R~CiE
~VD
CLERK’S
OFACE
FEB
-
~J
2004
~-~$M~EOF ~LUNOIS
BEFORE THE ILLINOIS
POLLUTION CONTROL ~
Contro’ Board
INTHE MATTER OF:
Petition ofNoveon, Inc.
foran Adjusted Standard from
35111. Adm.
Code 304.122
)
)
)
)
)
)
)
AS 02-5
NOTICE OF FILING
DorothyM. 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 on
Monday, February
9,2004, we filedthe attached
EXHIBITS TO WRITTEN TESTIMONY OF T. HOUSTON FLIPPIN with the Illinois
Pollution Control Board,
a
copy ofwhich is herewith served upon you.
Respectftilly submitted,
NOVEON,
INC.
Richard J. Kissel
Mark Latham
Sheila H. Deely
GARDNER CARTON & DOUGLAS LLP
191
N. Wacker Drive
—
Suite 3700
Chicago, IL
60606
By:
‘IsA~~s
One of
THIS FILING IS
SUBMITTED ON RECYCLED PAPER
CERTIFICATE OF SERVICE
The undersigned certifies that a copy ofthe foregoing Notice ofFiling and EXHIBITS TO
WRITTEN TESTIMONY OF T. HOUSTON FLIPPIN was filed by hand delivery with the Clerk
of the
Illinois Pollution Control Board and served upon the parties to whom said Notice is
directed by
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite
11-500
Chicago, IL
60601
(personal delivery)
Deborah Williams
Assistant Counsel
Division ofLegal Counsel
Illinois Environmental Protection
Agency
1021
N. Grand Avenue East
Springfield, IL
62794-9276
(first class mail and electronic
delivery)
Bradley P. Halloran
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, IL
60601
(personal delivery)
on Monday, February 9,2004.
CHO2/22292364. I
CLERK’S
OFFiCE
BEFORE
THE
ILLINOIS POLLUTION CONTROL
BOARD
FEB
-
S
2004
INTHEMATTEROF:
)
STATE OF ILUNOJ3
)
POH~ti~n
COfltIOj
Board
Petition ofNoveon,Inc.
)
)
AS 02-5
)
for an Adjusted Standard from
)
35
Iii.
Adm. Code 304.122
)
EXIIIBITS TO
SUBSTITUTED WRITTEN TESTIMONY OF T. HOUSTON FLIPPIN
Respectfully submitted,
NOVEON, INC.
By:
_______
One ofIts Attorneys
Richard J. Kissel
Mark Latham
Sheila H. Deely
GARDNER CARTON &
DOUGLAS LLP
191 N. Wacker
-
Suite 3700
Chicago, IL
60606
CHO2/22292376. 1
Exhibit
A
EXHIBITA
RESUME
OF T. HOUSTON FLIPPIN, P.E., DEE
~~t~tment
T.
Houston Flippin,
P.E.,
DEE
Asslgnm.nt
Experience
Summary
Capacity
Evaluation
Houston Flippin
has 20 years of
experience in
industrial
and municipal
Education
wastewater
management.
Mr.
Flippin is particularly
adept
at
maximizing
MS., Environmental
and Water
treatmentprocess performance.
This is
due to years of
conducting,
VdftUl~th~1984
evaluating, and
developing full-scale process design and
operating
guidelines
from bench-, pilot- and
full-scale wastewater
treatment studies. These
~E~~and
Environmental
studies have
evaluated both biological and
physical/chemical
processes for
Vanderbift UnIversity,
1982
treating waters, wastewaters,
and
sludges laden with conventional pollutants,
Registration
priority pollutants, and aquatic toxicants.
Mr. Flippin
has
used this
Profosslonal Engineec
Tennessee,
experienceto
both develop treatmentcost
savings (capital and operating)
Illinois, Kentucky, and Michigan
while maintaining reliable effluentcompliance and to
negotiate more
Diplomate:
AmericanAcademy of
reasonable effluentlimits.
His “hands on” experience and his
talent
for
Environmental Engineers
communication has made him a frequent workshop lecture,client
staff
Experionc.
trainer, and negotiator. Recent workon the industrial side
has
inv-olved
20
years
developing innovative,
reliable and
cost-effectivepretreatment processes
Joined Firm
and minimizing upgrade costs of treatment lagoon systems. Recent work
on
1984
the municipal side has
involvedreratingcapacities of POTWs using site-
Relevant
Expertise
specific data, developing cost saving actions for aeration and sludge
•
Developing site specific operating
handling, and developing staffreorganization
plans
to enhance productivity.
guidelines and treatment
Mr. Flippin also has experience in potablewater treatment,
stormwater
capacities,
permitting, wasteload surveys, and waste minimization.
S
Developing
cost
savings for
______________________________________________________________________
treatment plants.
•
~
Organic Chemicals,
Herbicides and Pesticides
Process
Design, Startup Assistance and Operator Training,
Ciba-
Geigy Corporation
LeadEn,gineer
andAuthor.
Responsible for an on-site
treatability
studies,
process design development, and final report for the treatment of
wastewaters
discharged from Ciba-Geigy Corporation’s largest U.S. organic
chemicalsmanufacturing complex including pesticides. The projectbegan
by evaluatingconversion of the existing aerated lagoon system to activated
sludge. This conversion was necessary
to meet effluent
requirements under
higher loading conditions and to meet RCRA closure requirements of on-
site surface impoundments.This evaluation involved an activated sludge
treatability study
evaluating
the impact of
varying
totaldissolved solids
concentrations
(0.5 percent to 2.5 percent), temperatures (8°Cto20°C)and
RCRA regulated stream discharge contributions. A process design for the
aerated lagoon/activated sludge conversionwas developed,presented, and
implemented. Mr. Flippindeveloped materials for and assisted in the
operator training course which preceded startup of the activated sludge
plant A follow-up treatability study was conducted and focused on TIN,
TOC, acute toxicity and color reduction through the use ofPACT®
treatmentas compared to tertiary GAC treatment. Special batch treatability
II
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testing evaluated altemative source control methods for a
highly
colored
wastestream. A process design was developed to meet revisedtreatment
objectives, a final reportwas issued, and a new WWTF was constructed.
Startup assistance and operator trainingwere provided for both WWTFs.
Process
Design, Rhodia, Mount Pleasant,
Tennessee
LeadEngineerandAuthor.
Responsible for an treatability studies, process
design development, and
final reportfor the treatmentof herbicide
wastewaters. Treatments evaluated
impact
of
photolytic decomposition,
carbon adsorption, and macroreticular resins. Solutionimplemented
included minor treatmentand recycleofwaters. Site converted to a nearly
zero discharge operation.
P01W
Impact and Discharge Negotiations, American Cyanamid,
Barceloneta,
Puerto
Rico
LeadEngineerandAuthor.
Responsible foran treatability studies that.
evaluated
impact
of herbicide and pesticide wastestreams on
POTW.
Testing
indicated no adverse impact on
BOD
removal, nitrification, and
sludge quality at the desired discharge rates. Results of testingwere used to
negotiate allowed discharges of these wastestreams to the
POTW
without
pretreatment.
WWTF
Troubieshooting, Zeneca Fine Chemicals, Mount Pleasant,
Tennessee
LeadEngineer andAuthor.
Responsible for treatability studies that evaluated
impact of
various
organicchemical, herbicide and pesticide wastestreams on
site’s
biological wastewatertreatmentfacility (WWIF).Developed approach
for screening impact of new wastestreams on the WWTF. Prescribed
maximum allowable discharge rates ofeach process waststreani toprevent
upset of the WWFF.
Pulp and Paper
Comprehensive Wastewater Management Plan, Chesapeake
Corporation, West Point, Virginia
Lead Engineer,
Field TeamManager, andAuthor.
Developed a comprehensive
wastewatermanagement plan for a Chesapeake Corporation
1,800 tpd
integratedmill.
Wastewatercharacterization studies defined sources and
distribution of waxes through the pulping and paper making process, the
impact of secondary fiberproduction on WWTF solids management, the
impact of bleaching process chlorine substitution on influent wasteloads,
effect of separate and combined
settling ofpulp mill and paper mill
wastewaters, and impact ofvarious equalization basin sizes and modes of
operation on influent load
dampening.
Batch treatability tests evaluated
alternative primary clarification schemes, alternative site applications of
dissolved air flotation (DAF) for wax removal and solids
recovery, impact
of CO2 stripping/coagulation and flocculation on pure oxygen activated
sludge
settleability andimpact of secondary fiber on activated sludge
settling
properties.
Continuous
flow treatability studies evaluated the effects of
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Houston Flippin, P.E., DEE
secondary
fiber
production, secondary fiberwastestream DAF
pretreatment, aeration basin temperatures, slitnicide loadings and bleaching
plant chlorinesubstitution
on
pure oxygen activated sludge plant
performance (particularly sludge settleability).
The continuousflow
treatability studies also involved evaluation of several types ofbiologkal
selectors to control filasnentous sludge bulkin~aerobic,two-stage aerobic,
anoxic/annerobic, and extended anoxic/anaerobic.
Elements of this project
were presented by Mr.
Flippin
at the
1992 TAPPI Environmental
Conference.
Lagoon Modeling and Upgrade Evaluation, Confidential Client,
Midwest
LeadEngineer.
Developed alternative upgrade measures for a wastewater
treatment lagoon systemto accommodate increasedwasteloadwhile not
exhibiting H2S emissions. One alternative was based on operatingthe
lagoons without oxygen and nutrient defidencies and thus achieving greater
BOD
removal rates.
This alternative was based on treatability data.
The
second alternative was basedon operatingthe lagoons under oxygen and
nutrient limitations, which decreased BOD removal rates but minimized
upgrade requirements.
Extensive full-scale system
data
was used
to
develop
a
model for evaluating system performance under alternative conditions.
The projectis currently in the
final design stage.
Hazardous
Waste
Groundwater Remedlation
Process Design, FLTG, Incorporated,
Crosby, Texas
ProjeciManagerandLeadEngineer.
Responsiblefor a groundwater
remediation
projectfor a company fbrmed
by
80
principle responsible
parties.
This Superfund sitegroundwater treatability investigation
considered how best to upgrade the existing treatment facility.
Air
stripping, peroxidation, ozonation, ultrafiltration, carbon adsorption, resin
adsorption, and anaerobic degradation separately and in conjunction with
activated
sludge treatmentwere considered.
Following a series of batch and
continuous flow treatability tests, activated sludge treatment followed by
granular activated carbon treatment was selected as the most cost-effective
means ofachieving discharge targets.
In addition, a cost-effective sludge
treatmentand disposalplan were developed.
Textiles
ToxicityReduction Evaluation/Toxicity Identification
Evaluation,
Globe Manufacturing, Gastonla, North Carolina
Project
Manager, LeadEngineer,
andAuthor.
Managed a wastewater
pretreatment projectwhere the industrial discharge was cited
as the source
of the POTW’s effluent aquatic toxicity problem.
Treatability tests were
conducted which screened the effects ofthe
followingtreatmentprocesses
on effluent toxicity reduction:
air stripping, cation exchange resin, activated
silica, macroreticular resin, granular activated
carbon, and biohydrolysis.
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T. Houston Flippin, P.E., DEE
Results of these tests and further
desktop
evaluations indicated the
biotoxicant was ethylenediamine and that activated sludge treatment would
provide the most cost-effective treatment.
Continuous
flow treatability
studies were used to develop the process design for the selected process.
Submitted design basis report for the pretreatment facility, reviewed final
design drawings and specifications, and provided startup assistance.
The
pretreatment facility eliminated all acute and chronic toxicity associated with
the wastestream discharge at its
flow contributionto the POTW.
Elements
of this project were publishedin
W”aterSdence Tecbnologj,
Volume 29, No.
9
(1994).
Food Processing
Waste Minimization, Quaker Oats, Newport,
Tennessee
ProjectManager, LeadE~~gineer,
andAutbor.
Developed a waste minimization
plan fora Quaker Oats
facility.
On-site wastewatercharacterization studies
coupled withinterview of site personnelwere used to develop practical,
cost-effective waste minimization recommendations.
Implementation of
the plan resultedin significant reductionofproduct losses and sewer
pretreatment surcharges.
Combined Municipal/Industrial Wastewater Management
ISP Chemicals, Calved
City,
Kentucky
PrincipalEngineer/Site CSM
Investigation of the impact of eight waste
streamson the onsite activated sludge process.
Clarlant Corporation, Elgin,
South Carolina
Provided alternative treatment system analysesprior to the
construction of a
Greenfleld wastewatertreatment facility.
Cooperative and Cost Effective Wastewater Treatment,
Ryan
Foods Company, Murray, Kentucky
ProjectManager
and
Pth4a/Engineer.
Worked with City of Murrayand
industry to develop a “win-win” strategy for minimizing wastewater
treatmentcosts for both the City and industry.
Eady estimates by the City’s
consultant had indicated that the POTW would have to spend
approximately $10 million to accommodate the discharge wasteload on the-
POTW with Ryan Foods at maximum loading (and without pretreatment).
Estimates indicated that Ryan Foods would have to spend $3
million to
meet the limits requested by the City ifpretreatment were to be installed.
A
review of pertinent information indicated the opportunity for significant
savings by both parties.
Treatability studies were conducted and POTW
performance data were reviewed.
Thiswork indicated that a much less
costlyapproach could be taken.
A
final design was developed for the
pretreatment facility and installed at a cost of $1.6 million.
The
pretreatment facility reduced the wasteload
by approximately70 percent.
However, the remaining wasteload to the P01W exceeded the
“rated
capacity”of the POTW.
A site-specific
analysis was conducted and used to
P~PRO.u3417
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T. Houston Flippin, P.E., DEE
reratethe capacity of the P01W.
A major component of this analysis was
sludge stabilization and alternative disposal methods.
This rerating allowed
the P01W to gain an additional 29 percent inrated capacity for a cost of
$0.7 million.
So, in the end, the City ofMurrayand Ryan Foods both saved
more than $1
million each.
The City also received definition of alternative
sludge disposal methods and a description of the incremental upgrades that
would be required in the future as the “real rated capacity”of the POTW
was approached.
Municipal Wastewater Management
Change Management
Program, Metro Water
Services,
Nashville,
Tennessee
Assistant TaskManagerfor Opera/ions Group.
Worked withclient to identify
cost-saving
action items to reduce annual O&Mcosts at two water
treatment plants
and
threewastewatertreatment plants.
The purpose in
these reductions was to render the plants’ operatingcosts
competitive
with
that estimated by private contractors and thus “stave offprivatization.”
Anhual savings ofgreater than $1,000,000 were identified.
Currently
serving
as advisor to teams
implementing savings regarding sludge
thickening and dewatering and aeration.
In addition
to
this work, have
assisted client inprocesstroubleshooting which has allowed client to avoid
effluent non-compliance.
Petrochemical and Synthetic Fuels
Safety Kleen Corporation, East
Chicago, Indiana
LeadEng/neer, ProjectManager,
andAutbor.
Responsible for on-site
wastewater treatment facility (WWTF) process troubleshooting and training
to facilitate
compliance
with pretreatment limits at this facility, one of the
largest oil re-refineries in the world.
Treatability studies and process design
were required for W’X1TF modifications to accommodate increased
production and more stringent pretreatment limits.
Brown and Caldwell provided sampling and analyticalprocedures modified
for
cyanide,
ammonia, and orthophosphate analyses.
A more
comprehensive and site-specific procedure was implemented to evaluate the
chemical conditioning requirements of the mixed liquor. “In situ” oxygen
transfer was determinedto assess upgrade requirements.
Treatability studieswere conducted. The effects of operatingtemperature
(30°Cto 60°cand F/M ratio (0.1 lb COD/lb MLVSS’ day to 0.7 lb
COD/lb
MLVSS
‘
day) on activated sludge settleabilityand effluent quality
were evaluated.
The effects of steam stripping, as a pretreatment step, on
activated sludge
system performance were evaluated.
Metals precipitation
with lime, alum and caustic was studied as a pretreatment and post
treatment process.
High pH air stripping and breakpoint chlorination were
examined as
effluent NH3-N reduction technologies.
Effluent peroxidation
and ozonation were evaluated
as a means of providing effluent total
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phenolics reduction.
The use of a biological selector and chemical
conditioning (e.g., coagulation and flocculation) were investigated as means
of improving sludge settleability.
A
process design to upgrade the existing WWTF was
provided and included
a
four
stage, aerobic biological
selector, temperatureand pH control,
coagulation,
flocculation, increased R.AS pumping capacity, breakpoint
chlorination and
tertiary
filtration.
Final design guidance
was
provided
on
selection ofequipment for the
biological selector and tertiaryfiltration.
Booth Oil Company, Buffalo, New
York
LeadEngineer andAuthor.
Responsible for wastewater sampling program to
definetreatmentprocess limitationsunder increased future loading
conditions.
Treatability
testing was conducted to evaluate alternatives for
controllingtotalphenolics discharge. Both improvements in oil/water
separation and hydrogen peroxide treatment were considered.
A
report
presenting
akematives for upgradingWWTi~
operations and for
prioritizing capital improvements was presented..
Groundwater Remedlatlon
PrOcess Design, FLTG, Incorporated,
Crosby, Texas
ProjectManag~randLeadEng/neer.
Responsible for a groundwater
remediation projectfor a company formedby
80 principle responsible
parties (almost exclusively petrochemicalindustries and refineries). The
groundwater at this siteexhibited an influent
COD
of approximately 600
mg/L and
had
free product present.
A
groundwater treatability investigation
was conducted to determine how best to upgrade the existingtreatment
facility.
Air stripping, peroxidation, ozonation,ultrafiltration, carbon
adsorption, resin adsorption, and anaerobic degradation
separately
and in
conjunction with activated sludge treatment were considered.
Following a
series of batch and continuous flow treatability tests, activated sludge
treat~nent
followed by granular activated carbon treatmentwas selected as
the
most cost-effective means of achieving discharge targets.
In addition, a
cost-effective sludge treatmentand disposal plan were developed.
Reilly Industries, Lone Star, Texas
LeadEngineer,
ProjectManager andAuthor.
Responsible for a two-tiered
project at this coaltar plant Treatability studies were conducted and
process designs were developed for alternative wastewatertreatment facility
upgrades that would
allow plant to meet more restrictive pretreatment
limits. A work plan was developed in cooperation with TNRCC that would
allow the P01W to seek permit relief whichin turn would allow the plant
to notrequire WWI~F
upgrades.
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T. Houston
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Permitting
Hunt Foods (formerly Quaker Oats), Newport, Tennessee
ProjectManager
and
Prindpa1Ei~gineeron
project involving wasteload
minimization, pretreatment facility
design
and negotiation of
pretreatment
limits.
Laldiaw (formerly Osco, mc), Nashville, Tennessee
ProjectManager and PñnápalEngineer on
projectinvolving pretreatment facility
design, startup, troubleshooting, and pretreatment permit negotiations.
J. Hungerford Smith, Humboldt, Tennessee
PrindpalEngineeron
project involving pretreatment
facility design, POTW
upgrade
design, and pretreatment permit negotiations.
Ryan Fàods Company, Murray, Kentucky
ProjectManager
and
PrindpalEngineer
on project involving pretreatment
facility design, construction management, startup, operator training, POTW
upgrades, pretreatment permit negotiations, and negotiation ofre-rated
capacity of P01W withKentucky Division of Water.
BF Goodrich Performance Materials, Henry, IllinoIs
ProjectManagerandPündpalEngineer
on project involving treatment facility
design, startup, operator training, treatment facility troubleshootingand
NPDES permit
negotiations
with
Illinois
EPA.
Meeting with Illinois Water
Pollution Control Board is pending.
ISP Chemicals,Texas City, Texas
Project Managerand Principa/Eng/neer
on projectinvolving modif~ring
existing
NPDES permits for stormwater and waste-water. Project also involved
conductof testingto get adjusted metals limits.
OxyVinyls (formerly Goon Canada), NIagara Falls, Ontario,
Canada
ProjectManagerand Principa/Engineer
on project involving treatment facility
troubleshooting, operator training, and
“NPDES
equivalent”
permit
negotiations.
Confidential Client, Barceloneta,
Puerto
Rico
ProjectManager andPrincipa/Engineer
on project involving treatability testing
and pretreatment permit negotiations.
Toxicity Reduction
Thiokol Corporation, Brigham City, Utah
LeadEngineer
on effluent toxicity identification evaluation (TIE)
followed
by
toxicity reduction evaluation (TRE) as a part oftreatability studies for a
newly designed WWTF.
The new WWTF replaced two existing WWTFs
that were abandoned.
Acidification, air stripping, alkalinization, chemical
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reductionwith sodium thiosulfate, filtration, granular activated carbon, ion
exchange (anion and cation), macroreticular resin, and metal complexing
withEDTA, were evaluated as a means of achieving effluent
toxicity
reduction for a selected wastestreani.
High salinity was identified as the
toxicant
The client decided to blend the selected wastestrearn with other
wastestreams causing a decrease in wastewater salinity and an increase- in-
wastewaterBOD.
Activated sludge treatment followed by ozonation
as a
means of toxicity reduction and disinfection was determined to provide
consistent compliance with effluent BOD and toxicity limits.
A process
design was provided.
The newly designed WWTFs included gritremoval,
equalization, activated sludge treatment, granular media filtration and
ozonation.
The final design for the WWTF was reviewed for consistency
with the process design.
Confidential Client, Indiana
LeadEngineer
andProjectEn,gineerA
ToxicityIdentificationEvaluation (TIE)
was conducted for a large-volume producer of metal ingots and sheet
aluminum.
The TIE used Phase I laboratory characterization procedures,
singlestream toxicity testing, and resynthesis testing with major
wastestreams treated for toxicity removal.
Both
Ceciodapbnia
and the fathead
minnow were used in acute tests throughoutthe study.
Study results
indicated that adsorptiveorganic compounds associated withan internal
wastetreatment processwere primarily responsible for toxicity.
Pure
chemical testswith the wastewatertreatment polymerused at the site
indicated that the polymer may play a role in effluent toxicity.
A ToxicityReduction Evaluation (IRE) work plan was
also conducted for
the client to develop a
means
to cost-effectively reduce effluent toxicity as
required
by the State.
Services included wasteloadcharacterization and
wastewatertreatment facility (WWTF) optimization.
Memberships
National Society
of
Professional Engineers (NSPE)
Technical
Association of
the Pulp
and
Paper Industry (TAPPI)
Water Quality
Committee Member
Water Environment
Federation
Pretreatment Committee
Member
Chi Epsilon
National Civil Engineeñng Honor Society
Publications/Presentations
‘Enhanced
Activated
Sludge Treatment of High Strength Sio—inhibitory
industrial
Wastewater’ with
R.
Rhoades,
IOU1
Annual
WEF Industrial
Wastes
Technical and Regulatory Conference,
Philadelphia, Pennsylvania,
August2004.
‘Treatment Alternatives for Removing
Ammonia-Nitrogen
from Landfill Leachate’
with
RE.
Ash
and
B.N.
Card, Annual Tennessee Solid and Hazardous Waste Conference,
Gathnburg,
Tennessee, April2004.
‘Alternative
Considerations
in Sizing
Aeration
Basins’ with W.
W.
Eckenfelder, Design,
Performance
and
Operation
of
Biological
Treatment
Processes
Pie-Conference Workshop,
Vanderbilt
University
and USEPA Conference, “Industrial Wastewater and Best Available
Treatment Technologies:
Performance,
Reliability, and Economics”,
Nashville, Tennessee,
February
2003.
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‘Modifying
Equalization
to
Provide Pretreatment
of
High
Strength Wastewaters’
with
DA
Moye,
19~
Annual
North
Carolina AWWAPNEF Conference Proceedings,
Winston-Salem, North
Carolina,
November 2002.
‘Benefits of Using
Nitrateas
Nutrient
in
Activated Sludge Treatment
Systems’with
W.
W.
Eckenfelderand DA
Moye,
8th
Annual WEF
Industrial
Wastes Technical and
Regulatory
Conference, Atiantic
City,
New
Jersey,
August2002.
‘Biological Treatment
of
HighTDS
Wastewaters,’
with W. W. Eckenfelder and V. J. Boero, Water
Environment
Federation- Industrial
Waste
Technical and Regulatory
Conference,
Charleston,
South Carolina,
August
2001.
‘Competitive
Performance
for Water and
Wastewater Utilities,’
with J.L
Pintenich,
NasiviilIe
Quality
Forum, Nashville, Tennessee1
October1999.
‘Reclaiming P01W Capacity,’ with M.L
Roeder,
American Society
ofCMI Engineers-Tennessee
Section Annual Meeting, Nashville, Tennessee,
October1999.
‘Batch
Activated Sludge
Testing to Determine
The
Impact ofIndustrial Discharges on
P01W
Performance’,
with J.S. Allen,
Ptoceedings
of
1998
WEFlndustriei Wastes Specially
Conference,
Nashviie, Tennessee,
March 1998.
‘Economics ofTreating Poorly
Degradable Wastewaters
Inthe Chemical Industry,’ with
KD.
Torrens, Thvceedings of
1998
WEFlndusfrial Wastes Specialty
Conference,
Nashville,
Tennessee, March 1998.
‘Effects ofElevated Temperature on
the
Activated
Sludge Process,’ with
W.W.
Eckenfelder, Jr.,
Proceedings of
1994 TAPPI
InternationalEnvironmental
Conference, Portland,
Oregon,
AprlI 1994.
‘Toxicity
Identi~cation
and
Reduction
in the Primary Metals Industry,’ presented
at
Spring AJChE
Conference,
Atlanta,
Georgia,
April
1994.
‘Treatability
Studies
and
Process
Design
for Toxicity
Reductionfor a
Synthetic
Fiber
Plant,’
with
J.L
Musterman,
WaterScienceTechnology,
VoL
29,
No.9(1994).
‘Granular Carbon Adsorption
of
Toxics,’
technical
review ofchapterfour
in
Toxicity Reduction
in
IndustrialEffluents,
P. W. Lankford and W. W.
Eckenfelder, Jr.
(Eds), Van
Nostrand
Reinhold,
1992.
‘Diagnosing and SoMng
a Pulp
and Paper Mill’s Poor Activated Sludge
Settleability Problems
Through
Treatability
Studies,’
with N. A Bellanca,
Proceedings
of
1992
TAPPI Environmental
Conference,
Richmond, VirgInia,
1992.
‘Hydrogen Peroxide Pretreatment of Inhibitory Wastestream
—
Bench Scale Treatability
Testing
to
Full
Scale Implementation:
A
Case
History,’ with R.
L. Linneman,
A’oceedbrgs of
Chemical
Oxidation:
Technology lbr
1990’s,
Vanderbilt
University,
Nashville,
Tennessee,
1991.
‘Control of Sludge Bulklng in a
Carbohydrate Wastewater Usinga
Biosorptlon Contactor,’-wlth
W. W.
Eckenfelder, Jr.
and N.
A.
Goronszy,
Proceedings
of
the
39th
Annual
Purdue
Industrial
Waste Conference,
1984.
Research
Topics
Biodegradation
of
PCBs
and HCB,
research
conducted at ECKENFELDER INC.
Volatile OrganicCompound Emissions from Activated
Sludge Systems,
research
conductedat
ECKENFELDER INC.
Performance of Selective Bacteria in Industrial Activated Sludge Systems,
research conducted at
Vanderbilt University
Biosorption for Improved Reactor Capacity, research
conducted
at Vanderbilt University
Control ofActivated Sludge Bulking Through the Use ofa Biosorptlon
Contactor, research
conducted at Vanderbilt
University
Workshops
Instructor, Tennessee State University, ‘Monitoring Requirements,
Operating Guidelines,
Calculations, and Troubleshooting,’
presented
during ‘Aerobic Biological Wastewater Treatment
Workshop,’
Nashville, Tennessee,
November1997, Apnl 1998, November
1998, and April
1999.
N
Instructor, Mississippi Water Pollution Control Operators’
Association,
Inc., ‘Clarifier Operation and
Maintenance Workshop,’ Tunica, Mississippi, April 1997.
P:~PRO~23417.
NoveonUlerw~
-
OO2~FHppl,_Ho~iston
9
resL,~1e.doC
T.
Houston Flippin,
RE,, DEE
Instructor,
Brown
and
Caldwell, ‘Activated Sludge
Wastewater Treatment
Workshop,
‘attended by
participants from
over 3
municIpalities
and 10
industries, Nashville, Tennessee,
November1999,
March 2000, May2001,
November2002 and
November2003.
lnshiictor,
Tulane
University and Louisiana Chemical Association,
‘Wastewater Strategies for
Industrial Compliance: GulfCoast
Issues
and Solutions’,
New Orleans, Louisiana,
December
2003.
Honors
Who’s
Whoof
Citation’s
Environmental
Registry, 1991
Eckenfelder Inc.
Technical
Employee ofthe
Year
Awan~,
1990
Outstanding Young
Men
of
America,
1986
P~RO~234~7
-
Nov~on~enry
-
~z~ppin~ou~to,
10
resjre,doc
m
03
EXHIBIT B
PERTINENT ARTICLES FROM
LITERATURE
REVIEW
r
NATIONAL
~‘
L
CORN
HANDBOOK
~
—~-------
~—
-
CROP
FERTILIZATION
NCH-55
Nitrification Inhibitors for Corn
Production
D. W. Nelson, UniversityofNebraska
D.
Huber,
Purdue University
Reviewers
K. D. Frank, Univesrity ofNebraska
G. W. Randall, University of Minnesota
R.
G. Hoeft, UniversityofIllinois
W. I. Segars,
University
of Georgia
0.
R. Keeney, University
of
Wisconsin
J.
E
Touchton, Auburn University
C. L. Maizer, University ofMinnesota
L if Welch, University of illinois (retired)
H. if Reetz,
Jr.,
Potash & Phosphorus Institute, illinois
Nitrogen
(N)
is an essential
element for plant
growth
and
reproduction.
The amounts of N taken up
by
corn
exceed those of any other soil-derived
element. Today an
average 25
of plant-available N
in soils
(ammonium and
nitrate)
originates from
the
decomposition (mineralization) of organic N
compounds in humus, plantand animal residues, and
organic fertilizers,
5
from N in rainfall, and
70
from
applied
inorganic N fertilizers (Figure 1). In soils,
organic N
is converted to ammonium
through
microbial decomposition. Ammonlum
formed in soil,
added as fertilizer,or In precipitation is rapidly
oxidized to nitrate in the nitrification process
carried
outby specific bacteria. Nitrification results in the
production ofnitrate, a form of plant-available N which
is readily lost from
soils. Nitrification inhibitors are
chemicals that slow down or delaythe nitrification
process, thereby decreasing the possibility that large
losses ofnitrate will occur before the fertilizer nitrogen
is taken
up by plants. This publication discusses N
losses from soils, characteristicsof nitrification
inhibitors, and how nitrification inhibitors can
be used
to improve efficiency of corn production.
THE NITRIFICATION PROCESS
Ammonium (NH4~)
added to
soils or formed
by
decomposition
of organic N compounds is oxidized to
nitrite
(NO2) by
Nitrosomonas
bacteria,
and nitrite is
further oxidized to
nitrate (NO3) by
Nitrobacter
bacteria
in
a process termed nitriflcation (Figure 1).
Nitrate is
normally the form of
N taken up
by plants;
however, most plants can also assimilate ammonium.
In most soils,
nitrification
of
applied ammonium is
rapid
(2-3
weeks),
but nitrification
rates
are greatly
reduced by cool soil temperature (50°F),low pH (5.5),
and waterlogged conditions. Nitrification converts
ammonium, a positively charged ion that is boUnd to
clay and organic matter, to nitriteand nitrate,
negatively charged ions that are free in the soil
solution and are readily lost from the plant rooting
zone of soils.
N LOSS
FROM SOILS
Only about50
of the
applied N
is taken up by
corn
during the year following fertilizer addition. About
25
is immobilized during residue decomposition or
remains in the soil as nitrate. The remaining 25
is
lost from the plant rooting zone by leaching and/or
dentrificatlon.
(See Table I for a
generalized estimate
of the fate of fertilizer N added to soils.) Some of the
immobilized
N will be mineralized (5
peryear) and
will be available to
subsequent crops. Nitrate
remaining
in the profile at the end of the cropping
season
will be
available to the succeeding crop unless
lost over the winter and spring by leaching or
dentrification.
Leaching Is important in coarse-textured soils.
Nitrate may be leached from
naturally well-drained or
tile-drained soils by percolating water. One inch of
infiltrating water will movenitrate I
to 2.5 inches
downward in clay loam and sandy soils,
respectively.
Thus, during periods of excess
rainfall, leaching may
move nitrate out of the effective rooting zone of
plants.
Denitrification (the microbiological conversion of
nitrate and nitriteto
gaseous forms of N)
isthe
major
pathway of N loss from most fine-textured soils. It
normally occurs in soils that
become waterlogged by
IOWA STATE
UNIVERsrFY
University Extension
NCH 55
Revised
February
1992
Electronic versIon July 2001
Figure
1.
The nitrogen cycle in soils (adapted from Nitrogen in AgriculturalSods).
excessive
rainfall or irrigation.
Denitrification occurs at
maximum rates when soils are
warm (60°F),
p1-I values
are high (7), nitrate is plentiful, and
an energy source
(carbon) Is available.
In waterlogged soils,
more than
100 lb.
of nitrate N per acre can be denitrifled within
a
5-day period. However,
in cold soils (40°F)or soils
with low pH values (5), denitrificatlon rates are slow.
TYPES AND USES OF
NITRIFICATION INHIBITORS
Nitrification inhibitors (Ni) are chemicals that
reduce the
rate at which ammonium is converted
to
nitrate by killing or interfering with the metabolism of
Nitrosomonas
bacteria
(Figure 1). The loss of N from
the rooting zone can
be minimized by maintaining
applied N in the ammonium form during periods of
excess rainfall prior to rapid N uptake by crops. A
number of compounds have been shown to inhibit
nitrification in laboratory and field
studies (Table 2);
however, only N-Serve® and Dwell® have U.S.
Environmental
Protection Agency approval for use on
cropland
in the United States. Additional
compounds
are used in Japan and other countries; and
registration is expected for additional compounds in
the
U.S.
N-Serve is currently labeled forcorn, sorghum,
wheat, cotton,
lice, and other crops and is sold in
emulsifiable and nonemulsiflable formulations. Dwell
was registered
as a nitrification inhibitor in
1982, but it
is uncertain if the product will be marketed. Both
chemicals are effective nitrification inhibitors when
Table 1. GeneralIzed Fate
Applied to Corn1
of FertIlIzer Nitrogen
Soil texture
Fate of applied
N
coarse
medium
and fine
Plant uptake (firstyear)
Remains
in soil as organic
and inorganic N
Lost from root zone:
—
of applied
N—---
40-60
50
-
60
20-25
25-30
Denltrification
Leaching
5-
10
15 -25
15-20
0-10
I
Average
values
over years for soils
In the Cornbelt and
southeastern
U.S.
and
irrigated soils or
the Great
Plains
and
western
valleys.
0.5 lb. of active ingredient (a.i.) peracre is used in a
band application with anhydrous ammonia orN
solution fertilizers.
N-Serve and Dwell may also
be impregnated
on
solid fertilizers or mixed with N solution fertilizers
prior
to broadcast applications.
However, incorporation of
the nitrification inhibitor-treated fertilizer must occur
shortly after application
because both compounds are
volatile.
Higher rates (2 to 4 times
band applications)
of N-Serve and Dwell are often
required to control
nitrification of broadcast ammoniacal fertilizers.
Recent studies haveshown that NI
can
also be
effectively used with liquid animal
manures and
sewage sludges that are injected into the soil.
ATMOSPHERIC GASES
N2,
NO2,
N20,
NO
A
A
A
S
/
F
I
F
F
I
I
V
LEACHINGTO
GROUNDWATER
OR
TILE DRAINS
2
Table 2. Compounds Marketed
Chemical name
or Proposed as
Nltriflcation
Inhibitors.
Common or
Registered In
trade name
Manufacturer
the U.S.A.
EFFECTS OF NITRIFICATION INHIBITORS
A number of studies throughout the
United States
have demonstrated that NI
effectively retards
the
conversion of ammonlum to nitrate in
a variety of
soils. Results indicate that application of NI delays the
conversion
of ammonium to nitrate for4 to 10 weeks,
depending
U~Ofl
soil pH
and temperature. With fall
applications of N fertilizers,
NI
minimize nitrification
untii low soil temperatures (40°F)stop the
process.
With spring applications,
NI prevent the formation of
nitrate during the late spring when rainfall is high and
uptake of N by crops Is low.
Corn yields are often increased as
N losses from
soils are reduced by the application of NI with both
conventional tillage and reduced tillage systems
(Table 3). The potential benefit from
NI application
depends on
a
number of site-specific factors, such as
soil type, climate, cultural practices,
and
N
management program.
Highest probability of yield
response from NI occurs with excessively drained or
poorly drained soils
because of N losses from
leaching and denitrification, respectively. For example,
a study
in
Indiana with fall-applied anhydrous
ammonia showedthat N-Serve application increased
corn yields
by 300
with a
very poorly drained silty
clay soil
and
1
with a well-drained
sandy
loam soil.
Significant corn yield responses from NI addition have
also been observed with irrigated sandy soils
(Table 4). YIeld responses from NI are more frequent
with fall
N applications than with spring applications
because of lower N losses from
denltriflcatlon
normally experienced when fertilizers are applied
nearer to the timeof crop need. There have been
consIstent yield responses from
NI
added to
ammoniacal fertilizers for corn produced with
a no-till
system, presumably because of larger N losses from
denitrification normally experienced with this
production
method.
The Increased
availability of
inorganIc N and the
presence of ammonium in the soil resulting from NI
addition also have been shown to
increase the protein
concentration of corn grain (Table
5). The feedIng
value of corn increases as the
protein level increases.
The application of NI to
inorganic and organic N
fertilizers also
has reduced the severityof
Diplodia
and
Gibberella
stalk rots of corn,
likely
because of
altered N metabolism in plants assimilating the
ammonium form of N (Table 6). Corn stalks in areas
receiving NI-treated fertilizers tend to remain green
later in the growing season and havethicker rinds,
both ofwhich
reduce pathogen effects and lodging.
Grain moisture content at harvest is unaffected by
NI
addition to fertilizers.
The amounts of nitrate leached into groundwater
and ozone-destroying
nitrous oxide (N20) emitted
into
the atmosphere through denitrification are reduced by
NI application. The use of NI also gives great flexibility
in timing the
application of N fertilizers. For example,
with most Cornbelt soils
all of the N
needed for a corn
crop can be applied as anhydrous ammonia during
Produced commercially:
2-chloro-6-(trlchloromethyl)-pyridine
5-ethoxy-3-trichloromethyl-1, 2, 4-thiadiazol
Dicyandiamide
2-amino-4-chloro-6-methyl-pyrimidine
2-niercapto-benzothiazole
2-sulfanilamidothiazole
Thlourea
Dow Chemical
Co.
Uniroyal Chemical
N-Serve
Dwell, Terrazole
(etradiazol)
DCD
AM
MBT
ST
TU
Yes
Yes
SKW
Trostberg AG
Mitsui Toatsu Co.
Onodo Chemical Industries
Mitsui
Toatsu Co.
Nitto Ryoso
No
No
No
No
No
Proposed
as nitrlficatlon Inhibitors:
2,4-diamino-6-trichloromethyl-5-triazine
Polyetherionophores
4-amino-I,
2, 4-trlazole
3-mercapto-1, 2,
4-trlazole
Potassium
azide
Carbon bisuifide
Sodium trithiocarbonate
Ammonium dlthiocarbamate
2, 3, dihydro-2, 2-dimethyl-7-benzofuranol
methyl-carbamate
N-(2, 6-dimethylphenyl)-N-(Methoxyacetyl)-
alanlne
methyl ester
Ammonium thiosulfate
1 -hydroxypyrazole
2-methylpyrazole-I-carboxamide
Amer. Cyanarnid Co.
Amer. Cyanamid Co.
Ishlhara Industries
Nippon Gas
Indus.
Pittsb. Plate Glass Co.
Imperial Chem.
lndus.
Imperial .Chem.
Indus.
FMC
FMC
Furadan
(carbofuran)
No
No
No
No
No
No
No
No
No
Olin
Corp.
CMP
BASF
GDR
No
No
No
No
3
Table 3. Effects on Grain Yields of Corn Grown with Conventional and No-Till Systems from Addition of NitrifI-~
catIon Inhibitors to Fail- and Spring-Applied Ammoniacal Fertilizers’
Location
Time
of
applIcation
No. of
experiments
No. of yield
increases from
NI2
Yield Incre
from NI3
ase
Indiana
No.
Illinois
Fall
Spring
Spring (no-till)
FaIl
SprIng
24
51
12
12
14
17
29
9
5
2
12.5
5.8
10.0
5.0
-1.0
•
So.
Illinois
Kentucky
•
Fall (NH3)
Spring (NH3)
Spring (no-till)
Fall (N solution)
Spring (N solution)
Spring (no-till)
7
9
2
5
5
8
7
7
2
4
2
7
4.6
4.6
8.5
3.3
-1.2
14.3
.
Wisconsin
Fall
Spring
2
2
1
0
4.7
1.5
•
‘Adapted from R. G. Hoeft 1984. Current status
of
nitrificatlon Inhibitors.
In R.
0.
Hauck
(ed.) Nitrogen
In
Crop Production. Am. Soc.
of
Agronomy, Madison, WI.
2
SIgnificant
at 95
probabIlity level.
3Average percent yield Increase across all
N rates and locations.
the previous fall if a NI
is used, thereby reducing the
workload in the critical spring planting season. The
use of
NI permits early spring application of N
In many
areas of the United States where N losses are a
consistent problem.
Data
In Table 3 show that NI
addition does not
result in yield increases In
all soils and climatic
conditions.
In fact, in some situations there isa low
probability of a
corn yield increase from NI.
Since the
purpose of NI application is to increase the efficiency
and amount of N available to plants by reducing
N
losses,
no response to NI
will be
obtained durIng
seasons or with soil types having little or no N loss.
Little or no N loss occurs during seasons with below
average
rainfall following
N
application because
N
loss through leachIng and denitrificatlon is directly
related to the amount and distribution of rainfall and
the drainage characteristicsof the soil.
No yield response will be obtained from NI
addition when N
rates used are farin excess of those
required for maximum yield.
For example, if maximum
corn yields could be
obtained with 150 pounds of N
per acre but 300
pounds peracre are applied, as
much as one-half of the applied N could be
lost before
a decrease in yield occurs. Late
side-dress injections
of N may reduce yield through mechanical damage to
the root system and increased root rot. Immobilization
of late-season applied N with
a
NI mayfurther
exacerbate this condition.
In sandy soils with very low cation exchange
capacities,
the addition of NI to ammonlacal fertilizers
may not reduce N
loss or increase crop yield because
of differential movement of ammonia and NI from
the
zone of placement. Some studies have shown that
ammonium ions were leached below the NI treated
zone by rainfall and irrigation water. In this situation,
nitrification deeper in the profile
produced nitrate that
was subsequently removed from the rooting zone by
leaching.
Table 4. Effects of Nitriflcatlon Inhibitors on the Yield
of irrigated Corn FertIlized with Urea. (Hubbard
Loamy Sand).’
N
rate
Nitriflcation Inhibitor
None
N-Serve
Dwell
lblacre
—-corn
yield, bu/acre—
0
59
—
—
60
89
119
98
120
105
151
145
180
136
170
171
240
171
182
186
N applIed
Treatment
NH3
NH3
+
N
Serve
lb/acre
—grain protein,
—
0
6.76
—
60
7.76
9.24
120
9.38
10.60
180
10.80
11.71
I
Study
conducted
in
Indiana
usIng
B73x Moll
corn hybrid.
Table 6. E
of Corn.’
ffects ofa Nitrificatlon Inhibitor on Stalk Rot
~
No. of
studies
N
Treatment
source
N
N
+
N
Serve
3
4
—-
plants with stalk rot’-----.
NH3
38
16
Swine manure
54
23
‘Average values for all locatIons, years, and N rates from
studies in
Indiana.
Table 5. Effect of a Nitriflcatlon Inhibitor on Corn
Grain Protein
Concentration.1
‘Taken
from G. L Malzer, T. J. Graff
and J. Lensing. 1979.
Influence ofnitrogen
rate,
timing
of
nitrogen
application
and
use
of nitrification
inhibitors for
irrigated spring wheat and corn, In
Univ.
Minn. Soil SerIes 105 Report on FIeld Research In Soils.
4
WHERE SHOULD
NITRIFICATION INHIBITORS BE USED?
The response of corn to applications of NI with
ammoniacal fertilizers varies greatly throughout the
United States because ofmajor differences
in
N loss
potential from
differing climate, soils, and production
systems. A summary of research results on
corn yield
responses from NI
addition for various corn
production regions is
presented in Table 7, and the
probabilities for obtaining a yield response from
NI for
several combinations of region, soil texture, and time
of fertilizer application aregiven in Table 8. The
addition of NI
to fertilizer should be looked upon as
insurance against N loss, and, thus, a decision to use
NI
should be based on the probability of obtaining
yield increases
over a period of time, e.g.,
5 years.
The usefulness of NI for corn production in three
general regions of the United States is discussed
below.
Southeast
The response of
corn
to NI applications in the
southeastern United States has been mixed. The
relatively high soil temperatures during the winter
result
in nitrificatlon of fall-applied N and subsequent
leaching or denitrification of the nitrate that is formed.
The addition of NI does not alleviate this problem
because of the limited longevity of the currently
registered inhibitor compounds in soil and the long
periodof time between N application and crop
uptake
of the nutrient. Thus, yield responses to
NJ added to
fail-applied fertilizers have not been consistently
observed. A number ofstudies have shown modest
corn yield increases from
the addition
of NI to spring-
applied N eventhough inhibitor persistence
Is limited
by high soil temperatures. Overall, the probability of
corn yield response from currently available
NI in the
southeastern
U.S. is poor for fall-applied N and fair to
poor for spring-applied N.
Eastern
Cornbélt
The response of corn to
NI application has been
more consistent over years in the eastern CornbeIt
than other portions
of the United States because
of
high rainfall, finer textured soils,
and cold soil
temperatures during the winter.
However,
overall only
about 50 and
70
of the trials with spring- and fall-
applied N haveshown yield response from NI. Yield
responses have been obtained with both spring- and
fall-applied
N in
Indiana, Kentucky, Ohio, and
southern Illinois. The consistency of yield responses
to NI has been less
in Michigan,
WIsconsin,
Missouri,
central and northern Illinois, and
Iowa than in other
eastern Cornbelt states. However,
all states in the
eastern Cornbelthave studies showing corn yield
increases from NI addition, and the largest and most
consistent increases are normally observed with fall-
applied
N orwith non-tillage programs.
There is a good
probability of obtaining a yield
increase from application of NI to fall-applied
ammoniacal fertilizers in the eastern Combelt
because of the large N loss normally associated with
fall applications. The use of NI will allow producers to
apply Nfertilizers somewhat earlier than generally
considered feasible (50°FIs traditionally considered
the maximum soil temperature for application of
ammoniacal fertilizers in the fall without a
NI). Fall
application of N
isnot recommended forlow CEC
coarse-textured soils because of the possibility of
ammonium leaching.
The probability is good that NI
added to spring-
prepiant
N will increase yields of corn growth on fine-
textured soils of the eastern Cornbelt because of the
likelihood of Nlosses by denitrificatlon after
fertilization. Only a fair
probability exists for a yield
response to
NI added with sprlng-preplant N applied
to silt barns and coarser textured soils. The
probability of loss in
such
soils depends
upon the
nitrification rate following fertilization, the Internal
drainage of the soil, and the dIstribution and intensity
Region
Time
of
applIcatIon
of studies with
yield
Increase
yield
Increase2
Southeast (GA,
MD, NC, SC, TN)
FaIl
Spring
17
43
14
15
Eastern Cornbelt (IL
IN, OH, KY)
FaIl
Spring
Spring (no-till)
69
51
82
9
3
13
Northern Cornbelt (Ml, MN,
WI)
Fall
25
5
not irrigated
Spring
17
12
Western
Cornbelt (KS, MN, NE)
Spring
52
30
irrigated coarse-textured soils
Western Cornbelt (KS, NE)
Spring
10
5
irrigated medium- and
fine-textured soils
Table 7. RegIonal Summary
of Corn Yield Responses
from Nitrification Inhibitors Added to Ammoniacal
Fertilizers Appled
at VaryIng Times.’
‘Data taken from
a
variety
of research
progress
reports and published materials.
2Average increases obtained
In experiments where NI addition gave significant yield increases.
5
of rainfall.
Heavy rains occurring 2 to 8 weeks
after
fertilization may resultin extensive N losses and yield
responses to NI
application. However, if a
below
average rainfall
period follows fertilization, little N
loss
or response tb NI will occur.
Western Cornbelt
Few yield responses to
NI have been observed
with dryland corn or irrigated corn
produced on fine-
texturedsoils in Minnesota, North Dakota, South
Dakota, and other states west of the Missouri river.
However, the use of NI
has resulted in increased
yields in areas where preplant N is applied to
irrigated
corn grown on sandy soils.
Data from Minnesota
(Table
4) illustrate the type of responses that are
sometimes obtained when a NI
is used to
reduce
nitrate leaching
in irrigated sandy soils.
There is poor probability of yield response with
spring-appliedfertilizer for drylandcorn production in
the western Cornbelt; however, with irrigated coarse-
textured soils the probability of a yield increase
improves. Thereis a fair probability of a response to
NI with fall applied fertilizer on finer textured soils. Fall
application of ammoniacal fertilizers is not
recommended for sandy soils.
ADDITIONAL CONSIDERATIONS WHEN
USING NITRIFICATION INHIBITORS
More consistent yield responses have been
obtained with no-till grown corn than with conventional
tillage systems fertilized in the spring
(Tables
3 and 8).
This finding results from greater infiltration rates,
higher watercontents,
a higher population of
denitrifying bacteria in no-till soils
and, thus, increased
N losses from leaching and/or denitrification.
The probability of yield responses to NI added to
spring-sidedress-applied N is considered low for all
soils because the fertilizer is added close to the time
of plant uptake.
However, a few investigators in the
eastern Cornbelt have observed significant yield
Increases from
NI added to early sidedressed N
fertilizers.Additional
studies are needed at several
locations in all corn-growing
regions to determine the
long-term probability of a response to NI application
with sidedress
N should exist on coarse-textured soils
receiving
excess rainfall or irrigation water.
The commercially available Ni have properties
that affect how they can be added to various types of
fertilizers.
N-Serve
and
Dwell can
be impregnated
on
solid fertilizers, oran
emulsifiable formulation may be
mixed with N solution fertilizers. N-Serve can
be
added directly to bulk anhydrous ammonia because of
Its high solubility in liquid ammonia. However, Dwell is
not soluble in ammonia, but can be added to
anhydrous ammonia
with a small electric pump that
meters the compound into the ammonia stream
between the nitrolator and the manifold system on the
applicator.
Reference to products in this publication is not intended to
be an endorsement to the exclusion of others which maybs-&rnilar. Persons
using such products assume
responsibility for their use in accordance with current directIons~of
-the-manufacturer.
A publication of the National Corn Handbook Project
and
Justice
for all
The U.S. Department ofAgriculture (USDA) prohibits
discrimination
in all its
programs and activities on the basis of race, color, national origin, gender.
religion, age,
disabitty,
political bell
at’s, sexual orientation, and marital or
family
status,
(Not
all prohibited
bases apply
to all programs.) Many materials
can be made available in alternative fcrmats forADA clients.To
file a
complaint ofdiscrimination,
writeUSDA,
Office of CMI Rights. Room 326.W.
Whitten Building, 14th and IndependenceAvenue,
SW, Washington,
cc
20250-9410 or call 202.720.5964.
Issued
in ftirtheranceof Cooperative
Extension work. Acts of
May 8 and June
30,
1914,
incooperation with the
U.S. Department ofAgriculture. Stanley R.
Johnson,
dIrector, Cooperative Extension
Service, Iowa State University of
Science and Technology, Ames, Iowa.
File:
Agronomy 2-2
Table
8. Probability of Corn Yield Increase from the AdditIon of NI to Ammoniacal Fertilizers Applied at
Varying Times.
Application
Region ofthe U.S.
Eastern
Western
Soil texture
time
Southeast
Cornbeit
Cornbelt
—Probability
of corn yield increas&—
Sands
Fall
Poor
Poor
Poor
:
Spring
Fair
Fair
Fair2
Loamy sands, sandy
barns, and barns
Fall
Spring
.
Poor
Fair
Fair
Fair3
Poor
Fair3
Silt barns
Fall
Spring
Poor
Good
Fair
Fair3
Fair
Poor
Clay
barns and
Fall
Poor
Good
Fair
clays
Spring
Fair
Good
Poor
‘Poor
=
less than 20
chance of yield increase at any location any yean fair
20.60
chance of increase
good
greaterlhan 60
chanceofincrease.
2
Fair for irrigated
soils,
poor for dryland corn.
Good for no-till production systems.
Exhibit
C
EXHIBIT C
SUMMARY DOCUMENT OF EFFLUENT AMMONIA-NITROGEN
REDUCTION EVALUATIONS FOR NOVEON-HENRY PLANT
MEMORANDUM
TO:
Mark Latham, Esq.
JOB NO:
27-21522.001
FROM:
T.
Houston
Flippin,
P.E., DEE
DATE:
May 17, 2002
SUBJECT:
Ammonia-Nitrogen Treatment Alternatiyes Support Exhibit
Brown
and
Caidwell
is
providing
below
a
summary
of
information
intended
to
support
the
discussion
of
ammonia-nitrogen
(NH3-N)
treatment
alternatives
described
in
the
Petition
For
Adjusted
Standard.
This
information is
the product of
treatability
testing,
full-scale
plant
testing,
and dataprovided by the Noveon-Henry Plant staff.
In order to
develop treatment
alternatives, a
“design influent and effluent wasteload” was required.
This wasteloads were developed based on
individual
wastestream data gathered in 1995 and
effluent
data gathered in 1999 through 2000 and are summarized below in Tables
1 and 2.
A
flowschematic
is provided in Attachment A
of
the wastewater treatment facility (WWTF) provided
at the Henry
Plant.
Table
1.
Influent Wasteload Used In Developing Treatment Alternatives
Parameter
PVC
Tank
PC
Tank
C-18
Tank
Holding Pond!
Well No.3
Waters
Total
Flowrate,
gpm
Average
401
107
6
46
560
Peak
499
150
15
105
769
SCOD,
lbs/day
Average
2,650
8,280
1,320
50
12,300
Peak
4,330
10,840
2,940
50
18,160
Estimated
BOD, lbs/day
Average
795
2,485
395
15
3,690
Peak
1,300
3,250
880
15
5,445
TKN, lbs/day
Average
459
494
,
82
3
1038
Peak
640
693
198
7
1537
NH3-N, lbs/day
Average
295
62
27
1
385
Peak
411
87
66
3
571
BROWN
AND
C
A
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D
\V
E
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P:\PROJ\21522\M051702 Latham.doc
Memorandum
to
Mark Latham,
Esq.
May 17, 2002
Page 2
Table 2.
Effluent Wasteload Used In Developing Treatment Alternatives
Parameter
Effluent Value
NH3-N, lbs/day
Average
909
Peak
1408
The
following
treatment alternatives
were considered
for ammonia
reduction.
Illustrations of each
are provided in Attachment A.
•
alkaline air stripping
ofPC
Tank contents with
off-gas
collection
and
treatment (No. 1)
•
alkaline
air stripping
of PVC
Tank contents
(No.2)
•
alkaline air stripping
ofsecondary clarifier effluent (No.3)
•
struvite
(NH4MgPO46H2O) precipitation
from combined influent (No.4)
•
breakpoint chlorination
of
secondary clarifier effluent (No.
5)
•
nitrification of PVC Tank wastewater (non-PC wastewaters) (No.
6)
•
nitrification
of combined wastewater (No. 7)
•
ion exchange treatment of final effluent (No.
8)
•
ozonation of final effluent
(No.9)
•
nitrification of secondary clarifier effluent (tertiary nitrification) (No.
10)
A
summary
of
conceptual
level
capital
costs
for
each
of
these
alternatives
are
summarized
in
Table 3.
The total costs presented in this
table
are
considered accurate to within ±
30 percent.
Table 3.
Capital Cost Estimates For Treatment Alternatives
Upgrade Components
Upgrade C
osts in
$
Milhions forTreatment
Alt
ernative Number
1
2
3
4
5
6
7
8
9
10
Pretreatment
0.65
0.10
0.00
0.05
0.00
0.02
0.43
0.00
0.00
0.00
Primary Treatment
0.00
0.00
0.00
0,00
0.00
0.25
0.00
0.00
0.00
0.00
Secondary Treatment
0.00
0.00
0.00
0.00
0.00
1.12
1.91
0.00
0.00
0.00
Tertiary
Treatment
4.21
0.75
0.57
4.6
4.00
Sub-total
0.65
0.10
4.21
0.05
0.75
1.39
2.34
0.57
4.6
4.00
Sitework/Interface Piping
0.10
0.01
0.32
0.01
0.11
0.21
0.35
0.09
0.20
0.50
Electrical/Instrumentation
0.25
0.16
0.40
0.16
0.26
0.36
0.50
0.24
0.50
0.30
Contractor Indirects
(8 )
0.05
0.01
0.34
0.00
0.06
0.11
0.19
0.05
0.37
0.32
Engin./Constr. Mgmt (18
)
0.12
0.02
0.76
0.01
0.14
0.25
0.42
0.10
0.83
0.72
Performance
Bonds
(1
)
0.01
0.00
0.04
0.00
0.01
0.01
0.02
0.00
0.05
0.04
Sub-total
1.17
0.30
6.07
0.22
1.33
2.33
3.82
1.04
6.54
5.88
Contingency
(15 )
0.18
0.04
0.91
0.03
0.20
0.35
0.57
0.16
0.98
0.88
Total Installed
Cost
1.35
0.34
6.98
0.25
1.53
2.68
4.40
1.20
7.52
6.76
P’PROJ\2 1522\M05
1702 Latham.doc
Memorandumto Mark Latham,Esq.
May 17, 2002
Page 3
A
summary
of conceptual level operations
and maintenance
costs for each of these alternatives
are
summarized
in
Table
4.
The
total
costs
presented in
this
table
are
considered accurate to within
±30
percent.
Table
4.
Annual Operating
and Maintenance Cost Estimates For Treatment Alternatives
Ann
Cost Components
1
2
3
ualO/M Costsin
$ Thousands for
Treatment Alternative Number
4
5
6
7
8
9
10
Labor ($40/hour)
32
32
60
8
60
60
60
60
30
60
Electrical ($0.06/kwh)
64
29
214
0
4
10
98
10
1,363
88
Natural
Gas ($0.06/therm)
18
0
0
0
0
0
0
0
0
0
Chemicals (Plant
Costs)
0
1,794
575
642
1,028
218
788
147
226
459
Resin
Replace. ($35/cu
ft)
0
0
0
0
0
0
0
242
0
0
Off-site Disposala
0
0
0
0
0
0
0
51
0
0
Maintenance Material&’
17
2
105
1
19
11
45
14
115
22
Sub-total
130
1,858
954
652
1,111
299
990
524
1,735
629
Contingency (10
)
13
186
95
65
111
30
99
52
173
63
Total Annual
143
2,044
1,049
717
1,222
329
1,089
576
1,908
692
a
Cost of disposing of spent regenerant
containing
29.7 percent by weight NH4C1 (8
percent N)
assumed to be
$0.10/gallon.
b
Based on
5 percent of equipment costs.
A comparison of alternatives
regarding present worth costs
and
ammonia
removal
is provided in
Table 5.
Table 5.
Comparison of Present Worth Costs and Ammonia Removal for Treatment Alternatives
Treatm
Components
1
2
3
4
ent
Alternative Number
5
6
7
8
9
10
NH3-NRemoval,lbs/day
247
147
864
217
891
423
891
891
891
891
NH3-N Removal,
27
16
95
24
98
47
98
98
98
98
Present Worth Costs
•
Capital
1.35
0.34
6.98
0.25
1.53
2.68
4.40
1.20
7.52
6.76
•
0/Ma
0.96
13.71
7.04
4.81
8.20
2.20
7.31
3.87
12.80
4.64
•
Total
2.31
14.06
14.02
5.06
9.73
4.88
11.71
5.07
20.32
11.41
a
Based on
10 year period, 8 percent
annual interest, and no salvage value.
P:\PRO3\2l~22\M0$I
702 Latham.doc
BROWN
AND
CAL DWELL
Nashville, Tennessee
P1PROJI2I522IFi9
1
FIGURE 1
BLOCK
FLOW
DIAGRAM
OF
WASTESTREAM
SOURCES AND
WWTF
Treatment
~~~P~Tank
ALTERNATIVE NO.1
- ALKALINE
AIR
STRIPPING
OF PC
TANK
CONTENTS
~testream~-Ø
—~
PVC Tank
~
To Primary
~-
Defoamer
,#‘
Treatment
ALTERNATIVE NO.2-ALKALINE AIR STRIPPING
OF
PVC TANK CONTENTS
Off-Gas
Treatment
Packed Tower
________________
~rSth~erT
~
Filtration
~
ALTERNATIVE NO.3-ALKALINE
AIR
STRIPPING OF SECONDARY
CLARIFIER
EFFLUENT
FIGURE 2
BLOCK
FLOW
DIAGRAM
OF
ALKALINE
_____
AIR STRIPPING
TREATMENTALTERNATIVES
I
Existing
Equipment
(Nos.
1, 2, and 3)
t......~
New
Equipment
BROWN
AND
(‘
A
T
~
~
T
Nashville,
Tennessee
PJPROJ/21 522/Fig 2
~
NOTE:
Existing FeCI3Addition
would be discontinued
I
I
Existing Equipment
EL._J
New
Equipment
FIGURE
3
BLOCK
FLOW
DIAGRAM
OF STRUVITE
PRECIPITATION TREATMENT ALTERNATIVE
(No.4)
BROWN
AND
PJPROJI21522IFI9 3
C
A
L
D
W
E
L
L
Nashville.
Tennessee
I
Existing Equipment
ET~1
New
Equipment
FIGURE 4
BLOCK
FLOW
DIAGRAM
OF BREAKPOINT
CHLORINATION
ALTERNATIVE
(No.5)
BROWN
AND
C
A
L
D
W
E
L
L
‘
Nashville, Tennessee
ti~od~
PJPROJ/21
522/Fig
4
‘
Existing Equipment
New
Equipment
PJPROJ/215221Fig5
FIGURE 5
BLOCK
FLOW
DIAGRAM OF NON-PC WASTESTREAM
NITRIFICATION TREATMENT ALTERNATIVE
(No.6)
WN
AND
LDWELL
1~
Existing Equipment
EJ
New
Equipment
I\\\\\~
Upgraded Equipment
PJPROJ/21 522/Fig
6
FIGURE 6
BLOCK FLOW
DIAGRAM OF COMBINED WASTESTREAM
NITRIFICATION TREATMENT ALTERNATIVE
(No.7)
BROWN
ELL
Regenerant
~~—-
Filtration
Ij~
Ion
Exchange
Treatment
-
To
Illinois Rive~~’~
Spent Regenerant
~ToOff-Site Disposat~
Existing Equipment
New
Equipment
BLOCK FLOW
DIAGRAM
OF ION EXCHANGE
TREATMENT ALTERNATIVE
BROWN
AND
FIGURE 7
(No.8)
PJPROJ/21
522/Fig
7
C
A
LD
WELL
I
Existing Equipment
LT~
New
Equipment
FIGURE 8
BLOCK FLOW
DIAGRAM
OF OZONE
TREATMENT ALTERNATIVE
(No.9)
BROWN
AND
CALD
WELL
Nashville.
Tennessee
P/PROJ/2152VFig8
‘
Existing
Equipment
F
1
New
Equipment
FIGURE 9
BLOCK FLOW
DIAGRAM
OF TERTIARY
NITRIFICATION TREATMENT ALTERNATIVE
(No. 10)
BROWN
AND
CALD
WELL
Nashville, Tennessee
P:/PROJ/215221Fig 9
ni
0
EXHIBIT D
SUMMARY
OF COST ANALYSIS FOR PROVIDING
INCREMENTAL
EFFLUENT AMMONIA-NITROGEN REMOVAL AT
THE
NOVEON-HENRY PLANT
WWTF
Component
Basis
PC Tank
PVC
Tank
Effluent
Effluent
Effluent
Effluent
Effluent
Struvite
Effluent BP
Non-PC
Combined
Stripping
Stripping
Stripping
Stripping
Stripping
Stripping
Stripping
Precipitation
Chlorination
Nitriflcation
Nitrilicatlon
w/
Off-gas.
wlo
Off-gas
w/ Off-gas
No
Off-gas
No
Off-gas
No
Off-gas
No Off-gas
75
removal
50
removal
25
removal
Additional Operations/
MaintenanceLabor
~LaborHours
800
800
1500
1300
1300
1000
1000
200
1500
1500
1500
*
AnnualCost,
$
$40/hr
32000
32000
60000
52000
52000
40000
40000
8000
60000
60000
60000
Electrical
Usage
~hp
162
75
545
505
450
300
300
1
10
25
250
*
kwh
1058664
490122
3561553
3300155
2940732
1960488
1960488
6535
65350
163374
1633740
*Annualcost,$
$0.06/kwh
63520
29407
213693
198009
176444
117629
117629
392
3921
9802
98024
Maintenance Materials
Low End EquipmentCosts,$
330,000
40,000
2106000
1263600
1013600
631800
379060
15000
375000
222,000
890,000
AnnualCosts,$
5ofECosts
16600
2000
105300
63160
50680
31590
16954
750
18750
11100
44500
Chemical
Costs
-
*
50
t4aOH, $ year
$240/ton
0
1770431.04
434000
434000
434000
217000
108500
0
955541
217772
742484
98l-12S04,$/year
$46/ton
0
24238
141000
119850
119850
70500
35250
0
0
0
45333
75
H3P04. S/year
$335/ton
0
0
0
0
0
0
0
407160
0
0
0
62
Mg(OH)2. S/year
$220/ton
0
0
0
0
0
0
0
235205
0
0
0
*
98
1-ICI, S/year
$70/ton
0
0
0
0
0
0
0
0
0
0
-
0
*
Chlorine Gas, S/year
$50/ton
0
0
0
0
0
0
0
0
72681
0
0
Annual Costs,
5/year
0
1794669
575000
553850
553850
287500
143750
642365
1028222
217772
787817
Annual
Resin Replacement,
S/year
$90/cuft
0
0
0
0
0
0
0
0
0
0
0
Annual
Off-site
Disposal,
S/year
$0.10/gal
Natural Gas Cost,
S/year
Annual Cost,
S/year
$0.06/therm
18240
0
0
0
0
0
0
0
0
0
0
Subtotal
Annual
Costa.
S/year
130260
1858076
953993
867039
832974
476719
320333
651507
1110893
298674
990341
Contingency (10).$/yr
13026
185808
-
95399
86704
83297
47672
32033
65151
111089
29867
99034
Total Annual Cost,
5/year
143286
2043884
1049393
953743
916271
524391
352367
716657
1221982
328542
1089375
Present Worth ofAnnual
Costs
$
10
years
961448
13714462
7041424
6399617
6148181
3518665
2364380
4808771
8199501
2204516
7309707
8
percent interest
Capital Costs, $
1,345.138
344.023
6,983,076
4,522,426
3,770,418
2,453,930
1.541,358
253,748
1,526,625
2,676,729
4,397,370
Total PresentWorth,
$
2.306,586
14,058,484
14.024.500
10,922,043
9,918,598
5,972,595
3,905.738
5.062,519
9.726,126
4,881,245
11.707,077
Average NH3-N Removal, lbs/day
247
147
864
664
648
432
216
217
891
423
891
Average Nl-l3-N Removal,
27.2
16.2
95.0
95.0
71.3
47.5
23.8
23.9
98.0
46.5
98.0
Presen(WorthCos(,$/lbNH3.f4
2.56
26.13
4,45
3.47
4.20
3.79
4.98
6.39
2.99
3.16
3.60
WVVTF Component
-
Basis
Effluent
Effluent
Effluent
Effluent
Ozonation
Tertiary
Tertiary
Tertiary
Tertiary
-
Ion
Exchange
ton
Exchange
Ion Exchange
Ion
Exchange
Nitrification
Nitrificatton
Nitr8ication
Nitrittcation
75
removal
50
removal
25
removal
75
removal
50
removal
25
removal
Electrical Usage
*
hp
*
kwh
*
Annual Cost,
$
Maintenance Materials
-
Low End
Equipment
Costs.
$
• Annual
Costs,
$
$0.06/kwh
5
of E
Costs
Chemical
Costs
• 50
NaOH,
$
year
*
98
H2804, $fyear
*
75
H3P04, 5/year
‘62
Mg(OH)2, 5/year
*
98
HCI,
S/year
*
Chlorine Gas. S/year
*Annual Costs,
5/year
Annual
Resin Replacement, $Iyear
$90/cu ft
Annual
Off-site Disposal, S/year
$0.10/gal
Natural Gas Cost, 5/year
Annual
Cost.
$1
year
$0.06/therm
Subtotal Annual
Costs, $/year
Contingency (10),$/yr
Total Annual
Cost,
$Iyear
Present Worth ofAnnual
Costs
$
10 years
8
percent
interest
Capital Costs,
$
Total Present
Worth,
$
Average NH3-N Removal,
lbs/day
Average NH3-N Removal,
Present Worth
Cost, $Ilb NH3-N
1500
1500
1500
1500
750
1500
1500
1500
1500
60000
60000
60000
60000
30000
60000
60000
60000
60000
25
18.75
163374
122531
9802
7352
12.5
6.25
225
168.75
112.5
56.25
81687
40844
22727273
1470366
1102775
735183
367592
4901
2451
1363636
88222
66166
44111
22055
284000
227200
170400
85200
2300000
444000
355200
266400
133200
14200
11360
8520
4260
115000
22200
17780
13320
6660
129861
97396
64930
0
0
0
0
0
0
0
17044
12783
8522
0
0
0
146905
110179
73453
242449
181837
121224
50727
38045
25363
0
0
0
524083
408772
293462
52408
40877
29346
576492
449650
322808
3868259
3017150
2166041
1,198.024
1.095.472
787,814
5.066,283
4,112.621
2,953.855
891
668
445
98.0
73.5
49.0
1.56
1.69
1.82
176731
1734781
629082
487921
346761
203380
17673
173478
62908
48792
34676
20338
194404
1908259
681990
536713
381437
223718
1304450
12804419
4643251
3601346
2659441
1501151
480,157
7,523,300
6,762,000
6,223,800
4,264,200
2,304,600
1,784,607
20.327,719
11,405,261
9,825,146
6,823,641
3,805,751
223
891
891
668
445
223
24.5
98.0
98.0
73.5
49.0
24.5
2.20
6.25
3.61
4.03
4.20
4.68
Additional
Operations!
Maintenance Labor
*
Labor Hours
*
Annual Cost, $
$40/hr
$240/ton
$46/ton
$335/ton
$220/ton
$70/ton
$50/ton
32465
226145
458660
343995
229330
114665
0
0
0
0
0
0
0
-
0
0
0
0
0
0
0
4261
0
0
0
0
0
0
0
0
0
0
0
36726
226145
458660
343995
229330
114665
60612
0
0
0
0
0
12682
0
0
0
0
0
0
in
in
EXHIBIT E
SUMMARY TABLE COMPARING
COST, EFFLUENT AMMONIA-NITROGEN
REDUCTION PERCENTAGES, RELIABILITY,
AND
PROS
AND
CONS OF
ALTERNATIVE
EFFLUENT AMMONIA-NITROGEN REDUCTION
PROCESSES FOR
THE
NOVEON-HENRY
PLANT
Comparison of Costs and Removals ofEffluent
NH3-N
Removal Processes
for the Noveon-Henry Wastewater Treatment
Facility
with
10-YearProject
Life
Annual Operating
-
Process
Capital Cost
($
millions)
Cost
($
millions/year)
Present
Worth
Costa
Effluent NH3-N Removal
(Average )
($
millions)
(i/lb NH3-N removed)
PC
Tank
Strippingwith
1.35
0.130
2.21
2.45
27
Off-gas Control
1.31
0.125
2.15
4.60
14
PVC
Tank
Stripping
0.344
2.04
14.1
26.13
16
without Off-gas Control
0.317
2.03
14.0
51.89
8
Effluent
Strippingwith
6.98
1.05
14.1
4.42
95
Off-gas Control
Effluent Stripping without
4.52
0.894
10.5
3.34
95
Off-gas Control
-
3.77
-
0.850
9.5
3.83
75
2.45
0.483
5.7
3.44
50
1.54
0.332
3.8
4.59
25
Struvite Precipitation
0.254
0.669
4.74
5.99
24
0.254
0.539
3.87
6.53
18
Effluent Breakpoint
1.53
1.22
9.73
2.99
98
Chlorination
-
P:\PROJ\23417
-
Noveon\Hcnry
-
002\Exhibit
Edoc
Page
1 of2
Comparison of
Costs
andRemovals ofEffluent NH3-N Removal Processes
for the Noveon-Henry Wastewater Treatment
Facility with
10-YearProject
Life
Process
Capital Cost
($
millions)
Annual Operating
Cost
($
millions/year)
Present
Worth
Cost
EffluentNH3-N Removal
(Average
)
($
millions)
($/lbNH3-N removed)
Non-PC Nitrification
2.68
0.329
4.88
3.16
47
Combined Single-Stage
4.40
1.09
11.7
3.60
98
Nitrification
•
MBT Removal Process
0.86
0.441
3.82
Less Than
25
•
WWTF
Upgrades
3.54
-
0.649
7.88
0
EffluentIon Exchange
1.20
1.10
0.79
0.48
0.688
0.533
0.379
0.222
5.82
4.67
3.33
1.97
1.79
1.88
2.01
2.38
98
75
50
25
EffluentOzonation
7.52
1.91
20.3
6.25
98
Tertiary Nitrification
6.76
0.692
-
11.4
3.51
98
-
6.22
4.26
2.30
0.536
0.381
0.223
9.83
6.82
3.81
4.03
4.20
4.68
75
50
25
aio years at
8
interest.
P:\PaOJ\23417
-
Nøveon\Heniy
-
0O2\E~hibit
E’3oc
Page 2 of2
Comparison of Costs andRemovals ofEffluent NHçN Removal Processes
for the Noveon-Henry Wastewater Treatment Facility
with
20-Year Project
Life
AnnualOperating
Process
Capital Cost
($
millions)
Cost
($
millions/year)
Present
Worth
Cost5
Effluent NH3-N Removal
(Average )
($
millions)
($/lb NH3-N removed)
PC
Tank Stripping
with
1.35
0.130
2.63
1.46
27
Off-gas
Control
1.31
0.125
2.54
2.72
14
PVC
Tank Stripping
-
0.344
2.04
20.4
18.90
16
without Off-gas Control
-
0.317
2.03
20.2
37.43
8
Effluent Stripping with
6.98
1.05
17.3
2.71
95
Off-gas Control
-
Effluent
Strippingwithout
4.52
0.894
13.3
2.12
95
Off-gas Control
3.77
0.850
12.1
2.44
75
2.45
0.483
7.2
2.17
50
1.54
0.332
4.8
2.90
25
Struvite Precipitation
0.254
0.669
6.8
4.30
24
0.254
0.539
5.5
4.64
18
Effluent Breakpoint
1.53
1.22
13.5
1.08
-
98
Chlorination
-
P:\PROJ\23417
-
Novcon\Hcrny
-
002\Exhibit E4oc
-
Page
1
of2
Comparison
of Costs and Removals of EffluentNH3-N Removal Processes
for theNoveon-Henry Wastewater Treatment Facility
with
20-YearProject
Life
Process
Capital Cost
($
millions)
Annual Operatin
Cost
($
millions/year)
g
Present
Worth
Cost
EffluentNH3-N Removal
(Average
)
($
millions)
($/lbNH3-N removed)
Non-PC Nitrification
2.68
0.329
5.9
-
1.91
47
-
Combined Single-Stage
4.40
1.09
15.1
2.32
98
Nitrification
•
MBT
Removal Process
0.86
0.441
5.2
Less
Than
25
•
WWI’F
Upgrades
3.54
0.649
9.9
.
0
EffluentIonExchange
1.20
1.10
-
0.79
0.48
0.688
0.533
0.379
0.222
•
8.0
6.3
4.5
2.7
1.23
1.27
L36
-
1.63
98
75
50
25
Effluent Ozonation
7.52
1.91
26.3
4.05
98
Tertiary Nitrification
6.76
6.22
4.26
2.30
0.692
0.536
0.381
0.223
13.6
11.5
8.0
4.5
2.09
2.36
2.46
2.76
98
75
50
25
~20years at8
interest.
P:\VROJ\23417
-
Noveon\Henxy
-
0O2\Exhibit E.doc
Page 2 of 2
Comparison ofRemovals
and
Reliability ofEffluent
NH3-N
RemovalProcesses
for the Noveon-Henry Wastewater Treatment Facility
Process
Effluent NH3-.N Removal
Reliability
(Average
)
Rating1
Comments
PC
Tank Stripping with
27
8
Involves adding surface aerator, oversized
withdrawal
fan, off-gas collection
Off-gas Control
and thermal
oxidation
ofoff-gas. Off-gas collection
and treatment are
needed
for
VOC
controL No chemical addition required since
PC
Tank
contents
are
normally
pH
11
s.u. Simple
to operate.
Performance will vary
as
volatile amine
content varies in wastewater. Averageremovals of 0 to 27 percent could be
achieved by
varying
the
size
of the surface aerator
placed in
thetank.
PVC Tank Stripping
16
7
Involves adding caustic addition
and
surface aerator
to PVC tank contents.
without Off-gas Control
Acid addition
in
primary
system will be required to lower pH to 9.0 s.u. Simple
to operate. Strong foaming potential in PVC
Tank which would
reduce
effectiveness. Performance will
vary
based on production discharges of NH3-N
and
volatile
amines,
and NH3-N returned
in sludge dewatering filtrate
and
tertiary
Liter backwash. Removals of0 to 16 percent could be achieved by
varying
the size of thesurface aerator placed in the tank.
Will
increase effluent
TDS.
‘,
Effluent Stripping
with
95
7
Involves
pumping sand filter
effluent through
two
packed towers in
series.
Off-gas
Control
Caustic
is added to increase pH to 11.5 s.u.
and acid
is added to lower the
treated effluent pH to 8
s.u.
Off-gas is directed to an acid
scrubber for recovery
of (NH4)2SO4. Scrubber dischargewould be disposed off-site. Complex to
operate. Equipmentmust be housedin heated
building
to prevent
freezing.
Fouling
oftower media
with
precipitants is anticipated. Removals of 75 to 95
percent would be achieved by treating thewhole effluent through different
sized columns. Removals
of25 to 50 percent would be achieved by
treating
only aportion
of the final effluent.
Will
increase effluent
TDS.
Page
1 of4
Comparison ofRemovals
and Reliability
of Effluent
NH3-N
Removal Processes
for the Noveon-Henry Wastewater Treatment
Facility
(Continued)
Process
Effluent NH3-N Removal
Reliability
-
(Average
)
Rating1
Comments
-
Effluent Strippingwithout
95
8
Same as above but without off-gas collection and
treatment. NH3-N would
be
Off-gas Control
discharged to atmosphere. Will increase effluent
TDS.
Struvite
Precipitation
24
6
Involves feedingmagnesium
hydroxide and
phosphoric acid to existing primary
treatment system. Simple to operate. However, the precipitant is prone to
foul
-
pumps and
piping. Removal could be varied between 18 and 24 percent
depending upon thequantity of
magnesium
hydroxide added. Performance will
vary strictly
as a
function
of
influent
NH3-N load.
Will
increase effluent TDS.
Effluent Breakpoint
98
9
Involves routing secondary clarifier effluent through
chlorination
step prior to
Chlorination
tertiary
filtration.
Caustic is fed to
maintain
pH
controL Reliable process.
Creates safety concerns and
may form chlorinated organics. Will
increase
-
effluent
TDS.
Non-PC Nitrification
47
7
Involves using
existing
activated sludge system to provide BOD removal
and
-
riitrification ofPVC wastewater. Treated effluent from
this
system would be
combined with
PC
wastewater and treated in newactivated sludge system.
Complex system to operate. Two
WWTFs
that would be subject to upset.
Performance would
vary
as a function of PVC NH3-N and
amine
loading. Will
increase effluent ‘IDS.
Page 2 of4
P;\PROJ\23417
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Noveon\Henry
-
002\Table
Akernañve
NH3.doc
Comparison ofRemovals
and
Reliability
of Effluent NH3-N Removal Processes
for theNoveon-Henry Wastewater Treatment Facility (Continued)
Process
-
Effluent NHçN Removal
-
(Average
)
Reliability
Rating1
Comments
Combined Single-Stage
98
7
Involves adding pretreatment system to remove
MBT and possiblyother
Nitrification
inhibitors from the PC tank contents with acid addition and precipitationat pH
2 s.u.. The
precipitant is separately
dewatered
and disposed. Caustic is added to
the treatedPC wastewater.
This
wastewater is blended
with
wastewater and
river water
and undergoes biological nitrification in an expanded
WWTF.
River
water addition is provided to maintain a set PC wastewater flow contribution.
Additional aeration equipment, aeration
tankage, and sand filtration would be
required. Complex to operate
with two
separate sludge dewateringoperations in
service. Performance would vary with
success of pretreatment facility in
removing inhibitors.
Will
increase effluent IDS.
Effluent Ion Exchange
98
6
Involves pumping
sand filter
effluent through two resin columns in series.
Caustic is added to neutralize effluent from strong acid resin treatment. Resins
would be regenerated
daily using acid and
spent regenerant (high cation content
NH4CL solution) would be disposed off-site. Complex to operate. Equipment
must be housed in heated
building
to prevent freezing. Fouling of mediawith
precipitants
and
biomass is anticipated. Removals of 25
to 95 percent would be
achieved by treating only a portion of the whole effluent. Should have little net
effect on effluent TDS.
Page 3 of 4
P:\PROJ\23417
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Noveon\Hcnry
-
002\Table
Alternative
NH34oc
ComparisonofRemovals
and
Reliability
ofEffluent
NH3-N
RemovalProcesses
for the Noveon-Henry Wastewater Treatment
Facility (Continued)
Process
Effluent
NH3-N Removal
Reliability
(Average )
Rating1
Comments
Effluent Ozonation
98
8
Involves routing secondary clarifier effluent through ozonation step prior to
tertiary filtration. Caustic is fed to
maintain pH control. Very complex system
requiring active monitoring and
safety controls.
Will
increase effluent TDS.
Tertiary Nitrification
98
-
7
Involves pumping secondary clarifier effluent into separate biological treatment
tank containing fixed film media. Magnesium
hydroxide is added for alkalinity
control.
Simple to operate. Removals of 25 percent to 95 percent would be
achieved by treating the whole effluent
through varying sized
reactors.
Performance would vary with
the success of theupstreamWWTF in removing
inhibitors.
Will
increase effluent TDS.
1Reliability Ratng based on a relative assessmentof mechanical and process performance reliabilityto achieve the average percent removal
(10 being highest
reliability).
Reliability
means the ability of the treatment process to achievethe predicted effluent ammonia-nitrogen
(NH3-N) concentrations on aroutine basis.
Page 4 of 4
P:\PROJ\23417
-
Noveon\Henry
-
002\Table
Alternaiive
NH3.doc
