BOARD OF

TRUSTEES

DENNISJ. COLLINS

PRESIDENT

TIMOTHY

A.

STRUTHERS

VICE

PRESIDENT

RONALD 0. NAYLOR

CLERK

February 25,

2002

Illinois

Pollution Control

Board

Docket Clerk

James R. Thompson Center

100 West Randolph Street

Suite 11-500

Chicago,

Illinois

60601

Subject:

Prefiled Testimony of Mr.

Michael Zima

Docket No.

R02-1 9

Attn:

Docket Clerk:

OFFICERS

MICHAEL ZIMA

MANAGER

JANICE TRIPP

ASST. MGR. ADMINISTRATION

DAVID PAULING

ASST.

MGR. OPERATIONS

RICHARD STOKKE

TREASURER

KEITH FOSTER

A1TORNEY

RECEIVED

CLER’~

~

MAR

4

2002

STATE OF IWNOIS

Pollutton

Control Board

Enclosed please find the testimony of Mr.

Michael Zima to be presented at the

Illinois

Pollution Control Board

(IPCB) Meeting of March 25,

2002.

This IPCB meeting

is

scheduled for

10:30 a.m.

and will take place at the James

R.

Thompson Center

in

Chicago.

The testimony will

be in the matter of the

Illinois Association of Wastewater

Agencies petition before the

IPCB

regarding ammonia-nitrogen water quality standards

in

Docket Number R02-19.

Please be aware that

I have served copies of the enclosed

testimony with

all persons

on the existing service list for R02-1 9.

If you have any questions, please

call

me at 815-758-3513.

Very truly yours,

Michael Zima

District Manager

Cc:

M. Callahan

D.

Zenz

D.

Schmidt

PHONE:

815-758-8611

FAX:

81 5-758-6615

---

RECEIVED

CLFR~’~

~

MAR

4

2002

TESTIMONY PRESENTED TO THE

IN THE

MATTER OF:

STATE OF

ILLINOIs

Pollution Control Board

PETITION OF THE

WATER QUALITY STANDARDS

DOCKET NUMBER:

MARCH 25, 2002

MR. MICHAEL ZIMA

DEKALB SANITARY DISTRICT

1

---

Introduction

The

Illinois

Association

of Wastewater Agencies

(IAWA)

has filed a

petition

before

the

Illinois

Pollution Control

Board (IPCB).

In this

petition,

the

IAWA

has proposed

a

change to Parts 302

and

304

of the

existing

IPCB

Water

Quality Standards

for

Ammonia.

The

IAWA

Petition

has

been assigned

Docket Number

R02-19

by the

IPCB

and public hearings on this

petition are

in

progress.

The

impetus

and genesis for

the

IAWA

petition

is

the

United

States

Environmental

Protection

Agency (USEPA)

1999 Update of Ambient Water Quality Criteria for Ammonia (EPA-822-R-99-

014)

which

was

released

in

the

Federal

Register

on

December

22,

1999

(Vol.

64,

No.

245,

Pages

71974-71980).

In

the

1999

update,

USEPA

took

note

of

the

fact

that

additional

information

has

been

gathered

since

it

published

its

Ambient Water

Quality

For

Ammonia

in

1984.

Based

upon

the

additional

information,

USEPA

prepared

the

1999

update

which

contained

revised freshwater quality criterion

for ammonia.

The

IAWA

petition essentially asks

the

IPBC to

enact

into

Illinois

Regulation,

USEPA’s

1999

Update

of Ambient

Water

Quality

Criteria for Ammonia.

The

USEPA

has

spent

considerable

effort

in

issuing

the

1999

update

and

the

states

are

expected

to

adopt

numeric water quality

criterion

for

ammonia

based

upon the

1999

update.

Protective criteria for ammonia

are expected to

be adopted in all states not later than 2004.

1

---

The DeKaIb Sanitary

District

The

DeKaIb

Sanitary

District (DSD)

was

created

on

July

12,

1928

and

for the

past nearly

74

years

has

provided

wastewater

collection

and

treatment

and

biosolids

management

for

its

Northern

Illinois

service

area.

By

1929,

the

DSD

provided primary and

secondary treatment to

its

entire

service area.

Since

1929,

the DSD

has

continuously upgraded its treatment

facilities.

In

1981,

DSD provided

second stage biological

treatment to

remove ammonia-nitrogen from it’s

effluent.

Also

in

1981,

tertiary sand filtration was

added

which greatly

reduced the suspended

solids and

oxygen

demand

of the DSD’s discharge.

In

1984,

DSD constructed

a

new facility to

treat

excess

flows

during

peak

flow

periods.

Most

recently

in

1997,

the

DSD

added

a

new

single stage

activated

sludge

nitrification

(ammonia

removal) facility to

handle

additional

flows

from

its

service

area.

A

new

headworks

was

also

constructed

in

1997

to

upgrade

the

raw

sewage

pumping and flow

measurement capabilities of the DSD’s treatment plant.

Since

1981,

the

DSD

has

spent

nearly

20

million

dollars

to

provide

modern

wastewater

treatment to

the nearly 40,000 people

in

the service

area. Today the DSD

provides

complete

secondary and

tertiary treatment and biological

nitrification (ammonia removal)

before discharge

to the South

Branch

of the Kishwaukee River.

Testimony of the DeKaIb Sanitary District

The testimony

of the DSD

before the IPCB will focus on the discharge permit limits which will

be

imposed

upon

the

DSD

based

upon

IPCB’s

existing

water

quality

standards

for

ammonia-

nitrogen

and

the economic

impact

of these

regulations.

Also the DSD

will discuss

the permit

2

---

limits which would

be

imposed

if

the IAWA petition

were to

be

enacted

and

the impact of

such

enactment on the

DSD.

The DSD

believes

that

it

is important

for

the

IPCB

to

understand

the

economic

impact

of

its

existing

ammonia-nitrogen

regulations on

publicly

owned treatment

works

(POTWs)

and

how

the IAWA petition

would affect this

impact.

IPCB Ammonia-Nitroçjen Water Quality Standards

The IPCB

in

December

1996 R94-1

(B)

adopted the existing

State

of Illinois

ammonia-nitrogen

and

un-ionized ammonia standards.

The IPCB 1996 water quality standards were

in

response

to the development of the USEPA’s

National Criteria Document for Ammonia

in

1984.

Because

of

the

release

of

USEPA’s

1999

update,

it

seems

entirely

logical

for

the

IPCB

to

consider

a

significant change

in

its 1996 water quality standards for ammonia.

The USEPA’s

1999

Update

of

Water Quality

Criteria for Ammonia was

published

only after

an

extensive review

of

the scientific

literature.

Upon

releasing the

1999

update,

USEPA

stated,

“These criteria

reflect the latest scientific

knowledge on the effects water pollutants

have on the

public

health and

welfare,

aquatic

life

and

recreation.

The

1999 update contains

EPA’s

most

recent

freshwater

aquatic

life

criteria

for

ammonia

and

supercedes

all

previous

freshwater

aquatic

life ammonia

criteria.

The new criteria

reflect recent

research

and data

since

1984 and

are a revision

of several elements

in the 1984 criteria...”

3

---

The DSD believes that the IAWA has

made an

honest and scientifically defensible adaptation

of

the

1999 update to fit the situation here in

Illinois.

The IAWA has

had

the petition

reviewed

by

the

IEPA and they are in

concurrence with

it.

The DSD

believes

that

the

IAWA petition

should

be adopted

in

its

present

form.

The

petition

accurately

reflects

the

USEPA’s

1999

update

and

therefore

represents

the

latest

scientific

knowledge. We urge the IPCB to enact the IAWA petition.

DeKaIb

Sanitary

District

National

Pollutant

Discharcie

Elimination

System

(NPDES)

Permit

Limits

The existing

NPDES

permit

for the DSD was

issued

on

December

12, 2000.

The IEPA issued

this

permit

after

finalizing

its

Part

355

procedures

for

ammonia-nitrogen.

These

IEPA

procedures were

issued on July

1,

1999.

For the period of

December 2000 through December 2003, the NPDES permit

requires the DSD

to meet the following ammonia-nitrogen limits.

AMMONIA-NITROGEN

Season

Monthly Average

Daily Maximum

April-October

1 .5

3.0

November-March

3.6

7.2

4

---

These limits

are the same

ammonia-nitrogen limits that

have

been

in

previous

NPDES

permits

for DSD.

Special

Condition

16

of

DSD’s

NPDES

permit

states

that

by December

2003,

the

DSD

must

meet the following ammonia-nitrogen permit limits:

AMMONIA-NITROGEN

Season

Monthly Average

Daily Maximum

April-October

1 .3

3.0

November-March

1 .2

5.1

The December

2003 permit

limits are

based upon the

IPCB water quality standards adopted

in

1996 and the

Part 355

procedures adopted

by the IEPA

in

1999.

Those

NPDES

permits which

expired

after

July,

1999

contains

limits

based

upon the

1996

IPCB

standards

and

the

1999

IEPA procedures.

Those

who

could

not

comply

with

the

new

limits

were

given three

years

to

comply.

Hence the DSD now has

a December 2003 compliance date

in

its NPDES permit.

DSD’s Alternatives to Meet the December 2003 Permit Limits

In order to

meet the December 2003 permit limits for ammonia-nitrogen, the DSD

is considering

a

variety of alternatives.

The DSD

has

retained Consoer Townsend

Envirodyne

Engineers

Inc.

(CTE)

to

study and

select the most cost-effective

alternative or alternatives which can meet the

December 2003 limits.

5

---

Biological Nitrification

(ammonia removal)

Almost without exception,

POTWs

in

Illinois

remove ammonia from

wastewater using

biological

nitrification.

In

essence,

nitrifying

bacteria

contained

in

biological

reactors

convert

the

toxic

ammonia

to

non-toxic

nitrates

before

discharge.

But

the

biological

nitrification

reaction

is

somewhat difficult to control

and

it is often

not always possible

to consistently achieve

levels of

ammonia-nitrogen below

1 .5 mg/I.

In the

IPCB hearing on

R94-1 (B),

the IEPA (Mr.

Dean Studer,

November 10,

1994) testified

that

biological

nitrification

is capable

of

consistently achieving a monthly average ammonia-nitrogen

concentration

of

1.5

mg/I

from

April-October

and

4.0

mg/I,

November-March.

It was

for

this

reason that

in

R94-1

(B), the

IPCB

decided

to establish

the concept

of effluent modified waters

(EMW).

EMWs

are waters

downstream from

a wastewater treatment plant that,

at a minimum,

can comply with a summer monthly average of

1.5 mg/I from April through October

and a winter

monthly

average

of

4.0

mg/I

during

November-March.

EMW’s

continue

downstream

of

the

facility, the distance that it takes for the chronic ammonia standards to be met.

The

DSD

must

essentially

comply

with

a

monthly

average

ammonia-nitrogen

permit

limit

by

December

2003

of

1.2-1.3.

mg/I,

year

round.

The

DSD

employs

biological

nitrification

and

meets its

existing NPDES permit limits of

1 .5 mg/I April-October and 3.6 mg/I,

November-March.

But the December 2003 limits cannot

be consistently met with the biological

nitrification systems

currently

in place.

6

---

This non-compliance

with

the 1996

IPCB

standards

using biological

nitrification

is not atypical.

In fact the IEPA stated

in testimony

on

R94-1(B) that at

least

19 facilities in

Illinois were

at risk

of

non-compliance

if

the

1996

IPCB

standards

were

adopted.

The

IEPA

indicated

in

its

testimony

that

most

of

the

19

facilities

will

have

to

be

redesigned

to

meet

the

proposed

standards.

Alternatives to

Reduce Ammonia-Nitrogen

in

DSD’s Effluent

DSD’s Consultant

(CTE Engineers)

is currently considering the following

alternatives

to

reduce

effluent ammonia-nitrogen in

order to comply with

its December 2003 permit limits:

1)

Ion Exchange

2)

Breakpoint Chlorination

3)

Improvements in

Fixed

Film Bioreactors

4)

Automatic

Dissolved Oxygen Control for the Single Stage

Nitrification System

Ion

Exchange

Ion

exchange

involves passing

a

liquid

through

a

column

or bed

of specific

natural or synthetic

resin and the exchange

of one

ion for another.

Clinoptilolite is the

resin

of choice for ammonia-

nitrogen

removal.

Ammonia-nitrogen

concentrations

of

0.5

to

1

.0

mg/I

are

possible

with

this

technology.

7

---

The 5

mgd

North

Tahoe-Truckee Wastewater Treatment

Plant has

used

ion

exchange

to treat

its discharge

to Lake Tahoe since the 1970’s.

Ion

exchange

is

a

workable

but

an

extremely

demanding

operation.

The

resin

must

be

frequently acid

washed

to

remove

scale

formation.

About

20

of

the

resin

must

be

replaced

per year. The

resin

regeneration process

presents

a extremely corrosive environment dictating

special

safety

concerns.

The

equipment

is

also

difficult

to

maintain,

repair

and

replace.

Operational

care

is

particularly

important

in

terms

of

preventing

ammonia

salt

crystallization

formation

which can contaminate the resins.

For

the

DSD,

the

capital

cost

for

ion

exchange

treatment plant

to

reduce

ammonia-nitrogen

levels

below

1 .5

mg/I

would

cost

approximately 20

million

dollars

and

annual

operating

costs

could exceed $600,000 dollars per year.

Breakpoint Chlorination

Breakpoint

chlorination

involves

adding

sufficient

chlorine

to

a

wastewater

to

oxidize

the

ammonia present.

Most

of the

ammonia-nitrogen is converted

to

nitrogen

gas

by the reaction

with

chlorine.

It normally takes about

10

mg/I of

chlorine

to

remove

1

mg/I of ammonia-nitrogen.

Dechlorination of the effluent is necessary because of

residual chlorine present at the end

of the

breakpoint reaction.

8

---

The

most

obvious

advantage

of

breakpoint

chlorination

is that

it

involves

technology

which is

normally present at

a POTW.

Most

POTW’s practice chlorination/dechlorination for their effluent

disinfection process.

For

the

DSD,

its

existing

chlorination/dechlorination

system

could

be

modified

to

employ

breakpoint chlorination.

The need for breakpoint chlorination

would

be

present about 50 to

100

days per year when about

10

mg/I of

chlorine

would

be

added

on

average

to

reduce ammonia

levels

in

DSD’s

effluent.

The

Capital

costs

for

the modification

to

DSD’s existing

chlorination

system

would

exceed

about

$400,000

while

the

annual

operating

costs

would

total

about

$100,000.

The

principal

disadvantage

of

breakpoint

chlorination

is

the

formation

of

chloramines

and

triholomethanes

which are

discharged

with

the effluent.

As with

any chlorination

system

there

also

are worker safety issues which must be continuously addressed.

Improvements

in

Existing

Fixed

Film Bioreactors

One of the biological

nitrification

systems now employed

by

DSD is a fixed film biological

reactor

system

for

nitrification.

It

is

possible

that

a

change

in

the

influent system

for

this

biological

reactor

could result

in

a

greater

removal

of

ammonia-nitrogen.

But there

is

no

guarantee

that

such

a change

will produce

a

lower effluent

ammonia

concentration.

The changes

required

in

the influent structures

involve adding

new pumps

and

a

new piping

system

to distribute influent

flow

more

equally to

the individual

components

of

the fixed

film

reactors.

This

system

would

only

be

used

periodically

but could

improve the

biological

nitrifying

population

present

in

the

9

---

reactors.

The

capital cost would

be

about

$50,000

and

the operating

costs

would

total

more

than $10,000.

Automatic

Dissolved Oxygen Control

The

DSD

is using

a single

stage

activated

sludge

process

to treat

a portion

of

its

wastewater

flow. This biological

nitrification

system could possibly be

improved by the addition

of automated

dissolved

oxygen

(DO)

control.

The

system

would

automatically

respond

to

changes

in

the

oxygen

demand

of

the

wastewater

and

this

could

possibly

improve

the

nitrifying

organism

population

in

the

activated

sludge

process.

The

capital

cost

for

the

system

would

be

about

$50,000 and annual

operating costs would exceed $40,000.

Screening of Alternatives

The DSD’s study of ammonia reduction alternatives

continues and a final decision

has not

been

reached

as to which alternatives

will

be

selected for

implementation.

The

IPCB

should

bear in

mind

that the costs

presented

here

are

preliminary

and

are

subject

to

revision

as the study of

alternatives

continues.

However

the

costs

are

sufficiently

accurate

to

give

a

reasonable

approximation of the final costs that could be incurred

by DSD.

It

seems

probable

that

DSD

will

ultimately

decide

to

implement

more

than

one

of

the

four

alternatives

presented

here.

Therefore

the

IPCB

should

not think

that

the cost

of

any

single

alternative

represents the DSD’s cost

of complying with the 1996 IPCB

regulations.

10

---

Impact

of the IAWA Petition

The IAWA petition would

result in the following effluent permits limits for the DSD:

CONCENTRATION,

Mg/

Season

Monthly Average

Daily Maximum

March-October

1 .5

6.7

November-February

4.0

6.7

Obviously the IEPA would

make the final decision as to

the permit

limits for the DSD.

However,

the above permit limits are

based upon the stream (South

Branch of

the Kishwaukee)

data used

by the IEPA to determine

the ammonia limits

in

DSD’s existing NPDES

permit.

Therefore these

above permit limits are a reasonable prediction.

As

can

be

seen, these

permit limits are

very similar to the permit

limits

now

in

effect for

DSD’s

treatment

plant.

DSD

can

meet

these

permit

limits

with

its

existing

biological

nitrification

systems

and

would

not

incur

the

capital

and

operating

costs

outlined

above

for

the

four

ammonia-nitrogen alternatives currently being

considered by DSD.

11

---

Summary and Recommendations

The

DSD

believes

that

the

IAWA

petition

represents

a

sensible

and

scientifically

based

adaptation to the State of

Illinois of the USEPA’s 1999

Update

of Ambient Water Quality Criteria

for

Ammonia.

This

update represents

USEPA’s

assessment

of

credible

scientific

data

on

the

aquatic life toxicity

of

ammonia.

The DSD

recommends

that the

IPCB enact the

IAWA

petition

so that the most scientifically defensible water quality standards can

be

used to protect aquatic-

life in the state

of Illinois.

The DSD

could

potentially spend

more

than

20

million

dollars

in

capital costs

and

more

than

$750,000

in

annual

operating

costs

to

meet

the

existing

IPCB

standards

for

ammonia

as

finalized

in

R94-1 (B).

If

the

IAWA

petition

is enacted,

DSD

would

not

be

required

to

expend

these

funds. The significant installation

and annual

operating

costs associated with

the various

ammonia reduction options are by no

means

inconsequential for the DeKaIb Sanitary

District or

its

service

population, especially

in

light of the

USEPA’s

1999

Update

of

Water Quality Criteria

for Ammonia and the subsequent

IAWA petition.

We are

hopeful that the forgoing

is of some value to the

IPCB’s decision

process regarding this

matter.

Again,

DSD recommends that the

IPCB enact the IAWA petition.

12