AS 02-5
THIS FILING IS SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
A. Ammonia Effluent Limitations
C. Mixing Zone and ZID
A. Facility and Process Description
C. Description ofArea Affected
D. Description ofDischarge
A. In-Process Reductions
B. Pretreatment
C. Post-treatment
Alternative #1
Alternative #2
Alternative #3
Exhibit List
Group, Inc., Henry Facility

MIXING ZONE/ZID ISSUES
ILLINOIS RIVER AT HENRY, ILLINOIS
NOVEON, INC.
GENERAL CONDITIONS
River Characteristics
OCTOBER 25, 1989 DISPERSION STUDY
Effluent
River
Plume
3,000
CONDUCTIVITY
EFFLUENT
DISPERSION
RATIO
900 liii 89.8
1,000 2.0 49.9
MEMORANDUM

RECEIVED

CLERK’S OFFICE

BEFORE THE ILLINOIS POLLUTION CONTROL BOAR~y

22 2002

IN THE MATTER OF:

Petition ofNoveon, Inc.

for an Adjusted Standard from

Ill. Adm. Code 304.122

)

AS 02-5

)

STATE OF IWNOIS

Pollution Control Board

NOTICE OF FILING

TO:

Dorothy M. Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph Street

Suite 11-500

Chicago, IL 60601

Bradley P. Halloran

Hearing Officer

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph Street

Suite 11-500

Chicago, IL 60601

Connie L. Tonsor

Special Assistant Attorney General

Illinois Environmental Protection Agency

1021 N. Grand Avenue East

Springfield, IL 62794-9276

PLEASE TAKE NOTICE

that on Wednesday, May 22, 2002, we filed the attached

Petitjon for Adjusted Standard

with the Illinois Pollution Control Board, a copy of which is

herewith served upon you.

Richard J. Kissel

Mark Latham

GARDNER, CARTON & DOUGLAS

321 North Clark Street

—

Suite 3400

Chicago, IL 60610

(312) 644-3000

Respectfully submitted,

NOVEON, INC.

By:

One ofIts Attorneys

THIS FILING IS SUBMITTED ON RECYCLED PAPER

RECEIVED

CLERK’S OFFICE

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

f~j3~’(

2 2 2002

IN THE MATTER OF:

)

STATE OF IWNOIS

)

Pollution Control Board

Petition ofNoveon, Inc.

)

ASO2-____

)

(Adjusted Standard)

for an Adjusted Standard from

)

35 Ill. Adm. Code 304.122

)

PETITION FOR

ADJUSTED STANDARD

Noveon, Inc., flk/a The BFGoodrich Company (“Noveon”), through its undersigned

attorneys, respectfully petitions the Illinois Pollution Control Board (“Board”) for an adjusted

standard pursuant to 35 Iii. Adm. Code 104 and Section 28.1 ofthe Illinois Environmental

Protection Act (“Act”). Specifically, Noveon requests an adjusted standard from 35 Ill. Adm.

Code 304.122(b) for the effluent from Noveon’s Henry, Illinois Plant.

PROCEDURAL

BACKGROUND

On August 30, 1989, Noveon submitted a renewal application for NPDES Permit No.

IL0001392, governing the wastewater discharge from the Noveon plant located in Henry, Illinois

(the “Henry Plant”). By letter dated December 28, 1990, the Illinois Environmental Protection

Agency (“Agency”) re-issued a final NPDES permit for the Henry Plant. In response to the re-

issued NPDES permit, on January 24, 1991, Noveon initiated a timely permit appeal (PCB 91-

17).

Noveon filed the appeal based on, among other grounds, the inclusion ofammonia

nitrogen effluent limitations that had not been included before in any ofthe previously issued

Henry Plant NPDES permits. The Agency claimed that the inclusion of an ammonia nitrogen

effluent limitation was based on the regulatory requirements of 35 Ill. Adm. Code 304.122(b).

That provision of the Board’s regulations states that:

Sources discharging to the Illinois River, the Des Plaines

River downstream ofits confluence with the Chicago River

System or Calumet River System and whose untreated

waste load cannot be computed on a population equivalent

basis comparable to that used for municipal waste treatment

plants and whose ammonia nitrogen discharge exceeds 45.4

kg/day (100 poundsper day) shall not discharge an effluent

ofmore than 3.0 mg/L oftotal ammonia nitrogen as N.

Id.

It was Noveon’s position in the permit appeal that this provision was not applicable to the Henry

Plant and that the Agency was without basis to include such a limitation in the NPDES Permit.

Noveon contended that, since the Henry Plant’s untreated waste load could be readily calculated

under 35 Ill. Adm. Code 304.122(a) on a population equivalent (“PE”) basis, 35 Ill. Adm. Code

304.122(b) was inapplicable because anotherprovision ofthe Board’s regulations, 35 Ill. Adm.

Code 304.122(a), should be considered with regard to the Henry Plant’s discharge. 35 Ill. Adm.

Code 304.122(a) provides that:

No effluent from any source which discharges to the Illinois River,

the Des Plaines River downstream ofits confluence with the

Chicago River System or Calumet River System, and whose

untreated waste load is 50,000 or more population equivalents shall

contain more than

2.5

mg/L of total ammonia nitrogen as N during

the months ofApril through October, or 4 mg/L at other times.

The untreated waste load for the Henry Plant is less than 32,000 PE. Thus, pursuant to Section

304.122(a), no effluent limitation for ammonia should apply to the Henry Plant because its

untreated waste load can be calculated on a PE basis, and the PE is less than 50,000.

During the mid-1970’s the Agency did raise the applicability of35 Ill. Adm. Code

304.122(b) in a draft NPDES Permit for the Henry Plant, only to remove the proposed ammonia

effluent limit and issue a permit without this condition. Nothing has changed with respect to the

discharge from the Henry Plant that would warrant a change in that Agency decision regarding

the applicability ofthis section.

Following initiation of the permit appeal proceeding and aftertwo days ofhearing were

conducted, Noveon and the Agency entered into negotiations to resolve the issues raised in the

permit appeal. After lengthy discussions with the Agency, the parties agreed that the appropriate

course of action would be forNoveon to file a variance petition with the Board to enable Noveon

to review and evaluate treatment alternatives that might allow the Henry Plant to reduce the

levels ofammonia in its wastewater discharge. Consequently, the permit appeal proceeding was

stayed by agreement ofthe parties through a series ofdecision deadline waivers, with periodic

status reports to the Board, and a variance petition (PCB 92-167) was filed on October 30, 1992.

By order dated November 19, 1992, the Board issued an order accepting the variance petition for

hearing.

As discussed in detail later in this petition, as part of the “study variance” proceeding,

Noveon and its consultants continued to review and evaluate different aspects of ammonia

reduction and treatment technologies that would, perhaps, reduce the ammonia nitrogen in the

wastewater from the Henry Plant. In addition, Noveon continued its internal studies focused on

determining whether it could take any actions to eliminate, recover or recycle the precursors to

ammonia contained in the Henry Plant wastewater. Because ofthe complexity of the various

studies, they took longer to complete than was anticipated. A series ofstatus reports were also

filed with the Board as part of the variance proceeding, detailing the progress Noveon made in

evaluating the ammonia issue at the Henry Plant. Noveon kept the Agency apprised ofits

efforts, and a series ofprogress meetings took place between representatives ofNoveon and the

Agency during the course ofthe various studies.

At the numerous meetings between the parties, the various reports detailing the potential

source reduction options, pretreatment options and treatment alternatives were discussed. Based

oii those studies and the evaluation ofthe various options reviewed, Noveon and its consultants

have concluded, and the evidence presented in this proceeding will show, that none ofthe

available treatment technologies are both economically reasonable and technically feasible for

Noveon to significantly reduce the ammonia in the wastewater from the Henry Plant to levels

that would achieve compliance with 35 Ill. Adm. Code 304.122(b). Consequently, a variance

would not be the appropriate vehicle for Noveon to obtain relief since that would require

eventual compliance with the standard from which relief was requested. Accordingly, the

Agency and Noveon agreed that it was appropriate to resolve the ammonia issue raised in the

permit appeal by pursuing adjusted standard relief from the Board.

35 ILL.

ADM.

CODE 104.406 INFORMATIONAL REQUIREMENTS

Standard From Which Relief Is Sought

Section 104.406(a)

Noveon does not believe that, for the reasons discussed earlier in this petition, 35 Ill.

Adm. Code 304.122(b), effective 1972, is applicable to its wastewater discharge from the Henry

Plant. Nonetheless, to resolve this issue with the Agency Noveon agreed to seek an adjusted

standard from the ammonia effluent limit of35 Ill. Adm. Code 304.122(b).

II.

Nature of Regulation ofGeneral Applicability

Section 104.406(b)

A. Ammonia Effluent Limitations

On January 6, 1972, the Board adopted Rule 406 ofits water pollution rules, which

limited the ammonia nitrogen level ofcertain dischargers to the Illinois River. That rule has

since been amended and is now codified at 35 Ill. Adm. Code 304.122. The rule as promulgated

was specifically intended to reduce the discharge of ammonia nitrogen to the Illinois River from

limit, 35 Ill. Adm. Code 304.122 remained in the Board’s regulations as ammonia nitrogen

effluent limitations.

B. Ammonia

Water

Quality

Standards

Noveon recognizes that as part ofthe triennial review ofwater quality standards the

Agency performs under Section 303(c)(1) ofthe Clean Water Act, 33 U.S.C.

1313(c)(1),

significant amendments to the water quality standards for ammonia nitrogen were adopted by the

Board toward the end ofthe 1996. In the Matter of: Triennial Water Quality Review

Amendments, R94-1(B) (Dec. 19, 1996) (Final Order). As amended in 1996, the ammonia water

quality standards consist offour separate un-ionized ammonia standards: an acute summer

standard, a chronic summer standard, an acute winter standard and a chronic winter standard. 35

Ill. Adm. Code 302.2 12. The ammonia nitrogen water quality standards, as amended, have been

approved by the U.S. EPA.

Noveon is also aware that the Board currently has pending before it a proposal to amend

again the ammonia water quality standards. The proposed amendments, if adopted, will change

the acute and general use water quality standards for un-ionized ammonia, among other proposed

changes to the ammonia water quality standards. Noveon is not seeking an adjusted standard

from the ammonia water quality standards, because as discussed below, Noveon meets those

standards through use ofa ZID and a mixing zone.

C. Mixing Zone and ZID

With an appropriately calculated zone of initial dilution (“ZID”) and mixing zone,

consistent with both Agency and U.S. EPA guidance on mixing zones, the discharge from the

Henry Plant will meet the summer/winter acute and chronic limitations set forth in the amended

ammonia water quality standards. See Exhibit 1. In Illinois water quality standards must be met

at the 7Q10 low flow condition. Historical river data has been analyzed by Noveon from various

monitoring stations, including the Agency’s Hennepin, IL and United States Geological Survey

(“USGS”) Henry, IL monitoring stations to determine appropriate ambient river parameters to

determine an appropriate mixing zone. See Exhibit 2.

Field studies have been conducted on the Henry Plant’s discharge to analyze the in-river

mixing taking place. According to the analysis arising from those field studies, based on a

computed total cross-sectional area, and a maximum plume width of 160 feet in the river, the

effluent plume will require less than 18 ofthe cross-sectional area ofthe total 875 foot width

ofthe Illinois River in the vicinity ofthe Henry Plant for a mixing zone. In addition, the 26-acre

limitation on mixing zones is easily met by the discharge from the Henry Plant. The size ofthe

ZTD calculated by Noveon’s consultant is

66.5

feet, with a mixing zone ofa 1,000 feet. See

Exhibit 1. This ZID and mixing zone will allow the effluent from the Henry Plant to meet both

the summer (April through October) and winter (November through March) acute and chronic

water quality standards at total ammonia nitrogen effluent discharge limits ofno greater than

189 mg/L for winter and for summer. See Exhibit 3 at Figure 1.

To ensure that maximum mixing continues to occur sufficient to meet the acute and

chronic ammonia water quality standards, Noveon will agree to replace the current single-port

diffuser with a multi-port diffuser, as part ofthe relief in this proceeding. Specifically, Noveon

will install and maintain a high-rate multi-port diffuser that will immediately and rapidly

disperse the treated effluent from Noveon into the Illinois River within a short distance from the

diffuser (on the order ofone diffuser length). The diffuser will be at least 15 ft. long and will be

placed in the river so that the normal water depth over the diffuser will be about 13 ft. at low

pool elevation of440 feet above the National Geodetic Vertical Datum of 1929. There will be

rime 2-in, ports set at an angle of 60 from horizontal, and the ports will be co-flowing with the

river. The port exit velocities have been designed to achieve an exit velocity of 10 fi/sec, which

will prevent habitation by biological species in the immediate vicinity ofthe diffuser. The

diffuser has been designed, using accepted U.S. EPA diffuser models, to meet an effluent

dispersion of43:1 for an effluent flow of 1.3 mgd, and all water quality parameters will be met at

the edge ofthe zone ofinitial dilution. The multi-port diffuser will be installed within a year of

the granting by the Board ofthe adjusted standard requested herein. See Exhibit 3 for a detailed

description of the multi-port diffuser.

Consequently, Noveon is not seeking adjusted standard relief from the ammonia water

quality standards. Noveon is only seeking an adjusted standard from the ammonia effluent limit

for discharges into the Illinois River as set forth in 35 Ill. Adm. Code 304.122(b). Noveon also

seeks from the Board as part ofthis proceeding, a determination that the ammonia water quality

standards will be met with the ZD and mixing zone calculated in Exhibit 1 and 3 and as

discussed above for the Henry Plant discharge.

III.

Specified Level of Justification

—

Section 104.406(c)

The regulation of general applicability from which Noveon seeks an adjusted standard

does not specify a level ofjustification. Thus, the Board can grant the adjusted standard upon

adequate evidence ofthe four criterion set forth in Section 28.1(c) ofthe Act, along with the

information required by 35 Ill. Adm. Code 104.406. The four criterion required by Section

28.1(c) ofthe Act are discussed later in this petition.

IV.

Facility and Process Description

Section 104.406(d)

A. Facility and Process Description

The HenryPlant is located on 1550 County Road, 850 N., in Henry, Illinois in

northwestern Marshall County. The facility was solely owned and operated by the BFGoodrich

Company from its initial construction in 1958 until 1993. In 1993, the BFGoodrich Company

divested the Geon Vinyl Division from the company and formed The Geon Company (“Geon”),

a separate, publicly held company. In February 2001 the BFGoodrich Company sold all the

assets of its chemical business, including the Henry Plant, and that former BFGoodrich division

is now known as Noveon, Inc.

Today, both Geon (now known as PolyOne) and Noveon continue to operate facilities at

the Henry site. The wastewater treatment system is owned and operated by Noveon, and the

system continues to treat the wastewater from both PolyOne’s and Noveon’s Henry Plant

processes. Approximately 360,000 gallons per day ofeffluent from the PolyOne operations are

treated by the Henry Plant wastewater treatment system and the Noveon operations contribute

approximately 180,000 gallons per day. The total daily discharge ofprocess water and non-

process water is approximately 800,000 gallons from the Henry Plant’s wastewater treatment

system. Noveon currently employs approximately 85 people and the PolyOne facility employs

approximately 100 people at the site.

The Noveon Henry Plant produces rubber accelerators and antioxidants for the rubber,

lubricant and plastic industries. The rubber accelerators are used in tires and other rubber goods

to “accelerate” the curing process. The antioxidants are used to inhibit the oxidation process in

materials such as rubber, jet fuel, greases, oils and polypropylene.

In the production of accelerators there are several key raw materials: sulfur, aniline,

carbon disulfide and amines. The manufacture ofaccelerators is a multi-step process including

the manufacture of an intermediate (sodium mercaptobenzothiazole). This intermediate is then

reacted with an amine and other raw materials to form an accelerator product. The product is

then isolated through filtration and drying.

There are various types ofantioxidants manufactured by Noveon at the Henry Plant. In

general, the antioxidant processes utilize either diphenylamine or one ofseveral phenols as a

starting material. The processes in which these products are manufactured consist ofboth batch-

and continuous reactors, filtration operations and solidification.

PolyOne produces polyvinyl chloride (“PVC”) resins. These resins are sold to a variety

ofcustomers including those in the construction, household furnishings, consumer goods,

electrical, packaging and transportation industries. While PolyOne is not a party to this

proceeding, as noted earlier, its process wastewater is combined with the Noveon wastewater and

treated in the Henry Plant’s wastewater treatment system by Noveon.

Between 1985 and 1987, three major physical changes occurred at the Henry Plant. The

first involved the installation ofa fluidized bed coal-fired boiler, which became operational in

1985, and is now operated by PolyOne. The second involved the addition offacilities for a new

rubber accelerator process building that became operational in 1986. In 1987 Noveon

significantly upgraded its wastewatertreatment system. This upgrade included installation of

two above ground biotreators, two above ground equalization tanks and a tertiary filtration

system. A third biotreator was added in 1989 and a fourth one was placed into service in 1998.

Auxiliary equipment and pretreatment systems were also installed to facilitate the operation and

effectiveness ofthe wastewater treatment system.

The levels of ammonia in the Henry Plant’s wastewater were particularly puzzling and

iequired significant investigation to discover the source, since ammonia is not a major raw

material in any ofthe processes at either PolyOne or the Noveon Henry Plant. As an ingredient

in the production processes, ammonia is only used in minor amounts in one low volume product

manufactured by Noveon at the Henry Plant. The only other ammonia used by Noveon at the

Henry Plant is in the ammonia cooling system, which utilizes ammonia in a closed-loop system

from which no ammonia is released. PolyOne uses a small amount of ammonia as an ingredient

to produce an emulsifier foruse in one ofthe PVC processes. Ammonia, however, is not a

primary ingredient in any ofthe processes carried out by either Noveon orPolyOne nor in the

products either company produces.

Since ammonia is not used in any significant amount in the processes conducted by either

Noveon or PolyOne that ultimately discharge to the Henry Plant’s wastewater treatment plant,

the levels of ammonia in the effluent required extensive investigation and analyses to determine

why ammonia was in the effluent following treatment. As discussed later in this petition, it was

ultimately discovered that the major source ofammonia is the degradation of amines that occurs

in the wastewater treatment process at the Henry Plant. The efforts ofNoveon to address the

source ofthe ammonia is also fully discussed later in this petition.

B. The Henry Plant Wastewater Treatment

System

The wastewater treatment system at the Henry Plant is a multi-process system that treats

both process wastewater and non-process discharges including stormwater and non-contact

cooling water. A block flow diagram of the system is included as Exhibit 4. The Henry

wastewater treatment system has historically provided greater than

BOD reduction while

discharging ammonia-nitrogen in an effluent concentration range of23 mg/L to 150 mg/L. See

Exhibit

and Exhibit 6 at 1-1.

Pretreatment ofcertain process wastewaters is the initial step in the treatment process.

The Cure-Rite 1 8® wastewater is pretreated with hydrogen peroxide. Some ofthe PVC

wastewater from PolyOne is pretreated by a wastewater stripping system that removes residual

vinyl chloride. PolyOne also pretreats certain centrate waste streams prior to discharge to the

Henry Plant’s wastewater treatment system.

Following pretreatment, all process wastewater is collected in equalization tanks prior to

transfer to the primary treatment system. Wastewater from the Henry Plant’s production of

accelerators and antioxidants discharge to either the polymer chemicals (“PC”) equalization tank

or to the Cure-Rite 1 8® equalization tank. PolyOne’s wastewater and sidestreams from the

combined wastewatertreatment facility discharge to the PVC equalization tank. Site-wide

stormwater runoffand sidestreams from the boilerhouse and water treatment facility discharge to

two holding ponds.

In the primary treatment system, the wastewater is fed into the treatment process where

pH is adjusted, coagulants are added, and a large settleable floc, a cluster of particles, is formed.

The wastewater is then sent to the primary clarifierwhere the solids in the wastewater settle to

the bottom. The solids that settle in the primary clarifier are pumped into a collection tank and

processed through a filter press for dewatering before being sent off-site to a landfill as a non-

hazardous special waste. The wastewater collected from the filter press is recycled back into the

treatment system.

After primary clarification, the wastewater is sent to activated sludge treatment by the

biotreatmnent system consisting offour “biotreators.” The biotreators are tanks that range in size

from 400,000 gal. to 1.3 million gal. and contain biomass to degrade the organic matter in the

wastewater. The degradation process is augmented by the addition of air into the biotreators.

The addition of air into the biotreators ensures that the biomass has sufficient oxygen to

complete the degradation oforganic materials and also ensures through agitation that the

biomass comes into adequate contact with the organic matter contained in the wastewater.

After biological treatment in the biotreators, the wastewater flows into the secondary

clarifier where more coagulants are added. The solids removed during secondary clarification

are primarily biomass and are returned to the biotreators.

The wastewater from the secondary clarifier is then sent to tertiary treatment provided by

a polishing filtration device called a traveling bridge sand filter. As the wastewater passes

through the sand bed, additional solids removal occurs and the effluent flows into a concrete

sump leading to the outfall. Any backwash from the sand filter is recycled back into the primary

treatment system and is processed again.

The non-process wastewater, including non-contact cooling water, stormwater, water

from the boilerhouse demineralizer and water treatment works, is discharged to a holding pond.

The non-process wastewater is then either pumped into the primary treatment system or pumped

directly to the sand filter to remove solids prior to discharge through the outfall.

The City ofHenry operates a municipal wastewater treatment system adjacent to the

Henry Plant and also contributes flow to the Henry Plant’s outfall. The City ofHenry municipal

treatment system consists ofan aerated lagoon followed by a sedimentation basin and effluent

disinfection. The treated discharge from the City ofHemy municipal wastewater treatment

system combines with the treated Henry Plant effluent and is discharged together through the

Henry Plant’s outfall into the Illinois River. Compliance sampling ofthe Henry Plant and City

ofHenry waste streams is performed before the waste streams are combined. It also should be

noted that the Agency has determined that the Henry Plant wastewater treatment system achieves

“best degree oftreatment” for all pollutants except for ammonia.

C. Description ofArea Affected

Following treatment, the wastewater is discharged through Outfall 001 to the Illinois

Riverpursuant to NPDES Permit No. IL0001392. The Illinois River is formed at the junction of

the Kankakee and Des Plaines Rivers near Joliet, Illinois and runs 273 miles west, southeast and

south to the Mississippi River, near Grafton, Illinois, which is a few miles upstream from St.

Louis. The Henry Plant is located on the right edge ofthe water (when looking downstream)

betweenriver mile 198 and 199.

The Illinois River at Henry is approximately 875 feet wide, with an approximate 18 foot

maximum depth. The average depth ofthe river is 11 feet, and it has a drainage area of

approximately 13,543 square miles at Henry, IL. The USGS has operated a gauging station at

Henry, Illinois since October 1981. The available USGS data for this gage indicate that the

Illinois River at this location has an annual mean flow of 15,340 cfs. The Illinois State Water

Survey reports an annual 7-day, 10-year low flow for the river at Henry of3,400 cfs.

D. Description ofDischarge

The effluent from the Henry Plant is discharged through an 18-inch, single-port

submerged diffuser into the main channel ofthe Illinois River. Since the Henry Plant sits 40 to

50 feet above the Illinois River, the effluent enters the river with a great deal ofvelocity. This

velocity causes rapid and immediate mixing, resulting in maximum effluent concentration

reductions and is ofsufficient turbulence to discourage habitation by aquatic organisms in the

areaofthe diffuser. As mentioned earlier, Noveon will agree to replace the current single-port

diffuser with a multi-port diffuser, as part ofthe relief in this proceeding.

The effluent from the HenryPlant historically has had an ammonia nitrogen

concentration ranging from 23 to 150 mg!L. See Exhibit

and Exhibit 6 at 1-1. Based on an

analysis ofthe Henry Plant discharge, up to 189 mg/L total ammonia can be discharged from the

existing single-port diffuser during summer and winter conditions, respectively, and still achieve

the applicable acute and chronic ammonia water quality standards. See Exhibit 3 at Figure 1.

The replacement ofthe single-port diffuser with a multi-port diffuser will ensure that the

discharge from the Noveon Henry Plant continues to meet applicable water quality standards.

Exhibit

contains the most recent summary ofthe types and quantities of other substances

present in the treated Henry Plant effluent.

Over the years Noveon expended significant resources in evaluating its production

processes and wastewater treatment system in an effort to determine what was contributing to the

ammonia levels in its wastewater. As noted earlier, the levels did not correspond to the small

amount ofammonia used by Noveon or PolyOne in theirrespective processes. As a result ofthe

various studies conducted by and on behalfofNoveon, it has been determined that ammonia is

generated as a degradation product of the Henry Plant’s wastewater treatment system. In

particular, the degradation ofamines in the wastewatertreatment process produces the ammonia

found in Noveon’s effluent. The efforts ofNoveon to evaluate various compliance alternatives

are discussed in the next section ofthis petition.

Cost of Compliance and Compliance Alternatives

Section 104.406(e)

As detailed below, Noveon has examined a variety of methods to reduce the level of

ammonia in its effluent. Initially, the Henry Plant evaluated the existing treatment system’s

ability to nitrif~’,or oxidize ammonia to nitrates. These preliminary nitrification studies led

Noveon to retain Brown and Caldwell, flk/a EckenfelderInc., to perform treatability studies

concerning the ability ofthe Henry Plant to nitrif~’.The proposal for the Brown and Caidwell

nitrification work was shared with the Agency, and the Agency’s comments and suggestions

resulted in a revisedproposal to examine the potential ofthe Henry Plant to operate as a single-

stage nitrifying unit.

Noveon originally had Brown and Caldwell examine the ability to reduce ammonia

through single-state biological nitrification in the late 1980’s. This early study concluded that

single-stage biological nitrification was not achievable in the existing activated sludge system.

The Agency requested a more extensive study ofsingle-stage nitrification as a means to reduce

ammonia. The requested additional treatability study was completed in December

1995,

and a

report was prepared and submitted to the Agency. The results ofthe treatability study

conclusively demonstrated that the Henry Plant could not achieve single-stage nitrification under

existing waste loads and optimum conditions ofmixed liquor pH, D.O., temperature, alkalinity,

F/M ratio and mean cell residency time. See Exhibit 6 at 1-1. The study also showed that the

addition ofa commercially provided “nitrifier-rich” biomass to the wastewater treatment plant

would not prompt the initiation ofnitrification due to the wasteload characteristics and not the

operating conditions. The inability of the Henry Plant wastewater treatment system to nitrify

was due to inhibition ofnitrifying bacteria by the PC tank and C-18 tank contents flows.

Noveon did not simply stop its efforts toward finding a solution for the ammonia issue

once it was determined that nitrification would not work. Noveon has investigated various other

technologies for the control andlor reduction ofammonia in its discharge. In general, Noveon

examined three areas for institution ofpossible technology-based ammonia reduction measures:

1) in-process reductions; 2) pretreatment ofthe wastestream; and 3) post-treatment ofthe

wastestream. The options that Noveon explored in each ofthese three categories are discussed

below.

A. In-Process Reductions

Noveon explored whether it could eliminate the use ofamines in the various processes or

whether it could recover andlor recycle the precursors to ammonia for reuse in the system. Both

ofthese methods were rejected as feasible compliance alternatives following analysis by a

research and development team from Noveon. Amines are an essential element in many of the

products that Noveon produces at the Henry Plant, and elimination of amines would essentially

require the complete elimination ofthe affected product lines, if not closing the entire plant. The

recycling option was also rejected on the basis that the recycled material was ofinferior quality

and would not guarantee production ofthe standard, high quality product Noveon’s customers

demand. In addition, the waste material generated in the recycling process would likely be

classified as a hazardous waste, which raises concerns about cross-mediaimpact associated with

this alternative. Excess amines are, however, currently recovered from processes where recovery

methods provide reusable quality materials and are not cost prohibitive.

B. Pretreatment

The second option, additional pretreatment of the wastewater, involved the removal of

certain constituents before the water was sent to the wastewater treatment system. Noveon

investigated a variety ofpretreatment options, including morpholine recovery, TBA recovery and

a liquid extraction process in which a solvent is passed counter-current to the wastewater

removing the amines from the water. None ofthe pretreatment options would achieve reduction

that would result in compliance with the ammonia effluent standard of35 Ill. Adm. Code

304.122(b). The pretreatment options also raised various technical issues including plant

personnel safety issues.

C. Post-treatment

Once it became clear that the Henry Plant could not achieve compliance through single-

stage nitrification, in process reductions or pretreatment options Noveon retained Brown and

Caldwell to develop preliminaryprocess designs and cost estimates to evaluate other post-

treatment alternatives that could reduce the ammonia in the effluent from the Henry Plant. The

report prepared by Brown and Caldwell is attached as Exhibit 6.

The alternatives consideredby Brown and Caldwell included:

Alkaline air stripping at different points in the wastewater treatment system (e.g.,

PC tank, PVC tank and secondary clarifier).

Struvite precipitation from the combined wastestream influent.

Effluent breakpoint chlorination.

Single-stage biological nitrification of non-PC wastestream combined with

separate biological treatment ofthe PC tank discharge.

Biological nitrification ofcombined influent wastestream.

Ion exchange treatment offinal effluent.

Ozonation and tertiarynitrification are two other potential compliance alternatives evaluated

after Brown and Caldwell completed the evaluation of compliance alternatives discussed in

Exhibit 6. Each ofthese post-treatment alternatives that were evaluated and the conclusions

reached by Brown and Caldwell are summarized below. Flow diagrams of each these ammonia

reduction alternatives are included in the figures to Exhibit 6 and in Attachment A to Exhibit 7.

Alkaline Air Stripping

Ammonia exists in two forms, aqueous and gaseous, and as pH increases the aqueous

form becomes a gas. Thus, by increasing the pH of a wastewater stream it is possible to strip or

remove the ammonia gas. This alternative as investigated involved the use ofair stripping at

three separate portions ofthe treatment system as a means of ammonia removal: 1) within the

PC tank; 2) within the PVC tank and 3) the secondary clarifier effluent. See Exhibit 6 at 2-1 to

2-2.

Because samples of the PC tank and PVC tank discharges contained greater than 500

mg/L TSS, a packed tower air stripper or horizontal tray stripper would require frequent

maintenance due to fouling. Thus, diffused air stripping and surface aeration processes were

both selected for evaluation in both the PC tank and PVC tank. Due to the slow rate of these

stripping processes, the small amount ofammonia available in these tanks, and the large flow

rates ofthe wastewater into the PC tank and PVC tank, only stripping within existing tankage

was considered. Building additional tankage and aeration equipment to address ammonia

removal from these wastestreams would have offered little additional benefit since the bulk of

the ammonia discharged from the Henry Plant is generated as a by-product in the downstream

wastewater treatment facility. Conventional packed tower air stripping was selected for

evaluation of the wastewater treatment facility effluent downstream ofthe secondary clarifier

wastewater since this is a well-established stripping technology.

The batch air stripping test results from 1996 for the PC tank, PVC tank and secondary

clarifier wastewater indicated that some ammonia reduction in those wastestreams could be

achieved. A combined removal ofammonia from the wastewater, however, ofless than 20

would be achieved by treatment ofeither the PC tank or PVC tank wastewater using surface

aeration stripping technology. See Exhibit 6 at 2-1 to 2-2. This low level ofammonia reduction

means air stripping from the PC tank and PVC tank would not achieve sufficient ammonia

reduction that would allow the Henry Plant meet the effluent limitation of35 Iii. Adm. Code

304.122(b). Further, given the presentworth costs (capital, operation and maintenance costs) of

$2.3 million for PC tank treatment and $14.1 millionfor PVC tank treatment, this alternative was

also deemed economically unreasonable in light ofthe high costs and low ammonia reduction

obtained. See Exhibit 7 at pgs. 2-3.

The ammonia removal achieved from the secondary clarifier was greater than 95 using

packed tower air stripping technology. This technology was evaluated again in 2000. One

difficulty with this alternative is that it would increase TDS by more than 20, which could lead

to aquatic toxicity ofthe effluent. The most important difficulty with this treatment alternative is

its high operation, maintenance and installation costs, which makes it an economically

unreasonable one with present worth costs ofover $14 million. See Exhibit 7 at pgs. 2-3. The

costs associated with this alternative are so high because additional equipment is required to

remove the ammonia from the off-gases.

Struvite Precipitation

This alternative involved an analysis ofthe ammonia reduction achieved by the

precipitation ofstruvite (NH4MgPO4.6H2O) from the combined Noveon Henry Plant and

PolyOne wastestream. See Exhibit 6 at 2-2 to 2-4. The results ofthe batch treatability studies

indicate that under certain operating conditions the combined wastestream ammonia

concentration can be reduced to approximately 25 mg/L in the treatment plant influent. This

treatment process, however, would provide only a 24 reduction in the average final

effluent

ammonia level at a present worth cost of

$5.1

million. See Exhibit 7 at 2-3. This alternative also

would increase TDS in the Henry Plant effluent.

In sum, struvite precipitation would not result in compliance with the ammonia effluent

limit. Because only a small portion of the wastewater nitrogen load would be removed from the

Henry Plant treatment system by struvite precipitation, combined with its high costs, this is not a

feasible compliance alternative.

Effluent Breakpoint Chlorination

Brown and Caldwell also evaluated the use ofchlorine to achieve ammonia reduction.

This alternative involved gravity discharge ofthe secondary clarifier wastewater to a reaction

tank where chlorine gas would be sparged into the tank and caustic soda added to maintain a pH

of approximately 6.9. See Exhibit 6 at 3-3 to 3-4. Following the addition ofchlorine, the

wastewaterwould be discharged to the existing sand filters.

This alternative could meet the ammonia standard set forth in 35 Ill. Adm. Code

304.122(b). See Exhibit 6 at 3-4. The problem it presents, however, is that breakpoint

chlorination is prohibitively expensive, at a present worth cost of$9.7 million, which makes it

economically unreasonable. See Exhibit 7 at pgs. 2-3. Thus, this alternative is economically

unreasonable. This alternative will also dramatically increase effluent TDS and may likely result

in the formation of chlorinated organics in the effluent.

Single-stage Biological Nitrification ofNon-PC Wastewater

Noveon’s consultant also examined what level of ammonia reduction would occur by

first-stage nitrification ofthe non-PC wastewater followed by second-stage biological treatment

ofthe PC tank wastewater after combination with effluent from the first-stage reactor. It was

determined afterthe batch treatability study that this was not a feasible compliance alternative

because ofthe low level of ammonia reduction that was achieved. The percentage of ammonia

reduction was only 47 and yet had a present worth cost of$4.9 million. See Exhibit 6 at 2-4 to

2-7 and Exhibit 7 at pgs. 2-3.

Biological Nitmification ofCombined Wastewater

This alternative required pH reduction to 2 ofthe PC tank discharge, followed by river

water addition and combined single-stage nitrification with non-PC wastestreams. The results of

the analysis by Noveon’s consultant, Brown and Caldwell, showed that biological nitrification of

the combined wastewater stream was a technically feasible compliance alternative. See

Exhibit 6 at 4-1. This alternative suffers from a lack ofreliability, which is necessary for

consistent compliance, since it is sensitive to the variable characteristics inherent in the

wastewater produced by the different batch processes at the Henry Plant.

Further, biological nitrification is a very costly alternative. Brown and Caldwell

estimated that the present worth costs ofthis alternative at $11.7 million. See Exhibit 7 at pgs. 2-

3. Those costs make this an economically unreasonable alternative, particularly in light of the

reliability concerns associated with it.

Ion Exchange

One other compliance alternative analyzed by Brown and Caidwell was ion exchange

treatment ofthe secondary clarifier effluent using clinoptilolite, an ammonia selective ion

exchange resin. See Exhibit 6 at 2-9 to 2-10; 3-4. This alternative could meet the ammonia

effluent standard of 35 Ill. Adm. Code 304.122(b). The batch treatability test results

demonstrated that approximately 50 lbs. ofclinoptilolite would be required to remove each

pound of ammonia. This poor removal efficiency was presumed to be due to the large

concentration ofcompeting ions in the effluent. Id. at 3-4. The poor selectivity of this

alternative for removing ammonia precluded further consideration ofion exchange as a

compliance alternative. This alternative had a present worth cost of$5.1 million. See Exhibit 7

at pgs. 2-3.

Ozonotion

This ammonia treatment alternative was evaluated recently by Noveon’s consultant as a

compliance alternative. This alternative could meet the ammonia standard set forth in 35 Ill.

Adm. Code 304.122(b). It was rejected as an alternative due to its high present worth costs of

$20.3 million. See Exhibit 7 at pgs. 2-3. Further, it would significantly increase the effluent

TDS concentrations. This alternative would likely also convert some ofthe effluent non-

degradable COD into BOD, which could cause BOD effluent limit violations.

Tertiary Nitrification

This alternative would involve pumping the secondary clarifier effluent through a

separate aeration basin containing fixed film media that nitrifying bacteria would grow on.

Alkalinity and D.O. would be controlled in this basin to meet the demands associated with

nitrification. Effluent from this tank would be directed to the existing tertiary filtration process

that would be expanded to accommodate the additional solids loading. Results ofanalyses dating

back to the late 1980s and confirmed during the 1990s indicate this process is a technically

feasible compliance alternative. The difficulty with this alternative is that it lacks reliability,

which is necessary to achieve compliance, due to its great sensitivity to variations in wastewater

characteristics that occur with the Henry Plant’s batch processes.

Further, tertiary nitrification is a very costly alternative. Brown and Caldwell estimated

that the present worth costs oftertiary nitrification is $11.4 million. See Exhibit 7 at pgs. 2-3.

Those costs make this an economicallyunreasonable alternative, particularly in light ofthe

reliability concerns associated with it.

In sum, Noveon evaluated a number ofin-process reductions, pretreatment measures and

post-treatment measures as methods to achieve compliance with the effluent limits of35 Ill.

Adm. Code 304.122. The results ofits evaluation demonstrate that there is no alternative that is

both technically feasible and economically reasonable that would allow the Hemy Plant to

achieve compliance with the ammonia effluent limit of35 Ill. Adm. Code 304.122(b).

VI.

Proposed Adjusted Standard

Section

104.406(1)

Noveon proposes the adoption by the Board of one of the following alternatives as the

adjusted standard language:

Alternative #1

Noveon, Inc. (“Noveon”) is hereby granted an adjusted standard

from 35 Ill. Adm. Code 304.122. Pursuant to thisadjusted

standard, 35 Iii. Adm. Code 304.122 shall not apply to the

discharge of effluent into the Illinois River from the Noveon plant

located at 1550 County Road, 850 N., in Henry, Illinois as regards

ammonia nitrogen. The granting ofthis adjusted standard is

contingent upon the following conditions:

Noveon shall not discharge calculated un-ionized ammonia at

concentrations greater than

3.5

mg/l during the months of

April through October and 7.9 mg/l during the months of

November through March from its Henry, Illinois plant into

the Illinois River.

Discharge into the Illinois River shall occur through a

diffuser that is at least 15 ft. in length, with 9 two-inch ports,

angled at 60 degrees from horizontal, co-flowing with the

river, designed to achieve an effluent dispersion of43:1.

Alternative #2

Noveon, Inc. (“Noveon”) is hereby granted an adjusted standard

from 35 Ill. Adm. Code 304.122. Pursuant to this adjusted

standard, 35 Ill. Adm. Code 304.122 shall not apply to the

discharge ofeffluent into the Illinois River from the Noveon plant

located at 1550 County Road, 850 N., in Henry, Illinois as regards

ammonia nitrogen. The granting ofthis adjusted standard is

contingent upon the following conditions:

The water quality standards will be met by the Noveon

Henry plant limiting its total ammonia nitrogen discharge

to 1200 pounds per day during the months ofApril through

October and 1735 pounds per day during the months of

November through March.

Discharge into the Illinois River shall occur through a

diffuser that is at least 15 ft. in length, with 9 two-inch ports,

angled at 60 degrees from horizontal, co-flowing with the

river, designed to achieve an effluent dispersion of43:1.

Alternative #3

Noveon, Inc. (“Noveon”) is hereby granted an adjusted standard

from

Ill. Adm. Code 304.122. Pursuant to this adjusted

standard,

Ill. Adm. Code 304.122 shall not apply to the

discharge ofeffluent into the Illinois River from the Noveon plant

located at 1550 County Road, 850 N., in Henry, Illinois as regards

ammonia nitrogen. The granting ofthis adjusted standard is

contingent upon the following conditions:

Noveon shall not discharge total ammonia nitrogen at

concentrations greater than

155

mgll during the months of

April through October and 225 mg/l during the months of

November through March from its Henry, Illinois plant into

the Illinois River.

Discharge into the Illinois River shall occur through a

diffuser that is at least 15

ft.

in length, with 9 two-inch ports,

angled at 60 degrees from horizontal, co-flowing with the

river, designed to achieve an effluent dispersion of 43:1.

VII.

Environmental Impact

Section 104.406(g)

The granting ofthe adjusted standard will not result in any adverse environmental impact.

As noted earlier, the Board’s rationale at the time

Ill. Adm. Code 304.122 was adopted was

premised upon the belief that larger dischargers were contributing to D.O. sags. The study

underlying that belief was later refuted by its authors when it was discovered that the D.O. sags

were occurring not as a result oflarger dischargers but primarily because ofsediment oxygen

demand. The discharge from the Henry Plant will not have a measurable effect on the D.O. in

the Illinois River.

Further, under the Board’s mixing zone regulations, it is appropriate to allow the mixing

of effluent with the receiving stream before determining compliance with water quality

standards. See, e.g., 35 Ill. Adm. Code 302.102. No adverse environmental impact will occur

because at the edge ofthe ZID and mixing zone calculated by Noveon’s consultant, consistent

with Agency and U.S. EPA guidance, both the winter (November through March) and summer

(April through October) acute and chronic water quality standards for ammonia will be readily

met. See Section II C. ofthis Petition.

The regulations set forth at 35 Ill. Adm. Code 302.102 govern allowed mixing, mixing

zones and zones of initial dilution. The calculated ZID and mixing zone proposed as a part of

this adjusted standard will meet each ofthe requirements of35 Ill. Adm. Code 302.102(b), in

that:

Mixing will be confined in an area or volume ofthe Illinois River no

larger than the area orvolume which would result afterincorporation of

a multi-port diffuser, engineered location and configuration ofdischarge

points to attain optimal mixing efficiency ofeffluent and the Illinois

River.

Mixing will not occlude any tributary mouth or otherwise restrict the

movement ofaquatic life into or out of the tributary.

Mixing will not occur in waters adjacent to bathing beaches, bank

fishing areas, boat ramps ordockages, or any other public areas.

Mixing will not occur in waters containing mussel beds, endangered

species habitat, fish spawning areas, areas ofimportant aquatic life

habitat, or any other natural features vital to the well being ofaquatic

life in such a manner that the maintenance of aquatic life in the body of

water as a whole is adversely affected.

Mixing will not occur in waters which contain intake structures of

public or food processing water supplies, points ofwithdrawal ofwater

for irrigation, or watering areas accessed by wild or domestic animals.

Mixing will allow for a zone of passage for aquatic life in which water

quality standards are met.

The areaand volume in which mixing occurs, alone or in combination

with other areas and volumes ofmixing, will not intersect any area or

volume ofany body ofwater in such a manner that the maintenance of

aquatic life in the body ofwater as a whole is adversely affected.

The area and volume in which mixing occurs, alone or in combination

with other areas and volumes ofmixing, will not contain more than 25

percent ofthe cross-sectional area or volume offlow ofthe Illinois

Riverincluding areas where the dilution ratio is less than 3:1. Mixing

will not occur in an area ofthe Illinois River having a zero minimum

7Q10.

Mixing will not occur where the water quality standard for ammonia is

already violated in the Illinois River.

The total Illinois River flow is not used for mixing.

The source ofeffluent is limited to a total area and volume ofmixing no

larger than that allowable for a single outfall.

The area and volume in which mixing will occur is as small as is

practicable under the limitations prescribed in 35 Ill. Adm. Code

302.102, and in no circumstances does the mixing encompass a surface

area larger than 26 acres.

Thus no adverse environmental impact, including harm to aquatic life, will result from the

granting ofthe requested adjusted standard, and the mixing, zone ofinitial dilution and mixing

zone that are an integral part ofthe relief Noveon seeks meet the requirements of 35 Iii. Adm.

Code 302.102.

VIII. Justification for Adjusted Standard

—

104.406(h)

As noted previously, the regulation of general applicability from which Noveen seeks an

adjusted standard does not specify a level ofjustification for such a standard. Section 28.1(c) of

the Act, however, allows the Board to grant an adjusted standard in the absence ofa specified

level ofjustification if the Board determines based upon adequate proofby the petitioner that:

Factors relating to the petitioner are substantially different from the

factors relied upon by the Board in adopting the general regulation;

The existence ofthose factors justifies an adjusted standard;

The requested standard will not result in environmental or health effects

substantially and significantly more adverse than the effects considered

by the Board in adopting the rule ofgeneral applicability; and

The adjusted standard is consistent with federal law.

415 ILCS

5/28.1(c).

Each ofthese factors is discussed below.

Substantially Different Factors

Section 28.1(c)(1)

The existing ammonia effluent regulation in 35 Ill. Adm. Code 304.122 is premised upon

two factors: the ability to treat ammonia and the desire to address D.O. concerns in the Illinois

River. Regarding the ability to treat ammonia, in amending the generally applicable rule the

Board expressly noted that “present technology is capable ofmeeting this limit and should result

in the removal ofmuch ammonia nitrification oxygen demand

...

from these stressed

waterways.” In the Matter ofWater Quality Standards Revisions, R72-4 (Nov. 8, 1973) (Final

Opinion). In general, there is technology capable of meeting the ammonia nitrogen limitation set

forth in 35 Ill. Adm. Code 304.122. Specifically as applied to the Henry Plant wastewater,

however, the numerous investigations and studies conducted by and on behalf ofNoveonhave

established that there are no alternatives that are both technologically feasible and economically

reasonable to achieve the ammonia reduction necessary to comply with 35 Ill. Adm. Code

304.122(b).

Secondly, the underlying technical justification that led the Board to adopt the general

rule, a concern about D.O. sags in, among other rivers, the Illinois River was later refuted as

being caused primarily by the discharge ofammonia nitrogen. Rather, the D.O. sags were later

determined to be primarily caused by sediment oxygen demand. Ammonia discharged at the

level requested by Noveon will thus have minimal, if any, impact upon the level of D.O. in the

Illinois River. See Exhibit 2. Nor will it contribute to any water quality violations or harm to

aquatic life as discussed in Section VII. above. In sum, the factors relied upon by the Board in

adopting what is now 35 Iii. Adm. Code 304.122 were substantially different than those

applicable to the Noveon HenryPlant.

Adjusted Standard Justification

Section 28.1(c)(2)

One factor that must be taken into consideration when adopting environmental

regulations in the State ofIllinois is economic reasonableness. 415 ILCS 5/27. The ammonia

nitrogen effluent limit from which Noveon seeks relief was adopted based upon balancing the

potential adverse impact upon D.O. against the cost and ease ofcontrol. On both of these latter

points, adverse impact and cost, the balance weighs heavily towards the requested adjusted

standard relief. The beneficial impact, if any, to the Illinois River would be minimal if Noveon

were required to meet the ammonia nitrogen limitation of35 Ill. Adm. 304.122(b). Further,

given the lack of any discernible environmental benefit, the high cost ofthe technically feasible

control technology makes it economically unreasonable for Noveon to meet the ammonia

effluent limitation and warrants the requested adjusted standard relief.

Environmental or Health Impacts

Section 28.1(c)(3)

There is no measurable impact upon the environment or human health that would result

from the granting of this adjusted standard. As discussed thoroughly in Section VII. in this

petition, the discharge from the Henry Plant will meet the winter and summer acute water quality

standards for ammonia at the edge of an appropriately calculated ZID. The winter and summer

acute and chronic standards will also be met at the edge of an appropriately calculated mixing

zone.

Thus, the impact will not be significantly more adverse than that contemplated by the

regulation ofgeneral applicability.

Consistency With Federal Law

Section 28.1 (c)(4)

The requested adjusted standard is consistent with federal law. The requested relief

applies only to ammonia discharges from the Henry Plant. There are no applicable federal

numeric effluent standards or water quality standards for ammonia. Under federal regulations:

A water quality standard defines the water quality goals ofa water

body, or portion thereof, by designating the use or uses to be made

ofthe water and by setting criteria necessary to protect the uses~

States adopt water quality standards to protect public health or

welfare, enhance the quality ofwater and serve the purposes ofthe

Clean Water Act (the Act). “Serve the purposes ofthe Act” (as

defined in sections 101(a)(2) and 303(c) ofthe Act) means that

water quality standards should, wherever attainable, provide water

quality for the protection and propagation offish, shellfish and

wildlife and for recreation in and on the water and take into

consideration their use and value ofpublic water supplies,

propagation offish, shellfish, and wildlife, recreation in and on the

water, and agricultural, industrial, and other purposes including

navigation.

40 C.F.R. 131.2. Under 40 C.F.R. 13 1.4(a) “states are responsible for reviewing, establishing

and revising water quality standards.” In turn, pursuant to 40 C.F.R. 13

1.5(a),

“EPA is to review

and to approve or disapprove the State-adopted water quality standards.” These standards are to

be protective ofthe designated uses (~131.5(b))and, where those uses are not protected, this

must be supported by “appropriate technical and scientific data and analyses.”

131

.5(b)(4)).

state is allowed to remove a designated use, which is not an existing use, if it “can demonstrate

BEFORE

THE

ILLINOIS POLLUTION CONTROL BOARD

iN THE MATTER OF:

)

Petition ofNoveon, Inc.

)

ASO2-____

)

(Adjusted Standard)

for an Adjusted Standard from

)

35111. Adm. Code 304.122

)

Exhibit List

AquAeTer June 4, 2001 memorandum “Review ofDispersion Achievable

for Meeting Water Quality Limits at the PMD Group, Inc. Noveon

HenryFacility.”

AquAeTer October 3, 2000 memorandum “Analysis ofDO in the Illinois

River Downstream from Henry, Illinois.”

AquAeTer June 22, 2001 report “Mixing Zone/ZID Issues, Illinois River

at Henry, Illinois.”

Wastewater Treatment Plant Block Flow Diagram.

2001 Discharge Data Summary.

Eckenfelder Inc. June 1996 “Evaluation ofTreatment Alternatives for

Reducing Final Effluent Ammonia Load.”

Brown and Caidwell May 17, 2002 memorandum.

Affidavit ofDavid E. Giffin.

opumizing environmental resources

• water, air, earth

~Ter

MEMORANDUM

TO:

Richard Kissel and Mark Latham, Gardner, Carton & Douglas

FROM:

Mike Corn,

P.E., AquAeTer

DATE:

June4, 2001

JOB NO:

001105

RE:

Review ofDispersion Achievable for Meeting Water Quality Limits at the PMD

Group, Inc., Henry Facility

In 1989, a dispersion study ofthe existing single port diffuser was conducted using specific

conductance at 25 °C(conductivity) as the tracer. From this information, dispersion from the

existing diffuser and physical dimensions ofthe zone ofinitial dilution (Z1D) and the total mixing

zone were estimated. Based on this tracer study, the diffuser was found to have a ZJD that extended

a total distance of

66.5

ft downstream, based on the discharge length scale, defined as the centerline

ofthe plume in the downstream direction, and the flux average dispersion (FAD) at the end of the

ZID. This distance was based on the in situ measurements of conductivity and also on the minimum

distance prescribed bythe Illinois Environmental Protection Agency (IEPA) forZIDs, which in this

case is based on 50

the square root ofthe cross-sectional area. The dispersion achieved at the edge

ofthe ZID based on the tracer study results of 13.2:1.

Additionally, in 1994 and 1995, as assessment ofthe Illinois River background water quality

conditions at Marseilles, Illinois were as follows:

Parameter

Units

Summer

Winter

Total Ammonia

mg/L

0.297

0.8

NH3,

75th

percentile

mg/L

0.011

0.005

Temperature,

75th

percentile

°C

26.0

6.5

pH, calculated

75th

percentile

S.U.

7.77

7.63

Based on the above data, the critical period for meeting water quality numeric effluent limits

was during surmner periods. Meeting the numeric water quality limits during winter conditions were

not an issue with this discharge based on the ZID described above and under the specified winter

time conditions.

A multiport high-rate diffuser was also conceptually designed to maximize the dispersion

from the combined PM) Group and City ofHenry discharge. Based on a flow of 1.0 million gallons

Mr. Richard Kissel, Gardner, Carton & Douglas

001 105/2

October 3,

2000

Page 2

be low compared to the upstream stations that were taken in the early to mid-

afternoon. Typically, DO in systems influenced by algae reflect average DO

concentrations in the diurnal cycle around noon to about 1400. Therefore, the

period average DO concentrations may be more reflective of River DO

conditions. Regardless, the DO concentrations are not reflective of a stressed

system, although there have been instances (grab samples) ofDO concentrations

less than the

milligrams per liter (mg/L) standard.

Nitrogen concentrations at these four stations are around 0.75 to 1.7 mg/L total

kjeldahl nitrogen (organic plus ammonia-nitrogen). These are not excessive

nitrogen levels. It is unclear from the data how much ofthe TKN is ammonia, but

it appears to be on the order of 0.05 to 0.3 mg/L for September.

Nitrate concentrations are high in the River upstream from Henry (i.e., 3 to 4

mg/L at Marseilles) and this is reflective ofnitrification in the River upstream.

Phosphorous is very high in the Illinois River with total phosphorous recorded in

September around 0.5 mg/L. Phosphorous would control this system, because it

is in- excess of what is required by the algae. Total phosphorous in the range of

0.05 to 0.15 mg/L is a typical range. The BF Goodrich wastewaters are

phosphorous limited and the facility adds phosphorous to aid in the biological

process. The River phosphorous is most likely controlled by nonpoint sources

(i.e., farming and most likely the City ofChicago effluent discharges).

The nitrogen to phosphorous ratio for healthy algae populations ranges from 60:1

to 10:1. Phosphorous at 100 ug/L for free-flowing streams and

ug/L for lake-

like settings is considered adequate for preventing nuisance algae blooms. For the

Illinois River, the N:P ratio is around .3:1, which would indicate that phosphorus

is in excess.

The U.S. Environmental Protection Agency (USEPA) wasteload allocation model,

QUAL2e, was utilized to project impacts of the BF Goodrich effluent to the Illinois River.

Model~inputs were projected from USGS and IEPA synoptic water quality data and from

deoxygenation and reaeration/algae productivity rates based on similar rivers where specific

wasteload allocation data have been collected. No specific assimilative capacity study data were

available from the agencies, although the Illinois Water Survey may have these data that may be

obtained through a Freedom ofInformation Act (FOJA) request.

The Henry discharge included both the BF Goodrich effluent and the Henry publicly

owned treatment works (POTW) discharge through the BF Goodrich effluent diffuser. The

- -~ -

ratio.,ultimateof 4:1.,carbonaecousThe followingbiochemicalinput parametersoxygen

demandwere (CBODU)used

for thewascombinedestimatedBFat

CBOD~/BODGoodrich

and5

Henry POTW discharge

October 3,2000

001105/3

Mr. Richard Kissel

Gardner, Carton & Douglas

Quaker Tower, Suite 3400

321 N. Clark Street

Chicago, Illinois 60610-4795

RE: Analysis of

in the Illinois River Downstream from Henry, Illinois

Dear Mr. Kissel:

AquAeTer,

Inc. (AquAeTer)

has conducted screening level dissolved oxygen (DO)

modeling of the Illinois River from about Illinois River mile (IRM) 200 to IRM 170. The BF

Goodrich treated effluent diffuser discharges to the River at about IRM 198. Data obtained form

the United States Geological Survey (USGS) and the Illinois Environmental Protection Agency

(IEPA) were used to develop an input data set for the River which is presented in Attachment 1.

Stream hydraulic characteristics were estimated based on other similar river/lake settings at

similar river depths and widths. Specific points of interest from the available data are listed

below.

The critical low-flow high-temperature month has been assumed to be September

when the 7-day 10-year low flow (7Q10) is around 2,900 cubic feet per second

(cfs) (at Marseilles) and the critical temperature is around 77.7 degrees Farenheit

•

(°F).

Location

Period Average

( of Saturation)

September Average

(

of Saturation)

Illinois R. c~Marseilles

109.9

101.8

Illinois R. ~

Flennepin

104.31

108.8

Illinois

R. ~ Lacon

97.60

96.4

Illinois R.

Peoria

106.52

94.2

Normally, 85 percent DO saturation is considered typical stream conditions.

These DO saturations are reflective of a stream- that is primarily reoxygenated by

the resident algae populations. It is important to note that the DO measurements

at the Water Intake at Peoria were taken around 10 am and would be expected to

optimizing environmental resources

water, air, earth

ii’

a’

DO saturation in the River ranges as follows:

P.O. Box 1187 +

Brentwoocl,-TN

+ 37024-1187 + Phone (615) 373.8532 + F’ax (615) 373-8512

Richard Kissel and Mark Latham, Gardner, Carton & Douglas

001105

June 4, 2001

Page 2

per day (mgd) from the PMD Group effluent discharge and 0.3 mgd from the

City

of Henry for a

total flow of 1.3 mgd, a 15 ft long diffuser with 4 4-in ports placed in 13 ft ofwater and with ports

at a 60 angle fro.m the bottom and parallel to the ambient current, a dispersion of 43:1 can be

achieved on the order ofone diffuser length downstream or from

7.5

to 22.5 ft downstream

(V2

diffuser lengths). The dispersion modeling was completed for a 7-day 10-year low flow (7Q10)

that occurs in September. The CORMIX model was used to project the diffuser dispersion. The

diffuser would result in all numeric waterquality limits being met in the shortest distance from the

diffuser pipe and in the smallest area.

The information presented in this report has been developed using available LEPA, USEPA

or other governmental agencies and using published dispersion models and guidance on mixing

zones. Ifyou should have questions or comments concerning this information, please call me at

(615) 373-8532 or by FAX at (615) 373-8512 or by e-mail at mcorn~aquaeter.com.

MIXING ZONE/ZID ISSUES

ILLINOIS RIVER AT HENRY, ILLINOIS

NOVEON, INC.

HENRY, ILLINOIS

BF GOODRICH

BRECKSVILLE, OHIO

~er

215

JAMESTOWN PARK, SUITE

100

•

7340

EAST

CALEY AVE., SUITE 200

BRENTWOOD, TN 37027

CENTENNIAL, CO 80111

(615)

373-8532

(303) 771-9150

JUNE

22, 2001

optimizing environmentalresources~

water,

air, earth

Mr. Richard Kissel, Gardner, Carton & Douglas

001105/2

October 3, 2000

Page 4

Ifyou should have questions or comments concerning these analyses, please contact us at

(615)

373-8532, or by FAX at (615-373-8512, or by email at mcorn~aguaeter.com or

smccormick~aguaeter.com.

Sincerely,

AquAeTer, Inc.

~1mQC&ryuLdJ

____________

Shaleen T. McCormick

Michael R. Corn

Project Scientist

President

cc:

Mark Latham, Gardner, Carton & Douglas

Dave Giffin, BF Goodrich, Henry, Illinois

• Ken Willings, BF Goodrich, Cleveland, Ohio

1..•

Mr. Richard Kissel, Gardner, Carton & Douglas

00 1105/2

October 3, 2000

Page 3

SOURCE

FLOW

(mgd)

(mgIL)BOD5

CBODU

(mgfL)

ORG N

(mg/L)

NH3+NH4-N

(rng/L)

BFG

0.8

160

137

BFG

0.8

137

BFG

0.8

I-IenryPOTW

0.4

The values used for the BF Goodrich effluent have been input into the model using

maximumconcentrationconcentrationsof

40 mg/L isora

upperdaily

maximumranges

ofpermitconcentrations.limit

and theFordailyexample,average valuethe

BODis

205

mg/L. Monthly averages are used for projecting wasteload allocations. The CBOD~/BOD5ratio

of 4:1 for the Henry plant is estimated from past time-series BOD’s conducted on organic

chemical plants, which indicate this ratio is much higher than that traditionally estimated for

domestic effluents (1.5 to 2:1).

Model results for dissolved oxygen are presented in Figures 1 and 2. Model inputs and

outputs are presented in Attachment 2. The results include four model runs:

The BOD5 in the BFG/Henry effluent discharge was set at 40 mg/L (daily

maximum);

The BOD5 in the BFG/Henry effluent discharge was set at 20 mg/L (monthly

average

—

this is the allocation scenario that the allocation would be based on in

the discharge);

The organic and ammonia nitrogen load from BFG was set at 6 mg/L; and

The BFG/Henry effluent discharge was removed from the River.

Based on the input parameters used, the model indicated that the BFGIHenry discharge

reduced the DO in the River for the critical September 7Q10 condition from a DO sag low point

of7.74 mg/L without the BFG/Henry discharge to 7.58 mg/L with the BFG/Henry discharge or

an impact of about 0.16 mg/L. The impact appears to occur between about IRM 178.75 to about

174.5, which is at the head of the Peoria pool. Without the BFG/Henry discharge, this sag

occurs from about IRM 179 to about IRM

175.25,

or approximately in the same general area.

There is still a DO sag in the area downstream from Henry even without the Henry plant. This

appears to be reflected in the DO saturations recorded at Lacon, although firm conclusions

should not be drawn from grab samples.

The nitrogen load from BFG does not appear to be impacting algal productivity (i.e., not

impacting nutrient enrichment), but it does impact the DO resources in the River. Since the BFG

effluent

has a minimal impact, less than 0.2 mg/L or within the accuracy of our ability to

Illinois

measureRiver.DO

(+/..

0.1 mg~),the nitrogen load from BFG is not having an adverse effect on the

r~-

ACUTE

CHRONIC

TOXICITY

CRITERIA

ANTIBACKSLIDING

PROVISION

WHOLE EFFLUENT

WATER QUALITY

BASED LIMITS

ACUTE

CHRONIC

RIO-

TOXICITY

ACCUMULATION

TESTING

ZID

1TTYT~

END OF PIPE

CLEAN WATER ACT OF 1987

WATER-QUALITY BASED TOXICS CONTROL

POLLUTANT BY

POLLUTANT

WATER QUALITY

BASED LIMITS

TECHNOLOGY

BASED

LIMITS

BAT

‘~

AND

• EFFLUENT LIMITS

GUIDELINES

NUMERIC OR

NARRATIVE

STANDARDS

CONVENTIONAL

AND

PRIORITY POLLUTANTS

HUMAN

f~ERRESTRIAL

HEALTH

LIFECYCLES

CRITERIA

ANTIBACKSLIDING

PROVISION

END OF PIPE

MIXING ZONE

TOTAL

END OF PIPE

TABLE 1.

EFFLUENT

AND

RIVER DATA

GENERAL CONDITIONS

Effluent Characteristics

Single-port submerged discharge pipe located

25 ft offshore at IRM 198.0

Average Effluent Flow

1.43 cfs or 0.92 mgd

Average Effluent TDS-~-6,500 mg/L (typical)

Average Effluent Conductivity

9,000-10,000 umhos/cm

River Characteristics

7Q10

3,400 cfs

Average

16,500 cfs

Conductivity

740 umhos/cm

OCTOBER 25, 1989 DISPERSION STUDY

Effluent

Q =

1.7

cfs cr1.1 mgd

TDS

7,000 mg/L

Conductivity

10,000 to 12,000 umhos/cm

River

6,550 cfs

Conductivity

775 umhos/cm

Plume

ZID

5:1 to 9:1

400 to 800 ft achieved complete vertical mixing

800 ft --.100:1

—

280

260

240

220

200

180

Li~I

160

IL-

Lii

120

~cioo

(I)

—100 —50

100 150

200

300 350 4-00

450 500 550 600

650

700 750

800

DISTANCE

DOWNSTREAM FROM OUTFALL (ft)

FIGURE 2

LATERAL AND

LONGITUDINAL ISOPLETHS

FOR

BOTTOM

SPECIFIC CONDUCTANCE

IWNOIS RIVER

CONDUCTNITY

—

775 umhoa/cm

EFFLUENT

CONDUCTIVI1Y

12.000

urnhos/crn

—---.:~—

TABLE 2. DISPERSION

ACHIEVED FOR THE

EXISTING SINGLE-PORT

DIFFUSER

3,000

2,000

19.8

10.9

5.0

9.2

CONDUCTIVITY

ISOPLETH

(umhos/cm)

EFFLUENT

()

DISPERSION

RATIO

L:1)

9,000

73.3

1.4

900

liii

89.8

880

094

106.9

1,000

2.0

49.9

Table 3. Calculation ofAllowable Total Ammonia in ZID

USEPA Equation (“1999 Update ofAmbient Water Quality Criteria for Ammonia”,

USEPA, Office ofWater, September 1999):

CMC=

0.411

58,4

(1)

107.204

0pH

— 7.204

where:

CMC

criterion maximum concentration (acute criterion)

=pHatedgeofZlD

Calculatingwhere:for CMC for Total ammonia or NH3

NIH4

pH 7.77 standard units (S.U.)

CMC

0.411

58A

107.204_7.77

—

7.204

CMC

(0.411/1.272)

(58.4/4.68

0.323

12.475

CMC

12.8

rng/L

‘lotal Ammonia~

Note: The 1998 arid 1999 CMC equations for streams absent salmonids are equivalent.

—r r r c r~c

~t c r r

r r- -~r- —.

FIGURE 1

TOTAL AMMONIA

ZID DISTANCE DOWNSTREAM

SUMMER

and

WINTER

ZID DISTANCE (It)

SUMMER

WINTER

-I-

—•-

600

500

~200

100

120

CALCULATION OF ALLOWABLE EFFLUENT AMMONIA

CONCENTRATIONS FOR THE SINGLE PORT DIFFUSER

(BF GOODRICH PROPOSED ZID)

The BF Goodrich effluent characteristics are assumed to be as follows:

Effluent

0.8 mgd or

556

gpm

Effluent TDS

10,361 mgIL

Effluent NH3+ NH4

Variable depending upon dispersion

BFG Effluent pH

7.00 S.U.

ZID pH

7.77 S.U.

Background River NH3÷NH4

0.297 mg/L (summer conditions)

ZID NH3÷NH4 CMC

12.80 mgfL (see Table 1)

ZID TDS WET Conc.

•

1,500 mg/L (to meet WET)

The effluent concentration can be calculated from the ZID required CMC or WET value as

follows.

Assume:

13.2

12.2 parts background river water and 1 part effluent

Therefore:

(13.2 total parts at edge of ZID

12.80 mgfL NH3+ NH4 CMC)

(1 part effluent

x mgfL NH3÷NH4

) +

(12.2 parts river

0.297 mgIL NH3+ NH4)

(168.96 mg/L

parts —3.62 mgIL

parts)/(1 part)

165.3 mg/L effluent Total NH1+ NH4 allowable for S

13.2:1

~er

CONSIDERATION OF

BF GOODRICH

AND

CITY OF HENRY POTW COMBINED

EFFLUENT

1,516.5

lbs/day

(0.3

mgd

20 mgfL

8.34)

+ (0.8 mgd *

8.34)

(1,516.5

lbs/day

—

50.04

lbs/day)/6.67 (mgd

lbs/day)/(mgfL

mgd)

= 219.8

mg/L total ammonia that can be discharged from BF Goodrich

MINIMUM

DISPERSION

REQUIRED

TO MEET ACUTE TOXICITY

DUE TO TOTAL DISSOLVED SOLIDS (TDS)

1)(1,500mgIL TDS)

= (x)(481

mgfL

TDS) + (1)(10,361

mg/L TDS)

1,500 mgIL x

1,500 mgfL

481 mg/L x

10,361 mg/L

1,500 mg/L x

481 mgfL x

10,361 mgfL

1,Ol9mg/Lx

8,861 mg/L

8,861 mgfLil,019 mgfL

8.7:1

to meet 1,500 mg/L TDS at edge of ZID

With Henry POTW x

8.2:1

to meet 1,500 mgfL TDS at edge ofZID

1111111

Mr. Richard J. Kissel

October

1998

1••~~

~.•

Diffusion Requirements

ARCHITECTSENGINEERS

AquAeTer’sThe

above assumptionsMike

Corn. AquAelerand

conceptual

recommends

plan and

use

profileof

the

layouts

following

were

design

discussed

parameters

with

PLANNERS

it relates to the diffusion header. As recommended by AquAeTer, the port size, length of

diffusion header, angle of ports and port spacing as shown below, will provide a

dispersion of about 43:1 at one diffuser length downstream at 7Q10 flow (low pool)

conditions.

Length of Diffusion Header~

15 ft.

Design Flow Rate:

1.3 MGD

Port Velocity at Avg. Design Flow Rate:

10 FPS

No.

of Ports:

Port Diameter~

2 inches

Port Angle (from horizontal):

60 degrees

Centerline Distance Between Ports:

1.67 ft.

Dispersion:

43:1

Other Hydraulic Determinations

As previously discussed, flows above the average design flow would cause higher

velocities and associated greater head loss through the diffusion system. The following

outlines various port exit velocities and the corresponding total hydraulic headloss through

the diffusion system at various flows.

Flow (MGD)

Port Exit Velocity (FPS)

Hydraulic Headloss (Feet)

1.3

9.9

2.9

1.6

12.1

4.4

2.1

15.9

7.6

2.4

18.2

9.9

4.7

35.6

37.8

5.0

37.9

42.7

95U~KI~eI.O98

~~IUT

B.F. Goodrich

Henry,

Illinois Facility

Multlport DiffusIon

System

Estimate of

Probable

Construction Costs

NGINEERS

~CHITECTS

Lt~m

Cost

- PLANNERS

Land mobilization

$15,000

River Mobilization

13,000

Bonds and Insurance

8,000

Excavation for Manholes

15,000

Excavation for Piping

45,000

Backfill

15,000

Rip Rap

20,000

Concrete Cast-in-Place Outfall Manhole

40,000

Handrail, Ladders and Fall Prevention System

15,000

Sheet Pile for Outfall Manhole

30,000

Foundation Piling for Outfall Manhole

3,000

Dewatering

10,000

Set-Over Precast Concrete Manhole

8,000

Closure Gates

30,000

Connection to Existing Manhole

3,000

Connection to Existing Pipe Line

2,000

Interconnecting pipe, Fittings and Appurtenances

12,000

Outfall Pipe Line

125,000

Diffusion Header and Ports

20,000

Pile Bent Placement and Support System

140,000

Miscellaneous

10,000

Subtotal

$579,000

Contingencies (15)

87.000

Total Construction Cost

$666,000

P:/PROJ/21522IFig 1

FIGURE 1

BLOCK FLOW DIAGRAM OF WASTESTREAM

SOURCES AND WWTF

Nashville, Tennessee

BROWN

AND

CALD WELL

---~-~--

—---—-----

----—~-

----I-——-

DMR Support Data

2001

Plant Effluent

Vinyl

Fecal

Residual

tBOD

TSS

Date

Chloride

Coliform Ammonia

Phenol

Chlorine

tBOD

TSS

Flow

Load

Temp.

(ug/L)

(#/100 mL)

(mg/L)

(mgIL)

(parts/MM)

(mg/I)

(gpm)

(#/day)

(F)

1-Jan

539.09

77.63

51.75

7.5

2-Jan

434.98

62.64

36.54

7.5

3-Jan

211.00

30.38

124.07

7.6

4-Jan

561.24

40.41

74.08

6.3

5-Jan

609.07

7.3

6-Jan

738.33

7-Jan

653.49

47.05

78.42

7.5

8-Jan

685.71

82.29

74.06

7.6

9-Jan

524.84

239.33

56.68

7.5

10-Jan

492.62

47.29

7.5

11-Jan

511.02

24.53

36.79

7.5

12-Jan

472.49

7.5

13-Jan

648.18

7.9

14-Jan

632.08

30.34

45.51

7.3

15-Jan

110

0.054

0.09

501.83

36.13

18.07

16-Jan

401.13

24.07

19.25

7.2

17-Jan

503.21

30.19

24.15

18-Jan

549.00

19.76

7.3

19-Jan

457.22

7.8

20-Jan

278.02

7.7

21-Jan

462.33

61.03

38.84

7.8

22-Jan

587.03

28.18

14.09

6.5

23-Jan

533.10

31.99

19.19

6.2

24-Jan

512.90

49.24

36.93

6.7

25-Jan

499.33

35.95

29.96

6.5

26-Jan

502.47

6.6

27-Jan

544.23

6.7

28-Jan

547.12

26.26

6.7

29-Jan

604.60

43.53

6.7

30-Jan

697.49

41.85

66.96

6.8

31-Jan

6.4

624.62

52.47

47.97

6.9

Average

10.000

110.000

0.054

0.090

8.130

8.017

532.896

50.545

44.790

7.148

71.677

Maximum

10.000

110.000

0.054

0.090

38.000

49.000

738.330

239.327

124.068

7.900

80.000

Minimum

10.000

110.000

0.054

0.090

3.000

2.000

211.000

19.764

14.089

6.200

63.000

Ww12001 Jan

5/22/02 11:23 AM

DMR Support Data - 2001

Plant Effluent

Vinyl

Focal

Residual

tBOD

TSS

Date

Chloride Coliform Ammonia

Phenol

Chlorine

tBOD

TSS

Flow

Load

Temp.

(ug/L)

(#11

00 mL) (mg/L)

(mg/L) (parts/MM) (mg/I)

(mg/I)

(gpm)

(#Iday)

(F)

1-Feb

503.81

24.18

96.73

6.9

2-Feb

367.63

6.9

3-Feb

363.40

6.9

4-Feb

2.4

491.11

23.57

14.14

6.9

5-Feb

3.2

587.66

28.21

22.57

7.3

6-Feb

5.2

300.00

21.60

18.72

7.3

7-Feb

7.6

494.97

29.70

45.14

7.4

8-Feb

730.47

43.83

113.95

7.3

9-Feb

608.08

7.4

10-Feb

702.58

6.7

11-Feb

6.4

455.51

38.26

34.98

6.8

12-Feb

5.6

504.81

60.58

33.92

13-Feb

642.72

161.97

61.70

6.9

14-Feb

636.33

114.54

160.36

6.9

15-Feb

639.73

245.66

184.24

16-Feb

501.79

7.6

17-Feb

498.53

7.4

18-Feb

495.49

130.81

178.38

7.3

19-Feb

664.23

223.18

167.39

7.3

20-Feb

651.30

187.57

195.39

7.5

21-Feb

140

0.068

0.344

608.38

109.51

116.81

7.6

22-Feb

553.56

139.50

325.49

7.2

23-Feb

629.09

8.3

24-Feb

634.60

7.4

25-Feb

653.04

250.77

109.71

7.1

26-Feb

501.26

84.21

60.15

7.3

27-Feb

8.4

554.22

106.41

55.87

28-Feb

5.2

518.41

80.87

32.35

Average

10.000

0.000

140.000

0.068

0.344

14.900

14.550

553.311

105.246

101.400

7.200

71.429

Maximum

10.000

0.000

140.000

0.068

0.344

32.000

49.000

730.470

250.767

325.493

8.300

80.000

Minimum

10.000

0.000

140.000

0.068

0.344

4.000

2.400

300.000

21.600

14.144

6.700

57.000

Ww12001 F~b

5/22/02 11:23AM

DMR Support Data - 2001

Plant Effluent

Vinyl

Fecal

Residual

tBOD

TSS

Date

Chloride Coliform Ammonia

Phenol

Chlorine

tBOD

TSS

Flow

Load

Temp.

(ug/L)

(#/100 mL)

(mg/L)

(parts/MM)

(mg/I)

(gpm)

(#/day)

(F)

1-Mar

6.1

5.2

493.66

36.14

30.80

6.8

2-Mar

569.01

6.9

3-Mar

600.80

4-Mar

7.6

581.66

90.74

53.05

7.3

5-Mar

5.6

415.74

39.91

27.94

6-Mar

5.6

463.61

55.63

31.15

6.8

7-Mar

7.6

418.28

35.14

38.15

6.8

8-Mar

506.11

- 85.03

48.59

6.7

9-Mar

514.14

6.7

10-Mar

433.90

6.3

11-Mar

487.18

64.31

6.4

12-Mar

9.6

633.74

45.63

73.01

6.9

13-Mar

120

0.11

665.01

135.66

127.68

14-Mar

0.196

670.57

120.70

48.28

7.2

15-Mar

6.4

619.60

66.92

47.59

16-Mar

637.14

17-Mar

626.87

7.2

18-Mar

4.8

647.50

54.39

37.30

7.1

19-Mar

4.4

595.87

78.65

31.46

7.1

20-Mar

7.2

563.66

60.88

48.70

7.2

21-Mar

7.6

528.79

57.11

48.23

22-Mar

8.4

519.49

68.57

52.36

7.1

23-Mar

507.06

7.2

24-Mar

488.70

25-Mar

487.76

29.27

46.82

7.1

26-Mar

2.8

392.56

32.98

13.19

27-Mar

5.2

431.69

41.44

26.94

7.3

28-Mar

379.69

72.90

36.45

7.2

29-Mar

3.6

430.44

82.64

18.60

7.6

30-Mar

425.12

6.8

31-Mar

445.81

7.7

Average

10.000

0.000

120.000

0.110

0.196

10.243

7.076

521.973

64.506

45.266

7.013

71.000

Maximum

10.000

0.000

120.000

0.110

0.196

17.000

16.000

670.570

135.662

127.682

7.700

79.000

Minimum

10.000

0.000

120.000

0.110

0.196

5.000

2.800

379.690

29.266

13.190

6.300

64.000

Wwt200l Mar

5/22/02 11:07 AM

DMR Support Data - 2001

Plant Effluent

I-Apr

2-Apr

3-Apr

4-Apr

5-Apr

6-Apr

7-Apr

8-Apr

9-Apr

10-Apr

11-Apr

12-Apr

13-Apr

14-Apr

15-Apr

16-Apr

17-Apr

18-Apr

19-Apr

20-Apr

21-Apr

22-Apr

23-Apr

24-Apr

25-Apr

26-Apr

27-Apr

28-Apr

29-Apr

30-Apr

Vinyl

Fecal

Residual

Chloride Coliform Ammonia

Phenol

Chlorine

tBOD

(ug/L)

(#11

00 mL)

(mg/L)

(mg/L) (parts/MM)

(mg/I)

tBOD

TSS

Flow

Load

Temp.

(mg/I)

(gpm)

(#/day)

(F)

5.6

577.47

510.17

447.16

541.42

540.00

575.02

657.02

625.63

6.4

610.51

600.82

629.01

297.29

524.93

606.28

621.76

5.2

500.54

511.07

512.59

626.82

516.97

539.63

545.40

623.27

.19

554.26

499.50

- 12

466.23

359.08

323.91

365.23

417.91

62.37

38.81

153.05

110.20

112.68

107.32

77.96

123.44

97.20

155.52

105.11

157.66

80.59

46.89

144.20

108.15

113.22

196.25

53.51

35.67

52.23

29.84

60.06

31.23

67.46

98.13

92.27

129.17

82.74

75.22

65.45

78.54

89.75

74.79

86.46

126.37

59.94

107.89

67.14

52.59

43.83

60.18

70.21

Ww12001 Apr

5/22/02 11:07 AM

Date

0.213

10.000

7.5

7.4

7.2

7.4

7.4 -

7.3

7.4

7.3

7.2

7.4

7.7

7.3

7.2

7.1

130

0.08

0.000

130.000

0.080

0.000

130.000

0.080

0.000

130.000

0.080

Average

Maximum

Minimum

7.4

0.213

13.273

0.213

25.000

0.213

7.000

14.373

524. 230

26.000

657.020

4.000

297.290

7.3

7.2

7.293

7.700

7.000

73.267

77.000

70.000

83.462

91 .467

153.051

196.251

52.228

29.844

DMR Support Data

2001

Plant Effluent

Vinyl

Fecal

Residual

tBOD

TSS

Date

Chloride

Coliform Ammonia

Phenol

Chlorine

tBOD

TSS

Flow

Load

Temp.

(ug/L)

(#/100 mL)

(mg/L)

(mg/L) (parts/MM)

(mg/I)

(gpm)

(#/day)

(F)

1-Jun

440.50

7.1

2-Jun

609.21

7.1

3-Jun

544.06

39.17

7.2

4-Jun

424.52

30.57

66.23

7.3

5-Jun

477.14

22.90

154.59

7.3

6-Jun

507.63

24.37

60.92

7.3

7-Jun

540.92

32.46

38.95

7.3

8-Jun

476.53

7.3

9-Jun

436.44

7.3

10-Jun

462.43

27.75

38.84

7.4

11-Jun

100

0.11

0.187

475.06

34.20

108.31

7.2

12-Jun

563.24

47.31

7.2

13-Jun

6NoData

7.1

14-Jun

569.84

61.54

7.1

15-Jun

616.74

7.3

16-Jun

580.42

7.2

17-Jun

484.49

110.46

209.30

18-Jun

490.60

29.44

94.20

7.3

19-Jun

565.22

74.61

189.91

7.1

20-Jun

647.21

85.43

248.53

7.1

21-Jun

602.44

79.52

303.63

7.5

22-Jun

533.94

23-Jun

634.64

6.9

24-Jun

617.77

22.24

126.03

25-Jun

664.29

47.83

119.57

7.3

26-Jun

597.46

179.24

236.59

7.1

27-Jun

568.40

88.67

184.16

7.1

28-Jun

649.22

93.49

155.81

7.1

29-Jun

631.81

7.2

30-Jun

630.63

7.1

Average

10.000

100.000

0.110

0.187

8.800

18.800

553.200

59.537

130.716

7.183

77.233

Maximum

10.000

100.000

0.110

0.187

25.000

42.000

664.290

179.238

303.630

7.500

82.000

Minimum

10.000

100.000

0.110

0.187

3.000

6.000

424.520

22.240

38.844

6.900

70.000

Ww!2001

June

5/22/02 11:07 AM

DMR Support Data

2001

Plant Effluent

Vinyl

Focal

Residual

Chloride Coliform Ammonia

Phenol

Chlorine

tBOD

(ug/L)

(#/100 mL)

(mg/L)

(mg/L) (parts/MM)

(mg/I)

tBOD

TSS

Flow

Load

Temp.

(mg/I)

(gpm)

(#/day)

(F)

1-Jul

2-Jul

3-Jul

4-Jul

5-Jul

6-Jul

7-Jul

8-Jul

9-Jul

10-Jul

11-Jul

12-Jul

13-Jul

14-Jul

15-Jul

16-Jul

17-Jul

18-Jul

19-Jul

20-Jul

21-Jul

22-Jul

23-Jul

24-Jul

25-Jul

26-Jul

27-Jul

28-Jul

29-Jul

30-Jul

31-Jul

584.87

460.51

669.34

616.73

536.26

602.67

637.07

625.00

546.52

718.98

775.62

728.89

666.09

633.08

583.43

586.56

589.83

674.00

679.06

721.81

692.31

670.24

678.44

748.13

701.43

711.94

669.36

671.39

639.49

549.88

643.63

12.261

645.566

30.000

775.620

2.000

460.510

21.06

133.35

44.21

77.37

32.13

24.10

37.00

22.20

19.31

12.87

22.50

26.23

32.79

51.77

77.65

83.77

139.61

78.72

236.16

21.dO

77.01

35.19

42.23

63.70

106.17

48.53

105.14

57.04

146.68

48.26

144.77

73.27

146.54

53.87

188.53

84.17

252.51

34.17

145.24

23.02

46.04

26.39

30.89

38.62

44.183

97.586

84.172

252.515

19.305

12.870

7.7

7.5

7.3

7.4

7.3

7.206

81 .323

7.700

88.000

6.400

77.000

Ww12001 July

5/22/02 11:07 AM

Date

7.1

7.2

7.3

6.8

7.1

6.4

6.9

6.8

6.8

7.3

7.2

7.4

6.9

7.3

7.4

7.1

7.2

7.4

7.3

7.4

7.5

7.6

7.5

0.088

0.363

10.000

80.000

96.000

0.088

0.363

5.652

10.000

8b.000

96.000

0.088

0.363

10.000

80.000

96.000

0.088

0.363

3.000

Average

Maximum

Minimum

DMR Support Data - 2001

Plant Effluent

Vinyl

Fecal

Residual

tBOD

TSS

Date

Chloride

Coliform

Ammonia

Phenol

Chlorine

IBOD

TSS

Flow

Load

Temp.

(ug/L)

(#/100 mL)

(mg/L)

(mg/L) (parts/MM)

(mg/I)

(gpm)

(#/day)

(F)

1-Aug

767.71

46.06

110.55

7.4

2-Aug

834.40

110.14

60.08

7.3

3-Aug

781.00

7.1

4-Aug

778.07

46.68

672.25

7.4

5-Aug

766.51

82.78

266.75

7.5

- 6-Aug

751.20

7.3

7-Aug

No Data

8-Aug

NoData

9-Aug

100

123.38

19.25

148.06

7.4

10-Aug

642.79

7.2 -

11-Aug

812.18

7.6

12-Aug

603.76

36.23

86.94

6.7

13-Aug

25 -

471.12

39.57

141.34

7.3

14-Aug

110

0.084

0.24

474.07

34.13

85.33

7.5

15-Aug

504.01

66.53

78.63

7.3

16-Aug

599.26

35.96

28.76

7.2

17-Aug

537.78

7.3

18-Aug

501.98

7.7

19-Aug

560.87

40.38

107.69

7.3

20-Aug

569.69

75.20

68.36

7.3

21-Aug

680.96

65.37

163.43

7.5

22-Aug

683.12

65.58

98.37

7.4

23-Aug

550.96

85.95

79.34

7.5

24-Aug

672.83

7.5

25-Aug

634.53

7.6

26-Aug

625.36

37.52 - 202.62

7.6

27-Aug

608.31

21.90

124.10

7.7

28-Aug

537.47

77.40

245.09

7.6

29-Aug

535.01

77.04

231.12

7.8

30-Aug

556.98

93.57

7.8

31-Aug

420.29

7.6

Average

10.000

30.000

110.000

0.084

0.240

8.762

24.571

606.400

57.862

154.618

7.428

78.379

Maximum

10.000

30.000

110.000

0.084

0.240

15.000

100.000

834.400

110.141

672.252

7.800

85.000

Minimum

10.000

30.000

110.000

0.084

0.240

3.000

4.000

123.380

19.247

28.764

6.700

72.000

* NoDataduetoPlantShutdown

5/22/02

Wwt200l

11:07

Aug

DMR Support Data

2001

Plant Effluent

Vinyl

Fecal

Residual

1BOD

TSS

Date

Chloride Coliform Ammonia

Phenol

Chlorine

tBOD

TSS

Flow

Load

Temp.

(ug/L)

(#/100 mL)

(mg/L)

(mg/L) (parts/MM)

(mg/I)

(gpm)

(#/day)

(#Iday)

(F)

1-Sep

594.99

7.6

2-Sep

533.58

44.82

128.06

7.4

3-Sep

548.92

39.52

131.74

7.5

4-Sep

516.52

49.59

61.98

7.5

5-Sep

559.53

80.57

67.14

7.5

6-Sep

578.06

69.37

215.04

7.5

7-Sep

658.01

7.5

8-Sep

725.20

7.5

9-Sep

698.70

50.31

117.38

7.5

10-Sep

578.60

41.66

62.49

7.3

11-Sep

570.18

54.74

7.3

12-Sep

583.73

77.05

84.06

7.3

13-Sep

552.36

26.51

152.45

7.4

14-Sep

472.39

7.4

15-Sep

458.39

7.4

16-Sep

594.80

107.06

256.95

7.2

17-Sep

150

0.1

0.7

547.29

91.94

216.73

7.4

18-Sep

537.03

96.67

141.78

7.4

19-Sep

556.23

106.80

246.97

7.3

20-Sep

531.63

82.93

197.77

7.5

21-Sep

618.67

7.4

22-Sep

765.58

7.4

23-Sep

668.17

56.13

352.79

7.6

24-Sep

562.74

81.03

297.13

7.4

25-Sep

479.71

74.83

241.77

7.9

26-Sep

478.18

45.91

126.24

7.2

27-Sep

554.79

59.92

86.55

7.5

28-Sep

582.08

7.4

29-Sep

433.97

7.1

30-Sep

481.14

127.02

173.21

7.3

Average

#DIV/0!

10.000

150.000

0.100

0.700

10.571

24.333

567.372

69.732

162.522

7.420

80.133

Maximum

0.000

10.000

150.000

0.100

0.700

22.000

44.000

765.580

127.021

352.794

7.900

88.000

Minimum

0.000

10.000

150.000

0.100

0.700

4.000

8.000

433.970

26.513

54.737

7.100

70.000

Ww12001 Sep

5/22/02 11:07 AM

DMR Support Data

2001

Plant Effluent

Vinyl

Fecal

Residual

tBOD

TSS

Date

Chloride

Coliform Ammonia

Phenol

Chlorine

tBOD

TSS

Flow

Load

Temp.

(ug/L)

(#/100 mL)

(mg/L)

(mgIL) (parts/MM)

(mg/I)

(gpm)

(#Iday)

(#/day)

(F)

1-Oct

537.71

103.24

96.79

7.2

2-Oct

536.67

70.84

244.72

7.0

3-Oct

573.01

89.39

110.02

7.0

4-Oct

540.48

64.86

272.40

7.0

5-Oct

632.27

7.6

6-Oct

674.20

7.6

7-Oct

690.77

157.50

281.83

7.3

8-Oct

553.06

59.73

172.55

7.5

9-Oct

495.79

71.39

7.2

10-Oct

- 13

547.23

85.37

91.93

7.1

11-Oct

684.88

98.62

172.59

7.1

12-Oct

675.28

6.9

13-Oct

693.32

7.0

14-Oct

623.73

172.15

7.1

15-Oct

489.76

235.08

270.35

6.8

16-Oct

100

0.079

0.461

648.44

178.97

140.06

6.8

17-Oct

596.18

93.00

107.31

6.9

18-Oct

493.31

59.20

65.12

6.6

19-Oct

429.39

6.7

20-Oct

535.18

6.7

21-Oct

568.39

61.39

27.28

6.9

22-Oct

559.59

73.87

40.29

7.0

23-Oct

432.28

62.25

108.93

7.1

24-Oct

402.41

48.29

91.75

7.0

25-Oct

424.56

50.95

7.4

26-Oct

421.70

7.1

27-Oct

589.66

6.9

28-Oct

614.08

88.43

7.0

29-Oct

432.18

41.49

51.86

7.0

30-Oct

6.8

423.16

66.01

34.53

6.7

31-Oct

427.16

102.52

46.13

6.9

Average

10.000

0.000

100.000

0.079

0.461

14.304

18.643

546.640

92.806

122.147

7.035

74.968

Maximum

10.000

0.000

100.000

0.079

0.461

40.000

46.000

693.320

235.085

281.834

7.600

84.000

Minimum

10.000

0.000

100.000

0.079

0.461

8.000

4.000

402.410

41.489

27.283

6.600

63.000

Wwt200l Oct

5/22/02 11:07AM

DMR Support Data - 2001

Plant

Effluent

Vinyl

Fecal

Residual

tBOD

TSS

Date

Chloride

Coliform Ammonia

Phenol

Chlorine

tBOD

TSS

Flow

Load

Temp.

(ug/L)

(#/1 00 mL)

(mg/L)

(parts/MM)

(mgil)

(mg/I)

(gpm)

(#/day)

(4t/day)

(F)

1-Nov

477.08

51.52

34.35

6.9

2-Nov

620.56

6.9

3-Nov

523.24

7.2

4-Nov

484.02

116.16

63.89

5-Nov

462.67

111.04

55.52

7.3

6-Nov

407.17

161.24

9.77

7.3

7-Nov

436.79

115.31

57.66

7.3

8-Nov

571.82

68.62

75.48

7.2

9-Nov

536.97

7.3

10-Nov

635.73

7.1

11-Nov

542.86

52.11

32.57

7.2

12-Nov

432.28

51.87

72.62

7.4

13-Nov

464.84

55.78

128.30

7.2

14-Nov

100

0.051

0.344

516.90

105.45

111.65

7.4

15-Nov

464.14

72.41

89.11

7.5

16-Nov

474.67

7.4

17-Nov

470.73

7.1

18-Nov

449.29

75.48

70.09

7.4

19-Nov

487.48

157.94

99.45

7.4

20-Nov

547.01

229.74

144.41

7.5

21-Nov

434.63

151.25

88.66

7.3

22-Nov

315.34

136.23

87.03

23-Nov

411.74

6.9

24-Nov

457.19

6.8

25-Nov

404.78

126.29

116.58

6.9

26-Nov

305.81

62.39

102.75

6.5

27-Nov

395.98

109.29

142.55

6.8

28Nov

48634

25679

27430

29-Nov

383.46

69.02

156.45

6.8

30-Nov

462.80

6.8

Average

10.000

0.000

100.000

0.051

0.344

20.857

18.190

468.811

111.236

95.867

7.127

74.767

Maximum

10.000

0.000

100.000

0.051

0.344

44.000

47.000

635.730

256.788

274.296

7.500

81.000

Minimum

10.000

0.000

100.000

0.051

0.344

8.000

2.000

305.810

51.525

9.772

6.500

68.000

1111111. Non-Compliance

Wwt200l Nov

5/22/02 11:07 AM

DMR Support Data - 2001

Plant Effluent

Vinyl

Fecal

Residual

tBOD

TSS

Date

Chloride

Coliform Ammonia

Phenol

Chlorine

tBOD

TSS

Flow

Load

Temp.

(ug/L)

(#/100 mL)

(mg/L)

(parts/MM)

(mg/I)

(gpm)

(#/day)

(F)

1-Dec

484.51

6.7

2-Dec

482.63

133.21

399.62

7.2

3-Dec

421.99

96.21

217.75

7.1

4-Dec

454.23

109.02

218.03

7.0

5-Dec

433.10

119.54

228.68

7.0

- 80

6-Dec

445.52

128.31

160.39

7.1

7-Dec

425.00

7.3

8-Dec

463.17

7.5

9-Dec

483.96

180.03

104.54

7.3

10-Dec

487.51

99.45

140.40

7.4

11-Dec

563.61

175.85

121.74

7.1

12-Dec

587.48

303.14

359.54

7.1

13-Dec

236.34

48.21

104.93

7.9

72.

14-Dec

563.48

7.8

15-Dec

687.21

7.2

16-Dec

120

0.062

565.32

196.73

162.81

7.0

17-Dec

506.44

97.24

194.47

7.3

18-Dec

0.537

536.98

96.66

103.10

7.1

19-Dec

597.00

85.97

50.15

7.0

20-Dec

636.27

76.35

83.99

6.9

21-Dec

600.88

7.1

22-Dec

379.59

6.6

23-Dec

421.04

70.73

80.84

6.8

24-Dec

420.54

80.74

105.98

7.0

25-Dec

216.78

41.62

70.24

6.6

26-Dec

329.40

59.29

189.73

6.5

27-Dec

294.05

49.40

77.63

6.8

28-Dec

410.46

6.8

29-Dec

480.82

6.6

30-Dec

119.16

21.45

32.89

6.2

31-Dec

210.13

27.74

63.04

6.5

Average

10.000

0.000

120.000

0.062

0.537

19.364

29.364

449.826

104.404

148.658

7.016

70.387

Maximum

10.000

0.000

120.000

0.062

0.537

43.000

69.000

687.210

303.140

399.618

7.900

80.000

Minimum

10.000

0.000

120.000

0.062

0.537

10.000

7.000

119.160

21.449

32.888

6.200

55.000

Wwt200l Dec

5/22/02 11:08 AM

DRAFT

EVALUATION OF TREATMENT

ALTERNATIVES

FOR REDUCING

FINAL

EFFLUENT

AMMONIA LOAD

Prepared for:

BF GOODRICH

Henry, Illinois

Prepared by:

ECKENFELDER INC.®

227 French Landing Drive

Nashville, Tennessee 37228

(615) 255-2288

February 1997

9387.01

Q:\9387.O1\TS\TSCVR.DOC

ECKENFELDER INC?

February 18, 1997

9387.01

Mr. Dave Giffin

Health, Safety and Environmental Manager

BF Goodrich

R.R. 1, Box 15

Henry, IL 61537

RE: Evaluation of Treatment Alternatives for

Reducing Final Effluent Ammonia Load

Dear Mr. Gi.ffln:

We are pleased to submit our Draft Report, “Evaluation of Treatment Alternatives

for Reducing Final Effluent Ammonia Load.” This Report presents the background,

methods and materials, and results of our work. We will

prepare a

Final Report

that addresses your review comments.

If you have any questions or need additional information, please contact me.

Sincerely,

ECKENFELDER INC.®

~th

~t774.1

T. Houston Flippin, P.E.

Project Manager

cc: Richard K.issel, Esquire

Gardner, Carton & Douglas

Ken Willings

BF Goodrich

W. Wesley Eckenfeld.er,

Jr.,

D.Sc., P.E.

227 French Landing

Drive

Nashville, Tennessee 37228

Q:\9387.O1\TS\TSL0218.DOC

615.255.2288

FAX

615.256.8332

TABLE OF CONTENTS

PaEe No.

Letter of Transmittal

Table of Contents

List ofTables

jjj

List ofFigures

1.0 BACKGROUND

1-1

1.1

Description of Wastewater Treatment Facility and Historical

Performance

1-1

1.2

Scope of Work

1-2

2.0 METHODS AND MATERIALS

2-1

2.1

Development of Preliminary Process Design

2-1

2.1.1 Alkaline Air Stripping

2-1

2.1.2 Struvite Precipitation

2-2

2.1.3 Single-Stage Biological Nitrification of Non-PC

Wastestreams Combined with Separate Biological

Treatment of the PC Wastestream

2-4

2.1.3.1

Clarification Requirements

2-4

2.1.3.2

BOD Removal Requirements

2-5

2.1.3.3

Biotreater Tankage and Oxygenation Requirements

2-6

2.1.3.4

Alkalinity Requirements

2-6

2.1.3.5

Sludge Handling Requirements

2-6

2.1.3.6 Pretreatment Requirements

2-7

2.1.4 Biological Nitrification of Combined Wastestream

2-8

2.1.5 Breakpoint Chlorination of Secondary Clarifier Effluent

2-9

2.1.6 Ion Exchange Treatment of Final Effluent

2-9

2.2

Preliminary Cost Estimates

2-10

3.0 BATCH TREATABILITY TEST RESULTS

3-1

3.1

Alkaline Air Stripping

3-1

3.1.1 pHAdjustment

3-1

3.1.2 Ammonia Removal

3-2

3.2

Struvite Precipitation

3-2

3.3

Breakpoint Chlorination of Secondary Clarifier Effluent

3-3

3.4

Ion Exchange Treatment of Final Effluent

3-4

Q:\9387.O1\TS\TSTOC.DOC

TABLE OF CONTENTS (Continued)

Pate No.

4.0 PRELIMINARY PROCESS DESIGNAND COST ESTIMATE FOR

ALTERNATIVES

4-1

4.1

Biological Nitrification of Combined Wastestream

4-1

4.2

Alkaline Air Stripping of Secondary Clarifier Effluent

4-2

4.3

Breakpoint Chlorination of Secondary Clarifier Effluent

4-2

4.4

Comparative Analysis of Treatment Systems

4-2

Q:\9387.O

1\TS\TSTOC.DOC

LIST OF TABLES

Follows

Table No.

Title

Page No.

1-1

Summary of 1996 Wasteload

1-1

3-1

Batch Alkaline

Air Stripping Test Results

3-2

Precipitation ofStruvite from Combined Wastestream

3-2

3-3

Breakpoint Chlorination ofSecondary Clarifier Effluent

3-3

4-1

Summary of Preliminary Cost Estimate for Biological

Nitrification of Combined Wastestream

4-1

4-2

Summary ofPreliminary Cost Estimate for Alkaline Air

Stripping of Secondary Clarifier Effluent

4-2

4-3

Summary ofPreliminary Cost Estimate for Breakpoint

Chlorination of Secondary Clarifier Effluent

4-2

4-4

Effectiveness of Alternative Treatment Processes on Final

Effluent Ammonia Load Reduction

4-2

Q:\9387.O

I\TS\TSLOT.DOC

111

L!ST OF FIGURES

Follows

Figure No.

Title

Page No.

1-1

Block Flow Diagram ofWastestream Sources and WWTF

1-1

1-2

Block Flow Diagram of

Alkaline Air Stripping Treatment

Alternatives (Nos. 1, 2, and 3)

1-2

1-3

Block Flow Diagram of Struvite Precipitation Treatment

Alternative (No. 4)

1-2

1-4

Block Flow Diagram of Biological Nitrification Treatment

Alternative (No. 5)

1-2

1-5

Block Flow Diagram ofBiological Nitrification Treatment

Alternative (No. 6)

1-2

1-6

Block Flow Diagram of Breakpoint Chlorination Alternative

(No. 7)

1-2

1-7

Block Flow Diagram of Ion Exchange Treatment Alternative

(No.8)

1-2

3-1

pH Adjustment ofPC Tank Discharge

3-1

3-2

pH Adjustment of PVC Tank Discharge

3-1

3-3

pH Adjustment ofSecondary Clarifier Effluent

3-1

3-4

pH Adjustment of Combined Wastestream

3-3

3-5

Clinoptiolite Treatment ofFinal Effluent for Ammonia

Reduction

Q:\9387.O1\TS\T$LOF.DOC

1.0 BACKGROUND

1.1 DESCRIPTION OF WASTEWATER TREATMENT FACILITY AND

HISTORICAL PERFORMANCE

BF Goodrich Company (BFG) and The Geon Company (Geon) own and operate

adjoining manufacturing facilities in Henry, Illinois. Wastewaters from the BFG

manufacturing processes discharge to either the Polymer & Chemicals (PC)

equalization tank or the Cure Rite® (C-18) equalization tank. Wastewaters from

the Geon manufacturing processes and sidestreams from the combined wastewater

treatment facility (WWTF) discharge to the Polyvinyl Chloride (PVC) equalization

tank. Site-wide stormwater runoff and sidestreams from the boiler house and water

treatment facility (WTF) discharge to a holding pond (Pond). Wastewaters from the

PC Tank, C- 18 Tank, and PVC Tank are fed at controlled rates to the WWTF along

with discharge from a groundwater recovery well (Well No. 3). Pond water is

discharged at a controlled rate to either the WWTF or through a sand filter into the

channel transporting WWTF effluent to the Illinois

River. The

WWTF consists of

chemical coagulation, sedimentation, activated sludge treatment, and sand

ifitration prior to discharge to the Illinois River. The discharge is regulated by a

NPDES permit issued by the Illinois Environmental Protection Agency (IEPA). A

summary of the 1996 wasteloads is presented in Table 1-1. A block flow diagram of

the wastestream sources and WWTF is presented in Figure 1-1.

The

WWTF has historically provided greater than 95 percent BOD reduction while

discharging an effluent ammonia-nitrogen concentration of 23 to 120 mg/L.’ The

IEPA has proposed a monthly average effluent limit of 3 mg/L for ammonia (as N).

A previous study conducted by ECKENFELDER INC. in 1995 indicated that single-

stage biological nitrification was not feasible in the existing activated sludge system

due to inhibition of nitrifying bacteria caused by the PC Tank discharge. The

PC Tank discharge is also inhibitory to BOD removal by the activated sludge

process. This effect has been controlled by adjusting its flow contribution to less

than 23 percent of the combined wastestream flow and its TCOD contribution to

1,100 mg/L in the combined wastestream.

1Based on once

monthly analysis of effluent NH3-N concentrations during the period of

January 1994

through December

1996.

Q:\0387.O1\TS\TSSQ1.DOC

-~-~

~.——‘

.,~...—

—..-......

0’:~

TABLE

1-1

SUMMARY OF 1996 WASTELOAD

Wastestream

Flow Rate

(gpm)

SCOD (lb/day)b

TKN (lb/day)

NH3-N (lb/day)

Averagea

Peak

Average

Peak

Average

Peak

Average

Peak

PVC

Tank

Discharge

401

499

2,650

4,330

335

485

215

300

Tank

Discharge

107

150

8,280

10,840

360

525

C-18

Tank

Discharge

1,320

2,940

150

Pond Water & Well No. 3

Discharges

105

Total Wastestream

560

670

12,300

14,500

757

1,165

281

427

aThe average 1995 flow rates for the PVC Tank, PC Tank, C-18 Tank, and Pond Water &

Well

No. 3 Discharges were 414, 107, 7, and

gpm,

respectively.

bSoluble COD defined as COD of ifitrate following 1.5

~tmfiltration.

Q:\9387.OIVFS\TSTOIOI.DOC

P~e I of I

q.~9387.Ol~ts\tsf13lOI

ppt

BLOCK FLOW DIAGRAM OF WASTESTREAM

SOURCES

AND

WWTF

ECKENFELDER I

Nashville,

Tennessee

Mahwah. New Jersey

INC.

Greenville. south Cerolina

Geon

~ction~4~~k

FIGURE

1-1

1.2 SCOPE OF WORK

BF Goodrich retained ECKENFELDER INC. to develop preliminary process designs

and budget level cost estimates for alternative treatment processes which would

reduce the ammonia load in the final effluent from the WWTF. The alternatives

considered are summarized below and illustrated in Figures 1-2 through 1-7.

• Alternative No. 1

Alkaline air stripping ofPC Tank contents

• Alternative No. 2

Alkaline air stripping ofPVC Tank contents

• Alternative No. 3

Alkaline air stripping of secondary clarifier effluent

• Alternative No. 4

Struvite (NH4MgPO4) precipitation from combined

wastestream influent

• Alternative No. 5

Single-stage biological nitrification of non-PC wastestreams

combined with separate biological treatment of the PC Tank discharge.

• Alternative No. 6

Biological nitrification ofcombined influent wastestream

• Alternative No. 7

Breakpoint chlorination of secondary clarifier effluent

• Alternative No. 8

Ion exchange

treatment of final effluent

Preliminary process designs were developed for each Alternative based on batch

treatability testing and wastestream characterization data gathered in previous

studies by ECKENFELDER INC., and additional treatability testing and

wastestream characterization data presented in this report. Average and maximum

daily effluent ammonia loads were projected under each alternative for the 1996

wasteload.

Preliminary cost estimates for the treatment alternatives were

developed using

preliminary process designs and information provided by vendors,

BF Goodrich, a cost estimating software program,. and ECKENFELDER INC.

The methods, results, conclusions, and recommendations of this evaluation are

presented in the following sections.

Q:\9387.O

1\T5\T5SO

I.DOC

Air

ALTERNATIVE NO.1 - ALKALINE AIR STRIPPING OF PC TANK CONTENTS

pvc Wastestreams) ~

~~0~~_____

~De1oarner

~iiIIXii)—~-

Sulfuric Acid

Caustic Soda

—D;;e...

To Illinois River

3To Primary Treatment)

FIGURE 1-2

BLOCK FLOW DIAGRAM OF ALKALINE

AIR STRIPPING TREATMENT ALTERNATIVES

(Nos•

2, and 3)

ECKENFELDER

INC.

Nashville,

Tennessee

Mahwah, New Jersey

Greenville,

South Carolina

PVC Tank

‘-

lulidly I pedUI,eII~,’

ALTERNATIVE NO.2-ALKALINE AIR STRIPPING OF PVC TANK CONTENTS

Secondary Clarifier

/ Effluent

/ ~

~ Caustic

ALTERNATIVE NO.3-ALKALINE AIR STRIPPING OF SECONDARY CLARIFIER EFFLUENT

Existing Equipment

New Equipment

q:\9387.O1’.ts\tsfOlO2.ppt

I Existing Equipment

jii

New Equipment

FIGURE 1-3

BLOCK FLOW DIAGRAM OF

STRUVITE

PRECIPITATION TREATMENT ALTERNATIVE

(No.4)

ECKENFELDER

INC.

Nashville, Tennessee

Mahwah, New Jersey

Greenville, South Carolina

NOTE: Existing FeCI3 Addition

would be discontinued

q’.9387.O1~Zs\tsfO1O3.ppt

I Existing Equipment

New Equipment

BLOCK FLOW DIAGRAM OF BIOLOGICAL

NITRIFICATION TREATMENTALTERNATIVE

(No.5)

ECKENFELD ER

INC.

Nashville, Tennessee

Mahwah, New Jersey

Greenville, South Carolina

FIGURE

1-4

q.~9387.O1~ls\tsfO1O4.ppt

~_00~•~00~~

—...~..

~~0~~~~00~

,0~_0...,0_...,

.00__-...0_.~..

—,.-.,00—000..

0~•_000~~_0_0~

Existing Equipment

New Equipment

\‘I Upgraded Equipmemt

FIGURE 1-5

BLOCK FLOW DIAGRAM OF BIOLOGICAL

NITRIFICATION TREATMENT ALTERNATIVE

(No.6)

ECKENFELDER

INC.

Nashville, Tennessee

Mahwah, New Jersey

q:t9387.O1~s~fOlO5.ppt

Greenville, South Carolina

I Existing Equipment

I ~__~_i

New Equipment

FIGURE 1-6

BLOCK FLOW DIAGRAM OF BREAKPOINT

CHLORINATION ALTERNATIVE

(No.7)

ECKENFELDER

INC.

Nashville, Tennessee

Mahwah, New

Jersey

Greenville, South Carolina

q~9387.O1~Ls\tstO1O6

ppt

VSecondary Clarifier~\ ~

Effluent

Regenerant

________

I Existing Equipment

ETTIII

New Equipment

FIGURE

1-7

BLOCK FLOW DIAGRAM OF ION EXCHANGE

TREATMENT ALTERNATIVE

(No.8)

ECKENFELDER

Nashville,

Tennessee

Mahwah, New Jersey

INC.

Greenville, South Carolina

Filtration

Ion Exchange

Treatment

q:’~9367.O1~ls’IsfO1O7.ppt

2.0 METHODS AND MATERIALS

2.1

DEVELOPMENT OF PRELIMINARY PROCESS DESIGN

Preliminary process designs were developed based on treatment of the 1996

wasteload as described in Table 1-1. Treatment process sizing and performance

assessment assumed complete biohydrolysis of the influent TKN load to ammonia

through the activated sludge process, an influent TCBODITCOD ratio of 0.30 lb/lb,

and a TCBOD removal requirement of 0.035 lb NH3-N/lb TCBOD.

These

assumptions yielded average and peak effluent ammonia loads for 1996 of

628 lb/day and 1,013 lb/day, respectively.

The BF Goodrich WWTF has historically exhibited 50 percent to 100 percent

biohydrolysis ofthe influent TKN load. It is anticipated that this same variation in

biohydrolysis ofthe influent TKN load occurred in 1996.

2.1.1 Alkaline

Air

Stripping

“Grab type” samples of the PC Tank discharge, PVC Tank discharge, and Secondary

Clarifier Effluent were collected on April 22,

1996 and shipped

via overnight

delivery to ECKENFELDER INC.’s Laboratory in Nashville, Tennessee.

The

samples were analyzed for pH, total suspended solids (TSS), and ammonia-nitrogen

(NH3-N). Following these analyses, the samples were refrigerated until used for

subsequent testing.

The pH of the PC Tank discharge, PVC Tank discharge, and Secondary Clarifier

effluent were 12.5 s.u., 8.7 s.u., and 7.2 s.u., respectively. Alkaline air stripping of

ammonia requires an operating pH of 10 s.u. to be effective.2 The BF Goodrich

activated sludge system requires an influent pH of 9.0 to 9.5 s.u. to ensure an

operating pH of 6.5 to 7.5 s.u. The BF Goodrich effluent permit requires a discharge

pH of 6.0 to 9.0 s.u. Consequently, the pH of PVC Tank discharge and Secondary

Clarifier effluent required an increase prior to stripping and all three wastestreams

required a pH reduction following stripping. The caustic soda (NaOH) and sulfuric

2”Process Design Manual for Nitrogen Control,” USEPATechnology Transfer, Washington,

DC (1975).

Q:\9387.O1\TS\T3502.DoC

2 1

acid (H2S04) addition requirements to achieve the necessary pH adjustments were

determined by development oftitration curves presented in Section 3.1.

Samples of the PC Tank and PVC Tank discharges contained greater than 500 mg/L

TSS which would foul a packed tower air stripper or horizontal tray stripper.

Consequently, these wastestreams were considered fcr stripping by diffused

aeration. Due to the poor efficiency of the diffused air stripping process and the

large flow rates of these wastestreams, only stripping within the existing tankage

was considered. Construction of additional tankage to achieve improved ammonia

removal would not be cost effective. Conventional packed tower air stripping of the

secondary clarifier effluent was considered since this is the most cost-effective and

demonstrated stripping technology. The preliminary process designs of the diffused

aeration stripping processes were based on modeling by ECKENFELDER INC. The

preliminary process design of the packed tower air stripping process was developed

based

Samples

on modeling

of the PC

Tank

Deltadischarge,Cooling Towers.PVC

Tank3

discharge, and Secondary Clarifier

Effluent were subjected to batch diffused aeration stripping tests to confirm the

ammonia in these wastestreams was “strippable.” An aliquot (1,300 mL) of each

sample was placed in a 2,000-mL graduated cylinder and aerated using a 1-inch

porous stone diffuser at a rate of 1,000 cfm/1,000 cu ft (maximum design aeration

rate) and pH 10 s.u. The NH3-N concentration was monitored with time during

these tests and water lost to evaporation was made up with distified water. Results

of these tests indicated the ammonia was strippable and progressed at a rate

consistent with conventional theory (i.e., Henry’s Constant).

In all cases, it was assumed that the off-gas would not require collection and

treatment.

2.1.2 Struvite Precipitation

Grab type samples of the PC, PVC,. and C-18 Tank discharges were collected on

April 22, 1996 and shipped via overnight delivery to ECKENFELDER INC.’s

3Keith Kay of Delta Cooling Towers, Inc., 134 Clinton Road, P.O. Box 952, Fairfield, New

Jersey 07004,

(201) 227-0300.

Q:\9387.O1\’FSVFSSOS.tiOC

Laboratory in Nashville, Tennessee. The samples were blended to form combined

wastestreams to simulate the average combined influent flow rate ratio for 1995

and a combined influent containing the peak 1996 PC Tank discharge COD load

(see Table 1-1). The combined 1995 influent was analyzed for NH3-N and subjected

to three Batteries (I, II, and III) of batch treatability tests to evaluate NH3-N

removal by precipitation as struvite (NH4MgPO4).

The combined peak 1996

influent was analyzed for NH3-N and subjected to Battery IV batch treatability

tests to demonstrate the impact of PC Tank discharge contribution on test results.

Battery I, II, III, and IV batch treatability tests consisted of placing aliquots

(500 mL) of the wastestream in 1,000-mL beakers. The beaker contents were

rapidly mixed, spiked with a magnesium sulfate solution containing 10,000 mg/L

Mg~H, spiked with a phosphoric acid solution containing 10,000 mg/L P04-P,

adjusted to the desired pH using NaOH, and mixed for 60 minutes. Samples were

removed after 60 minutes, subjected to 0.45 ~imfiltration, and the filtrate analyzed

for NH3-N.

Battery I tests evaluated the impact of pH on ammonia removal while maintaining

a Mg++ dose equal to 118 percent of the stoichiometric amount required to

precipitate struvite (2.0 mg Mg~~per mg N versus 1.7 mg Mg~per mg N) and a

P04-P dose equal to 168 percent of the stoichiometric amount required to

precipitate struvite (3.7 mg P per mg N versus 2.2 mg P per mg N). Work by Arnold

and Wolfram4 indicated that excess P addition increased NH3-N removal while

excess Mg~addition did not improve NH3-N removal. Battery II tests evaluated

the impact of increased Mg~addition (3.9 mg Mg~/mgN) and P04-P addition

(7.3 mg P/mg N) on NH3-N removal while operating at a perceived optimum pH (12

to 12.5 s.u.). Battery III tests evaluated whether increased Mg~addition (2.0, 2.9,

and

3.9 mg Mg~/mgN) at a pH 9.5 s.u. would provide comparable

NH3-N

reduction to that experienced at pH of 12 s.u. and 2.0 mg Mg~/mgN while

maintaining a constant P04-P addition of 3.7 mg P/mg N. Lastly, Battery IV tests

evaluated the effect of operating pH on NH3-N

removal from the combined peak

1996 influent while providing the Mg~addition (3.9 mg Mg~~/mgN) and P04-P

addition (3.7 mg P/mg N) deemed most favorable from Battery I, II, and III tests.

4”Ammonia Removal and Recovery from Fertilizer Complex Wastewaters,” D.W. Arnold and

W.E. Wolfram,

Proceedings of 30th Industrial Waste Conference,

Purdue University, 1975.

Q:\0387.O 1\TS\TSSO2.DOC

In full-scale application, magnesium would be added as Sul-PO-Mag,5 and

phosphorus would be added as 85 percent (by weight, w/w) phosphoric acid

(H3P04). Primary clarifier effluent pH would continue to be maintained by addition

of 50 percent (w/w) NaOH.

2.1.3

Single-Stage Biological Nitrification of Non-PC Wastestreams

Combined with Separate Biological Treatment of the PC Wastestream

Previous work by ECKENPELDER INC. in 1995 indicated that all wastestreams at

the BF Goodrich Henry Plant (excluding the PC Tank discharge) will support

biological nitrification at their respective 1995 loads and peak 1996 loads. Further

work in 1996 and 1997 indicated that the combined wastestream was treatable for

BOD removal under the peak 1996 loads. Consequently, one alternative for effluent

ammonia reduction would be first-stage nitrification of the non-PC wastestreams

followed by a second-stage biological treatment of the PC Tank discharge after

dilution with effluent from the first-stage reactor.

Development of the preliminary process design for this treatment alternative is

described in the following subsections.

2.1.3.1 Clarification Requirements.

The peak solids loading rate (SLR) on the

secondary clarifier which the BF Goodrich WWTF has operated successfully for

weeks at a time is 29 lb MLSS/day sq ft calculated from Equation (2-1). This was

considered to be the peak allowable SLR in sizing clarification area for first-stage

and second-stage biological treatment processes.

(Qrn

Q~)

8.34

MLSS

2 1

SLR-

(-)

where:

SLR

solids loading rate, lb/day sq ft

= 29

lb/daysq ft (peak)

5Sul-PO-Mag

(11

percent w/w Mg), distributed by IMC Global, One Nelson C. White

Parkway, Mundelein, Illinois 60060, (847) 970-3000.

Qf\9387.OI

\TS\TSSO2.DOC

2-4

peak influent flow rate, MGD

Qp~

peak return activated sludge flow rate, MGD

MLSS

mixed liquor suspended solids concentration in biotreater, mg/L

clarification area, sq ft

2,826 sq ft for existing secondary clarifier

2.1.3.2

BOD Removal Requirements.

The required operating MLVSS

concentration for first-stage and second-stage BOD removal was calculated from

Equation (2-2)

So (So

Se)

XVHRT

KSe

(2-2)

where:

biotreater influent total carbonaceous biochemical oxygen

demand (TCBOD) concentration, mg/L

assumed equal to 0.30 x influent soluble chemical oxygen

demand (SCOD) concentration, mg/L

final effluent SCBOD concentration, mgTL

biomass concentration in biotreaters, mg/L MLVSS

assumed equal to 0.7 x MLSS concentration

HRT =

hydraulic residence time in biotreaters, days

CBOD removal rate constant, 5.2 day-i at the winter mixed liquor

temperature of 27°Cbased on 1996 treatability data

The primary clarifier effluent BOD load (S0 for first stage) was calculated by

multiplying the non-PC wastestream SCOD load (4,020 lb/day average and

7,320 lb/day peak) by the 1995 observed ratio of 0.30 lb TCBOD/Ib TCOD for these

wastestreams. The second stage BOD load was calculated by multiplying the PC

wastestream SCOD load (8,280 lb/day average and 10,840 lb/day peak) by the 1995

observed ratio of 0.30 lb TCBOD/1b TCOD. Lastly, the required HRT while

operating at the peak MLSS defined in Equation (2-1) was calculated based on

discharging effluent filtered BOD concentrations (Se) of 16 mg/L (monthly average)

and 36 mg/L (daily maximum) to comply with the monthly average and daily

maximum permit limits for effluent BOD of 20 mg/L

and 40

mg/L, respectively.

Q:\9387.O1\TS\T5302.DOC

This assumes that the filter effluent TSS concentration is 16 mg/L and exhibits a

BOD contribution of0.25 mg TCBOD/mg TSS.

2.1.3.3

Biotreater Tankage and Oxygenation Requirements.

Oxygen

requirements for first-stage and second-stage treatment were calculated based on

observed

1996

consumption

of 0.4 lb O2flb TCOD

applied

plus

4.6 lb 0211b NH3-N removed through nitrification. The existing aeration system is

capable of transferring 4,310 lb 02/day at a 2 mg/L dissolved oxygen (DO)

concentration and 31°Cand 5,050 lb On/day at a 1 mg/L DO concentration and 3 1°C.

Additional oxygen requirements beyond this capacity will be provided by addition of

biotreater tankage which is equally oxygenated since this oxygenation rate is within

14 percent of the maximum achievable with the existing diffuser type and sidewall

2.1.3.4

depth.6

Alkalinity Requirements.

Approximately 7.1 mg total alkalinity (as

CaCO3) is consumed per mg NH3-N removed during biological nitrification.

BF Goodrich currently adds NaOH to the combined influent wastestream to

maintain a minimum effluent pH of 6.5 s.u. However, quicklime rather than NaOH

would be added to the primary clarifier effluent to support the alkalinity demands

of biological nitrification due to its lower cost ($40 vs $560 per ton of alkalinity

added).

2.1.3.5

Sludge Handling Requirements.

An additional same-sized filter press

(75 cu ft) is currently needed at the BF Goodrich-Henry, Illinois Plant. This need

will become more acute with~the increased sludge production associated with

biological nitrification.

The required operating MLVSS concentration for nitrification was calculated using

Equations (2-3) and (2-4). The MLVSS calculated in Equation (2-4) was used to

calculate the clarification

area required in

first-stage treatment, assuming a

0.70 mg MLVSS/mg MLSS.

6GregWendzicki ofRoediger Pittsburgh, Inc., 3812 Route 8, Allison Park, PA 15101,

412-487-6010.

Q:\9387.O1\TS\TSSO2.DOC

2.6

(2-3)

where:

~max

maximum nitrification rate which can be achieved treating the

specific wastestream, 0.25 mg NH3-N/mg MLVSSnit~ers•day at

27°Cbased on 1997 treatability data

MCRT

mean cell residence time, days

nitrifying biomass net yield, assumed 0.1 m MLVSS~t~ifier5/mg

NH3-N oxidized

MCRT

(a (CODp)

bXdXv

fSi

Y(NH3.Np))

(2-4)

where:

heterotrophic biomass

growth yield,

0.30 mg

MLVSS/mg CODR based on 1996 treatabifity data

CODR

COD removal through activated sludge system,

mg/day

endogenous

decay

term,

assumed

0.15 mg

MLVSS/mg degradable MLVSS day at winter mixed

liquor temperature of 27°C

fraction of MLVSS which is degradable, assumed

equal to 0.8/(l

0.2 b MCRT), dimensionless

MLVSS mass in biotreaters, mg

fraction of primary clarifier effluent VSS which is

non-degradable, assumed 0.5 mg/mg

mass loading of primary clarifier effluent VSS

assuming a 30 mg/L concentration, mg/day

NH3-NR

NH3-N removed through activated sludge system,

mg/day

2.1.3.6 Pretreatment Requirements.

The preliminary process design for the

PC Tank discharge pretreatment system was developed based on batch treatability

testing. Quicklime (CaO) and sulfuric acid (H2S04) addition rates were based on a

Q:\9387.O1\TS\TSSO2.DOC

titration curve developed for the wastestream. Rapid mix and sedimentation times

were assumed to be 3 minutes and 60 minutes, respectively. Sludge quantities were

estimated based on treatabiiity data. Filter press dewatering was selected for

dewatering of the underfiow due to its demonstrated performance at the

BF Goodrich WWTF.

2.1.4 Biological Nitrification of Combined Wastestream

Previous work by ECKENFELDER INC. indicated that all non-PC Tank discharges

will support biological nitrification at their respective peak 1996 loads. Further

work indicated the PC Tank discharge would also support nitrification if pretreated

by precipitation by pH 2 and limited to a 1,000 mg/L TCOD contribution (based on

its unpretreated TCOD concentration) in the feed. Consequently, one alternative

for effluent ammonia reduction would be pretreatment of the PC Tank discharge

followed by river water addition and combined single-stage nitrification with

non-PC wastestreams. The required combined wastestream flow rate would be

900 gpm based on the 1,000 mgIL contribution limit

and peak

PC Tank discharge of

10,800 lb/day SCOD.

The required non-PC wastestream flow rate would be

750 gpm

(900

gpm

150

gpm). The available non-PC wastestream average flow rate

is 453 gpm. Consequently, a river water supply system would be installed which

would be capable of providing 297 gpm (750

453

gpm). Work completed in 1997

indicated that partial biological nitrification (?40 percent reduction in effluent

NH3-N) could be achieved in the absence of river water addition. However, river

water addition was included to maximize nitrification potential.

The same calculations described in Section 2.1.3 were used to evaluate the upgrade

measures required for oxygenation, biotreater tankage, and secondary clarification.

Secondary clarification was also limited to the peak hydraulic loading rate

sustained in 1996 (350 gpdlsq ft) due to the susceptibility of the clarifier to floc

carryover. Sand ifitration requirements were based on a peak solids loading rate of

1.0 lb TSS/day•sq ft and a peak secondary clarifier effluent TSS concentration of

50 mg/L. Same-sized secondary clarifier (60-ft diameter) and sand filter (9 ft x

24 ft) units were provided as needed.

Q:\9387.O1\TS\T5502.DOC

2.1.5 Breakpoint Chlorination of Secondary Clarifier Effluent

A grab type sample of the Secondary Clarifier effluent was collected on April 22,

1996 and shipped via overnight delivery to ECKENFELDER INC.’s Laboratory in

Nashville, Tennessee. The sample was analyzed for NH3-N and subjected to four

Batteries (I, II, III, and IV) of batch treatability tests. These tests consisted of

placing 500-mL aliquots in 1,000-mL beakers. The beaker contents were rapidly

mixed, spiked with a sodium hypochlorite solution (10,000 mg/L Cl2), adjusted to

the desired pH of 6.5 to 7.2 s.u. using H2S04, and mixed for a given contact time.

Samples were removed and analyzed for free available chlorine (FAC) and NH3-N.

The LTSEPA Nitrogen Control Manual suggests that the optimum pH for breakpoint

chlorinatior~is 6.5 s.u., and the BF Goodrich final effluent typically exhibits a pH of

7.2 s.u.

Battery I testing evaluated the impact of chlorine dose (0, 100, 300, and 400 mg/L

FAC) on residual NH3-N concentrations at a constant reaction pH of 6.5 s.u. and

reaction time of 5 minutes. Battery I testing indicated that 400 mgIL FAC was an

insufficient chlorine dose to provide significant NH3-N reduction and that a

5-minute óontact time was too brief to allow complete reaction with the FAC.

Consequently, Battery II testing evaluated the impact of a much higher chlorine

dose (1,000 mg/L and 2,000 mg/L FAC) and much longer contact time (60 minutes)

on residual NH3-N concentration at a constant reaction pH of 6.5 s.u. Battery II

testing indicated that a 1,300 ±100mg/L FAC dose completely oxidize all residual

NH3-N and that a shorter contact time could be provided. Battery III testing

evaluated the impact of contact time on FAC residual and confirmed whether a

1,300 mgIL ±100mg/L dose would provide complete oxidation of residual NH3-N at

a constant reaction pH of 6.5 s.u. Lastly, Battery IV testing evaluated whether

there was any difference in breakpoint chlorination performance at a reaction pH of

6.5 s.u. versus the typical BF Goodrich final effluent pH of 7.2 s.u.

2.1.6 Ion Exchange Treatment of Final Effluent

ECKENFELDER INC. developed a Freundlich isotherm for ammonia removal from

the final effluent using cinoptiolite, an ammonia selective ion exchange resin. This

isotherm was used to estimate resin usage to achieve specified effluent NH3-N

Q:\9387O1\TS\TSSO2.DOC.

reduction. Common design practices were used to size the ion exchange columns

(i.e., 3 gpm/sq ft).

2.2 PRELIMINARY COST ESTIMATES

Preliminary cost estimates presented in this Report were developed based on vendor

estimates, data from a commercial software program, and ECKENFELDER INC.’s

judgment. These estimates are considered accurate to within -10 percent to

+30 percent. Installed costs were based on the preliminary process design of a

system required •to treat the peak influent TKN load assuming complete

biohydrolysis of TKN to NH3-N through the activated sludge process. Annual

operation and maintenance costs also assumed complete biohydrolysis of the

influent TKN load. Present worth costs were based on a 10-year project life and an

8 percent annual interest rate.

Installed costs included construction materials and equipment plus an additional

5 percent for electrical hookup and interface instrumentation, 10 percent for

interface piping and site work, 15 percent for contingency, and 30 percent for

engineering, general contracting, permitting, and project administration.

Operation and maintenance costs considered only labor and chemical usage. The

cost of labor was assumed as $30/hour. The cost of chemicals were as follows:

$350/ton of 50 percent NaOH, $90/ton of 93 percent H2S04, $750/ton of 75 percent

H3P04, $110/ton of Sul-PO-Mag, $200/ton of chlorine gas, $70/ton of 90 percent

CaO, and $35/l00 lb of sodium bisulfite. Costs for maintenance materials and

electricity were not included in the estimate.

Q:\9387.Qi\TS\TS$02.DOC

2-10

3.0 BATCH TREATABILITY TEST RESULTS

ECKENFELDER INC. conducted batch treatability tests to assess the feasibility of

treatment alternatives discussed in Sections 1.0 and 2.0. Results from these tests

were used to develop preliminary process designs for those treatment alternatives

deemed feasible. The results are described in the following subsections.

3.1 ALKALINE AIR

STRIPPING

3.1.1 pH

Adjustment

The PC Tank discharge, PVC Tank discharge and secondary clarifier effluent

required pH adjustment to provide alkaline air stripping for ammonia removal and

subsequent discharge.

The pH adjustment requirements of these three

wastestreams are illustrated in Figures 3-1, 3-2 and 3-3 and are discussed below.

The quantity of 93 percent by weight (w/w) H2S04 required to lower the PC Tank

discharge pH (10.6 s.u.) to that required for discharge to the biotreaters (pH 9.25 ±

0.25 s.u.) is 5 lb/1,000 gallons. Consequently, the average and peak usage of

93 percent H2S04 in 1996 would have been 770 lb/day and 1,080 lb/day,

respectively.

The quantity of 50 percent, w/w, NaOH required to elevate the PVC Tank contents

from pH 8.3 s.u. to pH 10.5 for stripping is 70 lb/1,000 gallons. At the average and

peak day flow rates of 401 gpm and 499 gpm, the required daily quantities of

50 percent NaOH would have been 40,400 lb/day and 50,300 lb/day, respectively.

The quantity of 93 percent H2S04 required to lower the pH from 10.5 s.u. after

stripping to that required for discharge to the biotreaters (pH 9.25 ±0.25 s.u.) is

4 lb/1,000 gallons. The average and peak quantities of 93 percent H2S04 required

would have been 2,310 lb/day and 2,870 lb/day, respectively.

The quantity of 50 percent NaOH required to elevate the secondary clarifier effluent

from pH 7.8 s.u. to pH 10.5 is 7.5 lb/i,000 gallons. At average and peak day flow

rates of 560 gpm and 670 gpm, the daily quantities of 50 percent NaOH required

would have been 6,050 lb/day and 7,240 lb/day, respectively. The quantity of 93

percent H2S04 required to lower the pH to 8.5 s.u. to ensure effluent permit

Q:\9387.O1\TS\TS$03.DOC

3.0

4.0

pH, s.u.

7.0

8.0

9.0

10.0

11.0

Figure 3-1 pH Adjustment of PC Tank Discharge

~40

~35

.—

~25

~20

50 NaOH

• 93 H2S04

2.0

5.0

6.0

q~\93~7.OPd$\TSJ’O3.XLS

155

150

145

140

135

130

125

120

115

110

~80

~70

~65

Ci)

~55

6.0

7.0

11.0

12.0

pH, s.u.

Figure 3-2 pH Adjustment of PVC Tank Discharge

8.0

9.0

10.0

0 50

NaOH

• 93H2S04

q:\9387.OI’.u\TSFO3.XLS

________________

—

‘-4

—9

.—

-‘I

C,7

5.0

6.0

10.0

11.0

12.0

pH, su.

Figure 3-3 pH Adjustment of Secondary Clarifier Effluent

7.0

8.0

9.0

0 50 NaOH

• 93

H2S04

q;\93i7.OI\uVtSI’O~7~5S

compliance (~pH9.0 s.u.) would have been 3.0 lb/1,000 gallons, or 2,420 lb/day

average and 2,890 lb/day, peak.

3.1.2

Ammonia

Removal

Batch alkaline air stripping test results for the three wastestreams are presented in

Table 3-1. These results indicate that the NH3-N present in these wastestreams

can be removed through alkaline air stripping.

Modeling conducted by

ECKENFELDER INC. indicated that 80 percent (36 lb/day) of the 1996 average

NH3-N load discharged from the PC Tank could be removed by in situ aeration of

the Tank contents at pH 10.6 and a rate of 100 cfm/1,000 cu ft.

Likewise,

60 percent (129 lb/day) of the 1996 average i.., 3-N load discharged from the PVC

Tank could be removed by aerating the Tank contents at this same rate and at a pH

of 10.5 s.u. These removal rates are ~21 percent of the 1996 average final effluent

NH3-N load of 628 lb/day assuming complete biohydrolysis of the influent TKN.

The low removals are due to the fact that the average influent NH3-N load which

can be removed at these two equalization tanks comprises only 34 percent of the

average influent TKN load in which all TKN is assumed to be biohydrolized to

N113-N through the activated sludge process. The 1996 average final effluent

NH3-N load could be reduced by 95 percent by alkaline air stripping of the

secondary clarifier effluent. This higher rate ofremoval is possible since it has been

assumed that all of the influent TKN load is biohydrolized by the activated sludge

process and is, therefore, available for stripping from the final clarifier effluent.

The secondary clarifier effluent is the most effective application point for alkaline

air stripping.

3.2 STRUVITE PRECIPITATION

Batch treatability tests evaluated precipitation of struvite (NH4MgPO4) from the

combined wastestream. Results of these tests are summarized in Table 3-2.’ They

indicate that the combined wastestream NH3-N concentration can be reduced to

approximately 25 mg/L under two operating conditions.

• A magnesium dose of 2.0 mg Mg/mg N, phosphorus dose of 3.7 mg P/mg N

and an operating pH of 10.5 to 12.5 s.u.

Q:\9387.O1\TS\TSSO3.DOC

TABLE

3-1

BATCH

ALKALINE AIR

STRIPPINGTEST RESULTS

Wastestream

Time of Aeration at

100 cfmll,000 Cu ft

(days)

Reaction pH

(s.u.)

NH3.N

Residual

(mg/L)

NH3.N

Removala

(lb/day)

PC Tank Discharge

0.1

1.0

2.0

3.0

7.0

12.5

12.5

12.5

12.5

PVC Tank Discharge

1.0

2.0

6.0

10.0

120

210

Secondary Clarifier Effluent

1.0

2.0

3.0

6.0

10.0

100

200

380

480

630

aBased on average 1996 flow rates for PC Tank discharge, PVC Tank discharge, and final effluent of 107

gjm,

401 gpm, and 560 gpm, respectively.

Q~’9387.O1\TS\TSTO3O1.DOC

Page 1 of 1

TABLE

3-2

PRECIPITATION OF STRUVITE FROM COMBINED WASTESTREAM

Test

Magnesium Addition

Phosphorus Addition

NaOH Addition

Reaction

Filtered

NH3-N

Battery

Doseb

Dose

Dosec

Doseb

Dose

Dosec

Dose

Dosec

Removaic

No.a

()

(mg/L as Mg)

(lb/day)

()

(mg/L

as P)

(lb/day)

(meq/L)

(lb/day)

(s.u.)

(mgIL)

(lb/day)

1995

Wastestream

10.0

114

4,860

166

150

3,730

8.0

114

4,860

166

150

3,730

2.2

1,180

8.5

114

4,860

166

150

3,730

5.8

3,130

9.0

114

4,860

166

150

3,730

10.4

5,600

9.5

114

4,860

166

150

3,730

14.6

7,860

10.0

114

4,860

166

150

3,730

10,800

10.5

113

114

4,860

166

150

3,730

11,800

11.0

114

4,860

166

150

3,730

19,900

11.5

139

114

4.860

166

150

3,730

23,200

12.0

104

114

4,860

166

150

3,730

47,900

12.5

139

229

160

9,810

333

300

7,470

31,800

12.0

104

229

160

9,810

333

300

7,470

105

56,500

12.5

139

III

114

4,860

166

150

3,730

9.4

5,060

9.5

171

120

7,380

166

150

3,730

9.6

5,170

9.5

229

160

9.810

166

150

3,730

9.6

5,170

9.5

104

Peak 1996

Wastestream

10.5

229

160

9,810

166

150

3,730

5.0

2,690

9.5

229

160

9,810

166

150

3,730

8,070

11.5

aTest Battery Nos. I, II, and III considered treatment of the 1995 average influent and Test Round No. IV considered treatment of the peak 1996 influent.

bPercent ofstoichiometric dose added.

CBased on 560

gpm

flow

rate.

Q:\9387.O1\TS\TSTOSO2 Doe

Poge

• A magnesium dose of 3.9 mg Mg/mg N, phosphorus dose of 4.1 mg P/mg N

and an operating pH of 9.5 s.u.

The second condition is less costly. It substitutes 4,950 lb/day more Sul-PO-Mag

($270/ton) for 5,630 lb/day less 50 percent NaOH ($350/ton). It also eliminates the

need for the 5 lb/1,000 gallons of 93 percent H2S04 required to lower the pH from

10.5 s.u. to 9.5 s.u. prior to discharge to the biotreaters (See Figure 3-4).

This treatment process is feasible, but would have provided only a 17 percent

reduction (105 lb/day) in the average final effluent NH3-N load projected for 1996.

This low removal rate is due to the fact that the average influent NH3-N load

comprises only 37 percent ofthe average influent TKN load and, as such, the bulk of

the potential effluent nitrogen load is not yet available for removal at this point in

the treatment system.

3.3

BREAKPOINT CHLORINATION

OF SECONDARY CLARIFIER

EFFLUENT

Batch treatability testing of breakpoint chlorination used sodium hypochlorite

(NaOCl). Sulfuric addition was required to maintain the desired reaction pH of 6.5

to 7.2 s.u. during the tests. Due to the large quantity of chlorine that would be

required, chlorine gas (and not NaOC1) would be used in the full-scale application.

Treatability testing indicated that chlorination of the Secondary Clarifier effluent

caused a net increase in alkalinity since NaOCl was used. However, a net decrease

in alkalinity would be experienced in full-scale application with chlorine gas

addition, and 12.0 lb NaOH per lb NH3-N oxidized would be required to maintain a

target pH of 6.9 ±0.3s.u. At average and peak effluent ammonia loads of 628 lb/day

and 1,013 lb/day, the average and peak addition rates of 50 percent NaOH would

have been 15,100 lb/day and 24,300 lb/day, respectively. Excess chlorine would be

quenched using 1.4 lb sodium bisulfite (NaHSO4) per lb chlorine reduced. Post

aeration would be provided downstream of NaHSO4 addition to quench residual

bisulfite.

Results of the batch treatability tests are summarized in Table 3-3. They indicated

that the secondary clarifier effluent exerted a background chlorine demand of

130 mg/L and required 7.8 mg Cl~/mgNH3-N oxidized.

This is in excellent

Q:\9387.O1\TS\’I’5503DOC

Cl)

~5o

~ 45

I-

Cl)

—

50NaOH

93 H2S04

7.0

8.0

9.0

10.0

11.0

pH, s.u.

12.0

Figure 3-4 pH Adjustment of Combined Wastestream

13.0

q:\9301OI\Is\TSFO3.XI.S

TABLE

3-3

BREAKPOINT CHLORINATION OF SECONDARY CLARIFIER EFFLUENT

Test

Chlorine Addition

Reaction

Time

FAC

Reaction

Dose

2S04

NH3-N

Battery

Dose

Dosea

Residual

Removala

No.

(mgIL)

(lb/day)

(mm)

(mgIL)

(s.u.)

(meqIL)

(mgIL)

(lb/day)

100

300

400

680

2,020

2,690

7.2

6.5

1.6

2.2

4.6

138

110

120

190

120

1,000

2,000

6,770

13,500

6.5

6.6

17.6

1.4

750

920

1,200

1,400

8,070

9,460

106

6.5

4.6

8.2

NAb

1.5

0.23

920

930

1,200

8,070

7.2

2.5

1.3

920

aBased on 560

gpm

flow rate, chlorine gas addition, and 93 percent w/w H2S04 addition.

bNot analyzed.

Q:\938701\TS\TSTOSO3DOC

Page 1 of I

agreement with the stoichiometric value of 7.6 mg Cl~/mgNH3-N oxidized.

Furthermore, the results indicated that near complete destruction of final effluent

NH3-N was

achieved at an operating pH of 6.5 s.u. to 7.2 s.u. and a 60-minute

contact time.

Breakpoint chlorination would have provided 97 percent reduction in the 1996

average final effluent NH3-N

load.

This is the best removal performance achieved

by any ofthe treatment alternatives considered.

3.4 ION EXCHANGE TREATMENT OF FINAL EFFLUENT

Batch treatability tests evaluated treatment of the secondary clarifier effluent using

cinoptiolite, an ammonia selective ion exchange resin. Results of this work are

illustrated in Figure 3-5. They indicate that greater than

50 lb of cinoptiolite

would be required to remove each 1 lb of

NH3-N at residual N113-N concentrations

less than 100 mg/L. This poor removal efficiency is presumed to be due to the large

concentration of competing cations in the effluent. The total dissolved solids

concentration of the final effluent is typically 8,500 ±1,500mg/L. This treatment

alternative would provide near complete

NH3-N

removal.

However, the

impracticality of adding and regenerating this quantity of cinoptiolite precluded

further consideration ofthis alternative.

Q:\9387.O1\TS\TSSO3.DOC

3-4

Residual

NH3-N

Concentration,

mg/L

Figure 3-5

Clinoptilolite Treatment of Final Effluent for

Ammonia

Reduction

0.1

0.01

0.001

I-

100

q:\0387.Ol\

(.i\TSFO3.XT..S

4.0 PRELIMINARY PROCESS DESIGN

AND

COST ESTIMATE FOR

ALTERNATIVES

Only three alternatives were both practicable and capable of providing greater than

a 25 percent reduction in the average effluent ammonia load (628 lb/day) and

greater than 65 percent removal in the peak effluent ammonia load (1,013 lb/day)

projected for 1996. These were, in descending order of effectiveness: Biological

nitrification of the combined wastestream, alkaline air stripping of secondary

clarifier effluent, and breakpoint chlorination of secondary clarifier effluent. Block

flow diagrams for these Alternatives were presented in Figures 1-5, 1-2, and 1-6,

respectively.

4.1 BIOLOGICAL NITRIFICATION OF COMBINED WASTESTREAM

Biological nitrification of the combined wastestream will require a pretreatment

system for the PC Tank discharge, additional biotreater tankage, and additional

aeration equipment. The required oxygenation capacity is 10,500 lb O~/dayto

satisfy the 1996 peak TCOD and TKN loads. This treatment capacity would be

satisfied by providing an additional 1.5 MG of equally oxygenated biotreater

volume.

The system would likely provide a 95 percent reduction in the average effluent

ammonia load. The effluent ammonia load associated with the peak day TKN load

(an additional 385 lb/day) could be nitrified if the load were preceded by a gradual

increase or could “pass through” if it were associated with a sudden increase.

Oxygenation and alkalinity addition capacities must, therefore, be capable of

supporting nitrification ofthe peak day TKN load.

In addition to biotreater tankage, the peak flow required to provide adequate

dilution for uninhibited nitrification is 300 gpm.

This additional flow will

necessitate a river water supply system, additional secondary clarifier, additional

sand filter, additional RAS pumping capacity, and reworking of WWTF piping. A

summary of the preliminary cost estimate for these upgrades is provided in

Table 4-1.

Q:\9387.O1\TS\T5S04.DOC

TABLE

4-1

SUMMARY OF PRELIMINARY COST ESTIMATE FOR

BIOLOGICAL NITRIFICATION OF COMBINED WASTESTREAM

Description

O&M

Installed

Cost

($)

Present

Worth

($/~)

($)a

($)

Pretreatment System

SulfuricAcid Addition System

Quicklime Addition System

2-Stage Rapid Mix Before Sedimentation

Flocculation

Sedimentation

Rapid Mix After Sedimentation

Filter Press for Sludge Dewatering

Sitework, Piping, Instrumentation, Electrical

Biological Treatment

300 gpm River Water Supply System

Additional 1.5 MG in Biotreater Tankage

Additional 6,200 lb 02/day Transfer Capacity

Additional 60 ft diameter Secondary Clarifier

Additional

9 ft x 24

ft Sand Filter

Additional 300 gpm RAS pumping capacity

Additional 75 cu ft filter press

Sitework, Piping, Instrumentation, Electrical

3,900,000

Sulfuric

Acid (4,950 lb/day of 93

H2S04)

81,300

546,000

Quicklime (4,000 lb/day of 90 CaO)

51,100

343,000

Labor (24 hr/day)

263,000

1,765,000

1,765,000

395,400

2,654,000

3,900,000

6,554,000

aCosts expressed in February 1997 dollars. Assumes 10-year project life at

percent interest and no

salvage value.

bApproximately $1,500,000 in capital and $2,000,000 in present worth would be saved if no river

water addition were provided since the river water supply system, additional secondary clarifier,

additional sand filter, and additional RAS pumping capacity would not be required.

Q:\9387.O1\TS\TSTO4O1.flOC

Page 1 of 1

4.2 ALKALINE AIR

STRIPPING

OF SECONDARY CLARIFIER EFFLUENT

Secondary clarifier effluent would discharge by gravity at a year-round temperature

of~25°Cthrough a pH adjustment step to raise the pH to 10.5 s.u. The pH adjusted

effluent would discharge to a wet-well and be pumped to packed tower air strippers.

The discharge from the air strippers would flow by gravity through pH

neutralization (reduction to pH 8.5 s.u.) and then to the existing sand filters. The

system would likely provide a 95 percent reduction in effluent ammonia load. A

summary of the preliminary cost estimate for this system is provided in Table 4-2.

4.3

BREAKPOINT

CHLORINATION OF SECONDARY CLARIFIER EFFLUENT

Secondary clarifier effluent would discharge by gravity to a completely mixed

reaction tank. Chlorine gas would be sparged into the tank and caustic soda would

be added to the tank contents to maintain a target pH of 6.9 ±0.3 s.u. Effluent

from the reaction tank would discharge into a second completely mixed reaction

tank into which sodium bisulfite would be added to quench residual chlorine (as

needed). Lastly, the effluent would discharge by gravity to a post aeration tank to

quench residual bisulfite and then to the existing sand ifiters.

This treatment system is capable of providing the greatest effluent NH3-N

reduction of the three alternatives discussed in this Section (likely a 97 percent

reduction). A summary of the preliminary cost estimate for this system is provided

in Table 4.3

4.4 COMPARATIVE ANALYSIS OF TREATMENT SYSTEMS

The projected effluent quality, reliability, and costs of the three alternative

treatment systems were compared. Results ofthis comparison are provided below.

All three treatment alternatives are capable of providing at least a 95 percent

reduction in the average effluent N113-N load. Breakpoint chlorination wifi provide

the lowest achievable effluent ammonia concentration of the three treatment

alternatives. However, effluent alkaline air stripping and breakpoint chlorination

could increase effluent aquatic toxicity due to alteration of effluent constituents

and/or an increase in effluent TDS (~1,300mg/L).

Q:\9387.O 1\TS\TSSO4.DOC

TABLE

4-2

SUMMARY OF PRELIMINARY COST ESTIMATE FOR

ALKALINE AIR

STRIPPING OF SECONDARY CLARIFIER EFFLUENT

Description

O&M

Installed

Cost

($)

Present

Worth

($/yr)

($)a

($)

Sodium Hydroxide Addition System

SulfuricAcid Addition System

2-Stage Rapid Mix before Wet Well

Wet Well and Pumping Station

Packed Tower Air Strippers

2-Stage Rapid Mix after Strippers

Piping, Instrumentation, Electrical

2,100,000

Sulfuric Acid (2,420 lb/day of 93 H2SO4)

39,800

267,000

Sodium Hydroxide (6,050 lb/day of 50 NaOH)

386,000

2,590,000

Labor (8 hr/day)

88,000

590,000

513,800

3,447,000

2,100,000

5,547,000

aCosts expressed in February

1997

dollars. Assumes 10-year project life at 8 percent interest and no

salvage value.

(~:\9387.O1\TS\TSTO4O2.DOC

Page 1 of 1

TABLE

4-3

SUMMARY OF PRELIMINARY COST ESTIMATE FOR

BREAKPOINT CHLORINATION OF SECONDARY CLARIFIER EFFLUENT

Description

O&M

Installed

Cost

($)

Present

Worth

($/yr)

($)a

(~)

Sodium Hydroxide Addition System

9,000 lb/day Chlorinator

2-Stage Reaction Tank (60 mm HRT)

Sodium Metabisulfite Addition System

Reaction Tank (15 mm HRT)

Post Aeration Tank (15 mm HRT)

Aeration System

Piping, Instrumentation, Electrical

1,700,000

Chlorine Gas (5,770 lb/day)

210,600

1,413,000

Sodium Hydroxide (15,100 lb/day of 50 NaOH)

964,500

6,472,000

Sodium Bisulfite (30 lb/day of NaHSO3)

3,800

25,000

Labor (8 hr/day)

88,000

590,000

1,266,900

8,500,000

1,700,000

10,200,000

aCosts expressed in February 1997 dollars. Assumes 10-year project life at 8 percent interest and no

salvage value.

S~5S

1S~SSS

Q:\9387.Ol\TS\T5T0403.DOC

Page 1 of I

Biological nitrification is the least reliable of the three treatment processes since it

is most susceptible to process upsets and requires the longest process recovery.

These upsets may be caused by improper pH and DO maintenance, slug loading

and/or bioinhibitory compounds present in the wastewater. Alkaline air stripping

has the next lowest reliability since its performance is affected by ambient air

temperatures, scaling of the media, and fouling of the media related to elevated

levels of effluent TSS. Breakpoint chlorination is the most reliable of the three

treatment ?.lternatives. Its effectiveness is a function of chlorine dose and operating

pH, both ofwhich are controllable.

The three alternatives have present worth costs that vary from $4,554,000 for

biological nitrification of combined wastestream without river water addition to

$10,200,000 for breakpoint chlorination (see Table 4-4). The treatment alternative

with the next lowest present worth cost was alkaline air stripping ($5,547,000). In

addition, alkaline air stripping has the lowest NH3-N removal cost ($2.55/lb NH3-N

removed).

Q:\9387.O1\TS\TSSO4.DOC

TABLE 4-4

EFFECTIVENESS OF ALTERNATIVE TREATMENT PROCESSES ON

FINAL EFFLUENT AMMONIALOAD REDUCTION

Treatment Process

Present Worth

Cost

($1,000)

Average NH3-N

Removala

(lb/day)

NH3-N Removal

Costb

($flb)

Combined Wastestream Nitrification

With River Water Addition

Without River Water Addition

6,554

4,554

595

—420

3.02

2.97

Alkaline Air Stripping of Secondary

Clarifier Effluent

5,547

595

2.55

Breakpoint Chlorination ofSecondary

Clarifier Effluent

10,200

610

4.58

aAssumes complete biohydrolysis of influent TKN load to NH3-N through the activated sludge

process.

bEased on removal during 10-year period of present worth analysis.

Q:\9387.O

1\TS\TSTO4O4.DOC

Page 1 of

BROWN

AND

CALD WELL

MEMORANDUM

TO:

Mark Latham, Esq.

JOB NO:

27-21522.001

FROM:

Houston Flippin, P.E., DEE

DATE:

May 17, 2002

SUBJECT:

Ammonia-Nitrogen Treatment Alternatiyes

Support Exhibit

Brown and Caldwell 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 data provided 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 flow schematic

is provided in Attachment A of the wastewater treatment facility (W\~VTF)provided at the Henry

Plant.

Table 1. InfluentWasteload Used In Developing Treatment Alternatives

Parameter

PVC Tank

PC

Tank C-18 Tank

Holding Pond/

Well No. 3 Waters

Total

Flowrate, gpm

Average

Peak

401

499

107

150

15

46

105

560

769

SCOD, lbs/day

Average

Peak

2,650

4,330

8,280

10,840

1,320

2,940

12,300

18,160

Estimated BOD, lbs/day

Average

Peak

795

1,300

2,485

3,250

395

880

15

3,690

5,445

TKN, lbs/day

Average

Peak

NH3-N, lbs/day

Average

Peak

295

411

87

66

3

385

571

P:\PROJ\21522\M051702 Latham.doc

Memorandum to 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

Cost Components

Annual O/M Costs in

Thousands

Treatment Alternative Number

for

910

Labor ($40/hour)

Electrical ($0.06/kwh)

Natural Gas ($0.06/therm)

Chemicals (Plant Costs)

Resin Replace. 

($35/cu

ft~

Off~siteDisposala

Maintenance Materialsb

32

0

0

32

1,794

0

0

60  8  

60  60  60

214

0000

575

642 1,028

218

788

00000

00000

105

45

60

147

242

51

14

30

1,363

226

0

0

115

60

459

0

0

22

Sub-total

Contingency (10

)

Total Annual

130

143

1,858

186

2,044

954

652 1,111

299

990

524 1,735

629

111

173

1,049 717

1,222

329

1,089 576

1,908

692

Cost of disposing of spent regenerant containing 29.7

percent by weight NH4CI (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 andAmmonia Removal for Treatment Alternatives

Components

Treatment Alternative Number

NH3-NRemoval,lbs/day

NH3-NRemoval,

Present Worth Costs

247

147

864

217

891

423

891

•

Capital

• O/M~

1.35

0.96

0.34

13.71

6.98

7.04

0.25

4.81

1.53

8.20

2.68

2.20

4.40

7.31

1.20

3.87

7.52

12.80

6.76

4.64

•

Total

2.31

14.06 14.02 5.06

9.73

4.88 11.71 5.07 20.32

11.41

Based onlO year period, 8 percent annual interest, and no salvage value.

P:\PROJ\2

522\MO51

702 Latham.doc

ATTACHMENT A

ILLUSTRATION OF AMMONIA-NITROGEN

TREATMENT ALTERNATIVES

May 17,

2002\00027\P:\PROJ\21522\ATTAcFIMENT A.doc

FIGURE 1

BLOCK FLOW DIAGRAM OF WASTESTREAM

SOURCES AND WWTF

BROWN AND

PJPROJ/21522/Fig1

C A L D

E L L

Nashville

Tennessee

Off-Gas

Treatment

Air

—

To Primary

Treatment

ALTERNATIVE NO.1 - ALKALINE AIR STRIPPING OF PC TANK CONTENTS

~~testream~-~

Caustic Soda

PVC Tank

‘~‘—

To Primary

Defoamer

Treatment

Air

Sulfuric Acid

ALTERNATIVE NO.2 - ALKALINE AIR STRIPPING OF PVC TANK CONTENTS

Off-Gas

Effluent

Acid

Pcwer

Treatment

ALTERNATIVE NO.3

ALKALINE AIR STRIPPING OF SECONDARY CLARIFIER EFFLUENT

FIGURE 2

BLOCK FLOW DIAGRAM OF ALKALINE

AIR STRIPPING TREATMENT ALTERNATIVES

Existing Equipment

(Nos. 1, 2, and 3)

New Equipment

BROWN

AND

P:/PROJ/21522iFig 2

________

C A L

L L

Nashville, Tennessee

~~nedInfluen~.—~j

pH Adjustment

‘-9i~

Coagulation

Sedimentation

To_Biotreater1~

Magnesium

To Filter_Pre~~

Phosphoric Acid

~icSod~

~nicPoIym~

NOTE: Existing FeCI3 Addition would be discontinued

‘ Existing Equipment

New Equipment

FIGURE 3

BLOCK FLOW DIAGRAM OF STRUVITE

PRECIPITATION TREATMENT ALTERNATIVE

(No.4)

BROWN

AND

Nashville, Tennessee

P:/PROJ/21522/Fig3

-‘

~-‘

L’

L, L~

Reaction

Filtration

To Illinois River

Chlorine Gas

Backwash

Caustic Soda

Existing Equipment

New Equipment

FIGURE

4

BLOCK FLOW DIAGRAM OF BREAKPOINT

CHLORINATION ALTERNATIVE

(No.5)

BROWN

AND

C A L D ~ E L L

Nashville,Tennessee

P:IPROJI21

522/Fig 4

Quicklime

C-18 Tank

PC Tank

Coagulation

“*

Sedimentation

Sulfuric Acid

Anionic Polymer

Sedimentation

Existing Equipment

New Equipment

FIGURE 5

BLOCK FLOW DIAGRAM OF NON-PC WASTESTREAM

NITRIFICATION TREATMENT ALTERNATIVE

BROWN AND

ALD WELL

(No.6)

P:IPROJ/21522/Fig 5

55~

River Water.

CTan~~

Sulfuric Acid

Coagulation

Sedimentation

Anionic Polymer

Quicklime

Existing Equipment

New Equipment

Upgraded Equipment

FIGURE 6

BLOCK FLOW DIAGRAM OF COMBINED WASTESTREAM

NITRIFICATION TREATMENT ALTERNATIVE

(No.7)

BROWN AND

CALD WELL

Dewatering

To Landfill

P:/PROJ/21522!Fig 6

Caustic

Soda

Regenerant

~~..Secondar~

CIar~~

Filtration

I—*i

Ion Exchange

——~inoisRive~-

Spent Regenerant

Off-Site Disposal

Existing Equipment

New Equipment

FIGURE 7

BLOCK FLOW DIAGRAM OF ION EXCHANGE

TREATMENT ALTERNATIVE

(No.8)

BROWN AND

C A L D W E L L

Nashville, Tennessee

P:/PROJ/21522/Fig

I~SecondarY Clari~~ ~

Filtration

I—~’ Treatment

~IinoisRive~’-

Caustic Soda

1 Existing Equipment

New Equipment

FIGURE 8

BLOCK FLOW DIAGRAM OF OZONE

TREATMENT ALTERNATIVE

(No.9)          

BROWN

AND

C A L D W E L L

Nashville, Tennessee

P:/PROJ/21522/Fig

Caustic Soda

Air

N~:~n ;..~J

Filtration

J~~linois

River

Existing

Equipment

New Equipment

FIGURE 9

BLOCK FLOW DIAGRAM OF TERTIARY

NITRIFICATION TREATMENT ALTERNATIVE

(No. 10)

BROWN

AND

C A L D ~ E L L

Nashville,Tennessee

P:/PROJ/21522/Fig

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

OF THE STATE OF

ILLINOIS

IN THE MATTER OF:

)

Petition ofNoveon, Inc.

)

ASO2-____

)

(Adjusted Standard)

for an Adjusted

Standard

from

)

HI.

Aclrn. Code 304.122

)

AFFIDAVIT

OF DAVID

E. GIFFJN

I, David E. Giffin, being duly sworn and upon

oath,

state as follows:

1 am the Health, Safety and Environmental Manager at the Noveon Henry Plant.

In that position, I have personal knowledge ofthe facts set forth in the attached

Petition for Adjusted Standard.

1-laying read the facts presentedtherein, I hereby state that to the best of my

knowledge and belief the material facts set forth therein are true and accurate.

FURTHERA~FIANTSAYETH

NOT

___________

., ~

DAVID E.

GIFF~

U~U~~L

~•~j~’

..,

NOVEON, iNC.

LESU~E

D~’~R ~

~ ~OTAI~Y

~. ~~‘(vrE

Rjjy~)is

~‘W

C~.

1i’c~i~..i

(1)au~

Of4~a~q

Notary Public

CHO1/12226804.1

)K*

TC~TP! P~F~ **