll1crea:seCl boron
from the Dallman Ash Pond are below the
adj
hut when
boron content of the FGDS blowdown is added to the
c!ari
at Outhlll 004 cxc:ee(ls the '),If! wl',,.,1 slaMarCI
III
trace ammoma {'.,'''....nIT''1
h
it
is gClleratc:<l
pollution
('1'>1,
fT.',! equipment and is not assoclateO with the fly
1, PI',
11 12,)
C.
Proposed CWLP
Di.scharge
to Sl\1SD
12.
CWI-I)
l~l'{\n'\"{"Q
,Ill
cnlue.llt water to the
wastewater
treatment.
\vaste strcmn is
estnnate:<l to
rate
m
or
9
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
water fhml Dallman Unit to
3L
and
and
Dallman Unit 4. SpecifIcally. CWLP
nrCll)oses construct
two
';"'''c',''''J\/
Ion holding tanks and a ClairCone
Ttvl
solids contact
c1aritjer, with a
240 gpnl capacity to pretreat the waste stream prior to pumping
watcr
to the
Plant
treatment. The ClairCone™
is
Cle~)lgllecl
to allm\'mixing.
11occulation,
and sedimentation to
place vvithin a completely hydraulically-driven
The conically
Sll,LDC'(! concentrator n1-'V"\'\1
the FODS blowdown ClISCtlarge
boron concentration., but will
conc(;'ntration and allovvs pL:mt personnel to visually monitor
nn>tn:;ltlllcnt
is not eXllccted to
b10wdown dlscll'lrgc.
Plant.
Ie
to
12.)
I ,
It
JIallClll:;'s wastewatcr
storm watcr
areas,
Plant were
COllstl'uctect
in1
, (
1-1-.
l, p,
treatment
10
nIY'>\!1[ 1("<;: treatment
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
removal of biological
demand
("BOD"),
total suspended solids
ammonia and bacteria,
and
the f()llowing !1win unit prClce:sses:
1.
Screening for
solids removal;
2.
Grit removal for
sand and
3.
4.
5.
Prinwry clarifiers for
"'~".'''';[!1''.''
solids and biological matter;
AeratIOn tanks for the main
treatment 1'11'('\('(0',::",
6.
7.
Disinfection. perG)nned on a serlso,nal
mgesllOll to
through
! .
R
at the COlllltlelll:::e
concrete
cllscl1C:lrgl,ng into the
in the
dl~;cllarJ!e
IS
(c1s)
or
c1IScll,arj1r,C is 1
d:) 01' 11 1
11
I,
"ecnOI1
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
Eo
Spring Creek {'Iant Oneration
16.
The Spring
Plant operates
hours per day, seven days per week
The Plant
is staffed by
7
full-time operators from
7
a.m. to
11
p.m. There is a separate
Jrwintenance crew on
8 hours per
5 days per
It
has an ,i\/l"!'"cr.'
capacity of
MOD.
Monthly
in 1004 through 2006
to peak
O\)W over 50 MGD. The uvc"."-." maximum now
the plant is currently
MOD. which
is
than the 1005 peak of 49
tvfOD.
but 49
l\10D
puts the plant at
percent
maXlmUln
Ca!)(lClty
I, p.
17.
On
low flow
of the
f\.1GD. A
15.)
!{)r
treatment
to
Plant
N
11.0021
Pennie), in 1>1"1.1\.'''''',">.
L
there will
are
led in
a new treatment plant
to
1l1creascc!''''''''n''''ICc,q)(lclly
COI1Sli:lel';cltl(Hl to
. I,
18.)
1
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
19.
Based upon the 2006 plant inJ1uent data, the CalCi)Cll1acc<)us 13005
11'0m I
to 114 milligrams
mg/L The
eBODs
removal after primary, secondary and tertiary treatment is about
G)r an
~U('I',H"~
emuent
CBOD
s
of approximately
3
The
concentration
a range from I
to 307
mg/L
2006.
\Vith
a removal rate of over
(ll<::~('1)'l1'C("
to the
t'I"('(~11Jln(r
stream had only
on
~\I('t',ICI('
18,)
nitrification, """'I,e;! operational
L1stments to
able to meet their seelsonal
req[UU'emlen't.s
1~)r
a reduction of ammonia from el!1 int1uent
the plant, the SMSD
aml1llJlHH
n
II
ni
nl',,"'-"" Ii
recomlnct1c1(:;(\ plant ImiPl\)VCltncnis
I,
p.
21.
is ne)t
Plant
into account P!1I)SIJ'!lorus t',,'l'!l,'\1P)
1,
p.
2-1
F.
wastewater
I
(,,~IV11'i"
Plant
from a
uen!
plant on
,HII'I'''(,,~
at a
. I,
p.
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
A current plant influent boron concentration of 0.25
was
as
background to calculate the new concentration with the
wastewater
included in the
Henv steam.
on the 7-day low efOuent flow of 11.31 MGD per ISWS, combined
with the FGDS wastcwater at 0.27
MGD
added J]Cl\V and a boron concentration
450
the maximum boron concentration of the Plant cffluent would be 11.0 mg/L.
It
is
anticipated that the
Plant
treatment
nf·(·\{'.~,cC'
will not be c'\o'nnu.".',nn
by or ,;,(1
'UPI"<:'"
1
and l'I,."',,di,,.,.,the diluent boron concentration is eXi[)c(:tccl to
conccntration is estimated to
11.0
mirror
inlluent COII1Cc:ntratllOl1
'lhus, the Plant's typical
(.>i'I·lfl,~,!'\t
l1Jaximum boron
boron
COII1C~:ntrat1lon
downstream ill the
IS
cstHl1at(~c1
to
. I,
p.
19,)
tel
to Ineel cOlmpl\lallt
was
the
I,
p.
C.llistorv of CWLP's Bonm Mitigation Efforts
l.
start
11. )
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
Subsequent to a
mC~ellI1,!!,
with IEI'A in July 2003,
eWLp
committed to
further investigation of the
chemistry and interaction of the constituent waste
streams; it investigated the component eflluent streams of Outt11 11 004, to identify the
nvcstlgzltlcm demonstrated that the
streanls with high boron content.
eWLp
H3nson Professional
-..:,~"'"
..,'>"
Inc. (
both
inten13l resources and those of
to conduct this investigation. The
blowdown, or the scrubber return water, which
IS
np",C>""1ti"i!
fi'om cle-w,atenrlg the scrubber solids (gypsum), was
a
primary culprit in
waste stream.
b]owdown is a means to remove chlorides and
cOlltanUJ.l<1I1lts that
buildup
cause a
,Y, fTC, " ,
p
a
I). eWLp \','c'\v,nlf{v!
to
2004. In
In\/estlgate the causes
the boron ex,ce(:;(fzlJ1ces,
'-'.J':lLl1ll1\-
to
waste streams
\vith
In op(;ratwl:l,
ozone
St~aSOll.
(In
II,
to f)reScl1t a
to
15,
it rnet.
15
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
CWLP submitted findings to IEI'A of additional investigative sampling,
which confinned that a highly significant contributor of boron to OuW1Il 004 was the
FGDS blowdown waste stream, or scrubber return water from the gypsum de-watering
Around July
2004, C\VLP pw,poscct to IEPA a
nllJltl-D1'orle~ect
approach to
solvi
the boron eX,CC(:C1
induding a proposal to
C'IHYlI1'('I~t'
and
"V'c",~,H
a
the
wastewater stn::an,1., with a
operational
ozone season, but
C'WLp
,'ilc',v,,,,C>''',c.dthat
to the complexity of the cl1emlstl'Yof
waste ,""AU", irnp'len1erl.tatlOl1
to
ozone season.
additionally in
to
"'''',hl\'l.''''
wastewater treatment
A
identified potentlal
ree,ommen(t(~(\
to CWLP to
treatment
wastewater
wastewater stream,
to
the wastewater treatment
In
Uecel11I:H~r
contract
wastewater treatment
The
was:tcwater stream treatment
a
16
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
evaporator, ,','1,''1',',''<1
to as a Brine Concentrator
Vvhich was designed to boil the
liquid down to
a
concentrated salt-water solution, The nl',\(',"'O<,
l~nl'l'(f"
would be
developcd by four vapor compressors tbat consume 550 horsepower each, The
Dryer ("SlY') thnt
would
solid salt \vould not be included with the
to a landfill. Ninety percent of
C0l1centratc:c1
""'1It',u"f{~I'
would
sent to n ''''''
.. 111'1'11
convert the solution into a powdered salt
but instead would be
to
",",'H,',I,,,,I
In '<"''-'<'0plant prClCe::;ses.
with Aql,wt(::ch
could
while
''''''i"\u(>",,'t!that the Aquatcch
~'\":I,",ln
31.
In F
on
cV:1J)()rarco water would be COillc!l:;m;cd
a prc'tn:atrnerH ,,':;<::t,C.," to rcmove
to
In April
to
extent
annual natural
costs
a
C011S11Jer'nLille
(>vn''''H'~''
and it was
difllcult to find
rcmoval plant
In ;::,c!nc:m
as the cnJ:;m
,
;;erlI1J-' nl'C)!![cssccL it Llcc:arrlc almat'ellt that
usc
waste strean1
be
nl'CHel::t on a
not
to treat an
IV;:Ic:;If>w:'ller
streanL
\vas
17
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* * * * * R2009-008 * * * * *
relatively low e).;pertise in this area, such that the
changed
as it had been
engineered, and
project
was considered a pilot project. For
,~v'''n''',~
the equipment,
typically uscd
cooling tower
blowdo\vl1 treatment in combustion turbine power plant
applications, was
a much different application due to the heavier
,,,.,ce,,.. ,,,!. in the FGDS wastewater stream,
''''''"
\!!.• , , solids loading
CWLP initially
1 to 2
anhour to
of
the waste byproduct material out
the spray dryer, but soon
learnt~C1
that
makrial
minutes. CWLP then considered a
'V,,,,,,","''''
to unload !l1(:re;(lse.t1 to 2
10
truck trailer
1"('lnnV01I arran!sern('llt'
were
that the number
ex,:;cs:Sl\iC costs in tmcking and landfill
to
had not
to
ClnllmlllC cost es\;al::ltH:ll1S and opera
lInig
the
the
COllCelltratccl
waste stream out
to an eV::!f)(JlallO,n
('(Hl<:t'I'II,..ted
in CWLP's
lC:lrtlt:O was not reaSlDlC
n,ll!linn!
bui
S1
anprc,acllCS tel
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
tbe complex problem, submitting the idea of using the
i)pnn~~
Plant as an
alternative method
fT".,fl,,;(y the FGDS bJowdown stream. CWLP retained CMT
to
review this alternative; thereafler, CWLP determined it was in the City's best interest to
further {,W"!."",, this option,
I ''''''''U'ie;
with the District numerous times to discuss it.
n.
STATEMENT OF PURPOSE AND EFFECT OF PROPOSAL
A.
Nature of
the Receiving
Stream
L
Historical Flow,
Receiving
III
and Boron Concentrations in the
\\i;lf'i't'"lll'.(j(',(1tllnrt"""" approximately 5,419
it
on
as
the (Icepest
PCHtlOtL
1,
3-2.)
<Olll";,,'\( in
ndL
the (WtH"!"ll le'atures
plant
(\1~;C!lar.£~e
,,11()\,J('(I
gr;Jidl(~I1t,
mean(lenng stream.
the
the
aDllears tel
out a wider
III
are a source
19
!"('(\!'r!ltl0'to
I!
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
Streamflow As:sesslnent I"fodel (tSWS, 2007) the mean 110w at the conl1uenee with
Spring
was 120 efs
the
period from
I
to 1997. During high now
periods, stream dlSl211acge can exeee(! 7,000
at this location.
(Ex,
1, pp.
6.)
,,,,",,,tt,>(, into the South
of Sangamon River four miles
east of :::Jpnngllelc! and approximately seven mIles
",u"""""',,
of OutLd Is 003 and 004 of
the
CWL~P
Plant Above
Outi1111s is the
(',,,II,,..nr
ft)r op,ll!l,(Jmg Dam,
IS a
of pools
n.
and
is primarily the outflow of
Springlldd.
and
2 1
below Spaulding
Dmn
OUtt~lllS
OCU and
plant,
n"""l
,<t.,,, the dlsl2l1arge flTlm
the SivlS[)"s
which
is
10
T'he
()
fruIH
River at
in
Jand.
41.
from the lEPA
f'()r
stremn CllscIlarge
nnen(!lx D,)
COl1.CentratH)nS over
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
ex(:ee,ctect the adjusted standard of
boron, with 0.394
the mean
concentration at Riverton ii'om 1999-2004. (Ex.
1, pp.
3,4,5 and 6.)
2.
Current
'V~lter
Quality GeneraUy
condition
four stream
se~~mc~nts
of the :::lallgamCl!1
at
(12-26), the :::laJng,lIncm River
to Richland
to
the
:::lanigarnon
from
that
aU
four are included on
2006 ;:)e(:uo,n 303(d) list: the Sangamon River
from the South Fork
the :::lallgcl,mc1n 1Uver to
the
:::l(1]lgamon River from Richland Creek
to the Illinois Riwr
I, p.
segmems are
as UllIJClI''-''
from
J)01tentHil sources
so mec cl!scll,lrg,cs,
treatment s
v~;telllS.
or impounchnents,
1, pp.
Aquatic and Fisheries data
1L)
nre
taxa
21
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
stream conditions and watcr quality; high values indicate a
Cle.!~nl(Je(j
stream and
reduced water quality,
(Ex. 1,
3
The
lEP
A in cooperation with the IDNR conclucted Intensive Basin
the
in 1
and
. IEPA conc!Uc:ted
ncar Riverside Park (E-50) in
in 2003. Exhibit 1, Table
provides the
nUlICl,()IllVel·t(~lm1t
sampling at Se\/Cr,]/ Sl.allons, including the :::iarlgamon
but
to
SPC~Cl~~S
from the :::iaJ1gamCIl1 River statL011S during the
16
tocatc'(j at
Illinois,
COll11JIJellCC with
;::,allgalHcln Ri ver.
not
Ii
use.
1score, eVII.denclng
,,,,.,,,,,,
of
I,
p.
13)
were COllctllCtCX!
the
I[)l~R
in 1
'"'' fT,'"''''
Slat.lon locatcct at
lIti
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
upstream of the South k'u'I..!'-':'"N"
conHuence with the Sangamon River.
I,p,
17.)
The fish species collected at the
~atlgamo,n
River stations were common
Midwestern streams
".~I.,)t"t.~
to stream
and none are
n"I''',~'1j
on the state or
ontlte
were
mC)(!CTately
while the station at
Oald~ml
in
on the IBI scores, the
sampling dates,
the
~~lllgamcln
equal.
statlol)S were relatively equal in
I
RIB!
scores,
impaired
aCltKltlC lite use
(t~tir
quality 1"1,,1111"'11""
L •• "l.",,.q
I. eni:talllgereCl or threatened SIH:CI(:S list. The total number
fish and the number of
Sl)(:CH:S collected were
,'"lcdj".~1
an RIB! score
In(llc,ltlrIL~
full "'")1111,'1
use and
resource
RI
.}
I "'''U''1l
01' Steam
llve..cal,cgicllY ",n,,,,,, til
I'll
!!I\,
publication
(l
IS classltlc'C[
~tre()lns}
which
a
'1"1C'lh,'I"\1
Ci)nSls1lng
L
p,
I.)
usc
recre(l,IIOnal resource
R
con,(1uc,'tco
to 111:lilnlm.n
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
The
catfish
01!1'V,"',V determined that channel and tlathead catfIsh populations were
robust, especially at the
Section
3,2.4)
lVC'f";'I(ff> Park/Riverton sectit..m of the Sangamon River,
(Ex,
I,
51.
4.
Threatened and Endangi::red Species and Natural A.rcas
Information from IDNR on aquatic threatened and endangered
and
natural areas of
::::;an.\2a11'lon River fl'om its conl1uence \vith
South Fork
of the
::::;al1g~l,m(\!1
River to the
III
River\vas
The Illinois Natural Heritage
the lake
chilt'n"'"n
a state en(]al1lgerco fish which inhabits
and
III
a state Uu'eaterled fish which is
Il1 bOlttOl111
in
In
area,
aOIJCarS to
a
I, pp,
B.
Toxicological
E~
is an
cl(~mi;:nt
rOrll11,;nt, and is
distributed
watcr
all
very
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
IU".UHUV'.J, source of boron to
aquatic environment is coal ash. Many cOllunerdally-
mined coal seams contain signi1Jcant concentrations
of boron. Of the total boron in coal,
most may be lost
to the atmosphere upon combustion, though more than 50 percent of the
boron fClUnd in coal ash is readily \vater soluble.
I,
pp.
1,
1.
Toxicological Effects of Boron
As
'-'AI,
"Ulll',U in Exhibit 1, 0C(:no,n
the
nnnHH'\f
potential "I.J""'"
boron concerns
of aquatic SI),:':CICS.
For eX,11l1pte, the
as a
D
Clcillerlt, m,Cmllllg that
is no human
mllnHll
(C'Vlileni',c
of boron
cm'CUlOj:'~cnlclty
In
111"nl1I1H\
n
to
I
hi
.)ltI\.II\..U In
.T
m
it
it was
blood within one day.
some
S\JCiC";S
fish
In mosqlllto
are
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
and bluegill, though one study reported an
11
of a spe:ClC:S oflargcmouth bass. (Ex. 1, pp. 5-4,5.)
fish SI)(:CI(:S such as the largemouth
day
lo\'{eS[·Ol)s(~rve(l-·enee[
eoneentration ("LOEe") of 12.17 mg/L of boron for Il'eshly
fertilized
tre:slw\rat(:r a(:IWllIC
\I,~,'h'I·\t""t.'",
applicable to the SatlgamO
I
!1
River and the lllinois River are
summarized in Table
I
of Exhibit
L
Amphibians res;pone! to boron at COllcentr:atl()JlS similar to
for
While some boron compounds were 1l1Ulld to be more
adult alnphibians,
no
on
(Raila DilliellS
I~lll,.n!i
,<.: srltter,eel
100
or tcr;:lto,gCJlCS1S in watcr I ,,?,r,h,d with boron COlnp'DUIlc!S at
boron was applied, while 10')'''"'[\
to
II
CIl,'nlY1'.l1'l'7prl
III
III
oceurs at 2 to 5
as
and nut trees.
usc
the srtll.gamon
at
in thi
at "'U'",,,,c C()l1C:entratIOI1IS,
or OUtalllC
a
,lPl)ll,::alJtc to
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
an:l!;aIuon River and
Illinois
are sUll11uarized in Table
I of Exhibit L
also,
1, Section
2.
No Anticipated Adverse Effects to Aquati.c Organisms
Boron
on aquatic
are highly
and
and
environment.
':)lUlllH~~S
shm\' that
are more
nv~;stlgatecl,
the early
life
aj):De~H'
to be most
",c,,-, "
.I
1\ 1<' to boron than later ones, and that ,c,tl 'Y\11"
<;::1
1,,'1 ncr boron in natural water is
than in reconstituted lab water.
Of
the
SD{~C!(~S
and
",,,,,,.d1\IP to boron. Trout elnbryo-Iarval
to
exposed to boron in natural water courses
reconstltutc;(j lab water. \Vild, healthy
contal!1lmg 13
A
not
IS [1l0C01IC(;nlr'atc't!
by ",-,"'"1'''11'''
in water.
L
:sectIOn
was (fj"';,nII't1 an aclllusl[cc! stream swnWJrcr for boron in
1
no
clctectal)le
de.gr~lclatlcm
an
aqlJatilC
c,:::m;vsllenl.
not
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
downstream, or by the maximum
Likewise, the III
Rivcr
anticipated mnxinlUlll boron COI1cc:ntll',ltlon
boron concentration
11.0
mg/L in the area
biological community would not be observably
<H"~'-".~'
by the anticipated maximum
boron COllcc,ntli'ation
60.
1,
pp.
16, 17.)
note that the Board
water
"",'>1.1" sl:anclat-cl
t()I'
up to
I
16, I
Il
was grantc,cl
an
out
c.
61.
LP
ovcr the
cle<:aC[C, pumping CWIJl'
wastewater stream. to
Plant is
wastewater stream.
Altern:atJves to
the
rate
a boron
eOllccntl'atlon
notes
are
no
wastewater stream
a
1, p.
LJ
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
fically, CWLP has CO:I1S1Clell'eCl tbe follO\ving:
•
Conversion to a dry ash <."CT,.""".
o
however, the FGDS wastewaters proposed fix transfer to
the SMSD Spring
Plant are generated by the air
pollution control
and \vould not
be elirninated by
modifying the
plant ash handling
although
the new Dallman Unit 4 will include dry l1y ash and bottom
ash handling systems.
o
Burns estimated that the installed equipment cost to convert
all
Dallman units
to dry
fly
ash would be $10.2
million. With added operational costs due to additional
equll:1ll1l:nt and operations, along with '-'-"''-'-1'-'-'
(!lsposal, Burns
the 2005 net
value of
1'I1n",~I",,1(\n
to dry fly ash as
$1
million, with a
net
of
million,
vi'hich
not ... rt,,,-.,,:,,,
pollution control
Sv~,tcl.n
m
Illinois
•
of
fromFGDS
o
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
o
Burns fClUnd that chelniea!. precipitation would be
ineftecti
ve because of the relativcly lovv' concentration of
boron compared to its solubility in the wastewater stream,
L
pp,
5,6.)
L
Brine Concentrator ("BC") followed
by
Spray Dryer
Mechanical evaporators that ""'1\"",.,1,,,
recover water from the
wastc\'v'atersolution, the most commonly
use
a vapor COll11JreSSOr to provide a
to
wastewater
\vaslewater
f()J'
relle£1:tlng the w£1stewater
which
is
mounted tube bundle.
to high
is 1l11fcctcd. 1.""/"-'" behind
I,
pp.
Burns concluded
to
(lC(~OllnmIO(latc
periodic m,lll1terlance,
Cit "Il"JU in the
in(~0I11in.!2,
wastewater
How
dual
of
would
50
pen~ent
the maximum caj)acnyrecIUll'('(\.
had a
cost
1,
p,
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
2.
Reverse
Osmosis followed by Crystallizer and Spray Dryer
65.
Bums
considered an RO
as an altemalive to the tirst
treatment, vlith mechanical evaporation
to concentrate the wastewater. Here, however,
due to the high concentrations of
il1c
<cnlu''''ilconstituents in the FGDS blovvdow11
high
is impossible due to the
and the
"""c'('1""~
limitation of
commercially
RD
Burns concluded that L,ei::aClse of
DS blowdown, including high suspended
ids, pretreatment
1, PI',
COI1SIltU,cnts, it was
rl,~t'''''''lt·,<"·d
al
of the
HERO is
the HERO, thc
pat,en\(;(J high-pH
R()
",te'",,,
t',~""",!"-,,
is
lilnited
the OSI1101IC DrC:SSllre.
the
!'("C,',\!,:"'I'V
an
COllS1(lcn~(t
a
H
crysta
1:1
iZ,:T IS
more eX!)CllISI'v'e
included
the
IS
if,.""
,"'-'"
,u
and consumes
cOlnmments
to op(;rate,
Crjist,llUZeJ is much
31
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
the spray dryer. Burns opined that boron removal in FGDS water
a lime/soda
softener followed by dual train
IIERO <;:\1"1"-'111,, had a capital cost of
120,000 and an
annualoperatingcostof$l,118,649,
(Ex. Lp. 6-8.)
values represent 2005
dol
This report
fkantly undCl'cslnrlat(:cl the capital and operating costs
the
option, by as much as
times,
3.
Electrocoagulation
In
to a request t!'om the IEPA, Burns evaluated boron ,-,,,,,,,,,,,,1
"t".tln',, oft'-,'."hn"wastcwater with eleClrlclltyto cause
contaminants
to [1C'COI.l1C
([e:staIJIlIZ(~(1
and precipitate, ""'lh''''llllf',of metallic electnJdc
thin
<tIlItc".'"
~1)cl\..C;~,
But
a(I~~On)tlcln
on alurninum uU,,'-t,t,nlll.)
,'Pl''''''fpt!to
only
aV2ulalJle boron.
both
which exist in
wastewater in high C011C(;ntl'allons.
1,
p.
.fically
m
waslewater
IS
tlr'nl"t1Il.'.111
S])(:CH~S
ill water,
to
is diil1cult to
remove
rnost
wastewater
1, p.
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
7 L
Burns opined that removal of boron in FGDS waskwater would requirc a
capital cost
$9,207,000 and annual operating costs
$14,074,000, concluding that
economically,
is not recommended fCJr FGDS wastewater due to high capital and
operating costs relative to low boron
enlclcl.1\;leS, based on assumptions
extrapolated from
StUlc!I(:S pcrfcmncd on wastcwaters much different fl'om
wastewater.
boron removal
(-,t'j"(","I1("\1
cannot
predicted due to
boron ",'W,1(,\!'lI etrlClI:nClCS in high boron and high
such that boron
PHII'II'nl"\!
IS eXIJCctC(! to
dramatical
from tl"""""'.",h",.1! cstunates
due
to COll1J)(;tlrll..!,
rc~aCl]OllS
in the
I
p.
10.)
4.
Boron Pilot Project
!\cluatcc'llto
appllcat.lOn
that
",,'''I,'oHlinn
translated into
\IV,~l''':,U
'-"(.tIl,;";"" as
Additionally,
and
!'lI,:(:aU1C too high to
I1n'\I'("i"(f
\vith
was atnll1c1lonc:c!, the capital cost h,ld
to
ntenancc cost
to
7 111111'.\,"'.
to
(llSDo:,e
of
waste "P'l(q",!f"t!
trcatIncnt <2\/1:1(''1''
never
1, p.
3
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
Usc
of
Non-llIinois
Coal
In Burns'
Phase 1I
COfllpfiallce S{WZv
Report
(Burns
McDonnell,
October
1998), switching the CWLP coal supply from Hlinois coal to Power River Ba.sin
("PRB")
was c\/aluat<.:d. PRB
mined in the western United W'."",-,,', is low-
sui
, low-boron coal as com.parcd to coal mined in HliIklis.
Jjc(~au;,e
C\VLP
not
any reliable
to
,·.~"c'"r"
ra iI-delivered coa
1
to the
plant,
the
plant
modifIcations would be required
alternati
enough
fIJI' unit train coal deliwrics,
PRB
is not
to
'"11(1:111" IIn'"I'1l
were
l",".tllI U,""
both involved unloading the
at an
plant
I,
p.
1.)
to
''-I'_I1U'',"'' 13
areas of concern
op(~ratlon
0 f
ex
svstenlS to bum PRB
n
the
'-,"E"",,.<,,, potential ('UI'lell)!'
I
as l11Clc1tlIe::ltH:ms to the
that
taC1:ors
to aellle\/c
nuous mr COlnDltar1Ce
1,
I,
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
75,
considering the
II SO?
Report,
CWLP
decided to add a FGDS to Dallman Units 31 and
Factors cited by CWLP
in support
of this
include:
on
lIlinois;
would be
.p_'.\}'J'V.\J';\J1
budgeted
$1
to
l)Cl,1Ctlt
cost long tcnn solution;
Econom.ic benefits for Springfield and the
o
Burn lIlinois coal
100 coal mine related
$101\1+ in annual coal
o
200 to
construction related jobs
•
•
PH.B
...
. L
3.)
CWLP's
CleC:'lSII.On
to continue to burn
111
coal is
'jl\i'n,,'"
the utility
an alJlunc!anl.cc
million
lIli
was
mi,ned in Illinois.
""'i"i,'d,,,
to
I,
p.
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
6.
Proposed Pretreatment of 'Vater for Transfer to SMSD
SJVlSD has contracted with CWLP to accept tbe FGDS wastewatcr stream,
at a cost to C\VLP of $1 OO,OOO/month, provided that its acceptance docs not upset normal
tests
S110\Vn in some mstances that ten percent of the
Plant c)perations.
CWLP mt,enc!s to treat the FGDS waste streanl with conventional
pretrcatlnent
removal prior
to pumping the wastewater to tbe SMSD
Plant. While laboratory
boron
in
wastewatcr can be
n'l1,10\l("(j
with solids
the
jar test
have not
corlsistellit: thus.
is not
boron removal
of
calculating boron COlleentratj()ns in this Ilrc)Ccecl.ll1g
. I, p.
13.)
nrCl!)oses ,-"'JJ1'-A,U"'Ethe
waste stream in a
~."lJ.\)\J\J
II
1.0
a
tapcr(:(\ Hoceulation
sectnnentahon
all
maintains a
Thc
cOicHcally
'''!('1)'-U
concclltrator
"w.""",,.,~u
blank!,;t that """"",;,,,,-
eorltac'C al;:ce']eratc:c! noe rOrJnatlon
slurry (l!sclJarfT,c
plant ,,,,,",,'nnn('1 to
mass
(
1,1'. 13.)
36
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
80.
part of this project, a pumping station would be constructed near the
",".,'nhh,'wBuilding at the CWLP 1:'1cility. A.II sump
pump materials
will be corrosion
resistant.
A
f(Jrccmain would be constructed from the pUll1ping station to a sanitary
sewer
in the
Plant
C:llll_fl,'Pcl
generally southwest of t5ergc:n Park in
Standard sewer forcemain construction will be used.
81.
[t
is anticipated that up to four air relem;e
\vill
required. Sealed
and lined vaults will be
to minimize
of ,','e,."\,'lI;cf
and scwer is an1:1Cllxtllecl at a minimum. CWLP will install,
maintain
one or
l110re chemical
or statiOllS as clc(:m(:cl neCC:SS:1ry by the District to control
14).
to
.5 million.
of
treatment
IS
anl.lClp;rtc<I to
treatment
(mUons.
IS
\..."I.lU"'~A'
to
While some costs may I'PIIEI,
n
M costs
, a pretre,ltment
30
8 DerccIll. this ,v"".d,,.c to a pre:SCllt
100,000, a
In addition,
7
no
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
D.
Other Similar P('rsons' or Sites' Ahility to Comply '\lith the
General Rule
The Board has noted in Adjusted Standards and Site-Specific Rule
prc1ce,:XlllDgs
re.\.~anclil1lg
boron, that
mc~etlng
water qual
standard
boron
is
problematic fell' utilities and industry
Illinois
In thc adjusted
sranClaro
Dr(lCee<l 111 a 0 fIll inois
referenced above, the Board states:
The Board originally adopted the
nrc'<:PIIl'
Quality Standard in
I
Mareh 7,
1
I-I
1
that
ofLO
,C>\J,[f,c>"V'('
that
can harm irrigated
'j""'''~''''
is unlikely in Illinois, the uncontrolled
quantlt\lcs
of boron was clearly undesirable. The 1.0
je)r the
Quality:::it,ll!lclar(\
adoption.
omitted.)
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
96-1 (lILPoLControL
May
1,
1996),
5.
At present, to Petitioners' knowledge, there is no other Illinois power plant
or utility buming
T1Hnois coal with the same air pollution control equipment or
which
is believed the current cause of CWLP's
While Petitionl:['s
bel
that two
(2)
permits
been
by the IEPA
fell'
the development and
construction of power plants util
fllinois coal, planning to install and util
similar
pol
cOlltnlls. neither
is
op,;;rattonal Ii"om which COlmr;lan1S011S can
as noted.
are currently
no known commercial
p[(Ke~ss<~s
utilized to
rell1.ove
. 1, p. ii.)
nCI2CSSa.l"Y
III
rc'.isonalJlc treatment or
mill
wastewater
stream
T
annual "",c"",>1",,,
and ma,inlcnan<:'e costs are
estlmat(~(1
will
1.6
million. Including
somc costs
The costs
to 1111\)1,"11''''111this nnlJ)(lSal.
impact on the
rOllUJ1('nt. are ,VCIH1Cll:)W
COlISll]ercCl. none
In
COlnnan:son to
110
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
HI.
SYNOPSIS OF TESTIMONY
Petitioners \vill call
''''\/{'l'':lI
individuuls to testify in support of the facts set forth in
this Petition and requested
reliet~
including the following:
A.
Deborah Ramsev
Deborah
l"dJdL.)I~Y
of Hanson I'rolessional "",'\11"",(,
Inc. will
',">"(""'0
other
the derivation of and caleulations supporting the prc,po:sed
water quality standard
boron; the ccmdition
of the
f"~{'(,'t\I.no
stremns; the
water downstream; and the
boron
for the r,C'(',"" \1">
ntC.,"fN"f watcr
se.~;mlcnts,
as well as the entltlt;S
it
to
to the
histone:lI
f'C','c'1VI!10stream, Mr.
Plant
(llS;cl\:ar~:c:
the prc1poscd
conditions can
uses or
n
JUl'"Jf~""'"
cOlnllmntty would not be
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
C.
William Brown
William Brown, of Crawt()rd, Murphy
Tilley, Inc. will
regarcltng
the
SMSD's Spring
Plant operations; the Plant's
Permit and effluent
data; the
beneficial impact ofSMSIYs
op(::n11lI011S to tbe
proposed rule on SMSD.
and the economic impact ofthe
D.
Springfield City Water, Light
Power will
"!J""" 1,"""J
and
Bnd
alternative tecIU10ICI!!I(;S
at
E.
areas:
thc
CC()l1Olnt.es
f
,V ,,'P'-"'Ul'-sltan(!aJC(! as pr(lpOSC(!
F.
trcatmcnt tectlJ1I:1!Oj2,jCS, the cdlt"rncltl'lIp,;;: C011SI(ICr(;(1
that
their
an assessment
western
to
.n'
1 ,..,u
as
Dalhnan
41
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
IV.
MOTION FOR WAIVER OF SIGNATURE REQUIREMENT
In a
rvlotion flied simultaneous with this Petition, Petitioners respectfLllly
request that the Board waive the requirement, set forth at
IlL Adm. Code § I02.202(f),
that
a
petition
rulemaking
by at least 200 person,s.
V.
EXHIBI1'S
are included by Petitioners in support of
Site
Sp(~CltIC
Rule proposed. and are hereby made a part of this Petition:
1.
rC-,)IX'ClIIC
BO/'Ol1
,)I{}'lll'l,')rtl
Plant,
,)(l,%'(,//Il()/J
Colinty, Illinois
(Ilanson Professional
Inc,
r\Il"II'" 2008).
VI.
to
"'-""5'"''''''''
uses 0
f
a water
R03-11 (July
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
The Board has stated previously that federal
it "broad
discretion
in determining the appropriate standard of control to apply to
discharges from watcr treatment plants". In re Site Specific Exception to
Eft1uent Standards for the Illinois American Water COlnpany,
S1.
Louis Treatment Plant (February 2, 1989), R85-11, slip op, ,11 10.
2000 WL 141
at
(IlL PoLControl.Bd.
7, 2000), Further, as referenced
the
previously granted a
'-:1'1,1'1'11"1,".Rule CI1<mg,c from the watcr quality standard
boron
up to 15 mg/L",
IS, March 1
Thus, the
it
ill
VB.
the
fic reI
eXl:stlrtg water quality staJlllallxl
' .... a,Jtllt .... nor eC(Hlcllmca!ly rcasolnatJle
CWLP.
11<" "tlnlp eC()l1(1l111C
m11Vl,l't
on CWLP
without
commensurate
Iv'nl.j,t
(0
not e:q)ectecl to harm
aqlJatl'c
Ii
III
ic
I
In
n
is antlClI"}[It(;(\
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
'['hisPetition satlsties the requirements of Section J '}"-."-\}'''-and Section 1
IOof
the llJinois Administrative
in that
it: details the langwlge of the proposed Site
Specific Rule; states {[lctS in support of the proposal, ineluding environmental, technical
and economic justi fication; demonstrates that requiring compliance with the
'du,oW'b
boron water quality stanc1.a1'cl is neither tcchnically lcaSIllle nor economically reaSOnal)le;
rule; ells,cusses details ofthc
Op(~nl1tlOrls
and facil
ofCWLP and the ""."",
Plant; clelnonstratl;;'s that the
with
Lvl,w',]
mc~lul:les
a
c';r"(~",Q1C'
ottestlml::lny to be
WII
City
"'t,"'"
" , Illinois,
of Public Utilities,
!y
"N'
1 j{',cf
SPRINGFIELD
D
ARY
CWLPOI)2iFil/Sik
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
PROPOSED SITE SPECIFIC
RULE
FOR CITY OF SPRINGFIELD,
ILLINOIS,
OF PUBLIC
UTILITIES, CITY WATER, LIGHT
AND
POWER AND SPRINGFIELD
METRe) SANITARY DISTRICT
FROM
ILL. ADM. CODE
SECTION
302.208(g)
)
)
)
)
)
)
)
)
MOTION TO WAIVE REQUIREMENT TO SUBMIT 200 SIGNATURES
of
~pr'lng,t!el(\,
Illinois., Oftke of Public Utilities,
and Povver C'CWLP") and Springfield Metro
District ("District")
through
HODGE
DWYEI<. ZEMAN
llIinel!s
to
l.
l)usU1c~;ses
III
~prmgtlcl(\.
nl'(\\lIri,~
potable water
reslClenlts of
~pr'Illg;t!el(i
and sun'oUllclilHr c()rnrnun,itre'S.
2.
District owns and Ol)(;nltles two wastewater treatment
including
ClaIllWli'Y
Treatlnent Plant ("'"..rll'\(Y
Planf') which lWllUl\,,,
waste\Vater
areas,
stonn water
fi'om a portion
,nrrnnlteld and surrounding
"""'fIN'
AttilClu:(11O
lVJ\J"lUlJ is
Petl
tl011
ers are
Seekll1.Q
a
to
an
am::Tnauve
c!lscl1nl}!,C at
Plant
to
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
River, to its confluence with
Illinois River,
and in the Illinois River 100 yards
downstream from the confluence with the Sangamon River. The general use water
quality standard for boron, which is set fOlth at 35 Ill. Adm. Code § 302.208(g), is 1.0
4.
Petitioners are reqlUet,tllllg an alternative water quality standard for boron to
Operation ofthe air pollution control sy:,tems at CWLP's
a pretreated industrial effluent stream
boron in a plant pFi"llflP,.,t stream
IS
Plant.
enable the District'sSpring
Plant
to
from CWLP's power sranon.
plant causes
elevnfecl
COI.lcc:l1tratlons
proposed to
to the District's ,nt'flH'
5.
The
SPC:CIIIC rulemaking
pel:!tl<mS lJ1
supply for Springfield and
6.
Motion is in the public Inh"rp<:1'
i:ipnngllel(j area, CWLP's power plant is a critical
~~I!.£L~UDJL~~Q!IlQm~!:;lg!!LQ1I~!!lliW.Jllc..ilim.1.J:..:J;;~~.!:2lL'J.JLL
R04-11.
the ('11'17"'1'<:of the
surroulI1dmg comnmnities.
speCIIIC water quality standard for boron is necess;ary
to
pollution regulations.
CWLP to
rll"~"'"h'
)jschan~e
EI
inllIlatJ(ln \,.',.
'0+"',,,
plant in compliance with its
~atl.onal
Pollutant
Public
2
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
att<)nlICYs respectfully"I"-'"I'"I""I"
Illinois Pollution Control Board to waive the
requirement
to submit 200 signatures in support of its Petition for
Respectfully submitted,
Specific Rule.
Datc:
CITY OF SPRINGFIELD, ILLINOIS,
OFFICE OF PUBLIC UTILrrIES,
CITY WATER,
LICTHT AND POWER_
and
SPRINGFIELD METRO SANITARY
DISTRICT,
!/F1liIlW;/l'v1cl{JUIl IU
HeqlIlrc'lnent to
Submit 20U
Slgl1,;:nul-es
3
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
PROPOSED SITE SPECIFIC
RIlLE .FOR CITY
OF SPRINGF'IELD,
ILLINOIS, OFFICE
OF PUBLIC
UTILITIES, CI'[Y WA.TER, LIGHT'
AND
POWER AND SPRINGFIELD
METRO SANITAR'{ DISTRICT
FROM
ILL. ADM. CODE
SECI'ION 302,208(g)
)
)
)
)
)
)
)
)
R08-
--'-"--'--
(Site ::)P<:ClllC Rule
MOTION FOR EXPEDITED REVIE\V
COTvlE
Water, Light and
("CWLP") and Springfield Metro Sanitary District C'D1strict")
(collectively "Petitioners"), by and through their
lU,,'I1(>1,/'O IJODGE DWYER
L~LI"j,,",1
IIUI,"."''''
to
II L
10 l.512, tH''''''''''
reCliJest
III inois Pollution
111
a
to
ish an altcrnaltl ve water qual
than that found
at
Ill.
2.
which is I.O
COl'ltatl!.lS the ."'-.\.-"\.-1<,, use water quality standard
fbr
3.
a
Specific Rule to est,lblu;h an
the point
dlsl~:narge
at Outfall 007
to the
III ino1s
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
The purpose of Petlt!cmers proposed
;)pC~cntc
R.ule is to enable the
District's Spring
Plant
to accept a pretreated industrial eflluent stream from
CWLP's power plant. Operation of the air pollution control systcn1s at CWLP'spower
plant causes
f'1f'''\f~Hf'{l
concentrations
boron in a plant eflluent stream that is proposed
to
be transferred to the
Spring
Plant
5.
Simultaneously with this Motion, Petitioners are fIling a Petition that more
fully
d"",~nihl'"
the purpose and
of the proposed
6.
;)P(~CltIC
Rule adopted as soon
as posstl)!e
!)I;:cause CWLP's
plant
is a critical power supply for
City
the
spe'CIIIC water quality standard
necessary
to
111 COrnp!laI1Ce
Perm
(III.
(Ill. ENV 2003);
1.",.." .... ,,) 717 (IlL
1997
).
8.
rea'Cl11Jl,g a
ClCC:1SIC)J1 on
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
Petitioners in their Petition only for purposes
First Notice. An electronic version of the
Petition, including tbe langU<lge proposed by Petitioners for the Site Specific Rule, has
been
filed with the Board to facilitate the Board moving expeditiously to First Notice in
this rulemaking.
9.
Petitioners also
tbat the requisite public hearing
scheduled as
soon as possible in accordance with Section
28(a)
of the Illinois Environmental
Protection Act,
415 ILCS
and that such a
hp'~I!'1t"(;
serve
as the hearing that
the
II
Procedure
1OO/5-40(b).
to proeecc\ to
IS {'f)"j'c>,,,o.t! in the
information
ne,~essal'Y
sel1leclulc a public
10,
Co,Jf)c:ratc to
eXIJCultlo,USli
y
II
to
IS
unUlSll~1
L
filed
CWLP with the Illinois Environmental Protection
project
that was
("IEPA") as a
IS
essence
to
of
Compliance Commitment
In support of this statement
Petitioners attach
ofCWLP's
UClto[)(;r 5,2006 and July]
2007, which includes the
CO]TCi;poncICn(~e
to
COlllslslent with ;:)ecnon IOL51
COlTcspOllClenc(,:s to IEPA
3
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
12.
The IEPA has been contacted and has no disagreement with the prorlOsed
Specific Rule and this Motion for
ited Review.
13.
The Petitioners will be Inaterially prejudiced if this motion is denied,
including bec:aut,e
IS
the essence due to the schedule
for this project
on which CWLP's
is based, and
h.,>,'""":,,,>
some activities to implement the fn1l1Sr(;r
CWLP effluent stream cannot commence unless and until the Board grants
Petitioners'
Specific Rule change.
14.
Ill.
101.512.
Mc)t!cm IS accompanied
an af1lrmation <lC""'O"""6
cited herein are true.
W
and tOfiegOmg reasons,
of Springf1eld,
n
linois,
o
Public Utilities.
, Light and Power
(0
rca,clll:ng a
U'-'~">t'J)1
on
OF SPRINe}FIELD, ILLINOIS,
/",T'C'Tnr: OF PUBLIC UTILITIES,
WATER, LIGHT AND
POWER
and
SPRINGFIELD METI{O
4
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
3I50 Roland
Post Office
Box
Springfield, Illinois
(217) 523-4900
AFFIDAVIT
OF
ILLINOIS
)
)
COUNTY OF SANGAfv10N )
William
Murray,
duly sworn
on oath, ',,'II''''1'1C'that,
upon
the
set timh in the Motion for
,L.'''IJ'-~H'~,U
f"ev.,'w above are true
Sul)sclnb<;ci and sworn to before me
day of ru'r;U.:H,
CWLP:OO::/FilIMotion lor
Review
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
1\1()TION FOR EXPEDITED REVIE'V
Group Exhibit A
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
OFFICE OF PUIUJIC U'l'ILITIES
CITY
OF SPRINGFIELD, ILLINOIS
TIMOTHY
J.
DAVLIN, MAYOR
R.
TODl) l{ENFROW, GENERAL MANAGER
October 5,2006
Illinois Environmental Protection
Bureau of Water - CAS #19
I.Tlemuon: Beverly Booker
P.O. Box 19276
Springfield, IL 62794-9276
Violation
f'.},,1rlr'I"
Facility
Ms.
l)O'OKe~r:
reqlue:stulg
a
period
months or until April 9,
boron mitigation project.
<.he'",'},>?>" option
Environmental
~md
Ofnce 201 East Lake Shore Drive ,.
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
July I 2007
OFFICE OF PUBLIC UTILITIES
CITY OF SPIUNGFIELD, ILLINOIS
TIl\lOTHY
J. DAVLIN,
MAyan
R. TODD
RENFROW, GENEHAL MANAGER
Illinois Environrnental Protection /-Hc,-"lC.•
Bureau of Water
#J 9
Attn: Beverly Booker
P.o.
I
:sprtngltew,IL
Violation "",net",,,,
ID:
rernainirtJ~
streams
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
July 1 2007
2
After the pretreatrnent
Utility, this stream will be sent via a
main to
the SMSD sewer line located at
adjacent to
Parle The waste stream
will
to
Spring
Facility
it will
further treatment by SMSD.
It
is anticipated that a reduction in boron levels will be obtained from the SlvlSD sludge
treatment
As part of this
Action Plan, SIvlSD and CWLP will jointly apply
fen' a site
water quality standard at the Spring
]7
acility
from the Illinois Pollution
Control Board.
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
nevv sctledlJJe to be submitted as a C;OmpdIallCe
'.A.lHUl.llU.llVIH
listed below.
1S
Pretreatment
Bid Pretreatment System
Award Pretreatment System
Pipeline System
v ....2>lf.:,u
Obtain Hights of Way for
'JIt~"",,,,,
Bid Pipeline System
l)r(:tre:a11neI1t System Contractor Mobilizes
Award Pipeline
Install Pipeline
Fabrication
or C};ari(:::orle
Claricone and
Tanks
Operational
September 2007
November 2007
February 2008
March 2008
April 2008
May
2008
May 2008
June 2008
r'Jr.'lIplY,h",l'
200S
Decemb,er 2008
March 2009
May
(temperature dependent)
July
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
1021 NORTH CRAt'iD AVENUE
1",0, Box '19276,
SPRII~GFIELI),
ILLINOIS 62794.9276 - (217) 782.3397
JAMES R, THOMPSON ONTER,
100
WEST RN'OOLPH, SUITE
11.300,
IL
60601 -
(312)
1314.6026
ROD R, l:\L/\G(:)IEVICH
COVERNOR
DOUGLAS p,
DIRECTOR
217/785-1
Environmental
Springfield
CWLP
i"
He: HAHl24767,
SPRINGFIELD
CV'lLP
CITY OF
.,Extension Request
Granted
Violation Numbcr':W-2003-00471
OCT
-
5 2007
I!Ci\LlH [, SM[fY
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *
CERTIFICATE OF SERVICE
1, Christine G. Zeman, the undersigned, certify that 1have <,,,,.,,,,,,,l
attached
ENTRY OF APPEARANCE OF KATHERINE D. HODGE, ENTRY OF
OF CHRISTINE
G.
""."VlrVl
PETITION FOIl SITE SPECIFIC RULE,
MOTION TO WAIVE REQUIREMENT
-
TO SUBMIT
200 SIGNATURES,
.
and
MOTION FOR EXPEDITED REVIEW, upon:
Suite
1300
U1Icago, Illinois 60601
Albert F.
l:ClLll1gt:r
for Prairie Rivers Network
Environmental
Policy
Drive
Mr. John Therriault
Assistant Clerk
of the Board
Illinois Pollution
R.
Thompson
100 West Randolph
Suite
11-500
CI11ca.go, Illinois 60601
on
2008;
upon:
I-I
Illinois DepartlTlent of
1'1
"f"IlI'C1I
j{e~:our'CC:S
S. ;)CC0I10
by clepOSllll1g
dOC:UI11ents m
United
in Springfield,
Illinois on
n.L1'''ll,~L
P()(P!Filin,,'s! NOF.COS Petition and Motion
Electronic Filing - Received, August 29, 2008
* * * * * R2009-008 * * * * *

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