than 2.5 mg/L of total ammonia nitrogen as N during the months of Apni through October,

or 4 mg/L at other times.

Sources discharging to

any

of the above waters

and

whose untreated waste load cannot be

computed on

a population equivalent basis comparable to that used for municipal waste

treatment plants

and

whose total ammonia

nitrogen as N discharge exceeds 45.4 kg/day(100

pounds per day) shall not discharge an effluent of more than 3.0 mg/L of total ammonia

nitrogen as N.

In addition to the effluent standards set forth in subsections

(a)

and

(b) of

this

Section,

all

sources

are

subject to Section

304.105.”

Section 304.105 states “In addition to the other requirements of

this

Part, no effluent shall, alone or

in combination

with

other sources, cause a violation of any applicable water

quality

standard.”

In my professional opinion, Sections 304.1 22a and 304.122b

do not apply to the Noveon-Henry

Plant discharge for several reasons.

The Noveon-Henry Plant untreated waste load can be “computed on a population

equivalent basis comparable to that

used for municipal wastewater treatment plants”.

Consequently, 304.122b does not apply. In my opinion, the word “comparable” merely

questions whether the data exist to express an untreated waste load in population equivalents

one does when either designing or evaluating a municipal wastewater treatment plant.

The data for the Noveon-Henry Plant do

existand such calculations can be and have been

made. The results from such calculations allow one to put the Noveon-Henry Plant’s

untreated waste load in a perspective others can readily understand (population

equivalents).

The term “population equivalent basis” is intended to put the relative

size of an untreated

waste load in perspective. The term was never intended to describe how the waste load was

to be treated but only the magnitude of the waste load.

•

An untreated waste load

can

be and has been calculated by me for the Noveon-Henry

Plant

discharge on “a population equivalent basis comparable to that used for municipal waste

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treatment plants”.The correct results from these calculations are stated below and clearly

define the Noveon-Henry Plant discharge as having less

than 50,000 population equivalents.

Consequently, 304.122a does not apply.

•

Since Sections 304.122a

and

304.122b do not apply, the Noveon-Henry Plant is not

required to provide additional effluent ammonia-nitrogen removal.

As stated above, correct calculations clearly define the Noveon-Henry Plant discharge as having less

than 50,000 population equivalents. IEPA has calculated the population

equivalents of the

Noveon-Flenry

Plant for flow and BOD

(based on data provided in the Baxter and Woodman-

Wastewater Treatment

Plant Report dated June

1994.

This

report

did

not present any

data

on the

combined untreated wasteload. The report discussed the wasteload fed from the equalization tanks

to the primary clarifier. However,

this

wasteload contains wastestreams that are internal to the

WWTF that add flow, BOD,

and

TSS including primary clarifier sludge

when sludge dewatering is

not occurring, filtrate from sludge dewatering, and backwash water from the tertiary (secondary

clarifier effluent) filter. These wastewaters and internal recirculation

streams are illustrated in Figure

above.

Even

with this

addition of flow and BOD

from recircuclating streams,, IEPA

calculated

flow and BOD population equivalents of 916 and 19,412, respectively. I corrected

the population

equivalent calculation for TSS based on data collected by Noveon during the period ofJuly 2002

through June 2003. The corrected value was 24,955 as illustrated below and in Figure 1.

This

calculation depends upon

calculating the untreated waste load TSS coming to (not recycling within)

the

WWTF

from all

sources and then adding them togetherwhich is done below. The waststreams

which

contribute TSS to the

WWTF

are

the PVC Lift Station Discharge which represents the waste

load discharged from the PolyOne production areas, the 213 wastestream waste load before

pretreatment,

the

PC Tank discharge, and the C-18 Tank discharge. It should be noted

that

the

C-18

wastewater pretreatment process does not change

the

flow or TSS of

this

discharge but does

increase its BOD. The TSS discharged

by the combined Well No.

and

Storm/Utility Pond

discharges

are less

than 25 percent of the total influent wasteload as reported in

the

Baxter and

Woodman report referenced above..

•

PVC Lift Station Discharge Averages(not the PVC

Tank

Discharge Averagespresented in Baxter

and

Woodman Report):

133

gpm,

1957 mg/TSS,

and

3123

lbs/day TSS

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