BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
IN THE MATTER OF:
)
)
)
REVISIONS TO WATER QUALITY
)
STANDARDS FOR TOTAL
DISSOLVED
)
R06-24
SOLIDS
IN THE LOWER DES PLAINES RIVER
)
(Site Specific Rule
EXXONMOBIL OIL CORPORATION
)
PROPOSED 35 ILL. ADM. CODE 303.445
1
Water)
NOTICE OF FILING
To:
Hearing Officer
Illinois Pollution Control Board
2 125 South First Street
Dorothy
M. Gunn
Anand Rao
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street
-
Suite 11-500
Chicago,
IL
60601
John Knittle
Division of Chief of Environmental Enforcement
Office of the Attorney General
100 West Randolph Street,
12'~ lo or
Thomas Andryk
Division of Legal Counsel
Illinois EPA
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794
-9276
Matthew J. Dunn
Director of Public Works and Utilities
City of Joliet
Department of Public Works
&
Utilities
921 E. Washington Street
Joliet. IL 6043
1
Champaign, IL 6 1820
Dennis L.
Duffield
Chief Legal Counsel
Illinois Department of Natural Resources
One Natural Resource Way
Springfield, IL 62702
Chicago, IL 60601
William Richardson
Susan M. Franzetti
Franzetti Law Firm, P.C.
10 S.
LaSalle Street
-
Suite 3600
Chicago, IL 60603
Please take notice that on May 31, 2006, we filed with the Office of the Clerk of the Illinois
Pollution Control Board via electronic mail the
TESTIMONY OF JAMES E. HUFF
and the
TESTIMONY OF STACEY
K. FORD,
a copy of which is served upon you.
Please also note that Exhibits
1 through 8 submitted in support of ExxonMobil Oil Corporation's
Petition for a Site Specific Rule Change will not be resubmitted. Exhibits
6A, 6B, 6C, 9, 10 and revised
Exhibit
5
will be submitted in support of the above-mentioned testimony.
Jeffrey C. Fort
Letissa Carver Reid
Elizabeth A. Leifel
Sonnenschein Nath
&
Rosenthal LLP
7800 Sears Tower
233 S. Wacker Drive
Chicago, IL 60606
-6404
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
IN THE MATTER OF:
)
1
1
REVISIONS TO WATER QUALITY
)
STANDARDS FOR TOTAL DISSOLVED
1
R06-24
SOLIDS IN THE LOWER DES
PLANES RIVER
)
(Site Specific Rule
-
Water)
EXXONMOBIL OIL CORPORATION
1
PROPOSED 35 ILL. ADM. CODE 303.445
)
TESTIMONY OF JAMES E. HUFF
My name is James E. Huff. 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 as well as in New Jersey.
I currently serve on the Board of Directors for the American Council of Engineering
Companies
-IL ("ACEC-IL") and served three years as Chair of the Illinois Environmental
Protection Agency Liaison Committee for the same organization. I also serve on the Illinois
Statewide Nutrient Science Committee, which is charged with proposing state nutrient standards,
and am the lead consultant for the Northeastern Illinois Planning Commission (
"NIPC") for
evaluating Facility Planning Amendment requests for consistency with
NIPC's Water Quality
Management Plan.
My work experience includes two years with Mobil Oil as an Advanced Environmental
Engineer during the construction and start
-up of the Joliet Refinery. My responsibilities at the
Joliet Refinery included the construction oversight and start
-up of the wastewater treatment
facilities, technical support for the wastewater treatment including training, sampling, discharge
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
monitoring reports, and National Pollutant Discharge Elimination System ("NPDES") permit
preparation. From this experience, I am familiar with refinery operations and the associated
wastewater treatment, as well as the Des Plaines River.
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 also assisted in
preparing the Economic
ImpactICost-Benefit Analysis on a proposed total dissolved solids
(
"TDS") rule change in Illinois. I then spent four years with the Armak Company, now called
Akzo Nobel Chemicals. 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 including fatty amines plants in
McCook and Morris,
Illinois.
For the last
26 years at Huff
&
Huff, Inc., I have been involved in over 30 environmental
impact studies associated with the impact of wastewater discharges on receiving streams
throughout the United States. Some of these studies have involved TDS, sulfates, and chlorides.
Surveys I have been involved with in Illinois have included the following streams:
Chicago Sanitary and Ship Canal
Des Plaines River
Casey Fork Creek
Aux Sable Creek
Flint Creek
Mill Creek
Thorn Creek
Kent Creek
Fox River
Mississippi River
Deer Run Creek
Salt Fork of the Saline River
Cedar Creek
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
Tyler Creek
Kiswaukee River
Beaver Creek
These stream surveys have included various combinations of water quality sampling,
fish, macroinvertebrate, mussels, and sediment quality, along with antidegradation analyses on
the more recent surveys.
I also have completed mixing zone studies on the large streams listed
above, including for the
ExxonMobil Joliet Refinery ("Joliet Refinery").
I have worked with the Joliet Refinery for the past 17 years on various wastewater issues
including two adjusted standards relating to ammonia, a mixing zone study, a thermal plume
analysis, and review of the draft NPDES permits.
I have been retained by the Joliet Refinery to assist in the evaluation of alternatives for
the wastewater stream generated by the new FCC wet gas scrubber, identifying water quality
impacts, assisting with the construction permit application and NPDES permit modification
application, and providing technical support on the request for an amendment to existing
regulations.
A copy of my resume is presented in Exhibit 9.
Presented herein is a description of the areas I have investigated that are related to this
request for an amendment to existing regulations, which incorporate questions raised by the
Illinois Pollution Control Board (the
"Board") in the same areas.
APPLICABLE REGULATIONS
The requested amendment is for TDS in the Des Plaines River. The wet gas scrubber
discharge will contain significant sodium sulfate, which is the source of the TDS subject to this
request for an amendment to existing regulations. From the refinery
outfall to the 1-55 Bridge
(1,600 feet), the Des Plaines River is classified as a
Secondary Contact
waterway with a TDS
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
water quality standard of 1,500 mg/L. From the 1-55 downstream, the Des Plaines River is
classified as
General Use
with a TDS water quality standard of 1,000 mg/L.
There are no water quality standards on sodium. The sulfate
General Use
Water Quality
Standard is 500
mg/L.
There is no
Secondary Contact
water quality standard for sulfate. The
proposed discharge will not cause or contribute to a sulfate water quality exceedance, and
therefore an amendment for the sulfate component is
not
requested.
EXISTING WATER QUALITY DATA
Exhibit 6 entitled "Predicted Water Quality Impacts on the Des Plaines River from the
Proposed Wet Gas Scrubber from the
ExxonMobil Joliet Refinery," dated December 2005 was
attached to the Petition. This report included the available water quality through late 2005.
The Joliet Refinery has collected TDS and sulfate data on the Des Plaines River weekly,
between February 28, 2005 to April 25, 2006. Exhibit 6A presents these data along with existing
effluent data. The maximum TDS upstream and downstream for last winter were both 900
mg/L, and both occurred on January 10, 2006. The maximum sulfate upstream was reported at
130
mg/L. Downstream, a sulfate of 490 mg/L was reported on May 3, 2005. The next highest
sulfate result was 120
mg/L, more consistent with the upstream result. The TDS associated with
the 490
mg/L sulfate was only 720 mg/L, suggesting that this single sulfate result is an outlier.
The mean downstream TDS and sulfate from the most recent refinery data (Exhibit 6A) is
630
mg/L and 92 mg/L, respectively.
In addition, more recent TDS data on the Chicago Sanitary
&
Ship Canal collected at
Lemont by the MWRDGC is presented in Exhibit
6B. Historically, there has been a high degree
of correlation between the TDS level in the Chicago Sanitary
&
Ship Canal and the Des Plaines
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
River. The MWRDGC data from January 21, 2003 to November 2 1,2005 reported a maximum
TDS of 1,094
mg/L at Lemont, and a mean value of 585 mg/L. The maximum TDS occurred on
the day that the chlorides also were at a maximum 470
mg/L.
Exhibit 6 contained available TDS and sulfate data collected by the MWRDGC, the
Illinois Environmental Protection Agency (
"Illinois EPA" or the "Agency"), and by the Joliet
Refinery. On the
Secondary Contact
portion of the Des Plaines River, the 1,500 mg/L TDS limit
has not been exceeded over the past five years. At the 1
-55 Bridge, where the General Use
begins, the 1,000
mg/L TDS standard was exceeded on three consecutive dates in 2001, as listed
below:
The three events occurred over three consecutive sampling events, implying that the TDS
excursion was persistent for longer than 15 days.
Limited TDS monitoring since 2001 has not
recorded a TDS level above 1,000
mglL at the 1-55 Bridge. From Table 1 of Exhibit 6, the last
documented time a TDS level above 1,500
mg/L was recorded in the
Secondary Contact
water
was January 4, 2001, at
Lockport on the Chicago Sanitary
&
Ship Canal. From the more recent
TDS data collected by the Illinois EPA, the MWRDGC, and by the Joliet Refinery on the
Des Plaines River, TDS levels above 1,000
mg/L continue to occur infrequently during winter
thaws. However, the peak TDS levels appear to be lower over the past five years, attributed to
better deicing practices adopted by highway departments.
Water quality monitoring for sulfate on the Des Plaines River consistently has been
below 500
mg/L, both upstream of and at the 1-55 Bridge.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
A review of all of the TDS data (Exhibits 6, 6A and 6B) reveals that all of the elevated
TDS readings occur in the winter, and are attributable to
snowrnelt runoff carrying salt runoff
from highway deicing activities.
Assuming during
snowmelt the streams are at their harmonic
mean flow, the flow at the 1
-55 Bridge would be 3,690 cfs.' This is a conservative flow estimate.
At 1,000
mg/L TDS, this translates into 20,000,000 pounds per day of TDS passing beneath the
1
-55 Bridge. The combined increase in the average TDS loading from the Lemont Refinery and
the
ExxonMobil Joliet Refinery to the river will be 348,000 pounds per day, or 18 mg/L, or 1.8
percent of the total loading under this scenario.
According to Standard Methods, the precision of the TDS test method with a known
sample TDS concentration of 293
mg/L when tested in 77 samples yielded a standard deviation
of 21.20
mg/L. In essence, the contribution from the two refineries will be less than the
precision of this test when the River exceeds 1,000
mg/L.
TOXICITYIFUTURE POSSIBLE CHANGES IN WATER QUALITY
Water quality standards historically have been developed based on toxicity. As TDS is
composed of a variety of anions and cations, there are no
"toxicity" values that can be applied to
the generic TDS parameter. Sulfates and chlorides make up the majority of the anions, and these
compounds typically are regulated. In Illinois for General Use waters, TDS, sulfates, and
chlorides all are regulated.
Several years ago, the Illinois EPA began a detailed review of these water quality
standards that by early 2004 led the Agency to hold a stakeholders' meeting. A subsequent
stakeholders' meeting was held in March 2006, where the Illinois EPA indicated that approval
from U.S. EPA had been secured and that a proposed rule change would be forthcoming to the
'
Harmonic Mean Flows for Illinois Streams, ISWS, 1991.
-6-
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
Board. The essence of the proposal will include an elimination of a TDS General Use Water
Quality Standard and amending the sulfate water quality standard based on the stream's hardness
and chlorides. For the Des Plaines River, the sulfate water quality limit would be on the order of
1,800
mgIL, if the changes are adopted. I understand the Agency is prepared to provide more
details on its efforts over the past several years and on the anticipated proposed changes and
timeline. If the Board ultimately should adopt the Agency's proposal, as currently drafted,
ExxonMobil no longer would need the requested relief downstream of the 1-55 Bridge.
The Agency's efforts are relevant to the Joliet Refinery's request, as it goes to the
environmental impact the proposed discharge will have; that is, sodium sulfate, at the proposed
levels discharged, will not impact the aquatic community in the Des Plaines River. There will be
no adverse effect on aquatic life due to the projected TDS and sulfate levels. There has been a
great deal of new information relating to TDS toxicity over the last several years.
(See
Exhibit 7A and B). I understand the Agency will provide additional information in support
of the appropriateness of revising the TDS standard in the Lower Des Plaines River Segment.
(See also Exhibit 8 indicating that by maintaining a standard for chloride, as the Agency is
presently considering, the danger of dissolved solids toxicity is addressed, thus making any TDS
standard unnecessary.)
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
PROJECTED EFFLUENT CONTRIBUTION
The projected effluent contribution was described in my report, Exhibit 6 and updated in
the attached copy (Exhibit 6A) will average 133,000 pounds per day of TDS (and 89,000 pounds
per day sulfate).
PROJECTED WATER QUALITY IMPACTS
The projected incremental increase in both TDS and sulfates to the Des Plaines River
-
from
-
both refineries were described in Exhibit
6.
This analysis was done based on the 7-day, 10-
year low flow rates in the streams, and relied on the 1997 mixing zone study completed by Huff
&
Huff, Inc. for the Joliet Refinery. (This mixing zone study was provided to the Board as part
of the Joliet Refinery's Ammonia Adjusted Standard request, R97
-28.) The effluent design has
not changed since that study, and remains valid with the added flow of 179,000 gallons per day
from the Wet Gas Scrubber. The Joliet
~efinery has three outfalls that combine before entering
the Des Plaines River. The combined
outfall will have a projected TDS concentration of 2,610
mg/L and sulfate concentration of 1,050 mg/L. The mixing zone study determined there is a
2 1
:
1 dilution within the mixing zone, so at the edge of the mixing zone, there will be an increase
in TDS of 91
mg/L and sulfates of 46 mg/L. The resulting mean TDS and sulfate at the edge of
the mixing zone will be 81 7
mg/L and 152 mg/L, respectively.
At low flow conditions, the combined contributions from the Wet Gas Scrubber at the
Lemont Refinery and the Joliet
ExxonMobil Refinery will increase the sulfate level in the Des
Plaines River at the 1
-55 Bridge by 29 mg/L and the TDS by 43 mg/L.
The resulting TDS and
sulfate levels in the River, after mixing, will be 748
mg/L and 124 mg/L, respectively. Thus,
under low flow conditions the current water quality standards will be achieved after the addition
of the discharges from the two wet gas scrubbers. The only time the existing TDS water quality
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
standard will be exceeded is when highway deicing salt is entering the Chicago waterway
system.
Exhibit
6 included recent TDS data on the Des Plaines River, DuPage River, Kankakee
River, and the Illinois River at Marseilles. The merger of the Kankakee River and Des Plaines
River is the beginning of the Illinois River. The DuPage River enters the Des Plaines River
before the beginning of the Illinois River. Using a mass balance approach, assuming all streams
are at low flow conditions and all streams are at the maximum TDS concentrations (a very
conservative scenario), the TDS concentration at the beginning of the Illinois River will
not
exceed 1,000 mg/L TDS from the increase in TDS from both refineries. Exhibit 6C presents this
material balance calculation for TDS.
Therefore, relief is requested from the point of
ExxonMobilYs outfall to the confluence of the Des Plaines River with the Kankakee River. As
the primary cause of the elevated TDS levels is highway deicing salt, the relief requested is
limited to the period November
1 to April 3oth each year. There are no other discharges in this
stretch of the Des Plaines River that are regulated for TDS, and therefore there will be no other
dischargers impacted by the proposed request.
ALTERNATIVES
Huff
&
Huff, Inc. considered several alternatives for this 179,000 gallons per day stream.
Deep well disposal initially was evaluated along with direct discharge. The Agency determined
that the injection of this waste stream would constitute a Class I underground injection well in
Illinois.
(See
Exhibit 13 in the Matter PCB 05-85.) Class I wells require injection beneath a cap
rock that will prevent migration upwards into higher aquifers.
Northeastern Illinois does not
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
have a cap rock above the Mount Simon formation used for disposal wells throughout the
Midwest, and therefore this alternative was not
viable.*
Treatment alternatives were described in the Site-Specific Rulemaking Petition, and these
technologies are addressed in the testimony of Stacey
K. Ford.
CONCLUSION
The Petition goes into some detail on the federal approvability of this request. I can
answer questions on those issues, but believe that the Petition speaks for itself. Moreover, the
correspondence between Illinois EPA and U.S. EPA on this very site
-specific request is direct
evidence on this topic.
Further, while I also could testify further on the Agency's investigations into appropriate
revisions to the water quality standard for TDS, I have not included details on those issues, as the
Agency is intending to address them.
--
2
See Evaluation of Underground Injection of Industrial Waste in Illinois, by R. Brown, and A. Visocky,
ISGS, 1989.
- 10-
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
Exxon Mobil
Date
Sampled
2/28/2005
3/9/2005
311 112005
311 512005
3/22/2005
3/25/2005
4/1/2005
4/5/2005
4/12/2005
4/28/2005
5/3/2005
511 012005
511 912005
5/24/2005
5/31/2005
6/7/2005
611 4/2OO5
6/21/2005
6/28/2005
7/5/2005
7/12/2005
711 912005
8/2/2005
811 012005
811 712005
8!23/2005
8/31/2005
911 312005
9/2012005
9/28/2005
10/4/2005
1011 112005
1011 912005
10/28/2005
11/1/2005
11/9/2005
11/17/2005
11/21/2005
11/30/2005
12/6/2005
1211 312005
12/20/2005
12/28/2005
1/4/2006
111012006
1/19/2006
1/24/2006
1/31/2006
2/7/2006
2/14/2006
2/21/2006
2/28/2006
3/9/2006
311 312006
3/22/2006
411 312006
411 812006
4/25/2006
Average
Maximum
Des
Plains
River Water Intake
River Sampling Project
COMBINED EFFLUENT,
001,002,
and 003
250
1,800
-emperatwe (deg
F)
DOWNSTREAM RIVER WATER
I
I
Sulfate
(rnglL)
C:\Docurnents and Settings\jrnhess\LocaI Settings\Ternporary Internet Files\OLK195\Refinery Stream Data
EXHIBIT 6A
rernperature
(deg F)
Total Dissolved
Solids(mg/L)
Sulfate
(rnglL)
Total Dissolved
Solids(mg1L)
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
WATER QUALITY DATA
CHICAGO SANITARY AND SHIP CANAL
Stephan Street, Lemont
Chloride,
TDS,
Date
mdL
mgk
112 1 /ZOO3
211 812003
311 712003
412 l/2OO3
511 912003
611 612003
712 112003
811 812003
911 512003
10/20/2003
1 111 712003
1211 512003
0 1 /2O/O4
021 1 7/04
0311 5/04
0411 9/04
051 1 7/04
0612 1/04
0711 9/04
0811 6/04
09/20/04
10/1 8/04
1 111 5/04
12/20/04
01/18/05
02/22/05
O3/2 1 lo5
0411 8/05
0511 6/05
06/20/05
0711 8/05
0811 5/05
0911 9/05
1011 7/05
11/21/05
Average
Maximum
Source: MWRDGC Water Quality Monitoring
C:\Documents and Settings\jmhess\LocaI Settings\Temporary Internet Files\OLK195\WQ SS Canal 2006
EXHIBIT 6B
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
PROJECTED TDS AT START OF ILLINOIS RIVER
EXXONMOBIL AND ClTGO WET GAS SCRUBBERS
Assumptions:
1) All streams at the 10
-yr, 7-day low flow
2) All streams at the maximum TDS since 1999 based on the State's Water Quality Network Data
3) Des Plaines at 1-55 Bridge is at 1,070 mg/L TDS before Wet Gas Scubber
4) Contribution of Just thewet Gas Scrubber to Refinery Effluent is 1,185 mg/L TDS
River
Flow, cfs
TDS, mg/L
Flow x TDS
Des Plaines
DuPage
Ka n ka kee
Exxon Mobil
Citgo
Sum
Citgo's Contribution
a/
Predicted Maximum TDS in Illinois River
936
a/ Based on pounds discharged by Citgo and 2,102.84 cfs, the incremental increase
C:\Documents and Settings\jmhess\LocaI
Settings\Temporary Internet Files\OLKI 95\lllinois River Predicted TDS
EXHIBIT 6C
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
JAMES E. HUFF, P.E.
Education:
1966
-1 970
Purdue University, West Lafayette, Indiana
B. S
.
in Chemical Engineering
1970
-1971
Purdue University, West Lafayette, Indiana
M. S .E. in Environmental Engineering
1974
-1 976
University of Chicago
Graduate School of Business. Part
time
Honors:
Omega Chi Epsilon (Chm. Engr. Honorary)
President's Academic Award
Graduated with Distinction
Fellowship
£tom the Federal Water Quality Adrnin.
Thesis:
"Destabilizing Soluble Oil Emulsions Using Polymers with Activated
Carbon,
" Major Professor, Dr. James E. Etzel
Experience:
Since 1980,
Mr. Huff has been vice president of Huff
&
Huff, Inc. responsible for projects pertaining to
wastewater treatment, design and operation, water quality studies, hazardous waste management,
groundwater and soil remediation, and compliance assessments.
A significant portion of his time has been
devoted to assisting clients on day
-to-day environmental issues; £tom permitting, training, to setting up
programs for compliance and
IS0 14000.
Mr. Huff has designed industrial wastewater treatment plants ranging in size fiom less than one thousand
gallons per day to eight million gallons per day. These designs have applied to various industrial sources,
such as, foundries, plating, printed circuit boards, organic chemical, pharmaceutical manufacturers, and
meat packing. Examples of industrial wastewater designs are listed below:
-
SBRs for BOD5/COD reduction at pharmaceutical plant
-
Site stream SBR for nitrification on meat packing three-stage lagoon
-
Breakpoint chlorination for ammonia removal at chemical plant and also a meat packer
-
Land application, with winter lagoon at chemical plant
-
Copper removal from printed circuit board facility using sodium borohydride
-
Integrated settling basin sludge drymg beds at foundry
Mi. Huff has also directed fourteen municipal wastewater treatment design projects. Examples of
municipal design projects are listed below:
-
Conversion of chlorine to sodium hypochlorite disinfection
-
Conversion of wet weather storage facilities to store-treat basins, with effluent disinfection filter
press for digested sludge dewater
-
Sludge storage pad with enclosure
-
Bar screen
-
Grit, washer replacement
EXHIBIT
9
-
Tertiary filter rehabilitation
U:\IHuMRESUMES 1\2004UEH 2004-WW.doc
Page 1 of 5
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
SecondaryITertiary high flow bypass with chlorine contact tank and flow measurement and
blending
Anaerobic digester supernatant treatment for ammonia removal using SBR
In
-stream high purity oxygen injection into effluent and receiving stream for increasing stream D.O.
Numerous force main and lift station designs
Mr. Huff has also designed cluster wastewater treatment systems with subsurface discharge for seven
residential
developers/country clubs, and a temple. These systems are typically 10,000 gallons per day,
utilizing two sequential batch reactors (SBR), computer controlled, followed by a large leach field. These
unique systems are permitted under the IDPH under a unique experimental use permit provision.
Mr. Huff has also conducted several CSO studies including Nine Minimum Controls, O&M Plans, and
Water Quality Impact Studies. Two novel
in-stream aeration systems, using high-purity oxygen on a
shallow Illinois stream, were designed and installed, and a system designed by
Mr. Huff for ammonia
removal
from anaerobic digesters received on engineering excellence award in 1999.
In the area of Water Quality Analysis, Mr. Huff has completed a variety of projects, including both
biological and chemical assessments.
Mr. Huff has directed studies for two of the Quad Cities to assess the
environmental impact of water treatment plant discharges on the Mississippi River. These studies
included evaluating various locations along the Mississippi for the presence of mussel beds, the potential
presence of endangered species, primarily the Lampsilis higginsi, and whether the areas were important for
fish spawning. The scope
-of-work for the mussel surveys developed by Mr. Huff were reviewed and
approved by U.S. Fish
&
Wildlife, IDOC, IEPA, and the Illinois Natural History Survey. Approvals for
both of the
outfalls were secured. On the Fox River, Mr. Huff was project manager for a group of
municipal dischargers on a project to collect and analyze weekly water quality samples along the river, its
tributaries, and
outfalls at over 30 locations to establish a better database on un-ionized ammonia levels.
Mr. Huff has directed fish and benthic surveys for industrial, storm water, and municipal wastewater
discharges located on the following waterways: Cedar Creek, Deep Run, Flint Creek,
Thorn Creek, North
Kent Creek, Tyler Creek,
Kiswaukee River, Chicago Sanitary
&
Ship Canal, and Casey Fork Creek, and
has
completed antidegradation studies as part of many of these studies. Thermal studies, mixing zone
studies, and multi
-part diffuser designs have been completed for a variety of clients.
Mr. Huff in 2004 was retained by the Northeastern Illinois Planning Commission as the lead consultant to
review FPA requests for consistency with the Commission's Water Quality Management Plan. To date,
Mr. Huff has completed over 20 FPA requests, including the Facilities Plan associated with these.
Antidegradation and nutrients have been two major issues on many of these applications.
In the hazardous waste field, over sixty industrial plants have relied on Mr. Huffs expertise for complying
with the regulations.
Mr. Huff has provided the required RCRA and DOT training, prepared inspection
plans, contingency plans, training plans, and waste minimization plans.
Mr. Huff directs H&H's
underground storage tank (UST) closure and remediation projects for a variety of clients. Both petroleum
and solvent tank releases have required regulatory reporting and
remehation. Tank systems have varied in
size from single units to 50 USTs.
Remediation designs, many associated with underground storage tank releases, are a major portion of Mr.
Huffs activities. He has designed and implemented landfming, soil vapor extraction, air sparging,
ground water pump and treat systems utilizing batch biological reactors, activated carbon, air strippers, and
in situ enhanced
bioremediation. Mr. Huff has completed treatability studies at a Federal Superfbd site
for cyanide and thiocyanate destruction in ground water, including operation of a 4,000 gpdpilot reactor at
the site and has completed a Feasibility Study
(FS) for a major chlorinated solvent release at a State
Superfund site. The selected remedy for this state site was the first in Ohio that recognized intrinsic
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
bioremediation as
part
of the remedy, and Mr. Huff is currently the Project Manager implementing the
selected remedy.
Mr. Huff has directed over fifteen hazardous waste closures of TSD facilities, ranging
fiom
drum storage areas to the complete clean-up of a 27-acre abandoned manufacturing facility. This
abandoned manufacturing site included plating solutions, cyanide bearing sludges, oils, and over 20,000
gallons of virgin chemicals requiring placement.
Mr. Huff has also been the project manager on the site
investigation at three former manufactured gas plants, and he has completed the risk assessment and a
remedial design that includes taking the coal tar to a hot-mix asphalt plant for one of these gas plant sites.
This site received one of the first comprehensive No Further Remediation letters fiom the IEPA, and was
the recipient of the top Honor Award for Engineering Excellence in 2000.
Compliance assessment is a significant part of
Mr. Huffs work. Over 100 environmental audits of
manufacturing
fms have been conducted by Mr. Huff over the last fifteen years. These audits have
included potential acquisitions as well as on
-going industrial operations. Mr. Huff has also been involved
in siting
and permitting of new industrial facilities, including a mining operation and peak energy plants.
From 1987 through 1990,
Mr. Huff was a part-time faculty member, teaching the senior level
environmental courses in the Civil Engineering Department at IIT
-West in Wheaton, Illinois.
From 1976 to 1980,
Mr. Huff was Manager of Environmental Affairs for the
Armak
Company (now Akzo
Nobel Chemicals), a diversified industrial chemical manufacturer. At Armak, Mr. Huff was responsible for
all environmental activities at eight plants located throughout the United States and Canada. Technical
work included extensive biological and chemical treatability studies
as well as designing new facilities,
including two wastewater pretreatment facilities, a land application system, and an incinerator system.
Previously,
Mr. Huff was an Associate Environmental Engineer in the Chemical Engineering Section at
12[T
Research Institute (IITRI). Much of this work involved advanced wastewater treatment development,
including applying a combination of
ozone/LTV treatment of cyanide, PCB's, RDX, HMX, and
TNT and the
use of catalytic oxidation of cyanide using powdered activated (carbon impregnated with copper in refinery
activated sludge units. At Mobil Oil's Joliet Refinery
Mr. Huff was employed as an Advanced
Environmental Engineer during the construction and start
-up of the largest grassroots refinery ever
constructed. Mr. Huff was responsible for wastewater training, permitting start
-up, and technical support
as well as for water supply, solid waste, and noise abatement issues at the refinery fiom 1971 to 1973.
Membership
Illinois Association of Wastewater Agencies
Consulting Engineers Council of
Illinois
Environmental Committee 1999
-
Present
Chairman
-June 2000-Present
Water Environment Federation Member
Illinois Water Environment Federation
National Water Well Association
Certified Class
2 and Class K Sewage Treatment Works Operator in Illinois
Licenses:
Registered Professional Engineer, Illinois and New Jersey
Papers:
"Ozone-U.V. Treatment of TNT Wastewater," E.G. Fochtman and J.E. Huff, International Ozone Institute
Conference, Montreal, May 1975.
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
"Characterization of Sensory Properties" Qualitative, Threshold, and Supra-Threshold," J.E. Huff and
A.
Dravnieks, American Water Works Assoc. Seminar, Minneapolis, MN, June 1975.
"Optimizing Wet Scrubber Systems for Odor Control in the Rendering Industry," R.H. Snow, J.E. Huff, and W.
Boehme, Purdue Air Quality Conference, Lafayette, IN, November 1975.
"Control of Rendering Plant Odors by Wet Scrubbers: Results of Plant Tests," R.H. Snow, J.E. Huff, and W.
Boehme,
APCA Conference Boston, MA, June 1975.
"Asbestos Manufacturing Waste Disposal and Utilization," P. Ase, J.E. Huff, L.L. Huff, C.F. Harwood, and D.
Oestreich, Mineral Waste Utilization Symposium, Chicago, IL, April, 1976.
"Alternative Cyanide Standards in Illinois, a Cost-Benefit Analysis," L.L. Huff and J.E. Huff, 31st Annual
Purdue Industrial Waste Conference, Lafayette,
IN, May 1976.
"Cyanide Removal fiom Refinery Wastewaters Using Powdered Activated Carbon," J.E. Huff, J.M. Bigger, and
E.G. Fochtman, American Chemical Society Annual Conference, New Orleans, LA, March 1977. Published in
Carbon Adsorption Handbook, P.N. Cheremisinoff and F. Ellerbusch, Eds.,
Ann Arbor Science Publishers, Inc.,
1978.
"Industrial Discharge and/or Pretreatment of Fats, Oils and Grease," J.E. Huff and E.F. Harp, Eighth
Engineering Foundation Conference on Environmental Engineering, Pacific Grove, CA, February, 1978.
"A Review of Cyanide of Refinery Wastewaters," R.G. Kunz, J.E. Huff, and J.P. Casey, Third Annual
Conference of Treatment and Disposal of Industrial Wastewater and Residues, Houston, TX, April 1978.
Published as:
"Refinery Cyanides: A Regulatory Dilemma," Hydrocarbon Processing, pp 98-102, January,
1978.
"Treatment of High Strength Fatty Amines Wastewater
-
A Case History," J.E. Huff and C.M. Muchmore, 52nd
Conference
-
Water Pollution Control Federation, Houston, TX, October 1979. Published JWPCF, Vol. 54, No.
1, pp 94-102, January, 1982.
"An Overview of Environmental Regulations," E.F. Harp and J.E. Huff, Soap
&
Detergent Association Annual
Meeting, Boca
Raton, FL, January 1980.
"A Proposal to Repeal the Illinois Pollution Control Board's Construction Permit Water Regulations," J.H.
Russell and J.E. Huff, Chicago Bar Record, Vol. 62, No. 3, pp 122-136, Nov.-Dec., 1980.
"Disinfection of Wastewater Effluents in Illinois-A Cost-Benefit Analysis," L.L. Huff and J.E. Huff, Illinois
Water Pollution Control Association 2nd Annual Conference, Kankakee,
IL, May 20, 198 1.
"Measurement of Water Pollution Benefits
-
Do We Have the Option?" L.L. Huff, J.E. Huff, and N.B.
Herlevson,
IL Water Pollution Control Assn 3rd Annual Conference, Naperville, IL, May 1983.
"Evaluation of Alternative Methods of Supplementing Oxygen in a Shallow Illinois Stream," J.E. Huff and J.P.
Browning, IL Water Pollution Control Assn 6th Annual Meeting, Naperville, IL, May 7, 1985.
"Environmental Audit for Wastewater Compliance," J.E. Huff, Federation of Environmental Technologists
Environmental '86 Seminar, Milwaukee,
WI, March 5, 1986.
"Technical and Economic Feasibility of a Central Recovery Facility for Electroplating Wastes in Cook County,
IL,
" J.E. Huff and L.L. Huff, 1986 Governor's Conference on Science and Technology in Illinois, Rosemont,
IL, Sept.
3,
1986.
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
"Hazardous Waste Closure Procedure,"
J.E. Huff, Federation of Environmental Technologists Seminar,
Rockford, IL,
Dec. 17, 1986.
"Training
&
Contingency Plan Requirements Under the Hazardous Waste/Right-To-KnowIOSHA Regulations,"
J.E. Huff, Federation of Environmental Technologists Environment '88, Milwaukee, WI, March 9, 1988.
"BiomonitoringlBioassay," J.E. Huff, Federation of Environmental Technologists Seminar, Harvey, IL,
December 11, 1989.
"Storm Water Discharges," J.E. Huff, Federation of Environmental Technologists Environment '90 Seminar,
Milwaukee,
WI, March 7, 1990.
"Cleanup Standards-Past, Present and Future,"
J.E. Huff and D.O1Neill, Chicago Bar Association's
Environmental Law Seminar
"Underground Tanks: Down and Dirty," Chicago, IL, June 8, 1993.
"Engineering Aspects of Individual Wastewater System Design," J.E. Huff, 22nd Annual Northern Illinois
Onsite Wastewater Contractors Workshop, St. Charles, IL, February 27, 1995.
"Illinois Site Remediation Program," J.E. Huff, Institutional Lenders Environmental Focus Group, Chicago, IL,
March 14, 1997
"Cleaning Up Contaminated Property in Illinois," J.W. Watson and J.E. Huff, Midwest Environmental
Corporate Counsel Association, September 18, 1997.
"Total Maximum Daily Loadings (TMDL) and Ammonia Conditions in the Fox River Waterway," J. E. Huff
and S. D.
LaDieu, Illinois Water '98 Conference, Urbana, IL, Nov. 16, 1998.
"The Illinois Ammonia Water Quality Standards: Effluent Im
p
lications
&
Strategies for Compliance," L.R.
Cunningham
&
J. E. Huff, Illinois Water '98 Conference, Urbana, IL, Nov. 16, 1998.
"Beneficial Reuse of Coal Tar Impacted Material in Recycled Asphalt-LaGrange Illinois Case Study," J.E. Huff,
Midwest Energy Association's Environmental Management Conference, Denver, CO, October 5,2000 and at
the Site Remediation Technologies
&
Environmental Management Practices in the Utility Industry, Orlando, FL,
December 4-7,2000.
"Impact of a High Sulfate and TDS Industrial Discharge on Municipal Wastewater Treatment," J.L. Daugherty,
J.E. Huff, S.D. LaDieu, and D. March, WEFTEC 2000, Anaheim, CA, October 17,2000.
"Remediation of MGP Source Material Below the Water Table
&
On-Site Water Treatment," J.E. Huff, M.
Matuck, and L.M. Paulson, Midwest Energy Association Environmental Management Conference, Itasca,
IL,
October 28,2002.
"Phase I1 Storm Water Regulations
-
Compliance Strategies For The Gas
Transmission/Distribution
Industry,"
J.E. Huff, American Gas Association 2003 Operations Conference, Orlando, Florida, April 28,2003.
"Endocrine Disrupters or Better Living Through Chemistry" Illinois Association of Wastewater Agencies Fall
Meeting,
Bloomington, I., November 14,2003.
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
IN THE MATTER OF:
1
)
1
REVISIONS TO WATER QUALITY
)
STANDARDS FOR TOTAL DISSOLVED
)
R06-24
SOLIDS
IN THE LOWER DES PLANES RIVER
)
(Site Specific Rule
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Water)
EXXONMOBIL OIL CORPORATION
1
PROPOSED 35 ILL. ADM. CODE 303.445
1
TESTIMONY OF STACEY K. FORD
I.
BACKGROUND
My name is Stacey K. Ford. I have been employed by ExxonMobil for the past 15 years.
I have worked at the Joliet Refinery since December 2001.
At the Joliet Refinery, I have held
the position of Environmental Group Leader and currently I serve as the New Source Review
Consent Decree Coordinator. I received a Bachelor of Science in Environmental Engineering in
1991 from
Cornell University and was awarded a Masters of Science in Management from
Boston University in
1996.
Prior to my time at the Joliet Refinery, I served as the ExxonMobil Advisor to American
Petroleum Institute and American Chemistry Council environmental committees. My experience
additionally includes engineering and environmental positions at the Coryton Refinery (Essex,
England) and the Torrance Refinery (Torrance, California) and various Petroleum Distribution
and Fuels Marketing facilities. Additionally, I have served as a facilities engineer for Mobil
Research and Development Corporation.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
11.
GENERAL REFINERY INFORMATION
The Joliet Refinery is located in Channahon Township on a 1,300-acre tract of land in
unincorporated Will County, Illinois. The site is adjacent to Interstate 55 at the Arsenal Road
exit, approximately 50 miles southwest of Chicago. To the immediate north of the refinery is the
Des Plaines River, while east and south is the former Joliet Army Arsenal, which is currently
being redeveloped as an industrial complex and the
Midewin National Tallgrass Prairie.
The Joliet Refinery employs more than 500 full
-time ExxonMobil employees to manage,
provide engineering for, and operate and maintain the plant. The refinery operates 24 hours a
day every day. Approximately 100 additional ExxonMobil employees who provide regional
support services are located at the refinery. Approximately 150 full
-time contractor employees
provide a variety of maintenance functions at the refinery on a continual basis. Construction
projects and intensive maintenance periods called turnarounds can swell the contractor
workforce by thousands during the year.
The refinery was built by ExxonMobil and began operating in 1972.
It was one of the
last grass
-roots refineries built in the United States. The refinery has a crude oil processing
capability of approximately 240,000 barrels per day, or nearly 10.1 million gallons a day. The
single
-train, high-conversion refinery produces approximately 9 million gallons a day of gasoline
and diesel fuel. Other products include: liquefied petroleum gas
("LPG"), propylene, asphalt,
sulfur and petroleum coke.
The refinery draws from and discharges to the Des Plaines River, approximately 1,000
feet northeast of the 1
-55 Bridge. The refinery takes approximately 10.2 million gallons of water
daily from the River, and 2 million gallons per day from wells, and discharges approximately
12.3 million gallons to the River.
[On average, stormwater quantities more than offset the
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
amount of water evaporated in the refinery.] The wastewater effluent contains dissolved solids
derived from compounds present in crude oil that are removed from the crude by various refinery
operations, as well as concentrating the total dissolved solids (
"TDS") present in the intake water
from the River from the evaporation cooling.
111.
DESCRIPTION OF REFINERY EFFORTS TO REDUCE EMISSIONS
The purpose of my testimony is to describe the current efforts by ExxonMobil to reduce
air and water emissions
from the Joliet Refinery. In December 2005, ExxonMobil entered into a
Consent Decree with the United States Environmental Protection Agency (
"U.S. EPA") and the
States of
Illinoisy Louisiana, and Montana to resolve certain alleged regulatory violations at
ExxonMobil refineries.
As part of this Consent Decree, ExxonMobil has agreed to install
1
pollution control equipment at the Joliet Refinery to reduce emissions of sulfur dioxide by over
95% or over 24,000 tons per year and nitrogen oxides by approximately 50% or over 1,800 tons
per year. (A copy of the December 2005 Consent Decree is submitted as Exhibit
1.)
ExxonMobil has a challenging schedule in order to ensure start-up is completed by
December 2008, and the consent decree schedule is met. The project is currently in the detailed
design stage. In order to ensure project completion, construction must begin by July 2007. Prior
to construction, the refinery must have a renewed National Pollutant Discharge Elimination
System (
"NPDES") permit and a construction permit for the project. Both are dependant on the
Board approving the Petition for a Site Specific Rule.
The Joliet Refinery currently operates under a NPDES permit (No. IL 0002861) issued by
the Illinois Environmental Protection Agency (the
"Illinois EPA" or the "Agency"). The permit
was modified on September 12,2001 and does not include effluent limits on TDS. The permit is
submitted as Exhibit
4.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
The Joliet Refinery wastewater treatment plant includes physical, chemical, and
biological treatment units used to perform primary, secondary, and tertiary treatment prior to
water discharge to the Des Plaines River. The original wastewater treatment plant, which began
operation in
1972, includes two pre-separator flumes for oil removal, two API separators for oil
and total suspended solids (
"TSS") removal, two dissolved air floatation units for further oil and
TSS removal, two activated sludge units, followed by a final effluent polishing basin and
aeration.
A revised wastewater treatment basin schematic is submitted as Exhibit 5.
The refinery has made numerous improvements to its wastewater treatment plant since its
initial start-up. These improvements include the addition of a large equalization basin with
aggressive biological treatment, larger blowers on the activated sludge units, new internals in the
secondary clarifiers, and upstream process changes able to reduce the pollutant loadings on the
treatment system. Additionally, the refinery has implemented a
"No Oil to Sewer" program
plantwide.
As described in our petition for a site
-specific rule change and briefly below, to meet the
emission requirements of the consent decree,
ExxonMobil will be installing a wet gas scrubber
(
"WGS") in the Fluidized Catalytic Cracking ("FCC") unit as well as other equipment in the
Joliet Refinery.
In addition, and to mitigate the amount of sulfates and dissolved solids to be
discharged, the Joliet Refinery will be using an added technology: Catalytic
SO2 Additive
Technology (
"DESOX).
The DESOX control complements the WGS and reduces SO2
emissions by transferring sulfur to a stable form able to be recovered as elemental sulfur. A
summary description of these technologies is submitted as Exhibit
3.
The WGS will create
additional sulfate and TDS in the Joliet Refinery treated wastewater.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
The WGS technology begins with the flue gas stream after the DESOX process. The
sulfur dioxide ultimately is converted to sodium sulfate salts in the WGS that are discharged in a
purge stream. This purge stream will be cooled, the catalyst solids removed and discharged
upstream of the refinery
Outfall 001 in the waste stream treatment system. Three alternative
treatment processes for the catalyst fines and ammonia are under consideration by the refinery.
None of these options will change the TDS or sulfates discharged, which are the subjects of this
site
-specific rule request.
The exit temperature will be limited to 90°F either by the
specifications for the WGS purge system or the equivalent
BTU's will be removed elsewhere in
the refinery. The particular design of the WGS is a proprietary technology and design for
ExxonMobil. This WGS technology allows refineries to reliably meet stringent FCC emission
requirements with well
-proven technology.
The WGS technology has the following advantages:
Can avoid costly CO boiler upgrades with allowable scrubber pressure drops as
low as zero inches of water;
Maximizes cat cracker availability
--
scrubber run lengths match longest FCC up-
time in the industry;
Extremely high reliability [99.9%+] with over 200 years of operating experience;
Meets or exceeds toughest particulate and SOX emission regulations;
Produces environmentally benign wastewater safe for direct discharge;
Collected catalyst suitable for direct low-cost disposal; and
Smallest commercially-proven FCC unit scrubber as it needs only 113 to 112 the
area of competitive systems.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
Dry scrubbing technology was considered instead of the WGS, but was not selected due to the
following disadvantages:
Dry scrubbing process cannot accomplish the desired SOz removal to comply
with the Consent Decree; and
Dry scrubbing processes cannot meet the run time consistent with an FCC unit.
While the DESOX technology complements the WGS and reduces the TDS loading to the sewer
system, it is inadequate by itself to achieve the requirements of the Consent Decree.
ExxonMobil has completed or plans further improvements to the existing wastewater
treatment system or in the upstream portion of the refinery to reduce pollutant loadings. These
improvements include the installation of a Purge Treatment Unit as part of the WGS project, sour
water stripper pH optimization able to reduce ammonia loading on the wastewater treatment
plant, installation of alternate piping to reroute FCC and
Reformer feed tank water draws from
the wastewater treatment plant to the light slop system, increased flow monitoring in the
wastewater treatment plant, and installation of new internals in the dissolved air floatation unit.
IV.
ALTERNATIVES INVESTIGATED
U.S. EPA has promulgated categorical limits on various industries, including the
petroleum refining industry.
The Joliet Refinery's wastewater treatment plant effluent
parameters meet or are well below all federal effluent guidelines and standards for the
appropriate petroleum refinery point source subcategory (40 C.F.R. 419, Subpart B
-
Cracking
Subcategory). The flow rate used to derive the Best Available Technology (
"BAT") effluent
values for a refinery the size and configuration is 5,200 gallons per minute (gpm), while the
refinery's actual current flow rate is 2,200 gpm, with a maximum hydraulic flow rate of 3,400
gpm. The refinery's wastewater treatment system goes beyond BAT requirements.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
The approach being pursued by ExxonMobil minimizes the overall environmental impact
and costs associated with the Consent Decree. Moreover, applying the existing TDS water
quality standards in this situation is neither technically feasible nor economically reasonable.
The Consent Decree, to which the Illinois EPA is a party, substantially reduces emissions of
sulfur dioxide, nitrogen oxides and particulate matter.
ExxonMobil agreed to these reductions
and will be investing over $180 million at the refinery, most of which costs are for the WGS,
which generates the TDS and sulfates identified above, and treatment for thermal, TSS and
ammonia removal. These investments are projected to reduce
SO2 emissions by over 24,000
tonslyear, and NOx emissions by over 1,800 tonslyear.
Petitioner has investigated methods of avoiding releasing the wastewater from the FCC to
the existing wastewater treatment system, including deep well disposal and removal technologies
as discussed in the testimony of James E. Huff. None of these alternatives are technically
feasible. Technologies for removing sodium sulfate from a dilute aqueous stream are limited.
Electrodialysis never has been applied in the chemical or refinery industries on the scale required
at the refinery. Biological sulfate reduction theoretically is possible, but this will not reduce the
overall TDS concentration merely by replacing the sulfate ions with carbonate ions. The
concentration of sodium sulfate is too high for reverse osmosis concentration, as the osmotic
pressure of the solution is too high.
The sole technology potentially available is
evaporation/crystallization,
an energy-
intensive approach that will result in increased carbon dioxide emissions to the atmosphere. Due
to the lack of space available at the refinery, construction of a
crystallizer/evaporator would
require removal of existing tankage, site preparation activities, as well as the construction of a
crystallizer unit sufficient to remove about 200 gpm of water, and handling of potentially 90 tons
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
per day of a dry sodium sulfate by-product (sulfate salt). Whether this by-product would be of
sufficient purity to have any market value, and whether demand for the large amount of sulfate
salt exists, has not been determined. The salt would possibly end up as a waste stream that
required disposal. The equipment required for the
evaporation/crystallization unit would include
a sulfuric acid storage tank
[6,000 gallon capacity], metering pumps, a pH adjustment tank, a
degasification tower, a 200 gpm crystallizer feed pump, a 24,000 gallon crystallizer feed surge
tank, a crystallizer system, consisting of a tower, pumps, drums
[lo ft diameter and 40 ft tall], a
preheat exchanger, a condenser and various surge tanks, driers, and instrumentation controls and
valves. The
evaporation/crystallization technology also would be paired with pretreatment. The
estimated cost of this size of the
evaporation/crystallization
system, including oxidation and
solids removal, is $36 million to
$56 million.
Operating costs, including depreciation, are estimated to exceed
$1 million per year, with
40% of this amount representing energy costs. The above cost estimate assumes the refinery has
sufficient steam capacity, and that a new boiler would not be required. If it was determined that
sufficient steam capacity did not exist, the refinery would need to increase boiler capacity or
install another boiler, potentially increasing capital cost by $3 million to $4 million for the
project. Moreover, Petitioner is not aware of a situation where the salt from the purge stream of
refinery WGS has been precipitated to produce a solid salt. Most applications of WGS utilizing
circulating caustic soda solution for absorption and removal of
SO;! in the refining industry have
been allowed to discharge the purge stream with their other wastewater. Therefore, assessments
of precipitation performance reliability impacted by corrosion and fouling are uncertain. Further
investigation would be warranted before such an approach was pursued.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
Short-term episodic storage is neither technically feasible nor economically reasonable.
The refinery has a relatively small footprint. All of the areas near the wastewater treatment plant
already are fully occupied by existing tankage, and that tankage is expected to be fully utilized in
the future, particularly in light of the energy needs of the region. The refinery would need to
remove one or two currently utilized tankage limiting flexibility of operations and replace with a
new 200,000 barrel storage tank, pumps, secondary containment, and associated piping. The
cost estimate for this option is $13,200,000.
Requiring Petitioner to install wastewater treatment for the scrubber TDS discharges into
the wastewater system is not economically reasonable. Petitioner is not the cause of any water
quality standard exceedance for TDS. Petitioner is investing substantial monies in the refinery to
substantially reduce air emissions and to substantially reduce the overall environmental releases
from the Joliet Refinery. The wastewater discharge involved is relatively modest and would not
pose an adverse threat to the receiving stream.
V.
CONCLUSION
Prior to filing its petition for an amendment to the current TDS regulations, ExxonMobil
discussed these issues at some length with the Illinois EPA. Based on those discussions, the
regulatory language proposed in the Petition appeared to address those issues. That language is
submitted as Exhibit 10. Additionally, there have been discussions between Illinois EPA and
U.S. EPA to confirm whether the approach proposed here is federally approvable which we
understand the Agency will address in its testimony for this proceeding. (See also Exhibit 2.)
ExxonMobil will invest over
$1 80 million on installation of pollution control equipment
at the Joliet Refinery in order to reduce its environmental impact. ExxonMobil will expend
approximately $40 million to remove the catalyst fines and to meet the TSS limitations and as
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
part of its wastewater control efforts. These improvements will allow the refinery to meet TSS
standards but not the limitations for TDS. There is no environmental benefit to reducing the
TDS discharge for the
WGS. Moreover, applying the existing TDS standards in this situation is
neither technically feasible nor economically reasonable. Therefore,
ExxonMobil requests relief
from the water quality standard for TDS as stated in the Petition and supporting exhibits.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
PROPOSED RULEIAMENDMENT LANGUAGE
Based on the suggestions we have received from the Illinois EPA, Petitioner proposes
that the following section be adopted by the Board:
303.xxx Seasonal Total Dissolved Solids Water Quality
Standard for the Lower Des Plaines River.
The TDS water quality standard for Secondary Contact and
Indigenous Aquatic Life Use water does not apply to the waters of
the state, from the dates November 1 through April 30, that are
located from the point of discharge of the
ExxonMobil discharge
point located at Interstate 55 and Arsenal Road into the Des
Plaines River, said point being located in Will County,
T34N, R9E,
S15, Latitude: 41°25" North, Longitude: 8S0, 1 1', 20" West to the
Interstate 55 bridge. TDS levels in such waters must meet a water
quality standard for TDS (STORET Number 70300) of 1,686
mg/L.
The TDS water quality standard for General Use water does not
apply to the Des Plaines River, from the dates November 1 through
April 30, from the Interstate 55 bridge to the confluence of the Des
Plaines River with the Kankakee River. TDS levels in such waters
must meet a water quality standard for TDS (STORET Number
70300) of 1,686
mg/L.
EXHIBIT 10
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
CERTIFICATE OF SERVICE
The undersigned, an attorney, certify that
I have served upon the individuals named on the
attached Notice of Filing true and correct copies of the
TESTIMONY OF JAMES E.
HCJFF
and the
TESTIMONY OF STACEY
K. FORD,
via electronic mail and First Class Mail, postage prepaid on
May
3 1,2006.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MAY 31, 2006
