NOTICE OF FILING
THIS FILING IS SUBMITTED ON RECYCLED PAPER
Introduction
PolyOne
Impact ofNoveon and PolyOne on the Local Economy
Conclusion

H280420 NaOH 20 NaOH
CLEAN PA FEED
AQUEOUS
PHASE

SOLIDS
1. TO PROCESSCHLOROMORPHOUNE
RECOVERY
(EXIST3NG)
1. TO WASTE TREATMENT
AQUEOUS PHASE
TBA RECOVERY
TANK (EXISTING)

RECE~VED

CLERK’S OFFICE

BEFORE THE ILLINOIS POLLUTION CONTROL

BOARD

FEB

62004

‘THE MATTER OF:

Petition ofNoveon, Inc.

for an Adjusted Standard from

Ill.

Adm. Code 304.122

NOTICE OF FILING

Dorothy M.

Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph Street

Suite

11-500

Chicago, IL

60601

Deborah Williams

Assistant Counsel

Division ofLegal Counsel

Illinois Environmental Protection

Agency

1021 N. Grand Avenue East

Springfield, IL

62794-9276

Bradley P. Halloran

Hearing Officer

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph Street

Suite 11-500

Chicago, IL

60601

PLEASE

TAKE

NOTICE

that

Friday,

February

2004,

filed

the attached

Written Testimony of David Giffin

with the Illinois Pollution Control Board,

a copy of which

is herewith served upon you.

Richard J. Kissel

Mark Latham

Sheila H. Deely

GARDNER CARTON & DOUGLAS LLP

191

N. Wacker Drive

—

Suite 3700

Chicago, IL

60606

312-569-1000

Respectfully submitted,

NOVEON, INC.

By:

One ofIts Attorne

)

02-5

)

STATE OF ILLINOIS

Pollution Control Board

THIS FILING IS SUBMITTED

ON RECYCLED PAPER

BEFORE

TILE

ILLINOIS POLLUTION CONTROL BOARIR ~

E ~YE

CLERK’S OFFICE

IN THE MATTER OF:

)

FEB

62004

Petition ofNoveon, Inc.

)

STATE OF ILLINOIS

)

AS 02-5

POII~tj~~

Control Board

)

for an Adjusted

Standard from

)

35111. Adm. Code 304.122

)

Written Testimony ofDavid Giffin

My name is David Giffin.

I reside at 336 County Road, 850 North, Sparland,

Illinois (approximately 18 miles west ofthe Noveon Henry Plant).

I am the HSE (Health

Safety and Environmental) Manager forthe Noveon Henry Plant.

I graduated from the

University of Illinois in 1967 with a Bachelor of Science degree in Zoology and a minor

in Chemistry.

In 1975 I received a Master’s ofEngineeringAdministration (MEA)

degree from Bradley University.

Introduction

I have been employed at the Henry Plant for 34 years.

I started as an Associate

Engineer at the Henry Plant afterbeing discharged from United States Army in July

1969.

In this capacity I worked as a shift foreman for 13

months in the Polymer

Chemicals’ area.

From

1970 to

1972, I worked as a Process Technical engineer in the

Polymer Chemicals’ area.

I was then asked to be the PlantEnvironmental Engineer, a

position I held from 1972 to 1978.

In 1978, I transferred to the Geon production area as

the General Foreman ofSuspension and Dispersion production.

In 1979, I became the

Production Manager for Geon Suspension and Compound production.

In 1982,1 became

the Technical Manager of Geon Suspension and Compounding.

In 1983,1 was asked to

be the Plant Engineer ofthe facility.

In 1992, I was asked to be the HSE Manager ofthe

facility and finally in March 1993,

I assumed my current position as the HSE Manager

for the Noveon plant.

Through my work experience I have interfaced with all ofthe

processes affected by the current NPDES Permit Appeal and Petition for an Adjusted

Standard.

The Noveon

Henry

Plant

The Henry Plant site was established in 1958 by BFGoodrich as a chemical

process facility manufacturing rubber chemicals for the rubber industry.

This site was

selected by BFGoodrich initially due to its unique location in proximity to the Illinois

River, Rock Island railroad system, state highway system, electrical power resources,

natural gas resources, water resources and positive work ethic ofthe local rural

population. The property was purchased adjacent to land owned by Rohm and Haas.

Since

1958, the plant has expanded and changed so that two separate companies,

Noveon, Inc. and PolyOne, now co-exist at the same site. PolyOne manufactures poly

vinyl chloride products and was created as a separate entity in 1993 when BFGoodrich

spun the Geon Vinyl division offand created a separate publicly traded company, the

Geon Company.

In 2001, Noveon, Inc. was created when BFGoodrich sold the

remainder ofits chemical operations to a private investment group.

The facility has a utility operation that serves both sides ofthe plant.

The utility.

operation consists of a boiler operation, water treatment process and a complex

wastewater treatment system that serves both companies on site.

The boiler operation is

owned and operated by Poly One while the water treatment and waste treatment systems

are owned and operated by Noveon.

In 1985, with the assistance ofthe State of Illinois,

BFGoodrich constructed a state ofthe art circulating fluid bed coal fire boiler for $21

million that

is capable ofburning Illinois high sulfur coal environmentally clean.

This

boiler has been in operation for the past 17 years consuming high sulfur Illinois coal and

supporting manyjobs in the Illinois coal industry.

The state ofthe art wastewater

treatment system is owned and

operated by Noveon, providing wastewater treatment for

both company’s wastewaterprocesses.

Noveon Products

The Noveon facility currently produces antioxidants and accelerators for the

mbber and plastics industry and employs 75 people.

Recently, the facility has added

Personal Care and Carboset products to its mix ofproducts.

The antioxidants and

accelerators are the “salt and pepper” chemicals used in the production ofrubber and

plastics.

In other words, the chemicals are used in small amounts to provide very key

effects for the rubber and plastic industries.

Without antioxidants present in sucharticles

such as rubber bands, the rubber band as it expands

and contracts will develop holes in

the rubber and quickly break.

This concept applies to tires as they support a vehicle and

roll down the road;

tires could not function safely without antioxidants.

One ofour

products called Geltrol is even approved for food grade applications such as baby bottle

nipples.

The accelerator products are used in the manufacture ofspecific rubber tires in

such a way that the vulcanizing process does not require 8 or 10 hours but accelerates the

curing action so that radial tires can be cured evenly in less than 30 minutes.

In practical

terms, this means that a tire that is going to cost less and last longer.

In light ofthe competitiveness of the rubber industry, the company more recently

has been expanding its productbase to include Personal Care products and Carboset

products that impact less competitive markets and have new product and better growth

marketing potentials.

PolyOne

The PolyOne facility produces specialtypolyvinyl chloride resins for niche,

specialty markets and the flooring industry and has an employment ofapproximately 100

people.

The resins produced by PolyOne have a myriad number of applications including

the wear layer (top layer) ofresilient floors, the support base ofthe resilient floor (bottom

layer), protective coating ofcans used for food processing and vinyl wallpaper.

Impact ofNoveon and

PolyOne on the Local Economy

Each ofthe companies play a major role in supporting the local

economythrough

payment ofwages, purchase ofmaterials locally and the payment ofreal estate taxes

(PolyOne

~$128,000 and Noveon

$142,000).

On an annual basis, each company

supports a payroll including benefits of$8.2 million (PolyOne) and $6.2 million

(Noveon).

These payrolls provide the economic energy that helps support the community

of Henry (population 2700) as well as local businesses within Marshall County and

elsewhere.

The average hourly rate for a chemical operator working at the site is

approximately $23/hour.

During a grant award ceremony for PolyOne as an aide to

Robert Michael, U.S. Representative Ray LaHood said “This company is like the

Caterpillar ofMarshall County in thejobs it provides and the stability it provides the

community.”

Typical economic models indicate that for everyjob created by Noveon’s

type ofindustry, six jobs

are created as a resultto support its overall production activities.

Overview ofWastewater Treatment Systems

The facilities’ wastewater treatment system (refer to the attached drawing)

serves

both companies on site.

It consists ofwastewater storage tanks for each company that

feed a primary treatment system consisting ofpH control, flocculant addition and

clarification.

The clarified wastewater is then fed to a secondary treatment system

consisting ofan activated sludge system involving four separate biotreaters (totaling 2

million gallons) and thento

a clarifier designed to remove and recycle the activated

sludge back to the biotreaters.

The clarified effluent is finally fed to a tertiary treatment

system consisting oftwo traveling bed sandifiters.

In addition to this system, non contact

water from the watertreatment system, boiler operations and storm water runoffare

collected in separate ponds and are either fed back into the wastewater treatment system

orto a Parkson sand filter, combined with the wastewater treatment effluent and

discharged to the Illinois river through a single port discharge pipe.

The wastewater treatment system has undergone a number ofimprovements

throughout the life ofthe facility.

In 1972, the primary and secondary systems (800,000

gallon aerationpond) were installed. The secondary system was changed in 1987 and

1988 to

above ground aerationtanks (1,000,000 gallons), and a sludge removal system

was added.

An initial tertiary sand filter system was installed in 1989.

This tertiary

filtering system was expanded to a second sand filter in

1992.

Additional aeration

(1,000,000 gallons) was added to the system in 1997 to provide more complete treatment

ofthe wastewater organic load to the system.

During the time period between 1990

and

the present, many studies were conducted to evaluate methods for removing the ammonia

nitrogen from the plant effluent.

The Noveon processes do not discharge any significant ammonia nitrogen directly

to the wastewater treatment system.

They do, however, discharge complex amine

chemicals to the wastewater system including tertiary butyl amine and morpholine.

These materials are discharged directly to the wastewater system due to the un-reacted

portion ofeach chemical or indirectly due to loss offinished solid product to the

wastewater system.

The solid product canbreak back down into amine bearing

byproducts.

The PolyOne processes discharge a small amount ofammonia nitrogen

directly to the wastewater system in the form ofammonium laurate, a dispersing agent

used in theirpolymerization reaction step.

Depending on the efficiency ofthe current

activated biotreater system, the complex amines and amine bearing byproducts are

converted to ammonia nitrogen and the ammonia from ammoniumlaurate are discharged

to the Illinois River.

Source Reduction

Efforts

Noveon through its Pollution Prevention efforts has evaluated all ofits processes

for contributing ammonia precursors to the wastewater treatment system.

Through these

evaluations the following source reduction activities have been pursued:

In 1990 a process evaluationlliterature search for removing morpholine from

the OBTS process was conducted by our R&D scientists.

The technology

identified forthe removal ofmorpholine involves a liquid/liquid extraction

system (refer to attached flow diagram).

It begins with chlorinating the

unreacted morpholine to n-chloromorpholine (NCM).

NCM is then extracted

from the water phase using an organic solvent such as toluene.

The

toluene/NCM

is separated from the water using a decanting step

and then

converted back to free morpholine and toluene using a reducing agent.

Since

the morpholine is soluble in water it canbe separated from the toluene using a

decanter and then recycled to the process as a rawmaterial.

The toluene is

flashed in a flash pot and reused in the reactor for extracting additional NCM.

Noveon did not proceed with this process because ofsafety, quality control,

and other concerns with its implementation.

These included the quality ofthe

morpholine returning to the process, the unstable nature ofNCM, which

would present a risk ofdecomposition and explosion, and the hazardous waste

generated from the process.

In 1990 a process evaluation/literature search for removingt-butylamine

(tBA) from the BBTS process was conducted.

This technology (see attached

flowdiagram) involves feeding the tBA waste stream to a steam stripping

colunm.

The tBA is condensed to a receiver and used back into the reactor.

The water ofthe column

is fed to the existing wastewater treatment system.

The materials ofconstruction forthe column would needto be made from

monel due to the high temperature and salt concentration.

In 1990 a process evaluation/literature search for removing morpholine from

the Curite

18 process was conducted.

This technology (see attached flow

diagram) is very

similar to the OBTS recovery process with the exception of

the organic extractant (methylene chloride) and the need to reduce the NCM

back to morpholine.

The safety, quality control, and other concerns would

remain the same as forthe OBTS recovery system.

Capital and operating

costs would be similar.

In.1990 a process evaluation/literature search for removing morpholine,

mercapto-benzothiazole, t-butyl

amine and otherby-products from the OBTS,

MBDS, BBTS and Cure-rite

18 processes was conducted.

This technology

(see attached flow diagram) used acidification forpretreating all ofthe

accelerator streams.

The process involves collecting all ofthe streams and

acidifying to a pH of 1, followed by neutralization to a pH of7 and

subsequent extractionofthe organics using an organic solvent such as

isopropanol in an liquid/liquid extractor.

The solventlorganic waste stream is

then fed to a

flash pot where the solvent is stripped off and the organic tars

are collected for disposal.

The solvent is re-purified and re-used.

In this

treatment scenario none ofthe organic tars would be suited for re-use in the

process.

Significant R&D would be needed to develop this treatment further.

Safety, environmental, and other concerns with this pretreatment involve the

potential

generation ofcarbon disulfide (auto-ignition at 200 degrees F),

amount ofhazardous waste

generated, and the high levels oftotal dissolved

solids (TDS) to the waste treatment system.

5..

In 1994 the MBDS process was started up atthe Henry Plant.

Since it also

uses morpholine as a rawmaterial,

a process evaluation/literature search for

removing morpholine from MBDS process was conducted.

Due to the

similarity ofthis process and the OBTS process it was determined that the

same literature search

and evaluation ofpotential treatments would be

applicable for the morpholine as for the OBTS process.

See the above

description and cost for the OBTS.

In 1996, Noveon spent more than $742,000 to install a new BHS filter system

improving significantly the dewatering ofthe BBTS

and Curite

18 streams

and reducing loss of solids to the waste treatment system.

The BHS system

technology relies on a series ofplates covered with a filter cloth media that are

located on the outer circumference ofa rotating steel hub.

Eachplate goes

through a fill step (filtration), two wash steps, an air blow step, and a cake

discharge step.

Prior to returning to a fill step, it goes through a cloth cleaning

step.

Due to the nature ofthe technology, solids removal is very efficient and

very dependent upon the nature ofthe cloth collecting the product.

As a result

ofthis improvement, the process efficiency increased by 47 lbs/charge and

reduced the amount ofBBTS to the wastewatertreatment system by

100,000

pounds in

1997.

Based on summer work in 2000 and 2001, performed by several ofNoveon’s

P2 Intern students (Rebecca Forbeck and Adam Lock) under Illinois EPA’s

Pollution Preventionprogram, Noveon optimized the filtration media ofits

BHS Rotary Filter media.

With this improvement, better capture ofthe

accelerator product occurred as it was processed through the filtration

operation, reducing 66,000 pounds ofproduct (BBTS) to the waste treatment

system.

In addition to this work, efforts were conducted to improve loss of

product from the BBTS fines scrubber used to prevent particulate emissions to

the air from the Fluid Bed Dryer.

Through Noveon engineering efforts and

also some later work done by the 2002 P2 Intern student, Crystal Johnson,

fines loss to the wastewater treatment

system was reduced further using a

polymer coagulant that improved the collection and processing of fines back

the BHS Rotary filter, reducing by 123,000 pounds the amount ofBBTS

fines to the wastewater treatment system.

Noveonwas recognized forthis

effort by the IEPAIIWMRC with the

15th

Annual 2002 Governor’s Award for

Pollution Prevention.

Finally, in 2003 Noveon engineers optimized the t-Butyl Amine (tBA)

recovery system by linking the vacuum control valve ofthe recovery system

to the measured heat load on the tBA recovery condenser.

As a result of

providing greater vacuum control, tBA recovery was improved by

and

reduced losses to the wastewater treatment system by

185,000 pounds.

Noveon was recognized for this effort with the

17th

Annual Governor’s P2

Award.

As already mentioned, the above

activities represent “source reduction” activities

investigated or completed by the plant to reduce ammonia precursorsto the waste

treatment system.

As most environmental engineers recognize, the best starting point to

solve a waste

issue is through “source reduction”.

Noveonhas made extensive efforts to

reduce the ammonia in the wastewater and expended a great deal ofmoney and time to

reduce solids and liquid losses to the waste treatment system.

Other Wastewater Ammonia Reduction

Efforts

In light ofthe IEPA’s “treatment” criteria, the plant conducted a number ofin-

house activities to determine whether there were appropriate end ofpipe options for

reducing ammonia discharge from

its waste treatment facility.

A more complete

evaluation ofthese activities will be provided by our consultant, Houston Flippin of

Brown and Caldwell.

However, I would like to discuss several ofthe assessments that

were completed on line with the current waste treatment system.

In 1997, the Noveon plant conducted a pretreatment experiment for several

months ofthe PC waste stream.

The pretreatment involved lowering the pH ofthis

stream using FeC13

and the precipitation and removal ofsolids prior to neutralizing the

stream and feeding the effluent back to the rest ofthe wastewater treatment system

(primary, secondary and tertiary treatment).

Noveon incurred a monthly cost of

approximately $40,000 to evaluate the effects ofsolids removal at a lower pH.

The

effluent showed a

COD reduction along with a reduction in mercapto-benzothiazole

(-~50).

In spite ofthis treatment, the system did not show any evidence ofnitrification

in the biotreaters.

The above experiment involved renting equipment including tanks, a

plate and frame press, flocculators, and providing contract labor to runthe system 24

hours a day.

During the summer of2000, the Noveon plant conducted full scale aeration

studies ofair stripping for various effluents through the modification ofthe East

Biotreater that had been taken out ofnormal biological service and converted to a

temporary air stripperusing

its normal air diffusion system and floating aerators and by

the installation ofa floating aerator in the Noveon waste tank.

These modifications were

estimated to

cost —~$50,000. The following trials were conducted:

Aeration ofthe primary clarifier effluent- Results: aeration was unable to

reduce ammonia nitrogen below 110 mg/l.

Also we were not able to control

the pH to the desired level due to the method of caustic addition. A

10 hp and

a 100 hp surface aerator were evaluated.

Aeration ofNoveon waste stream only (PC Tank):

100 hp surface

aerator was installed in the PC Tank and the tank influent and effluent was

characterized for TKN removal, morpholine removal and tBA removal.

The

outcome was that TKN was reduced during the trial

as was the tBA;

however,

there was no morpholine removal.

All ofthese experiments had many

variables that could not be controlled due to the evaluation being conducted

on a full production sized system.

The above trials were stopped due to the difficulty ofcontrolling pH and also due to

production demands.

The testimony ofHouston Flippin will more fully address the

potential ofair stripping ammonia from the Noveon waste water.

Conclusion

In light ofall ofthe above

“source reduction” and “end-of-pipe”

activities

conducted by the plant, the plant has determined that there is no silver bullet that will

allow its

wastewater treatment system to comply with the

mg/i and 6 mg/i ammonia

standard that the Illinois EPA is attempting to impose by application of35

Ii. Adm. Code

304.122.

Due to the ubiquitous nature ofthe ammoniaprecursors located throughout

the facility, no single pre-treatment lends a final feasible solution.

The various treatments

studied in 1990 are extremely expensive to install and operate, and in many cases would

result in environmental impacts offar more concern than the facility’s current discharge.

CHO2/22291908.1

____________________________

I..

—

ACCELERATOR

PRETREATMENT

H2804

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TBP,RPRE

CERTIFICATE OF SERVICE

The undersigned

certifies that

copy of the

foregoing

Notice

of Filing

and

Written

Testimony

of David Giffin

was filed by hand

delivery with

the Clerk of the Illinois Pollution

Control Board and

served

upon the parties

whom

said Notice

directed by

first

class

mail,

postage prepaid, by

depositing

in the

U.S.

Mail at

191

Wacker Drive,

Chicago, Illinois

Friday, February 6, 2004 and facsimile.

CHO1/12336764.1