REC~1VED
CLERK’S OFFICE
BEFORE
THE
ILLINOIS POLLUTION CONTROL
BOAR)
FE~
-
~
2004
for an Adjusted Standard from
35
Iii. Adm. Code 304.122
STATE OF ILLINOIS
PoII~tj~~
Control Board
NOTICE OF FILING
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R.
Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, IL
60601
Deborah Williams
Assistant Counsel
Division ofLegal Counsel
Illinois Environmental Protection
Agency
1021 N. Grand Avenue East
Springfield, IL
62794-9276
Bradley P. Halloran
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, IL
60601
PLEASE
TAKE
NOTICE
that on
Monday, February
9,2004, we filed the attached
MOTION TO WITHDRAW
AND
SUBSTITUTE WRITTEN EXPERT TESTIMONY OF
T. HOUSTON FLIPPIN
with the Illinois Pollution Control Board, a copy ofwhich is herewith
served upon you.
Respectfully submitted,
NOVEON, INC.
Richard J. Kissel
Mark Latham
Sheila H. Deely
GARDNER CARTON &
DOUGLAS LLP
191 N. Wacker Drive
—
Suite 3700
Chicago, IL
60606
By:
fIts~e~
—
Oneo
IN ‘THE MATTER
OF:
Petition ofNoveon, Inc.
)
)
)
)
AS 02-5
)
)
THIS
FILING IS SUBMITTED ON RECYCLED PAPER
RECE~VED
CLERK’S OFFICE
BEFORE
THE
ILLINOIS POLLUTION CONTROL
BOARD
FEB
-9
2004
IN ‘THE MATTER OF:
)
STATE OF ILLINOIS
)
PoIIut~on
Control Board
Petition ofNoveon, Inc.
)
)
AS 02-5
)
for an Adjusted Standard from
)
35
Iii. Adm. Code 304.122
)
MOTION TO
WITHDRAW AND
SUBSTITUTE
WRITTEN EXPERT TESTIMONY
OF
T. HOUSTON FLIPPIN
Noveon, Inc., hereby moves to withdraw the testimony ofT. Houston Flippin that was
filedFriday, February 6,2004, and substitute the attached written testimony.
In support thereof,
Noveon states as follows:
1.
To assist in expediting the hearing on this matter, Noveon prepared written
testimony for most of its witnesses.
Testimony includes that for T. Houston Flippin, Noveon’s
expert ofthe treatability ofits wastewater.
2.
On Friday, February 6, 2004,when testimony waspre-filed, Mr. Flippin
inadvertently sent a draft version ofhis testimony.
This testimony was then mistakenly pre-filed.
3.
As soon as counsel for Noveon learned ofthe error, counsel contacted the hearing
officer to disclose the erroneous
filing, and subsequently prepared a motion as directed to correct
the filing.
4.
Noveon does not believe any prejudice will result from this correction, as Illinois
EPA waspromptly served with the corrected version oftestimony, and the pre-filed testimony
will still serve to expedite the hearing on this matter.
WHEREFORE, Noveon hereby moves to withdraw and substitute the attachedtestimony
ofT. Houston Flippin.
Respectfully submitted,
NOVEON, INC.
By:
/~4~
iW~1~ç~
OneofIts Atto
eys
Richard J. Kissel
Mark Latham
Sheila
H. Deely
GARDNER CARTON & DOUGLAS LLP
191
N.
Wacker
-
Suite 3700
Chicago, IL 60606
CH02122292356.1
CERTIFICATE OF SERVICE
The undersigned certifies that a copy ofthe foregoing Notice ofFiling and
MOTION TO
SU)STITUTE
WRITTEN EXPERT TESTIMONY
OF T. HOUSTON FLIPPIN
was filed
by hand delivery with the Clerk ofthe Illinois Pollution Control Board and
served upon the
parties to whom said Notice is directed by
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, IL
60601
(personal delivery)
Deborah Williams
Assistant Counsel
Division ofLegal Counsel
Illinois Environmental Protection
Agency
1021 N. Grand Avenue East
Springfield, IL
62794-9276
(first class mail
and electronic
delivery)
Bradley P. Halloran
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, IL
60601
(personal delivery)
on Monday, February
9, 2004.
CHO2/22292364.1
Petition ofNoveon, Inc. For An Adjusted
Standard
NPDES Adjusted From 35 ILL
ADM. Code
Standard
304.122, B 02-5
And
Noveon, Inc.v. Illinois Protection
Agency,
PCB
91-17
Written Testimony of
T. Houston
Flippin
as wastewatertreatment
expert
representing Noveon, Inc. in
this
proceeding.
Introduction
and Experience of
T. Houston
Flippin
as Wastewater Treatment
Expert
Representing Noveon Inc.
My
name
is Thomas
Houston Flippin. I
was retained by Noveon, Inc in December
1989 to provide
wastewater treatment consulting services and
have continued to provide such services for theiast 14
years.
During this
entire
time
period, I have served as lead process engineer on all Noveon-Henry
Plant matters in which my firm Brown
and
Caidwell has beeninvolved. My firm was previously
known as Eckenfelder Inc and was acquired by Brown and Caidwell in 1998.
I received
two
degrees from Vanderbilt University. I received my Bachelor of EngineeringDegree in
Civil and Environmental Engineeringin 1982 and my Master of Science Degree in Environmental
and
WaterResources Engineering in 1984.
I immediately went to work for
AWARE
Incorporated in 1984 and have remained with
the.
same
company for the last 20 years in progressively more responsible positions (from project engineer to
project manager to
principal
engineer) in the area of wastewater engineering (see Exhibit A for
resume documenting
this
experience).
My firm has changed names twice. In 1989, we renamed
ourselves Eckenfelder
Incorporated to honor Wes Eckenfelder
our
Chairman Emeritus who is
still
with
us today. Much ofwhat I have learned has been under Dr. Eckenfelder as agraduate student
and as a co-worker.
During my career, I have personally conducted treatment (treatability) testing of
industrial
wastewaters
and
contaminated groundwaters
and
developed treatment process design criteria from
lof 32
test
data. I have provided troubleshooting or optimization services
forwastewater treatment
facilities (WWTFs) and
conducted waste minimization studies.
I have also overseen the work
described above, designed wastewater andcontaminated groundwater treatment processes, assisted
in effluent permit negotiations, supported expert testimony preparation and trained treatment plant
operators. I currently serve as lead process engineer on more technically challenging projects and to
train other engineers within the firm.
I am alicensed professional engineer in the states of Illinois,
Michigan,
Kentucky, and Tennessee. I
also am certified as a Diplomat in the American
Academy of
Environmental Engineers in the
specialty area ofwater supply and wastewater. This
certification is held
by less than 1300 people in
the United States and requires stringent peer reviewand testing to acquire.
I have published 16 technical papers of which 7 are directly relatedto
the Noveon-I-Ienry Plant’s
issues and have provided material for I textbook (Activated Sludge Treatment of Industrial
Wastewaters,John L. Musterman andW. Wesley Eckenfelder, Technomic Publishing Company,
1995). I also provided the technical review of a chapter from another textbook (“Granular Carbon
Adsorptionof Toxics” from Toxicity Reduction in Industrial Effluents, Perry W. Lankford andW.
WesleyEckenfelder, Van Nostrand Reinhold,
1992).
I have served as in instructor in numerous workshops including the following
•
“Clarifier Operation and Maintenance” sponsored by Mississippi Water Pollution Control
Operators’ Association in 1997;
•
“Aerobic Biological Treatment” sponsored by Tennessee State University in 1997, 1998, and
1999;
•
“Activated Sludge Treatment” sponsored by Brown and Caidwell and attended by more than
10 industries during each offering in November 1999, March 2000, May 2001, November
2002, andNovember 2003; and
2 of32
•
‘Wastewater Strategies for Industrial Compliance: Gulf Coast Issues andSolutions”
sponsored by Tulatie University andLouisiana Chemical Association
in December 2003.
Specific Design Experience Related to this
Petition
I have developed
the process design for the
following biological
nithflcation facilities. Each of these
are fullyoperational today and
meeting permit compliance.
•
Ciba Specialties, McIntosh, AL
•
City ofSpringfield, MA
•
City of Forest, MS
•
Globe Manufacturing Company, Gastonia, NC
I have provided
optimization assistance for the following biological nitrification facilities. Each of
these are fullyoperational today and meeting permit compliance.
•
American Proteins, Cummings, GA
•
International Specialty Products, Calvert City, Kentucky
•
City of
Murray,
Kentucky
•
Noveon, Gastonia, North Carolina
I have developed process design for the followingbiological nitrificationand denitrification facilities.
One of these (Lower Bucks County)
was never built due to alack of funding. The Chesterfield
County facility is fully operational and meeting effluent limits. The Puerto Rico facility is under
construction and will begin operation later this year.
•
Rohmand J-Iaas combined with Lower Bucks County, Bristol, PA
•
Chesterfield County, VA
•
Eli Lilly, Puerto Rico
Lastly, I developed the process design for the breakpoint chlorination facility forthe Allied Waste
Landfill in Murfreesboro, Tennessee. This facility, unlike that considered for the Noveon-Henry
3of32
Plant, required small enough quantities
of
chlorine that a mucg safer chlorine source could be used,
liquid sodium hypochlorite. This facility also discharged to a Publicaly OwnedTreatment Works and
not areceiving water body. I will present the evaluation that led to the design of this breakpoint
chlorination
facility at the Tennessee Solid Waste and Hazardous Waste Conferencein Gatlinburg,
Tennessee
in
April
2004. Several other technologies were considered for design development. These
were struvite precipitation, ion exchange, selective membrane treatment,
alkaline air stripping,and
biological nitrification. Bio-inhibition was the reasonthat biological nitrificationwas not selected for
treatment to remove ammonia-nitrogen from thisleachate. This is the same factor that made
biological nitrification at the Henry Plant expensive and unreliable.
Noveon-Henry Plant Experience:
1989 to 2004: Have provided the following assistance
in chronological order listed below. I
have
also spent a cumulative of at least 2 months onsite at this facility throughout the years with no more
than two years elapsing between visits. My last visit to the plant was in the Fall of 2003.
•
Optimization of WWTF operations.
•
Setup, conductand oversight of treatability testing that was used to develop process design
of C-I 8 wastewater pretreatment systemand aeration basin upgrade. Testing was
also used
to set allowable loading rates ofvarious wastestreams.
•
Train WWTF operators in process optimization and analyticaltesting.
•
Setup, conduct and oversightof treatability testing that was used to develop conceptual level
design criteria for alternative processes for effluent ammonia-nitrogen
reduction. Developed
conceptual level designs for these alternative processes. Worked with construction cost
estimators and venders to develop conceptual level cost estimates of these alternative
processes.
•
Provided as requested guidance
to Noveon regarding WWTF operations and full-scale
testing of processes and procedures intended to reduce effluent ammonia-nitrogen.
4 of 32
•
Authored or reviewed all reports submitted to Noveon by Brown and Caldwell (formerly
AWARE Incorporated and Eckenfelder Inc) during entire period of 1987 through 2004.
•
Represented Noveon in discussions with IEPA regarding the Petition for an Adjusted
Standard.
Noveon-Henry Plant WastewaterTreatment Facilities
Many of the terms that I have used above and throughout this report are definedbelow as the
Noveon-Henry Plant WastewaterTreatment Facility (WWTF) is described. An understanding of the
WWTF is critical to understanding the evaluations conducted and the condusions reached.
The wastewater treatment facility at the Henry Plant site is owned and operated by Noveon, Inc.
This facility treats wastewaters discharged from two manufacturing areas
(resins and specialty
chemicals) that were once owned by BF Goodrich. BF Goodrich sold the resin business to the
Geon Company who later sold itto the PolyOne Corporation. BF Goodrich sold the specialty
FIGURE 1
BLOCK FLOW
DIAGRAM
OF
WASTESTREAM
SOURCES AND
WWTI4
S of 32
chemicals business and the site’s wastewater treatment facility to Noveon, Inc. The wastewaters
discharged by Noveon comprise about 35 percent of the total dry weather flowrate to the WWTF
with the remaining 60 percent being discharged from the PolyOne production areas.
Wastewaters from the Noveon-Henry Plantproduction areas discharge to one of two places as
illustrated in Figure I. All wastewaters excluding those from C-18 manufacturing discharge directly
to an equalization tank (the PC Tank), as shownin Figure I. The wastewaters from C-18
manufacturing discharge to apretreatment system and are thenpumped to
an equalization tank
(C-18 Tank). Prior work thatI either conducted or oversaw defined the pretreatment of the C-I8
wastewater that would be required forthe WWTF to treat these wastewaters while complying with
effluent BOD limits. Prior to installingpretreatment, the bulk of the C-I 8 wastewaterswere
collected and transported foroff-site treatment and disposal. After this pretreatment was installed,
the pretreatment allowed the Noveon-Henry Plant to treat all
C-18 wastewaters onsite while
maintaining compliancewith effluent BOD
limits. This pretreatmentwas not required of the other
Noveonwastewaters. This pretreatment also had no
effect on effluent ammonia-nitrogen
concentrations nor would it have any such effect if applied to any other Noveon wastewater.
Wastewaters from the PolyOne Plant production areas discharge to one of two places as illustrated
in Figure 1.
All wastewaters excluding those from 213 manufacturing discharge directly to an
equalization tank (the
PVC Tank). The wastewaters from 213 manufacturing discharge to a
pretreatment system and are then pumped to same equalization tank (PVC Tank). This pretreatment
was not required of the other Polyone wastewaters. This pretreatment also had no effect on effluent
ammonia-nitrogen concentrations nor would it have anysuch effect if applied to any other Polyone
wastewater.
Stormwater from the both the Noveon andPolyOne sites and discharges from cooling towers,
boilers, and riverwater treatment are discharged to the Storm/Utility Pond (the “Pond”)
as
illustrated in Figure
1. A portion of the Pond contents are pumped through a filter to remove TSS
prior to discharge the Iffinois River. The remainingportion is pumped to the PVC Tank for
subsequent treatment. The amount of Pond Water returned to the PVC Tank is a function of the
capacity of the filter treating the Pond Water, the PVC Tank operating level, and the need for other
wastewater to compliment the required PC Tank discharge flowrate. The PVC Tank has a minimum
6 of32
allowable operating level, belowwhich the tank mixer shuts off. Work that I have conducted and
overseen
has indicated that the PC Tank discharge must be limited to approximately 23 percent of
the combined influent flow to the aeration basins to maintain compliancewith effluent BOD limits.
The PC Tank discharge contains compounds that can inhibit or slow down the bacteria responsible
for BOD removal iftheir concentrations are allowed to exceed certain critical
concentrations.
So the
amount of Pond water diverted to the PVC Tank for subsequent treatment increases during awet
weather period when the capacity of the filter on the pond
discharge is approached, when the PVC
Tank level nears its minimum operating level, and whenthe flow contribution of the
PC
Tank
discharge approaches 23 percent. The
contents ofthe PVC Tank,PC Tank,
and C-18 Tank are
pumped to a pH adjustment tank along with groundwater from awell (Well No.
3). The pH of the
combined wastewater is adjusted. Coagulant and polymer are added to the combined wastewater to
assistin removing solids from the
combined wastewater in
the sedimentation basin (also known as
primary clarifier). The solids settle for approximately one hour in the primary darifler. The settled
solids then combine with solids discharged from the bottom of the second sedimentation basin (also
knownas the secondary clarifier) and are dewatered using a filter press. The dewatered solids are
disposed in apermitted off-site landfill. The filtrate from sludge dewateringis returnedto the PVC
Tank forreprocessing through the WWTF. When the filter press is not operating, the sludge from
the primary darifler underfiow is pumped back to the PVC Tank for reprocessing in the WWTF and
sludge discharge from the secondary clarifier is ceased.
The effluent from the primary clarifier is pumped to fOur aeration basins (2.0 million gallons
combined volume)
that operate in paralleL These basins are aerated to mix the tank contents and to
maintain a minimum operating dissolved oxygen concentration of 1.5 mg/L. Sludge is returned
from the bottom of the secondary clarifier to keep these tanks supplied with an acclimated culture of
bacteria. p1-i is controlled as needed to maintain an optimum range forbacterial growth (pH
6.5 to
pH
8.5). The bacteria grown in this tank remove organic compounds with the aid of dissolved
oxygen, ammonia-nitrogen, andphosphorus. In the process of this removal these bacteria also break
away ammonia-nitrogen from organic compounds containing anthes-(also-known -as organic
nitrogen compounds). Both biological treatment steps are illustrated below. Dissolved
oxygen
needed for biodegradationis provided by
the aeration equipment. The two predominant nutrients
required for biological degradation are ammonia-nitrogen and phosphorus.
Ammonia-nitrogen is
presentin the wastewater and is formed through degradation of the organic nitrogen compounds
7 of 32
such as amines, morpholine, and mercaptobenziothiazole. Phosphorus is added to the return sludge
going back to the aeration tanks.
Biological Treatment Reactions
Organic compounds (measured as BOD, Biochemical Oxygen Demand)
+
Ammonia-Nitrogen
+
Phosphorus+ Dissolved Oxygen
+
Bacteriayields More Bacteria (reproduction
and growth)
+
Carbon Dioxide
+
Water
Organic Nitrogen
(an organic compound with essentially ammonia-nitrogen attached)
+
Phosphorus+ Dissolved
Oxygen
+
Bacteria yields Organic Compound
+
Ammonia-
Nitrogen.. .The Organic compound then gets degraded justlike above usingsome of the
ammonia-nitrogen generated.
The bacteria stayin the aeration tanks about 2.5 days where they degrade organic compounds and
organic nitrogen. They are then discharged through a line where theyget conditionedwith polymer
to help them settle better in the secondary clarifier. They settle approximately 3 hours in the
secondary clarifier. They are removed continuouslyoff the bottom of the clarifier and sent back to
the aeration tanks to degrade more organic compounds and organic nitrogen. A portion of the
bacteria is removed from the system (termed “sludge wasting”) to control population growth and
keep the average age of the bacteria (the Mean Cell Residence Time) and Food-To-Mass (F/M) ratio
in an optimal range. The bacteriaremoved from the system are discharged to the filter press for
sludge dewatering and subsequent off-site disposal in a landfill.
The treatment described includes pretreatment, primary treatment (pH adjustment, coagulation and
primary clarifier), and secondary treatment (aeration and secondary clarifierwith sludge return). This
treatment is defined by USEPA as the “Best Available Technology Economically Available” for the
Organic Chemicals, Plastics, and Synthetic Fibers industrial category (Code of Federal Regulations
Title 40, Part414.83, Subpart Fr).This industrial categoryincludes Noveon and PolyOne. However,
Noveontreats the wastewater even further by discharging the effluent from the secondary clarifier
to a filter to remove additional solids. This additional treatment process is termed tertiary treatment.
Noveon also filters the water coming out of the Pond to remove solids. These two filtered
-
8of32
‘wastewater streams
combine and discharge through the effluent compliance point that Noveon
monitors for flow and regulated compounds such as specific organics, BOD and TSS.
The design and operation of Noveon’s WWTF are compatible with conditions
defined by
35
ILL.
Admin. Code 370.920, 35 ILL. Admin. Code 370.1210, and Ten State Standards to grow nitrifying
or ammonia-degrading bacteria as illustrated belowin Table
1. However, these bacteria do not grow
in Noveon’s WWTF. The Illinois regulations cited and the Ten
State Standards are design and
operating standards that are intended to promote complete-nitrification-in-municipal wastewater
treatment facilities. These standards are intentionally excessive
(or conservative) andallow for a
significant margin of error in waste load determinations and operatingconditions based on my
experience. These regulations
and standards are principallyused
by regulators to-critiqueWWTF
designs to ensure
theyprovide adequate facilities to support complete nitrification. There are no
Illinois or Ten State standards for single stage nitrification of industrial wastewater treatment
facilities
since the nature of these wastewaters varies from industry to industry. These industrial
design standards are developed on a site
specific basis
using wastewater characterization data,
treatability testing, and professional experience. It should be noted, though, that the Noveon-Henry
Plant does provide the equipment and treatment condinons~necessary
to achieve and maintain
biological nitrification. Its lack of nitrificationis not due to alack of equipment or unfavorable
treatment conditions, but due to the presence of bio-inhibiting compounds.
Nitrik~iing
or ammonia-degrading bacteria are much more sensitive than the bacteria that degrade
organic compounds and organic nitrogen. The reason these bacteria will not grow is because there
are compounds present in the Noveon wastewater that prevent or inhibit their growth. If the
bacteria were not inhibited and could grow in the aeration tanks theywould provide ammonia
removal in the same tankage
as the other bacteria used to provide organics removal. Consequently,
the treatment would be termed single stage nitrification since in the same existing-tanka-ge
(same
stage) both organics removal and ammoniaremoval would occur. If you were to grow these
ammonia-degrading bacteria in a system downstream of the secondary clarifier, it would be called
tertiarynitrification. These nitrifying bacteria grow in the manner described as
follows:
9 of 32
Biological Treatment Reaction
Ammonia-Nitrogen
+
Phosphorus+ Dissolved
Oxygen
+
Alkalinity
+
Bacteria yields
More
Bacteria (reproduction and growth)
+
Nitrate-Nitrogen
Table
1. Comparison of Illinois Standards,
10 State
Standards, and Noveon-HenryPlant
Conditions for Single Stage Nitrification
Illinois
Ten State
Noveon
Condition
-
Standarda
Standardb
Plant’
Aeration Tank Loading, lbs BOD/day per
1000 cu ft
~I5
?15
-
14
Aeration Basin Mixed Liquor DO, mg/L
?
2
?
2
?
2
Aeration Basin Mixed Liquor
pH,
s.u.
7.2 to
8.4
Not Defined
6.8 to 7.2
Sludge Age, days
?..20
Not Defined
?40
Aeration Basin Mixed LiquorTemperature, degrees F
?
50
Not Defined
?
80
Aeration Basin Average Hydraulic Residence Time, days
?
0.33
Not Defined
2.5
Aeration Basin F/M Ratio, lbs BOD/day per lb MLVSS
Not Defined
0.05
to 0.10
0.10
ReturnActivated Sludge Flow,
of Ave Influent Flow
15 to 100
50 to 200
100
a
Illinois Administrative Code,Title 35, Subtitle C, Part 370, Subpart I, Title370.920 and Subpart L~
Title 370.1210. Both govern municipal (not industrial) WWTF design.
b
Recommended Standards for WastewaterTreatment Facilities,
1997 Edition, Wastewater
Committee of The Great Lakes-Upper Mississippi River Board of State and Provincial Public
Health and Environmental Managers (includes Illinois), Chapter 90. These standards are to
provide guidance in the design of municipal
(not industrial) WWTF design.
1999 through 2004.
Applicability of35 ILL. Admin. Code 304.122: The provisions of Illinois Title 35, Subtitle
C, Part
304, Subpart A, Section 304.122 (35
ILL. Admin. Code 304.122) is stated as follows:
a)
No effluent from anysource which discharges to the Illinois River, The Des Plaines River
downstream of its confluence with the Chicago River System or the Calumet River System,
and whose untreatedwaste load is 50,000 or more population
equivalents shall contain more
10 of 32
than 2.5 mg/L of total ammonia nitrogen as N during the months of Apni through October,
or 4 mg/L at other times.
b)
Sources discharging to
any
of the above waters
and
whose untreated waste load cannot be
computed on
a population equivalent basis comparable to that used for municipal waste
treatment plants
and
whose total ammonia
nitrogen as N discharge exceeds 45.4 kg/day(100
pounds per day) shall not discharge an effluent of more than 3.0 mg/L of total ammonia
nitrogen as N.
c)
In addition to the effluent standards set forth in subsections
(a)
and
(b) of
this
Section,
all
sources
are
subject to Section
304.105.”
Section 304.105 states “In addition to the other requirements of
this
Part, no effluent shall, alone or
in combination
with
other sources, cause a violation of any applicable water
quality
standard.”
In my professional opinion, Sections 304.1 22a and 304.122b
do not apply to the Noveon-Henry
Plant discharge for several reasons.
The Noveon-Henry Plant untreated waste load can be “computed on a population
equivalent basis comparable to that
used for municipal wastewater treatment plants”.
Consequently, 304.122b does not apply. In my opinion, the word “comparable” merely
questions whether the data exist to express an untreated waste load in population equivalents
like
one does when either designing or evaluating a municipal wastewater treatment plant.
The data for the Noveon-Henry Plant do
existand such calculations can be and have been
made. The results from such calculations allow one to put the Noveon-Henry Plant’s
untreated waste load in a perspective others can readily understand (population
equivalents).
The term “population equivalent basis” is intended to put the relative
size of an untreated
waste load in perspective. The term was never intended to describe how the waste load was
to be treated but only the magnitude of the waste load.
•
An untreated waste load
can
be and has been calculated by me for the Noveon-Henry
Plant
discharge on “a population equivalent basis comparable to that used for municipal waste
11of32
treatment plants”.The correct results from these calculations are stated below and clearly
define the Noveon-Henry Plant discharge as having less
than 50,000 population equivalents.
Consequently, 304.122a does not apply.
•
Since Sections 304.122a
and
304.122b do not apply, the Noveon-Henry Plant is not
required to provide additional effluent ammonia-nitrogen removal.
As stated above, correct calculations clearly define the Noveon-Henry Plant discharge as having less
than 50,000 population equivalents. IEPA has calculated the population
equivalents of the
Noveon-Flenry
Plant for flow and BOD
(based on data provided in the Baxter and Woodman-
Wastewater Treatment
Plant Report dated June
1994.
This
report
did
not present any
data
on the
combined untreated wasteload. The report discussed the wasteload fed from the equalization tanks
to the primary clarifier. However,
this
wasteload contains wastestreams that are internal to the
WWTF that add flow, BOD,
and
TSS including primary clarifier sludge
when sludge dewatering is
not occurring, filtrate from sludge dewatering, and backwash water from the tertiary (secondary
clarifier effluent) filter. These wastewaters and internal recirculation
streams are illustrated in Figure
I
above.
Even
with this
addition of flow and BOD
from recircuclating streams,, IEPA
calculated
flow and BOD population equivalents of 916 and 19,412, respectively. I corrected
the population
equivalent calculation for TSS based on data collected by Noveon during the period ofJuly 2002
through June 2003. The corrected value was 24,955 as illustrated below and in Figure 1.
This
calculation depends upon
calculating the untreated waste load TSS coming to (not recycling within)
the
WWTF
from all
sources and then adding them togetherwhich is done below. The waststreams
which
contribute TSS to the
WWTF
are
the PVC Lift Station Discharge which represents the waste
load discharged from the PolyOne production areas, the 213 wastestream waste load before
pretreatment,
the
PC Tank discharge, and the C-18 Tank discharge. It should be noted
that
the
C-18
wastewater pretreatment process does not change
the
flow or TSS of
this
discharge but does
increase its BOD. The TSS discharged
by the combined Well No.
3
and
Storm/Utility Pond
discharges
are less
than 25 percent of the total influent wasteload as reported in
the
Baxter and
Woodman report referenced above..
•
PVC Lift Station Discharge Averages(not the PVC
Tank
Discharge Averagespresented in Baxter
and
Woodman Report):
133
gpm,
1957 mg/TSS,
and
3123
lbs/day TSS
12 of 32
•
PC
Tank Discharge Averages: 94 gpm,
900
mg/LTSS, and 1015 lbs/day TSS
•
C-l8 Tank Discharge Averages: 3.6 gpm, 300 mgfL TSS, and
13 lbs/thy TSS
-
•
213 Averages (included in PVC Tank Discharge data presented in Baxter andWoodman Report):
35 gpm, 2000 mg/LTSS (estimate), and 840 lbs/thy TSS (estimate)
•
Total:
4991
lbs/dayTSS (summation of above) or apopulation equivalent (PE) of 4991
lbs/day
TSS divided by 0.20 lbs/day TSS per person(capita)or 24,955 population equivalents. This is
much less thanPEof 265,000 calculated by IEPA. The reason for this large discrepancy is due
to recycle solids included in the IEPA calculation. These solids stay within the WWTF and
are not part ofthe untreatedwaste load for which these calculations are reserved.
Even though not a part of the IEPA’s definition of “population equivalent”, population
equivalents
can also be calculated based on ammonia-nitrogen, andTotal Kjeldahl Nitrogen (TKN) loads that
are really the thrust of 35 ILL. Admin. Code 304.122. TKN is the summationof ammonia-nitrogen
and organic-nitrogen. The wasteload used to develop all effluent ammonia-nitrogen reduction
-
-
options included average loadings of 385 lbs/dayammonia-nitrogen and 1038 lbs/dayTotal
Kjeldahl Nitrogen (TKN). Based on population equivalent factors of 0.019 lbs ammonia-nitrogen!
capita per dayand 0.029 lbs TKN/capita per day(see WastewaterEngineering
Treatment and
Reuse: Metcalf and Eddy, Inc., Fourth Edition, page 182), the Noveon-Henry Plant population
equivalents would be 20,263 and 35,793, respectively.
In my professional opinion,
all correct and relevant population equivalentcalculations for the
Noveon-Henry Plant place
it
under
50,000 population equivalents rendering 35 ILL. Admin. Code
304.122a and 304.122b
not applicable.
13of32
Highlights
ofEffluent
Ammonia-Nitrogen
Reduction Evaluations at
Noveon-Henty Plant
Itis my professional opinion that 35 ILL. Admin.
Code 304.122a and
304.122b do not
apply.
Consequently, no effluent limitations and therefore no additional effluent ammonia-nitrogen
reductions are required.
The Noveon-Henxy Plant currently provides effluent ammonia-nitrogen reduction through source
control and removal associated with BOD removal nutrient requirements. However, in an effort to
resolve disputes with the TEPA, Noveon retained Brown and Caldwell (where I serve as lead
engineer) to evaluate whether therewere any feasible technologies that would provide additional
effluent ammonia-nitrogen reduction.
Both Noveon and Brown and Caldwellhave extensively
evaluated a numberof effluent ammonia-nitrogen reduction methods and technologies over the last
14 years.
All statements made belowrepresent my understanding of the issues and my professional opinion
regarding these issues.
14 of 32
1.0
Unique Characteristics ofthe Noveon-Henry Plant
and
its Associated Wastewaters:
In my
professional opinion, several factors make the Noveon-Henry Plant and its associated
wastewaters unique as it relates to these proceedings. These factors make the wastewaters at The
Noveon-Henry Plant more technically difficult and more costly to treat than either municipal
wastewaters or most other industrial wastewaters. These factors are listed below.
First, IEPA has reportedthat there are only three other plants- in the country that-generate a similar
wastewater. Two of these three plants discharge to a Publicly Owned Treatment Works. Only one of
these plants discharges directly to a receivingwater.
So, the wastewateris not commonly found.
Second, the buildingessential block ofNoveon’s main product line at the facility (rubber
accelerators)
is MBT (mercaptobenzothiazole). As a building block,
it
is presentin numerous
wastestreams throughout the plant sewer system. Consequently, therewas not a smallisolated
stream that could be treated for MBT removal. Nearly all Noveon wastewaters contained MBT. It is
also a well-recognized inhibitorof biological nitrification even attrace levels of 3 ppm as reported by
M.L. Hockenbury and C.P.L. Grady in the Journal of the Water Pollution Control Federation in
1977
(see E±hibit
B). This compound is poorlydegradable which makes
it
ideal for a rubber-making
additive. No consumer wants to buy readily degradable tires and other rubber products. Because of
its poor degradabffity, MBTis also used as an additive to nitrogen fertilizers to inhibit biological
nitrification in the soil so that more ammonia nitrogen will be available to the crops (see Exhibit B
for article publishedin the National Corn Handbook, February 1992). However, the large use of this
inhibitingcompound in production at the Noveon-I-lenxy Plant make the most widelypracticed and
least expensive ammonia-nitrogen removal process (single stage nitrification) technically infeasible at
the Noveon-Flenry Plant. MBT removal is proyided in the WWTFNoveon-Henry Plant but cannot
be reducedwithin the WWTF to the trace levels required for biological nitrification to occur.
Consequently, atypical and expensive processes would be required to reduce effluent ammonia-
nitrogenconcentrations.
Third,
the Noveon-Henry Plant and PolyOne Plant contain wastestreams that require pretreatment
ahead of the onsite biological treatment plant to prevent process upsets and non-compliance with
-
15of32
effluent BOD andTSS limits. Consequently, there is an inherent unreliability with
any biological
treatment process used onsite whether it is used for BOD removal or nitrification.
Fourth, the Noveon wastewater contains several degradable organic nitrogencompounds such as
tertiary butyl amine. When these compounds are degraded, they release ammonia-nitrogen.
Consequently, effluent ammonia-nitrogen concentrations increase as the presence of these
compounds increase in the influent wastewater and as these compounds are more thoroughly
biodegraded. This
explains why the influent ammonia-nitrogen concentration at the Noveon-Henry
Plant is much less than the effluent concentration (less than 40 mg/L versus greater than 80 mg/L).
This means that the majority of the effluent ammonia-nitrogen at the Noveon-Henry Plant is due to
thorough biological treatment of organic compounds.
Fifth, the compounds present in the Noveon-Henry Plant wastewater make oxygen transfer into this
wastewater about halfas efficient as municipal wastewater as measured by aparameter known as
“alpha”. Alpha is the ratio of oxygen transfer in wastewater divided
by the oxygen transfer in
tapwater. In municipal wastewater this alpha value for fine bubble diffused aeration is typically
0.60 versus the 0.35 measured in the Noveon-Henry Plant wastewater in 1987
by Gerry Shell.
Consequently, the Noveon-HenryPlant has to use blowers with about twice the horsepower to
transfer the same amount of oxygen used at municipal wastewater treatment plants.
Furthermore,
this increased power has to be accompanied by increased aeration tankage to keep operating power
levels in a reasonable range.
Sixth, the Noveon-HenryPlant wastewater is lightlybuffered. Consequently, if
biological
nitrification could be implemented with inhibitorcontrol, the majority of alkalinity would have to be
chemically
added whereas in biological nitrification of municipal wastewater the majority (if not all)
of the alkalinity required is presentin the wastewater. This furthermakes the Noveon-Henry Plant
wastewater technically challenging and expensive to treat foreffluent ammonia-nitrogen reduction.
Eighth, the Noveon-Henry Plant does not have anyadditional
appreciable electrical power available
at the WWTF. Any significant additional power required at the WWTF would require installation of
anew motor control center and installation of a new power line to a substation located
approximately 0.5 miles away. Consequently, any WWTF upgrade (regardless of magnitude) to
l6of32
address effluent ammonia-nitrogen reduction will require a significant increase in power delivery and
this too leads to greater treatment costs.
l7of32
2.0
History ofEffluent Ammonia-Nitrogen Reduction Evaluations
at the Noveon-Henry
Plant
During the last
14 years, Noveon and Brown and Caldwell have extensively evaluated whether there
are any feasible technologies that would provide additional effluent ammonia-nitrogen reduction at
the Noveon-Henry Plant. These evaluations have consisted of literature review, consultationwith
additional experts, laboratory-scale treatment investigations, full-scale operations and capital
enhancements, and full-scale plant trial investigations. Many of these evaluations were based on
results ofprior evaluations in an attempt to continue to build on findings of prior evaluations. In my
professional opinion, therehave been “no relevant stones left unturned”. The significant evaluations
in which I haveparticipated are summarized below.
-
2.1
Single Stage Nitrification, Powdered Activated Carbon Addition, Effluent Ion
Exchange and Tertiary (Effluent) Nitrification
When I first got involved at the Noveon-HenryPlant in 1989,the focus was on developinga
strategy for achieving consistent
effluent BOD compliance. Brown and Caldwell conducted
continuous flow treatabilitytesting that I designed and oversaw which indicated consistent,
compliance could be achieved with pretreatment of one major wastestream
(C-i
8). During the
course of the treatability studies, we noticed that the WWTF would discharge elevated
concentrations of ammonia-nitrogen while providing excellent BOD removal. Despite carefully
controlled conditions of F/M (approximately 0.10 lbs BOD/day/lb MLVSS), MCRT, pH,
temperature and DO that should prompt biological nitrification, none was observed. This likely
indicated that bio-inhibitors were present in the influent at sufficient levels to prevent biological
nitrification. It was eventually determined following significant research and testing efforts that MBT
was a prime inhibitor of nitrification at the Noveon-Henry Plant. Batch testing was conducted in
early 1989 to determine ifpowdered activated carbon (PAC) could be added to remove these
inhibitors and allow single stage biological nitrification. Furthermore, batch testing also evaluated
selective ion exchange treatment (clinoptilolite) of the effluent, and tertiary (effluent) nitrification of
the effluent. This work indicated that an untenable, large dose of PAC would be required to allow
single stage nitrification (5000 mg/L or
17 tons/day). Because ofthis finding (untenable carbon
18of32
-
usage) and the certainty of foulingproblems, no further consideration was given to carbon
-
treatment. This work also indicated that even the most appropriate ion
exchange media was not
selective for ammonia-nitrogen removal due to the other competing cations in the wastewater
(approximately 100 pounds resin required to remove
1 pound of ammonia-nitrogen).Lastly, this
work suggested that the effluent could be biologically nitrifled with yet another treatment unit
(known as tertiary treatment). Consequently, subsequent evaluations considered more thoroughly
tertiary nitrification.
2.2
Further Evaluation of Tertiary Nitrification and Pretreatment with Single Stage
Nitrification
Based on
these results, Noveon’s corporate Research andDevelopment group initiated a laboratory-
scale, continuous flow treatability study that focused on tertiary nitrification ‘with alkalinity addition.
This work was conducted over about a- 6 month period using fixed film biological nitrification and
secondary clarifier effluent samples that were collected monthly. The work preliminarily indicated
that tertiary nitriflcation could be accomplished and low discharge ammonia-nitrogen concentrations
(less than 6 mg/L)
could be achieved with alkalinity addition and effective performance of upstream
treatment processes. There were, however, legitimate
concerns about how reliably this process
would have performed under the daily variability of secondary clarifier effluent
quality. The same
bio-inhibiting compounds that prevented nitrification in the current WWTF would be expected to
be presentin the WWTF effluent,on occasions, in concentrations that would either prevent or
greatly slow ammonia-nitrogen removal in the tertiary process.
Brown and Caldwell also initiated a series of batch treatability tests that I designed and oversaw.
This testing was to identify ifavailable technologies could be used to remove the bio-inhibitors
present in the influent wastewater to the extent that the most widelypracticed ammonia-nitrogen
removal process (single stage nitrification) could be employed.
These treatability tests evaluated
hydrogenperoxide treatment, clay absorption, and precipitation. However, the rate ofbiological
nitrification was
slower than would be expected for an uninhibited
system indicating
that bio-
inhibitors were still presentin the effluent from the treatment plant. This work indicated that
precipitation and filtration of the NoveonwastewateratpH 2 would allow single stage nitrification
to proceed. However, thispretreatment would require significant acid addition to lower the
19 of 32
wastewater pH from pH 10 to pH 2 andthen significant alkali addition to increase the pH from
Ph 2 to pH
7 for biological treatment. The precipitant from the pH 2 pretreatment was analyzed and
found to be predominantly MBT (a known nitrification inhibitor). Implementation of this
pretreatment process and subsequent single stage nitrificationwould suffer from reliability issues as
the nitriflcation achieved would only be as successful
as the pretreatment process was in removing
all bio-inhibiting substances. It was uncertainwhether MBT was the only bio-inhibitorof concern.
2.3
Further Evaluation of Pretreatment (pH 2
Precipitation and
Solvent Extraction) and
Single Stage Niti±flcation
Based on results of the work described above, Brown andCaidwell conducted a continuous flow
treatability study, which I designed and oversaw, to
evaluate pH 2 pretreatment of the PC
wastewater and single stage nitrification. This study indicated that single stage nitrification could be
achieved with this pretreatment. The rate ofnitrification was inhibited indicating that some
bio-inliibitors still remained in the combined influent. Effluent ammonia-nitrogen concentrations
from this process varied from I mg/L to 20
mg/Lb indicating a variation in remaininginfluent
bio-inhibitor concentrations. It was concluded that this pretreatmentprocesswould support single
stage nitrification to an extent. The extentwas unknown due to the short lived demonstration period
and the potential forother bio-inhibitors being present that would not be affected by this
pretreatment. It was certainthat effluent ammonia-nitrogen concentrations from this treatment
processwould not consistently achieve those limited by 35 ILL. Admin. Code 304.122a or 304.122b.
During this same period of time, Noveoninvestigated a process used in Germany forMBT
recovery. This process used solvent extraction. It is my understanding that results of this
investigation indicated that the process would pose safety concerns
(potential for explosions) and
would also be cost prohibitive to implement at the Henry Plant (greater than $10 million in capital
cost alone).
20 of 32
2.4
Assessmentof
WWIP
for Compliance with Conventional Design for Single Stage
Nitrification 35
IlL. Admin. Code 370.1210 and 370.920
Noveon retained Baxter and Woodmanin 1994 to review the WWTF for compliancewith the
Illinois design standards for single stage nitrification of municipal wastewaters. These standards are
conservative to allow a significant margin of error in waste load determinations and operating
conditions based on nay experience. There are no Illinois design standards for single stage
nitrification facilities forindustrial wastewaters. It should be noted though that the Noveon-Henry
Plant does provide the equipment and treatment conditionsneeded to establish and maintain single
stage nitrification.
The review by Baxter and
Woodman indicated the
WWTF would comply with the municipal
wastewater standards with the addition of about 65 percent more aeration tankage. Noveon
expanded the aeration tankage in 1998
by 100 percent to provide greater aeration capacityand
greater treatment plant
flexibility. This addition put the WWTF in full compliance with 35 ILL.
Admin. Code 370.1210 and370.920 and
Ten State
Standards (which includes Illinois) for single
stage nitrification and yet the WWTF did not exhibit any nitrification. The reason nitrificationwas
not achieved was not due to a lack of equipment, but rather the presence of bio-inhibition.
2.5
Alternative Bacteria
IEPA had conducted a literature search and found an article that seemed to imply that special
bacteria could be grown in the Noveon-Henry Plant that would both degrade the difficult
-‘
compounds (such as morpholine) and remove ammonia-nitrogen at the same time. I explainedto
IEPA that these were not the findings of this article. However, IEPA was persistent that these
bacteria could achieve both types of degradation (morpholine and-ammonia-nitrogen).
Consequently, Noveon brought in the author of this article from England (Dr. Jeremy Knapp).
Dr. Knapp reviewed the Noveon-Henry Plant operation with me; Gardner, Carton and Douglas;
Noveonand TEPA. He then explained to
all that the bacteria that he wrote about were already
present in the Noveon-Henry Plant based on morpholine removal data he had reviewed and that the
conditions present in the Noveon-Henry Plant were suitable for maintaining a culture of these
21
of32
bacteria. He further explained that these bacteria do not provide nitrification. He also explained that
the Noveon-HenryPlant provided all the
rightconditions for single stage nitrification ifbio-
inhibiting compounds were not present.
Noveonon
several occasions has triedadding specialty bacteria to remove difficult to degrade
compounds. During these same periods, Noveonhas added nitrifying bacteria from the Peoria
PCYIW.
In no instance has Noveon been able to initiate nitrification. This once againindicates that
the lack of nitrification is due to inhibitors that are not degraded within the confines of the Noveon-
Henry Plant evenwith special bacteria addition. Furthermore, this Plant offers the biological
treatment opportunity that is required by Ten State
Standards and 35 ILL. Adrnin.
Code 370.1210
and 370.920 for single stage nitrification.
2.6
Numerous
Occasions of
Seeding Plant with Nitrifying Bacteria
The Noveon-Henry Plant is in-compliance with Ten State Standards and 35 ILL. Admin.
Code
370.1210 and 370.920 for single stage nitrification. Noveon has added on numerous occasions
bacteria from other
WWTF that are actively nitrifying. These additions were intended to improve
the Noveon-Henry Plant WWTF performance in removing ammonia-nitrogen. Yet, in no
case has
nitrification occurred at the Noveon-Henry Plant despite optimum conditions ofMCRT
(greater
than30 days), temperature (28 to 32 degrees C),pH (6.8 to 7.5), DO (greater than 2
mg/L).
Again,
it is my professional opinion that this is due to the presence of bio-inhibiting compounds in the
influent.
2.7
Full-Scale
Plant Trial of
Alkaline Aix Stripping
to Achieve Effluent
Ammonia-
Nitrogen Reduction
The Noveon-HenryPlant conducted a full-scale trial of alkaline air stripping’ofthe combined
influent to quantify the effluent ammonia-nitrogen
removal that would be achieved. This required
Noveon to set up an interim pumping system, caustic addition system, and acid addition system.
This interim system diverted all primary clarifiereffluent (approximately 560 gallons per minute) to
an aeration basin that had been set aside for this testing. Caustic was added to the aeration basin to-
maintain a target pH value of 10.5. A surface aerator was placed in this basin and operated to assist
22 of32
in air stripping. Effluent
from this tankwas diverted to a blend tank where the pH was lowered. The
blend tank contents were thenpumped to the other threeaeration basins for biological treatment.
This treatment did demonstrate some reduction in effluent ammonia-nitrogen (less than20-percent).
This reduction was low, in my opinion, due primarilyto the fact’that the majority of the effluent
ammonia-nitrogenis formed during biological
treatment. Secondly, the pH control method was
unable to consistently keep the tank contents at or above pH
10.5. This treatment process-is-not a
viable method for achievingsignificant effluent ammonia-nitrogen removal.
2.8
Full-Scale Trial
of
Pretreatment and Single Stage Nitrification
Noveon environmental staffconducted aliterature search and found an article that indicated that
MBT could be co-precipitated with ferric hydroxide at an elevatedpH (see Exhibit B). The
article
indicated that significant removal could be accomplished at pH 4.5 versus the pH 2 pretreatment
evaluated by Brown and Caldwell. Noveon conducted a full-scale trial
of
this pretreatment system in
hopes of achieving single
stage nitrification.
I reviewed the article, believed there was a likelihood of
success in this trial, helped design the trial, reviewed data from the trial and witnessed this trial in
progress. The trialinvolved Noveon installingan interim precipitation systen’~andseparate sludge
dewatering systemto treat and segregate pretreatment byproducts (sludge and filtrate from sludge
dewatering). The entire PC wastewater ‘discharge (120 gpm) was routed through this system
involving ferric chloride
addition to lower the PC Tank wastewater to pH 4.5. The pH adjusted
waterwas
allowed to separate in interim clarifiers. The treated wastewater was transferred using an
interim pumping system to the existingprimary treatment system. The precipitated sludge was
dewatered usingan interim filter press with precoat addition system. The
filtrate from sludge
dewatering was touted back to the pretreatment system. The pretreatment system was operated for
months and did demonstrate significant MBT removal
(greater than 50 percent). At the end of this
operatingperiod, Noveon brought in a tanker load (5000 gallons) of bacteria from aplant in Indiana
that had a high population of active nitrifying bacteria.The bacteria were added to the aeration
basins. The pretreatment system continued to operate while Noveon checked for signs of
nitrificationin the activated sludge system. The activated sludge system was operated under adequate
DO, pH, MCRT and alkalinity control to prompt nitrification. Yet, despite greater than 50 percent
MBT removal,no nitrification occurred with this largeinvestment of resources (greater than
23 of32
$100,000) and time (greater than 4 months). It is my opinion that nitrification did not occur because
of the continued
presenceof
bio-inliibiting compounds in the influent (MBT
and likely
others).
-
2.9
Consideration of Other Lesser Known Technologies
Another consultant (Ecology and Environment, mc) was retained to review the work of Brown and
Caidwell for Noveon. It is my understanding that this consultant believed that all
feasible
technologies had been considered foreffluent ammonia-nitrogen reduction excluding ozonation. A
conceptual level design and costestimate was developed for this treatment process. The process
would presumably achieve a 98 percent reduction in effluent ammonia-nitrogen but ata present
worth
cost of$20.32
million (almost
twice
the cost of
any other process considered). This
process
would also significantly increase the
effluent
total dissolved salt concentration due to the- caustic
addition required to neutralize the acid generated from this process.Additionally, a significant
substation upgrade would be required to deliverthe additional -power consumed (equivalent to
approximately 3500 hp demand).
-
I discovered in 2003 a company in Memphis, Tennessee that had a patented membrane that
selectively separated ammonia-nitrogen from wastewater containing little other constituents besides
ammonia-nitrogen. This membrane was testedto remove ammonia-nitrogen from a landfill leachate
and groundwater stream that was less concentrated in other constituents than the Noveon
wastewater. The company conduded after actual testing that the membrane would not be suitable
for treating the leachate andgroundwater stream due to interference caused by other compounds
present in the wastestream. Consequently, I did not further pursue use of this membrane at the
Noveon-Henry Plant for effluent ammonia-nitrogen reduction.
2.10
Comparative Performance and Costs of all Proven Effluent Ammonia-Nitrogen
Reduction Processes
After approximately 14 years of extensive evaluations
by Noveon and Brown and Caldwell, all
applicable treatment processes, in my professional opinion, have been considered for effluent
ammonia-nitrogen removal. Treatment processes considered went beyond those included in the
USEPA Process Design Manual: Nitrogen Control (EPA 625R93010). No stone has gone unturned.
24 of 32
The proven treatment processes described in this
testimony have been developed by me and
support staffwell enough to accomplish the
following:
•
predict potential effluent ammonia-nitrogen reduction,
•
understand the pros and cons,
•
develop conceptuallevel designs for theirapplication, ‘and
•
develop conceptual level design cost estimates (capital, annual, and presentworth costs) for
these treatment alternatives to within 30 percent accuracy using availableinfluent waste load
data.
The proven treatment processes that were evaluated are listedbelow.
•
Alkaline air stripping
(air stripping at pH 10.5) of PC Tank contents with off-gas collection
and treatment. Noveonbelieved this off-gas collection and treatment would be required to
comply with air quality regulations. At high pH ammonia-nitrogen exists
as a gas dissolved in
liquid and can be removed from the liquid by air stripping.
•
Alkaline air stripping of PVC Tank contents.
-
•
Alkaline air stripping of secondary clarifier effluent.
•
Struvite precipitation of combined influent prior to primary clarification. Ammonia-nitrogen
can be precipitated as NH4MgPO4(H20)6.
•
Breakpoint chlorination of secondary clarifier effluent. The addition of chlorine
converts
ammonia-nitrogen to nitrogen gas that exits the liquid to the atmosphere without the need
for air stripping.
25 of 32
•
Nitrification of PVC Tank wastewater (non-PC wastewaters). Nitrification is a process by
which bacteria convertammonia-nitrogen to nitrate-nitrogen. The bacteria consume large
-
amounts of oxygen (4.6 lbs oxygen/lb ammonia-nitrogen removed) and--alkalinity (7.14lbs
alkalinity/lb ammonia-nitrogen removed).
•
Nitrification of the combined wastewater. This process would require pretreatment of the
PC wastewater to remove bio-inhibitors.
•
Nitrification of secondary clarifier effluent (tertiary nitrification).
-
•
Ion exchange treatment of the
final effluent. Ion’ exchange is aprocess where another cation
(e.g., sodium (Na4)
or
hydrogen (H4) is released from a resin into the water so another
cation (NH44)
can be
removed from the water.
-
The treatment process evaluation described above is briefly summarized in Exhibits
C, D, and E.
This evaluation established that the process offering the lowest presentworth cost for reducing
effluent ammonia-nitrogen was alkaline stripping of the PC Tank contents ($2.31 million). This
alternative, however,would only provide at most a 27
percent reduction
in effluent ammonia-
nitrogen. If reductions in effluent ammonia-nitrogen were required at the Noveon-Henry Plant to
meet,
35 ILL.Admin.
Code 304.122b, the average effluent ammonia-nitrogen would have to be
reduced by 98 percent (135 mg/Lreduced to
3 mg/L). Under peak effluent conditions, the effluent
ammonianitrogen reduction would have to exceed 98 percent. The process offering the lowest
presentworth cost that would be capable of meeting the
98 percent reduction requirement was ion
exchange ($5.07 million). However, this process would be complicated to operate, would generate a
waste byproduct (liquid arnmonium chloride) requiring offsite disposal andwould be prone to
fouling by scaling and bacterial growth. This treatment process would be difficult to operate and
maintain and, consequently, would pose reliability issues. Secondly, it could cause effluent toxicity
problems due to an ionic imbalance. The next least expensive process capable of achieving98
percent reduction was breakpoint chlorination
($9.73 million). However,
this process poses
significant
safety and site security concerns
(chlorine gas is extremely haaardous),
would significantly
increase effluent total dissolved salt CIDS) concentrations, maygenerate chlorinated organics, would
increase
effluent aquatic toxicity due to the elevated TDS and likely presence of chlorinated
26 of 32
organics. Lastly, the nextleast expensive process capable of achieving 98 percent-reduction-was
nitrification of the combined wastestream as a single stage process ($11.71 million) or as a tertiary
process
($11.41 million). Both processes would result in an increase in effluent TDS andboth
processes would provide unreliable performance based on the variability
ofinfluent
bio-inhibiting
compounds. At times, neither process would comply with the requirements of 35 ILL. Admin. Code
304.122a and 304.122b.
2.11
Evaluation ofAlternative Methods ofEffluent Ammonia-Nitrogen Measurement
Given the concentrations of ammonia-nitrogen and the difficulty-in- treating it made me question
whether there could be a fundamental error in the measurement of effluent ammonia-nitrogen. The
method used
by the IEPA laboratory and the outside laboratory used by the Noveon-Henry Plant
for effluent compliance monitoring were the same. Both laboratories used the ion selective probe
method. This method is recognized by USEPA as registering artificially elevated values in the
presence of organic nitrogen compounds. These compounds are likely to be presentin the Noveon-
Henry Plant effluent. Noveon, atmy suggestion, conducted a testing program where the secondary
darifler effluent was analyzed using the historical method without distillation, the historical method
with distillation, and the phenate method with distillation. All three methods are
approved by
USEPA. The last method mentioned was the method least prone to interference by organic
nitrogen. Results of this test method indicated a slightly lower value for effluent ammonia-nitrogen
with distillation and with the phenate method. However, the average of all values was within
15
percent regardless of the method
selected. This findingindicated the historical effluent ammonia-
nitrogen concentrations
were reasonablyaccurate
and that the historical method could continue to
be used with reasonable accuracy to monitor effluent ammonia-nitrogen concentrations. The
effluent concentrations measured throughout all treatment evaluations could be considered
reasonablyaccurate. Effluent ammonia-nitrogen reduction hadindeed been as difficult to achieve as
measured.
27 of 32
3.0
OTHER ISSUES
3.1
Source Reduction Measures implemented by Noveon-Henry Plant
Noveon has installed in-plant recovery devices and instituted pollution prevention-plans-to-minimize
the discharge of organic nitrogen (such as tertiary butyl amine) to the WWTF which would have
been converted to ammonia-nitrogen through biological treatment had such recovery not been
provided. Further, Noveon has even been recognized by the State of Illinois forprogress in
pollution prevention
(Annual Governor’s Award for Pollution Prevention in 1999, 2002, and 2003
with Governor’s Citation Award for Pollution Preventionin 1998). Second, the Noveon-Henry
Plant has
consistently removed ammonia-nitrogen through
its WWTF as a nutrient required for
BOD removal (approximately 0.04 lbs ammonia-nitrogen removed/lb BOD removed). BOD-
removing bacteria are more tolerant ofinhibitors than are nitrifying bacteria. Without this
BOD
removal, Noveonwould discharge approximately an additional 20 mg/L ammonia-nitrogen in the
final effluent. The Noveon wastewater just contains more ammonia-nitrogen than required as a
nutrient for BOD removal. Lastly, it should be noted that Noveon has exerted significant effort in
conductingtwo fullscale
trials
in
an attempt to demonstrate a
WWTF
modification thatwould
provide effluent ammonia-nitrogen reduction. One trial provided less than a20 percent reduction
and the other trial provided no reduction.
3.2 Comparative Cost of Ammonia-Nitrogen Removal for Noveon and Others
As described in
I
above, the Noveon-Henry Plant has several unique features that render its cost of
providing ammonia-nitrogen removal more expensive than others. The comparisons madeby the
IEPA considered only the capital costs of single stage nitrification. Operations and maintenance
(annual) costs were not included in the comparison. However, as noted in Exhibit C, these annual
costs for Noveon would be significant. The
facilities used in the comparisons by the IEPA were
likely required to add little or no chemicals to achieve nitrificationwhereas
the Noveon-Henry Plant
would be required to spend $788,000 annually on chemicals alone. This high chemical cost is due to
chemicals required for the pH 2 pretreatment process (acid to lower the pH and causticto raise the
pH for biological treatment) and caustic required providing the alkalinity consumed in nitrification.
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This yields a presentworth chemical only
costof$5.29
million
exduded from the cost comparisons
made by IEPA (based on a 10 year project life). In
some cases, a
20 yearproject life is considered
more representative. Under this project life, the present worth cost of chemicalswould increase to
$7.73 million. Either way, this is a significant omissionin cost comparisons. In addition, this does
not include the added operatingcost that Noveon would have related to pretreatment system
operations andincreased aeration horsepower.
Only present worth cost comparisons are meaningful
when there is a significant difference in operating costs
as is the case here. In
my
professional
opinion, there is no doubt that single
stage nitrification atthe Noveon-Henry Plant would be far
more expensive on apresent worth basis than most fadilities(principally POTWs) envisioned by the
Illinois Water Pollution Control Board in developing 35 ILL Admin. Code 304.122.
It is likely that a present worth cost comparison of these facilities would reveal that the cost of
ammonia-nitrogen removal is less than $0.20/lb (the surcharge costimposed-by the Knoxvffle
Utility
Board on ammonia-nitrogen is $0.12/pound of ammonia-nitrogen) for the POTWs. The present
worth cost for Noveon to implement single stage nitrification is $3.60/lb to $2.32/lb (depending on
whether a 10
year or 20 year project life is assumed, respectively) of ammonia-nitrogen reducedor
18 to
12
times the cost for other facilities.
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4.0
INCREMENTAL
COST OF PROVIDING EFFLUENT
AMMONIA-NITROGEN REDUCTION
-
It should be recognized that the Noveon-Henry Plant already provides effluent ammonia-nitrogen
reduction through source control practices and ammonia-nitrogen removal accomplished in BOD
removal. Noveon requested that Brown and Caldwell calculate the cost of incrementally providing
additional
effluent ammonia-nitrogen reduction. I personally developed the basis for this cost
analysis and reviewed and approved the process by which theywere calculated. In some cases
incremental effluent ammonia-nitrogen would be accomplished by treating only a portion of the
wastewater. In other cases,
it
would be accomplished by sizing the treatment vessel to only provide
partial treatment. The results of this exercise are summarizedin Exhibit D.
These results indicated that even a 25 percent reduction in effluent ammonia-nitrogen would have a
presentworth cost of $1.8 million to
$
3.9 million depending upon
the treatment process selected.
More importantly, the 25 percent reduction would not achieve compliance with 35 ILL. Admin.
Code 304.122b assumingit applied (and
it
does not apply).
30 of 32
-
5.0
SUMMARY
The Noveon-Henry Plant
currently provides effluent ammonia-nitrogen reduction through source
control and
removal associated with BOD removal nutrient requirements. In my professional
opinion,any
further
reductionin effluent ammonia-nitrogen is not requiredby 35 ILL. Admin.
Code 304.122a or 304.122b. Both 304.122aand304.122bdo
not apply because the Noveon-Henry
Plant clearlyhas an untreatedwasteload with a population equivalentless than
50,000 based on all
relevant calculations.
Extensive efforts have beenmade by Noveonand its consultants-over-thelast 14 years in examining
effluent ammonia-nitrogen reductions. They have been undertakenin a good
faith attempt to
resolve a dispute with
the
IEPA and to evaluate whether therewere any feasible technologies that
would provide additional effluent ammonia-nitrogen reduction.
The
findings of effluent ammonia-nitrogen reduction efforts have been sharedwith IEPA and are
summarizedin Exhibits C, D, and E. These findings show the
following~
•
The Noveon-HenryPlant has at least
eight unique characteristics that render
it
unusually
difficult and expensive to achieve any further ammonia-nitrogen removal.
•
Every proven treatment process for effluent ammonia-nitrogen reduction has been
considered by the Noveon-Henry Plant, even one that was in the developmental stages.
•
Noveonhashad several consultants evaluate effluent
ammonia-nitrogen removal. These
have included a well-respected Illinois firm, a nationally-recognized engineering firm, and a
research professor from England.
•
No treatment technologywas found by IEPA or any of these consultants that could provide
significant effluent ammonia-nitrogen reduction (greater than
50
percent) for a present
worth cost of less than $5.0 million. Even a 25 percent effluent ammonia-nitrogen reduction
had a present worth cost of at least $1.8
million.
31
of32
•
The present worth cost of installing single stage nitrification, like facilities IEPA used in
cost
comparisons, was
$11.7 million. This
costwhencompared
to the surcharge cost imposed by
a POTW on ammonia-nitrogen indicated that the Noveon-HenryPlant costs for
ammonia-nitrogen removal would be
18 times greater than that for a POTW. This cost
difference was not
revealed in EPA
analysis due a lack of consideration given to
disproportionate operating costs.
In my professionalopinion, Noveon has gone far beyond that which Illinois regulations require in
evaluating effluent ammonia-nitrogen removal.Good faith and a willingness to work with IEPA
have been demonstrated. Fourteen years and considerable resources have been applied in an effort
to finda technically feasible and economically reasonable method to reduce effluent ammonia-
nitrogen at the Noveon-Henry Plant. An agreeable position with IEPA has been sought through
these efforts. Such
an agreement was not reached. If 304.122 is determined
to be applicable,
Noveon’s Petition forAdjusted Standard is reasonable and
should be supported by theBoard in
conformitywith Illinois regulations.
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