IN THE MATTER OF:
Petition ofNoveon, Inc.
for an Adjusted Standard from
35
Iii. Adm. Code 304.122
)
)
)
)
)
)
)
RECEIVED
CLERK’S OFFICE
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
Thursday, April 15,
2004, we filed the attached
Support
Requested By Illinois EPA for Data Referenced By Houston Flippin
with the
Illinois Pollution Control Board, a copy of which is herewith served upon you.
Richard J. Kissel
Mark Latham
Sheila H. Deely
GARDNER CARTON & DOUGLAS LLP
191 N. Wacker Drive
—
Suite 3700
Chicago, IL 60606
Respectfully submitted,
NOVEON, INC.
APR 15 2004
BEFORE
THE
ILLINOIS POLLUTION CONTROL BOARDS
POII~tj~~OFControlILUNOISBoard
AS 02-5
NOTICE OF FILING
By:
~
One ofIts Attome~
THIS FILING IS SUBMITTED ON RECYCLED PAPER
SUPPORT REQUESTED BY ILLINOIS EPA FOR DATA REFERENCED BY
HOUSTON FLIPPIN ON PAGES 12
AND
13 OF HIS TESTIMONY
2.0 METHODS AI41)
MATERIALS
Phase
I
consisted
of
characterization and batch treatabilitytesting ofthe five major wastestreams
and the primary clarifier effluent to evaluate their impact on biohydrolysis and nitrification by
activated sludge. A summary of the flow contributions by the individual wastestreams is
presented in Table 2-1.
2.1 Wastestream Sampling, Preparation, and Characterization
BF Goodrich collected grab samples of the contents of the PVC Tank, the PC Tank, the Pond,
C-18 Tank, Well No. 3 discharge, and primary clarifier effluent on September 28, 1995 ‘and
shipped them by overnight courier to ECKENFELDER INC.’s laboratory in Nashville,
Tennessee. All samples (except primary clarifier effluent) were subjected to the chemical
coagulation and sedimentation procedure provided in the WWTF as described below.
I. Adjustment to pH
9.5
standard units (s.u.) using either sodium hydroxide (NaOH) or
sulfuric acid (H2S04).
2. Addition of 300 ppm FeCl3 followed by a rapid mix time of4 minutes.
3. Addition of 1 ppm anionic polymer (DREWFLOC® 2205 manufactured by Drew
Industrial Division ofAshland Chemicals) followed by a rapid mix time of4 minutes.
4. Re-adjustment to pH 9.3 (±0.2)standardunits using either NaOH or H2S04.
5.
Gentlemixing (flocculation) for 18 minutes.
6. Settling for 90 minutes.
7. Decanting ofsupernatant for subsequent characterization and testing.
The primary clarifier effluent and pretreated samples of the PVC Tank contents, PC Tank
contents, Pond Water, Well No. 3 discharge, and C-l 8 Tank contents were then split into two
aliquots. One aliquot was preserved and analyzed for total carbonaceous biochemical oxygen
demand (TCBOD), total chemical oxygen demand (TCOD), total Kjeldahl nitrogen (TKN),
ammonia-nitrogen (NH3-N), nitrite-nitrogen (N02-N), nitrate-nitrogen (N03-N), morpholine,
Q.\938701\TSR
3
TABLE 2-1
WASTESTREAM ORIGIN
AND FLOW CONTRIBUTION
Wastestream Origin
FlowRate
Average
(gpm)
Range
(gpm)
Contributiona
()
Discharge from Pond
35
25
to 100
4
to
16b
Well No.
3
7
7 to 11
1
to
2
Discharge from C-I
8
Tank
7
2
to
14
0
to
2
Discharge from
PVC
Tank
450
330
to
490
54
to
80
DischargefromPCTank
Combined Wastestream (i.e.,
Primary Clarifier Effluent)
110
90to140
15to23
609
454
to
755
a1~ngeofcontribution to primary clarifier effluent based on a combined average primary clarifier effluent
flowrate of609 gpm.
bBold typeindicates target peak flowcontribution used in batchtreatability tests.
Q:’938701\TSTO2OI
Page I oil
and total alkalinity. The methods of preservation and analysis for these parameters are
summarized in Table 2-2. The remaining aliquot of primary clarifier effluent and of the
pretreated wastestreams was kept refrigerated until used in the batch biohydrolysis test and the
first set of batch nitrification tests.
BF Goodrich also collected grab samples of primary clarifier effluent, the PVC Tank contents,
and PC Tank contents on October 19, 1995 and shipped them via overnight courier to
ECKENFELDER JNC.’s laboratory in Nashville, Tennessee. The PVC Tank contents and the PC
Tank contents were pretreated in the same manner as described above. The primary clarifier
effluent and the pretreated PVC and PC Tank contents were split into two aliquots. One aliquot
was preserved and analyzed for TCBOD, TCOD, TKN, NH3-N, and combined nitrite- plus
nitrate-nitrogen (N02-N plus N03-N). The remaining aliquot was refrigerated until used in the
second set ofbatch nitrification tests.
BF Goodrich recorded the flows of all wastestreams at the time of sampling. These flows were
coupled with wastestream characterization data to calculate the flow and load contribution of
each wastestream to the combined wastestream as monitored at the primary clarifiereffluent.
2.2 Biomass Preparation
Two types of biomass were used in the treatabilily testing as illustrated in Figure 2-1:
BF Goodrich biomass and “nitrifier-rich” biomass. BF Goodrich biomass was used in both the
batch biohydrolysis test and the batch nitrification tests. The nitrifier-rich biomass had been
cultured in ECKENFELDER INC.’s laboratory for over two years and was used only in the batch
nitrification tests.
Both biomasses were acclimated to test conditions of 3 mg/L DO,
pH 7.7 ±0.2standard units, 22 ±2°C(for batch biohydrolysis tests), and 32±2°C(for batch
nitrification tests) as described below.
BF Goodrich collected grab samples of primary clarifier effluent and return activated sludge
(RAS) on September28, 1995 and October 19,
1995,
and shipped them to ECKENFELDER INC.’s
laboratory in Nashville, Tennessee. Upon arrival, the RAS was aerated at 3 mg/L DO for
1.0 hour to “freshen” the biomass. During aeration, the RAS was adjusted to pH 7.7 standard
units using NaOH. Aeration was then shut off and the mixed liquor was allowed to settle for one
hour. Sixty percent of the initial volume was decanted and replaced with primary clarifier
effluent which had been spiked with 35 mg P/L using phosphoric acid (H3P04). Aeration was
then restored andthe RAS was aerated for 24 hours at a mixed liquor DO and pH of3 mg/L and
Q:\938701\TSP.
4
TABLE 3-I
SUMMARY OF WASTESTREAM CHARACTERIZATION RESULTS
Sample
Wastestrearn Origin
PVC Tanka
PC
Well
C- 18 Tanka
Primary
Collection
Parameter
Tanka
ponda
No. 3~
Clarifier
Date
Effluent
9-28-95
Flow, gpm
377
109
14
7
10
517
Flow,
of Primary Clarifier
73
21
3
1.4
1.9
--
Effluent
10-19-95
Flow, gpm
412
98
9
7
8
534
Flow,
ofPrimaryClarifier
77
18
2
1.3
1.5
--
Effluent
Flow,
,
Evaluated During
8 to 80
0.2 to 23
15 to 16
1.7 to 1.8
1.7 to 1.8
0.8 to 85
TreatabilityStudies
9-28-95
Total Alkalinity, mgIL
340
1,120
30
510
4,300
550
9-28-95
TCBOD, mgIL
131
1,998
4
52
6,390
669
TCBOD, b
14
63
0
0
18
(95)C
10-19-95
TCBOD, mg/L
114
1,140
NAd
NA
NA
390
TCBOD,
23
54
NA
NA
NA
(77)
9-28-95
TCOD, mg/L
410
4,900
25
90
17,200
1,840
TCOD,
16
56
0
0
18
(90)
10-19-95
TCOD, mg/L
545
5,800e
NA
NA
NA
1,350
TCOD,
31
79
NA
NA
NA
(110)
9-28-95
TKN,mg/L
81
290
1
10
820
150
TKN,
39
41
0
0
11
(91)
10-19-95 TKN, mg/L
59
270
NA
NA
NA
100
TKN,
46
50
NA
NA
NA
(96)
9-28-95
NH3-N, mg/L
50
31
0.6
3
280
51
NH3-N,
71
13
0-
0
1
(85)
10-19-95
NH3-N, mg/L
39
42
NA
NA
NA
39
NH3-N,
77
20
NA
NA
NA
(97)
9-28-95
Morpholine, mgIL
37
418
1
16
1,880
169
Morpholine,
16
52
0
0
22
(90)
9-28-95
N02-N, mg/L
0.1
0.1
0.2
0.1
7.6
0.1
N02-N,
Nd’
NC
NC
NC
NC
(NC)
9/28/95
N02-N
+
N03-N, mgIL
0.1
Il
28
0.3
13
0.1
N02-N+N03-N,
73
100
100
4
1
(100)
10-19-95
N02-N
+
N03-N, mg/L
0.1
11
NA
NA
NA
0.1
N02-N
+
N03-N,
77
100
NA
NA
NA
(100)
Q\9387Ol\TSTO3OI
Page I of2
TABLE 3-I (Continued)
SUMMARY OF WASTESTREAM CHARACTERIZATION RESULTS
Sample
Wastestrearn Origin
PVC Tanka
PC
Well
C-I 8 Tanka
Primary
Collection
Parameter
Tanka
ponda
No. 3a
Clarifier
Date
Effluent
9-28-95
Organic NitrogenS, mg/L
Organic Nitrogen,
31
23
259
55
0
0
7
0
540
II
99
(89)
10-19-95
Organic Nitrogen, rng/L
Organic Nitrogen,
20
25
228
69
NA
NA
NA
NA
NA
NA
61
(94)
aCharacte~.j~ationfollowing sample pretreatment described in Section 2.1.
bContrjbution of individual wastestreams to measured primary clarifier effluent load.
CValues in parentheses represent percentage calculated by summing contributions of individual wastestreams,
dNot analyzed.
eValue determinedby BFG at time ofsampling.
~Notcalculable.
gCalculated as difference between TKN andNH3-N concentrations.
Q:\9387 Ol\TSTO3OI
Page 2 of2
Wastestream
PVC Tank PC Tank
C-i8 Tank Well No. 3
Total
Table 2-1
Average Flowrate,
gpm
Maximum, gpm
Minimum, gpm
Factor
Factored Average
Factored Maximum
450
110
7
490
140
14
330
90
2
0.89
0.97
0.86
401
107
6
42
609
III
755 Essentially used these maximums as future maximums.
32
454
1.10
Factor used to scale to future based on discussions with Noveon.
46
560
Table 3-1
9/2812004 Flow, gpm
10/19/2004 Flow, gpm
Average
Maximum
Factor
Factored Average
Factored Maximum
Presented Average, gpm
Presented Maximum, gpm
401
107
499
150
6
46
560
15
105
769
Table 3-1
9/28/2004 TCBOD, mg/I
10/19/2004 TCBOD, mg/L
Average, mg/L
Maximum, mg/L
9/28/2004 TCBOD, lbs/day
10/19/2004 TCBOD, lbs/day
Average (9/28-10/19), lbs/day
Design Average, lbs/day
Factor
Design Maximum, lbs/day
Factor
Presented Average, lbs/day
Presented Maximum, lbs/day
131
1998
6390
114
1140
NA
123
1569
6390
131
1998
6390
593
2613
767
564
1341
578
1977
767
589
2015
460
1.35
1.23
0.86
784
3596
1150
1.66
0.90
0.77
795
2485
395
1300
3250
880
5
3978
5
3327
11
1.36
25
0.60
15
3690
15
5445
9/2812004 TCOD, mg/I
10/19/2004 TCOD, mg/L
Average, mg/L
Maximum, mg/L
9/28/2004 TCOD, lbs/day
10/19/2004 TCOD, lbs/day
Average (9/28-10/19), lbs/day
Design Average, lbs/day
Factor
410
4900
17200
545
5800
NA
478
5350
17200
545
5800
17200
1855
6409
2064
2694
6821
2275
6615
2064
2298
6869
1238
1.15
1.21
1.07
47
NA
47
47
12
10340
12
10966
26
10431 Design Ave.FlowX Ave. Meas. Conc.
1.93
Factor used to scale to future based on discussions with Noveon.
377
109
10
21
517
412
98
8
16
534
395
104
9
19
526
20
NA
20
20
Design Ave.FlowX Ave. Meas. Conc.
Factor used to scale to future based on discussions with Noveon.
Design Max.FlowX Max. Meas. Cone.
Factor used to scale to future based on discussions with Noveon.
Wastestream
PVC Tank PC Tank C-I8 Tank Well No. 3
Total
Design Maximum, lbs/day
3263
10440
3096
59
Design Max.Flow X Max. Meas. Cone.
Factor
1.33
1.04
0.96
0.84
Factor used to scale to future based on discussions with Noveon.
Presented Average, lbs/day
2650
8280
1320
50
12300
Presented Maximum, lbs/day
4330
10840
2940
50
18160
9/28/2004 TKN, mg/I
81
290
820
4
10/19/2004 TKN, mg/L
59
270
NA
NA
Average, mgiL
70
280
820
4
Maximum, mg/L
81
290
820
4
9/28/2004 TKN, lbs/day
366
379
98
1
845
1011 9/2004 TKN, lbs/day
292
318
Average (9/28-1 0/1 9), lbs/day
329
348
98
1
777
Design Average, lbs/day
337
360
59
2
758 Design Ave. Flow X Ave. Meas. Cone.
Factor
1.36
1.37
1.39
1.36
Factor used to scaleto future based on discussions with Noveon.
Design Maximum, lbs/day
485
522
148
5
Design Max.FlowX Max. Meas. Cone.
Factor
1.32
1.33
1.34
1.39
Factor used to scale to future based on discussions with Noveon.
Presented Average, lbs/day
459
494
82
3
1038
Presented Maximum, lbs/day
640
693
198
7
1538
9/28/2004 Nl13-N, mg/I
50
31
280
1.2
10/19/2004 NH3-N, mg/L
39
42
NA
NA
Average, mg/L
45
37
280
1
Maximum, mg/L
50
42
280
1.2
9/28/2004 TCBOD, lbs/day
226
2461
6935
0
9622
10119/2004 TCBOD, lbs/day
193
49
Average (9/28-10/19), lbs/day
210
1255
6935
0
8400
Design Average, lbs/day
214
47
20
I
282 Design Ave.FlowX Ave. Meas. Cone.
Factor
1.38
1.32
1.34
1.51
Factor used to scale to future based on discussions with Noveon.
Design Maximum, lbs/day
299
76
50
2
Design Max.FlowX Max. Meas. Cone.
Factor
1.37
1.15
1.31
1.98
Factor used to scale to future based on discussions with Noveon.
Presented Average, lbs/day
295
62
27
1
385
Presented Maximum, lbs/day
411
87
66
3
567
CERTIFICATE OF SERVICE
The undersigned certifies that a copy ofthe foregoing Notice
of Filing
and
Support Requested
By Illinois EPA for Data Referenced By 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 Thursday, April
15,
2004.
A4~L
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