for an Adjusted Standard from

35

Iii. Adm.

Code 304.122

)

)

)

)

)

)

)

REcvF~

CLERK’S OFACE

FEB

~i

2004.

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

Exhibits to Expert

Written

Testimony

of Michael

R. Corn,

P.E.

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

312-569-1000

By:

One ofIts AttorneYy

•

BEFORE THE ILLINOIS POLLUTION CONTROL BOARI~TATEOF ILLINOIS

Pollution

Control

Board

IN THE MATTER OF:

Petition ofNoveon, Inc.

THIS FILING IS

SUBMITTED ON RECYCLED PAPER

---

CERTIFICATE OF SERVICE

The undersigned certifies

that a copy ofthe foregoing Notice

of Filing

and

Exhibits to

Expert Written Testimony ofMichael R. Corn, P.E.

was filed by hand delivery with the Clerk

of

the

Illinois

Pollution

Control Board

and

served

upon

the parties

to

whom

said

Notice

is

directed by

first

class

mail,

postage prepaid, by

depositing in the

U.S.

Mail at

191

N. Wacker

Drive,

Chicago, Illinois on Monday, February 9, 2004 and facsimile.

CHO1/12337055.1

---

RECE~VED

CLERI’S

OFFICE

FEB

-

92004

BEFORE

THE

ILLINOIS POLLUTION CONTROL BOARDSTATE OF

ILLINOIS

Pollution

Control Board

IN

THE

MATTER OF:

)

)

Petition ofNoveon, Inc.

)

)

AS 02-5

)

for an Adjusted Standard from

)

35

III. Adm. Code 304.122

)

EXHIBITS TO EXPERT WRITTEN TESTIMONY OF MICHAEL R CORN, P.E.

---

SPECIFIC WATER QUALITY

AND

RELATED EXPERIENCE

Mr.

Corn,

P.E.

has twenty-eight years

of experience as

an

environmental

engineering

consultant having worked on CWA,

CAA, RCRA, CERCLA,

and

TSCA related projects.

He is

currently

President

of AquAeTer,

Inc.

and

the

Technical

Director

for

the

company.

He

is

recognized as a leader in the fields ofwater

quality modeling and diffuser design, hazardous waste

management and remediation, and

air

emissions estimates

and permitting.

Mr. Corn has conducted water quality

studies and

assessments on over

200 streams, lakes,

and estuaries in the United States and internationally.

The studies

include wasteload allocations

and

Total

Maximum

Daily Load

(TMDL) studies

and analyses,

biological

inventory,

fish

advisory

analysis,

QUAL2E

dissolved

oxygen

and

WASP

dynamic

DO

modeling

studies,

hydrologic/hydraulic analyses, and dispersion and mixing

zone

analyses.

He also assists clients in

permit applications and negotiations; with

the goal ofreceiving the best technically

sound and cost

effective permits

possible for the client.

Mr.

Corn has

been

a leader in real-time permitting for

complex receiving stream effluent discharge scenarios.

Mr.

Corn

is

a

recognized expert

in

water

quality

and

water resource

studies.

He has

conducted water quality and quantity studies including modeling.

He has trained the Texas Water

Resources staffin radiotracerreaeration ofstreams, trained the West VirginiaDepartment ofNatural

Resources in wasteload allocation stream studies and QUAL2E modeling, and worked in cooperation

with Bob Ambrose and Tom Bamwell ofUSEPA,

Athens to provide the first calibration of the

USEPA

WASP

model.

He

has

previously

worked

with

Jim

Greenfield

of

the

Georgia

Environmental Protection Division (currently

TMDL Coordinator for USEPA, Region 4) and the

USGS in Doraville, Georgia to provide monthly wasteload allocations for the Conasauga Riverin

Dalton, Georgia, and provided through

a

State of Tennessee grant to the Duck River Agency a

monthly wasteload allocation for the Duck River near Columbia, Tennessee.

Mr. Corn is currently

working on a TMDL analysis for the Ouachita River in Arkansas and Louisiana.

He has previously

completed waste load allocations and TMDL analyses for the Turtle River in Brunswick, Georgia;

the Altamaha and Ocmulgee Rivers from Warner Robbins to Everett, Georgia; the Flint River/Lake

Blackshear from

Oglethorpe to Flintside,

Georgia; the Broad River/Lake Murray near Elberton,

Georgia; the GrandNeosho Riverin Oklahoma; theRed Riverin Arkansas and Oklahoma; the Duck

River near Columbia, Tennessee; the West Fork Stones River at Murfreesboro, Tennessee; and the

Saluda River/Lake Murray near Newbeny, South Carolina.

Mr. Corn has considerable experience

in effluent discharge dispersion and water quality analyses on diffusers and dispersion analyses in

rivers, estuaries, and oceans.

Mr. Corn has conducted radiotracerreaeration measurements on about

200 miles ofstreams, has used most water quality models, and has knowledge ofmost water quality

investigative and field procedures.

Mr.

Corn was Project Manager for radiotracer reaeration studies

conducted forNCASI

in Arkansas and Louisiana in 1980. The datawere used to developthe current

versions ofthe QUAL2E model.

Mr. Corn has

conducted over

40

mixing zone studies involving computer simulations, dye

tracing

and

diffuser design.

He has given expert testimony

before state regulatory agencies and

---

Michael

R. Corn, P.E.

Page2

President

beforehearingjudges on establishing mixing

zones,

impacts from discharges and defining mixing

in rivers, lakes, estuaries and oceans.

Specific experience includes mixing

zone studies

and

diffuser

designs for the Turtle

River in

Brunswick, Georgia, theChattahoochee River at Atlanta and Marietta,

Georgia, the Broad River/Russell Lake at Elberton, Georgia; the Mississippi Riverat Cordova, Alton

and

Sauget,

Illinois,

the

Illinois River at Joliet,

Ottawa,

and

Henry, Illinois, the Rock River at

Rockford

and

Joslin,

Illinois, the Green River near Sheffield,

Illinois;

the Ohio River at Mount

Vernon, Indiana, Lake Michigan

at

Whiting, Indiana; Fields Brook/AshtabulaRiver in Ashtabula

and Lake

Erie in Ashtabula, Ohio; Taunton River at Dighton, Massachusetts;

Quinnipiac River in

North

Haven,

Connecticut;

Arthur Kill in

Port

Reading, New Jersey, Atlantic Ocean off Toms

River, New Jersey, the Delaware River at Thorofare, New Jersey; the Allegheny River at Natrona,

Pennsylvania; the Kanawha River at Institute,

West Virginia;

the Cape Fear River near Castle

Hayne, North Carolina; the SaludaRiver/Lake Murray nearNewbeny, South Carolina; Hillsborough

Bay at Tampa, Florida, WestBay ofSt. AndrewBay,

nearLynn Haven, Florida; the Mill Creek and

the Cumberland River at Nashville, the Tennessee River at Counce, Tennessee, the White Oak Creek

and the Clinch Riverat Oak Ridge National Laboratory

; the Tennessee River at Decatur, Alabama,

the Alabama River near Burkville, Alabama, Huntsville

Spring Branch, Indian Creek on Redstone

Arsenal, Alabama; Black Creek Cooling Water Facility near Pascagoula, Mississippi, the Pearl

River at Monticello, Mississippi; the Tennessee River at Calvert City, Kentucky, the Green River

at Maxey Flats, Kentucky; the Red River near Valliant, Oklahoma; the Cedar River at Columbus,

Junction, Iowa; Hylebos Waterway at Tacoma, Washington; Amuay Bay at Amuay, Venezuela; and

the Mediterranean Sea offJaffa, Israel.

These studies have included dye, salt, radiotracer and other

tracer studies, near-field and far-field mixing regimes, modeling, diffuser designs for acute, chronic,

human health and wildlife criteria.

Constituents studied have included color, salt, ammonia, metals

including mercury, chromium, arsenic and lead, organics, temperature,

radionuclides, PCBs,

DDT,

lindane and

other pesticides/herbicides.

The studies

have

also

included biological inventories,

habitat analyses, macrobenthos investigations, mussel identification and

counts,

and uptake and

depuration studies of constituents from the water column, food sources and sediments within the

mixing zones.

Mr. Corn has conducted water quality studies and analyses for the Georgia Environmental

Protection

Division,

the

Texas

Water

Resources

Department,

the

Tennessee

Department

of

Environment

and Conservation,

West Virginia Department of Natural

Resources, the

Cities

of

Columbia,

Murfreesboro,

and Nashville,

Tennessee,

the

City of Columbus,

Ohio,

the

Cities of

Sauget, East Alton,

and

Rockford,

Illinois,

and the

Cities of Atlanta

and

Dalton,

Georgia; the

Department of Energy; and

Oak Ridge National

Laboratory.

These water quality

studies

were

usually in cooperation with the USEPA.

Mr.

Corn

is

a

co-holder ofan U.S.

Patent

for a hazardous waste treatment

system (U.S.

Patent No. 4,844,813 issued July 4,

1989).

This patented design was the only land treatment unit

to receive a Resource Conservation and Recovery (RCRA) Part B Permit in the State ofNew Jersey.

---

Michael R. Corn, P.E.

Page3

President

In 1993,

Mr. Corn received the

Engineering Excellence Award, along with an affiliate design firm,

from the Consulting Engineers Council ofIllinois

for work on a multiport diffusion

system for

treated wastewatereffluent forthe Rock River Water Reclamation District ofRockford, Illinois.

Mr.

Corn was responsible forthe field study to delineate the mixing zone and the modeling to determine

dispersion and the preliminary diffuser design.

The multiport diffusion system is an application of

waterresource engineering on inland waterways and provides a cost effectivemethod fordeveloping

rapid initial mixing and dispersion oftreated wastewater.

Mr. Corn was the Technical Director for

preparation of a

Title V

Permitting Manual

for the

wood treating

industry

sponsored

by

the

American Wood Preservers Institute (AWPI).

Mr.

Corn

has worked with industry, trade groups, municipalities, state governments, federal

agencies, and defense agencies.

He has worked on projects in over 40 states, 2 U.S. territories, and

20 foreign countries.

Mr. Corn is a Registered

Professional Engineer in Alabama,

Connecticut,

Delaware,

Florida,

Georgia,

Illinois,

Indiana,

Iowa,

Kentucky,

Louisiana,

Maine,

Maryland,

Massachusetts,

Minnesota,

Mississippi,

Missouri, Nevada, New Jersey, North

Carolina,

Ohio,

Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, Tennessee, Texas, Virginia, West

Virginia, and Wisconsin.

Mr. Corn has given expert opinions andlor testimony in Arkansas, Connecticut, Georgia,

Illinois, Louisiana, and Ohio on toxicity, waterquality impacts, mixing zones, diffuser designs and

expected dispersion, CERCLA and TCSA remediations, and

air emissions estimates.

Mr.

Corn

serves on the TAPPI Environmental Division as Secretary ofthe Program Committee and was the

past Chairman of the Water Quality Committee.

He is also a member ofthe Water Environment

Federation.

---

—

—

..

I

•

I

i~1ARSIIALF,

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---

I

1

ILLINOIS

RIVER

CONDUCTIVITY

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EFFLUENT

CONDUCTIVITY

=

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00

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FIGURE 2

AND

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FOR BOTTOM SPECIFIC

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280

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---

/R

ESTRA11 FICAT1ON

BUOYANT

_______PREADING

LI__H5

ZONE

FAR-RELD

ZONE

Ia

NEAR—REID

FAR-REID

“-I

To Define the Dispersion

from Effluent Momentum and Ambient Diffusion

~IOT

TQ

~1LE

~2IJ

FIGURE

3

HYDRAULIC

MIXING

CONCEPTS

ZONE

.

optlnrJrthg

ernkeflfllefltar

.‘escarces

wilier,

iii.

zør4h

JET

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(ZIIfl

ftOW

---

I

•~

-

NATIONAL

ACADEMY OF

SCIENCES,

WATER

QUALITY COMMITTEE, 1972

TIME

AND CONCENTRATION

CRITICAL

PARAMETERS IN

EXPOSURE SCENARIO

HYPUTHETICJ~LEXPOSURE

SCEFU~RIOFOR

FISH

PASSING THROUGH A~ID

V

FIGURE 4

HYPOTHETHICAL EXPOSURE FOR

FISH PASSING

THROUGH

ZID

cpt,’~r

eIi,ceale~aI

..ate..

.~r.

~~dt

UNF~SINrr~

nnrin~ri1r~Inn

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nnn

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m~L~

62

mm.

---

____________________________

I

ZONE OF

FLOW

PORT

CON CENTRAflON

PROFILE

AquAeTer

ZONE

OF FLOWESTABLISHMENT

~pt.rrTz~

e,i~rc~nea,~ai

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---

——

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_a

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FIGURE

6

SCEHMATIC FOR DISPERSION

FROM

A DIFFUSER

AMBIENT

CLIRRDIT

Uc

UNIFORM

DEHSIT?

PO&TIVELY

~JOYANT

FAR—FELO

AMUIENT

IJIFFUSION

---

Water Depth

=

28.6

ft

Velocity

=

1.51

fps

Distance

Downstream

(ft)

0.0

20.0

40.0

60.0

80.0

100.0

120.0

140.0

0.0

-2.0

-4.0

-6.0

-

-8.0

-10.0

-12.0

I

-14.0

-16.0

-18.0

-20.0

-22.0

-24.0

-26.0

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~

A

A

A

V

V

-30.0

-32.0

•

Centerline

a

Top

Edge

A

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•

FIGURE

7

MULTIPORT JET ZONE

AN

ALYSIS

DIFFUSER

~pt~t&e~

ni

rmro,e,,~a1

.ai,a. .~r

.tarii~

---

I

TMZ

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—100

0

100

200

300

400

500

600

700

800

900

1,000

1,100

1,200

1,300

1.400

1,500

1,600

1,700

DISTANCE

DOWNSTREAI~

FROM

OUTFALL

(if)

EFFLUENT

103

mg/I

LUNOIS

RIVER

BACKGROUND

0.6

mg/L

FIGURE

8

300

250

200

150

100

50

0

I-,

TOTAL

AMMONIA

DISPERSION

FOR

THE

NOVEON

SUBMERGED

SINGLE—PORT

DIFFUSER

—

SUMMER

---

•

•

•

•

•

•

•

•

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FIGURE

9

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ILLINOIS

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---

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