AS99-~

(Adjusted

Standard)

NOTICE OF FILING

To: Attached

Service List

PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the Pollution

Control Board the Petition for Adjusted

Standard of Illinois-American Water Company

and

Appearances of Nancy

J. Rich and James

E.

Mitchell, copies of which are herewith served

upon you.

Nancy

March

19,

1999

Katten Muchin &

Zavis

525

W.

Monroe

Street

Suite

1600

Chicago, Illinois

60661-3693

312-902-5200

THIS FILING IS SUBMITTED

ON

RECYCLED PAPER

q

-~

—

~

POLLUTION

CONTROL

BOARDRECEIVEO

CLERK’S

OFFICE

MRR

1

91999

STATE OF ILLINOIS

pollution Control

Board

BEFORE THE ILLINOIS

PROPOSED ADJUSTED STANDARD

APPLICABLE TO ILLINOIS-

AMERICAN WATER COMPANY’S

ALTON PUBLIC WATER SUPPLY

REPLACEMENT

FACILITY

DISCHARGE TO THE MISSISSIPPI

RIVER

)

)

)

)

)

)

)

)

Doe #:CH02

(03879-00005) 924925v1 3/I 8/1999/Tinie:14:24

---

SERVICE LIST

Dorothy

M.

Gunn

Illinois

Pollution

Control Board

James

R.

Thompson Center

100W.

Randolph St.,

Ste.

11-500

Chicago,

Illinois

60601

IEPA Division of Legal

Counsel

1021

North Grand Avenue

East

Springfield,

Illinois

62794

Attn:

Lisa

E.

Moreno,

Esq.

Assistant Counsel

Robert Lawley, Esq.

Chief Legal

Counsel

Illinois

Department of Natural Resources

524

5~

2nd

Street Room

400

Springfield,

Illinois

62701

---

RECEIVED

CLERK’S

OFF’CE

MI4R

1

9

1999

BEFORE THE ILLINOIS POLLUTION

CONTROL BOARDSTATE OF

ILLINOIS

Poj/~j0,,Contr0j Board

IN THE MATTER OF:

)

PROPOSED ADJUSTED

STANDARD

APPLICABLE TO ILLINOIS-

)

AMERICAN WATER COMPANY’S

)

ALTON PUBLIC WATER SUPPLY

AS 99-

REPLACEMENT

FACILITY

)

(Adjusted

Standard)

DISCHARGE TO THE

MISSISSIPPI

)

RIVER

)

APPEARANCE

I hearby file my

appearance

in this proceeding,

on

behalfof Illinois-American Water

Company.

~rch1;i!99

Katten Muchin & Zavis

525

W.

Monroe Street

Suite

1600

Chicago, Illinois

60661-3693

312-902-5200

Doc #:cHO2

(03679.00005) 924645v1;3/16/lD99Tflme:14:27

---

CLrRK~Ive~

MAp

1

9

~

BEFORE THE

ILLINOIS POLLUTION

CONTROL BOAR~SlEifl

~

c

°~tro/

IN THE

MATTER

OF:

)

PROPOSED ADJUSTED STANDARD

)

APPLICABLE TO ILLINOIS-

)

AMERICAN WATER COMPANY’S

)

ALTON PUBLIC WATER SUPPLY

AS

99-

REPLACEMENT

FACILITY

)

(Adjusted

Standard)

DISCHARGE TO THE MISSISSIPPI

)

RIVER

)

APPEARANCE

I hearby file my

appearance

in this

proceeding,

on behalf of Illinois-American

Water

Company.

~.Mitchell

Katten Muchin &

Zavis

525

W.

Monroe Street

Suite

1600

Chicago,

Illinois 60661-3693

312-902-5200

---

RECEIVED

CLERK’S

~ppirr

BEFORE

THE

ILLINOIS POLLUTION

CONTROL BOARD

MAR

191999

IN THE

MATTER

OF:

STATE OF ILLINOIS

PROPOSED

ADJUSTED STANDARD

APPLICABLE

)

AS

9?0~Wb0h1

Control

Board

TO

ILLINOIS-AMERICAN WATER COMPANY’S

)

(Adjusted

Standard)

ALTON

PUBLIC WATER

SUPPLY REPLACEMENT

FACILITY DISCHARGE TO THE

MISSISSIPPI

RIVER

PETITION FOR ADJUSTED

STANDARD

Petitioner,

Illinois-American

Water

Company

(“Water

Company”),

by

its

attorneys, Katten Muchin & Zavis, pursuant to Section 28.1

ofthe Illinois Environmental

Protection

Act

(“the Act”),

415

Ill.

Comp.

Stat.

5/28.1

(formerly Ill.

Rev.

Stat.

1991,

ch.

111 ½,

para.

1028.1),

and

Part

106 of the Procedural Rules

of the Illinois Pollution

Control Board

(“Board”),

35

Ill.

Adm.

Code

Part

106,

respectfully

requests

the Board

to

grant

an

adjusted

standard from

35

III.

Adm.

Code

304.124

for

discharges of total

suspended

solids

(“TSS”)

and

total

iron

(“iron”)

for

the

Water

Company’s

proposed

replacement public

water

supply

treatment

facility

(“replacement

facility”)

located

in

Alton,

Madison County,

Illinois.

The Water Company also

requests the Board to

grant,

to

any

extent

it

deems

necessary

to

fashion

complete

relief,

an

adjusted

standard

from

two additional sections of its regulations:

1)35

III.

Adm.

Code

304.106,

which provides

in

relevant part

that

no

effluent

shall

contain

settleable

solids

or

sludge

solids,

and

that

turbidity

must

be

reduced

below

obvious

levels;

and

2)

the

analogous

water

quality

provision,

35111.

Adm.

Code

302.203,

which provides

in relevant part that waters of the

State

shall

be

free

from

sludge or bottom

deposits

and

turbidity

of

other than

natural

---

origin.!’

In

support

of

its

Petition

for

an

Adjusted

Standard

(“Petition”),

the

Water

Company

states

as follows:

BACKGROUND

1.

Section

28.1

of the

Act

enables the Board

to

approve adjusted

standards

to

regulations

of general

applicability

for

persons

who

can justify

such an

adjustment

consistent

with

subsection

(a) of Section

27

of the

Act.

Section

27(a)

provides

that:

In promulgating regulations under this

Act, the Board

shall

take

into

account

the

existing

physical

conditions,

the

character of the area

involved,

including

the

character

of

surrounding land

uses,

zoning classifications,

the nature of

the existing

air quality,

or receiving body

of water, as the

case

may

be,

and

the

technical

feasibility

and

economic

reasonableness of measuring or reducing the particular type

of pollution.

415

Ill.

Comp.

Stat.

5/27(a).

2.

Pursuant

to

this

grant

of

authority,

the

Board

promulgated

procedural

regulations

for the approval

of adjusted

standards.

See

35

Ill.

Adm.

Code

106.701

et

seq.

Specifically,

Section

106.703

of the

Board’s

Procedural

Rules

provides

that

any

person may

singly orjointly

with the Illinois

Environmental

Protection

Agency (“Illinois

EPA”)

file

a

written

petition

for

an

adjusted

standard.

In addition,

Section

106.705

identifies the content requirements of the adjusted standard petition.

Those requirements

None of the four public

water supply

facilities to

which the Board

has previously granted relief (the existing

Alton facility, and the facilitieswhich serve Rock Island,

East

Moline,

and East St. Louis) have sought relieiframtther

of these

regulatory provisions.

As

discussed herein,

the

Water

Company

also

believes

that

the replacement facility’s

discharge

will

not

be

substantively

different

from

those

of

the

public

water supply

facilities

to

which

the

Board

has

already granted

relief.

The

Water Company

is

also unaware

that exemptions from these sections have been sought

by

any

of

the

other

dischargers

to

waters

of

the

State

whose

effluent

contains

settleable

solids.

Nonetheless,

at

the

suggestion of Illinois

EPA

the Water Company

seeks relief from

these regulatory provisions

in order to

ensure:complexe

relief.

2

---

and

other

relevant

regulatory

provisions

are

discussed

under

the

applicable

headings

below.

3.

The

Water

Company

files

this

Petition

because

it

intends

to

construct

a

public

water supply

treatment

facility in

Alton,

Madison

County,

Illinois

to

replace the

existing

facility

in

Alton

(“existing

facility”),

which

was

inundated

by

the Mississippi

River

(the

“River”)

in

1993

and

threatened

again

in

1995.

The Water

Company seeks

to relocate its existing facility to minimize the potential

for future flooding and to replace

the

aged facility.

The severity of the

1993

flood,

which

shut

down the facility

for four

days

and

required

consumers

to

boil

their

water

for

ten

days,

is

documented

in

the

photographs

provided

as Attachment

A hereto.

4.

The Water Company has conducted

a Site-Specific Impact Study (“SSIS”),

attached

hereto

and

incorporated

by

reference

as

Attachment

B,

to

address

the

site

specific / adjusted standard factors enumerated

in Section 27(a) of the Act.

These factors

include

the character of the

raw water

(i.e.,

Mississippi

River),

environmental

impact,

technical

feasibility,

and

economic

reasonableness

of

potential

alternatives.2’

In

September,

1996,

the Water Company met with

Illinois EPA

to

discuss a draft workplan

for conducting

the SSIS.

The Water

Company

thereafter developed

the draft workplan

In addition to

the adjusted

standard

factors listed

in

the

Act,

the

SSIS

also anticipated and addressed the

Best

Professional

Judgment

(“BPJ’)

standard

that,

during

any future

permit

process,

Illinois

EPA

must apply

pursuant

to

Section

402(a) of the federal Clean water

Act’s National Pollutant Discharge

Elimination System (‘NPDES”) program,

33

U.S.C.

§

1342(a).

Please note that even though

BPJ

is

a permit

requirement,

it provides a means of setting effluent

standards

for an

individual discharger,

which

is exactly what

the Water Company

is

asking the Board to

do

here for the

replacement facility.

As applied to public

water supply

discharges,

the BPJ permit factors overlap many

of the

adjusted

standard factors--e.g.,

the technical

feasibility and economic reasonablenessof reducing the particular type of pollution,

and other unique

factors

such

as existing physical conditions.

Also

note that, with

the exception of the Section

28.3 and

Best

Degree of Treatment (‘BDT)

(35

III.

Adm.

Code

304.102)

factors

discussed below,

there

are

no

other

directly

relevant standards for evaluating the merits of a public water supply

facility’s request for relieffrom the Board’s

general

industrial

effluent standards.

3

---

and

forwarded

it

to

Illinois

EPA

for

review

and

comment.

The

Water

Company

incorporated

Illinois

EPA’s

comments

in

the

final

SSIS

workplan.

Due

to

a

change

in

project

location

from

Godfrey,

Illinois

to

Alton,

Illinois

to

capture

a

greater

than

six

million dollars

savings

in

pipeline

and

construction

costs,

the Water

Company

met

with

Illinois

EPA

in August,

1997 to revisit the

SSIS

workplan to

identify any

additional site-

specific

factors

for

the

replacement

facility.

As

a

result

of this

meeting,

a

habitat

characterization/protected

species

survey for

mussels

was

added

to

the

workplan.

See

SSIS

at Appendix

B.

Pursuant

to

a

follow-up

meeting

and

subsequent

correspondence

with

Illinois

EPA,

the

Water

Company

performed

and

incorporated

into

the

SSIS

a

Discharge

TSS Modeling

Evaluation, which

also

included a

Particle Deposition Study.

See

SSIS

at Appendix

F.

5.

The SSIS provides a brief description of the existing facility and

a general

design of the proposed replacement facility.

The design,

together with the results ofpilot

facility

testing,

was

used

to

develop

estimates

of

effluent

flows

and

concentrations

anticipated

from

the replacement

facility.

The proposed

10.5

million gallons

per

day

(“MGD”)

annual average

flow replacement

facility will

have

two

processes generating

effluent discharges

(plus a periodic

cleaning-related maintenance

discharge), which

were

identified as potentially

requiring

treatment

to

meet

TSS

and

iron

standards.

6.

Pursuant

to

the

site-specific

rule

codified

at

Section

304.206

of

the

regulations,

the existing

facility has

no

effluent limitations for TSS

and

iron.

The

Board

granted this

site specific

relief in

1984 as

follows:

Section

304.206.

Alton

Water

Company Plant

Discharges.

4

---

This

Section applies to

the existing

18.3

million gallons

per day potable

drinking

water treatment

plant

owned by

the

Alton

Water

Company

which

is

located at,

and

discharges into, river

mile

204.4

on

the Mississippi River.

Such

discharges

shall

not

be

subject to

the effluent

standards

for total

suspended

solids and

total

iron

of 35

III.

Adm.

Code

304.124.

35

Ill.

Adm.

Code

304.206.

A

copy

of the

Board’s

final

Opinion

and

Order

in

that

case,

PCB

82-3,

is

appended

hereto

as

Attachment

C.

The

Board

subsequently

granted

relief

from

its

general

industrial

effluent

standards

to

all

of the other public

water

supply

facilities

located on

the River

in

Illinois

that

do

not

use lime

to

soften

the

raw

water

--

i.e.,

Rock

Island,

Moline

and

East

St.

Louis.

Copies of the Board’s

final Opinions

and

Orders

in

those

cases

are appended

hereto

as

Attachment

D

(Rock

Island,

PCB

AS

91-13,

October

19,

1995),

Attachment

E

(East

Moline,

PCB

AS

91-9,

May

19,

1994)

and

Attachment F

(East

St.

Louis,

PCB

AS

91-11,

May

20,

1993).

7.

Rock

Island,

East

St.

Louis

and

East

Moline

all

obtained

adjusted

standards pursuant to

Section 28.3 of the Act,

415

III. Comp.

Stat.

5/28.3.

Section 28.3

was

intended

to

prompt

a

quick

resolution

of

existing

public

water

supply

facilities’

inability

to

meet

the

general

effluent

standards

absent

installation

of

potentially

economically

infeasible technology and

thus

the

filing deadline relief under Section 28.3

has

passed.

Nonetheless,

the factors

that

the legislature directed

the Board

to

consider

under Section

28.3

continue

to

be relevant

to public

water

supply

facilities

which do

not

use lime softening and receive their raw water supply

from the highly turbid

and variable

River.

These

highly relevant Section

28.3

factors include:

An adjusted

standard

...

shall

be

based

upon

water

quality

effects,

actual

and

potential

stream

uses,

and

economic

considerations,

including

those

of

the

5

---

discharger

and

those

affected

by

the

discharge.

...

Justification

based

upon

discharge

impact shall

include,

as a

minimum,

an

evaluation of receiving stream

ratios,

known

stream uses,

accessibility

to

stream

and

side

land

use

activities

(residential,

commercial,

agricultural,

industrial,

recreational),

frequency

and

extent

of discharges,

inspections

of unnatural

bottom

deposits,

odors,

unnatural

floating

material

or

color,

stream

morphology

and

results

of

stream

chemical

analyses.

Where

minimal

impact

cannot be

established,

justification

shall

also

include

evaluations

of

stream

sediment

analyses,

biological

surveys

(including

habitat assessment),

and thorough

stream chemical

analyses that

may

include

but

are

not

limited

to

analysis of parameters regulated

in

35

Ill.

Adm.

Code

302.

415

III.

Comp.

Stat.

5/28.3.

8.

The National Pollution

Discharge Elimination

System

(“NPDES”) permit

for the existing facility requires daily monitoring of flow and monthly monitoring of PH,

TSS,

iron

and

total

residual chlorine

(“TRC”).

An

effluent

limitation

exists for pH of

6.0

to

9.0

standard

units

(“SU”).

As

a

result of the site-specific rule

applicable to

the

existing

facility,

no

treatment

is

required

for

the

discharge

effluent

except

for

dechlorination,

which

was

implemented

in

November

1998

as required

by

the facility’s

NPDES

permit.

9.

The existing facility directly

returns

to

the River the residual natural

silts

and

sediments

contained

in

the raw

River water,

along

with

a very

small

percentage

of

water treatment

additives

used

to

treat the raw water

--

i.e.,

the percentage of naturally-

occurring material

in

the

total

solids

returned

to

the

River

is

typically

91

or greater.

SSIS

at 6-2.

The remaining 8.7

of total

solids

are contributed by

the coagulant.

Of

this,

only

a trace amount

is

comprised of any of metals of concern (aluminum),

and

this

is

only about one third of one percent

(0.348)

of the facility’s

solids

discharge.

This

percentage

is

comparable

to

that

achieved

at

the Water

Company’s

East

St.

Louis

water

treatment

facility, which

uses these same coagulants and,

pursuant to an adjusted standard

6

---

codified

at

35

Ill.

Adm.

Code

304.220,

also

returns

its

discharge

solids

to

the

River.

The other

99

2/3

percent of the discharge solids

are derived directly

from

the raw River

water or are from

coagulant constituents

that

are

not

comprised of any

of the metals

of

concern

--

i.e.,

non-metal,

biodegradable

polymer

constituents,

and

trace

amounts

of

inorganics

(primarily

sulfates).

SSIS

at

6-2.

In

addition,

the

mussel

habitat

characterization found that

the area does not

support

any

unionid communities

(Id.

at

4-4

and

5-2I),

and

that

there

are

no

discernable

impacts

from

silt deposition

(Id.

at

5-

10).

The Discharge

TSS Modeling Evaluation also

found

no

adverse impacts

from

the

discharge

of the residuals

into the River.

Id.

at 5-22 to

5-23.

10.

Rather

than

subject

the

replacement

facility

to

Board

regulations

with

which

no

other similarly situated

public

water

supply

facility has

ever been required

to

comply,

an

adjusted

standard

should

be

developed

through

analysis of the site-specific

factors

specified

in

Sections

28. 1,

27(a)

and

28.3

of the

Act

and

pursuant

to

the

Best

Professional Judgment (“BPJ”) requirements of Section 402(a) of the federal Clean Water

Act

(“CWA”),

33

U.S.C.

§

1342(a).2’

BPJ

for public water supply

facilities

is

established

by

applying

the

factors

listed in

40 C.F.R.

§

125.3(c)(2),

which applies

to

facilities or categories of facilities for which there

are no federal eftluent standards.

BPJ

is

reached

by

considering:

(i)

the appropriate technology

for

the category or class of point sources of which

the applicant

is

a member

(e.g.,

public

water supplies

on large,

turbid rivers), and (ii) any unique

factors

relating

to

the applicant

(e.g.,

it

does not

use lime

softening).

Two other elements must also be considered in determining

BPJ:

best practicable control technology

currently

available (“BPT)

and best

conventional

pollutant

control

technology (BCT’).

40

C.F.R.

§

125.3(d).

BPT factors are:

(i)the total

cost of application of technology in relation to the effluent reduction benefits

to be acthin~d

from such application;

(ii)

the age

of equipment and facilities involved;

(iii)

the process employed;

(iv)

the engineering

aspects

of

the

application

of

various

types

of

control

techniques;

(v)

process

changes;

and

(vi)

non-water

quality

environmental

impact (including

energy

requirements).

40 C.F.R.

§

l25.3(d)(l).

The

BCT

analysis

includes the BPT

issues and one additional

factor:

the comparison of the cost and level of reduction of such pollutants

from

the discharge

from publicly owned

treatment works to

the

cost and level of reduction of such

pollutants frorin ctas~crce~tegtnyuf

industrial

sources.

7

---

INFORMATIONAL REQUIREMENTS

Description of the Regulation of General Applicability

11.

Section

106.705(a) of the Procedural Rules provides that

the petition must

describe the standard from which

an

adjusted

standard

is

sought.

This

shall

include

the

Administrative

Code

citation

to

the

regulation

of

general

applicability

imposing

the

standard

as

well

as

the

effective

date

of that

regulation.

The

regulation

of

general

applicability,

Section 304.124

of the Board’s Water

Pollution Regulations,

35

Ill.

Adm.

Code

304.124,

establishes

effluent

standards

which

are applicable

to

dischargers

to

the

waters

of

the

State

of Illinois.

The

Water

Company

seeks

an

adjusted

standard

for

discharges of iron and

TSS.

Section 304.124 establishes a discharge limitation of 2 mg/l

for total

iron

and

15

mg/I for TSS.

Section 304.106

of the Board’s effluent

standards,

35

III.

Adm.

Code

304.106,

provides

in

relevant

part

that

no

effluent

shall

contain

settleable

solids

or

sludge

solids,

and

that

turbidity

must

be

reduced

below

obvious

levels.

The

analogous

water

quality

provision,

Section

302.203,

35

Ill.

Adm.

Code

302.203,

provides

in

relevant part

that

waters of the

State

shall

be

free from

sludge

or

bottom

deposits

and

turbidity of other

than

natural

origin.

12.

The effluent limitations provided in Section 304.124 apply to

all discharges

to

waters of the

State of Illinois,

regardless of the nature of the receiving

stream or the

environmental

impact of the discharge.

The Board’s

effluent

standards,

including

the

iron

and

TSS

limitations now codified

at Section

304.124,

became effective on

January

6,

1972.

See

Opinion of the Board,

PCB

R 70-8

ci’

al.,

Jan.

6,

1972,

a

copy of which

8

---

is

appended

hereto

as

Attachment

GY

These

standards

were

not

developed

on

an

industrial

category

basis

like

the

subsequent

federal

effluent

standards.

As

a

result,

certain dischargers,

such

as

public

water supplies

located

on

large rivers,

are subject to

two potentially contradictory standards for obtaining their NPDES discharge permit

--

the

generally applicable

Illinois effluent

standards and the federal

BPJ

requirement tin-der the

CWA.

As noted on page

1,

above, the Water Company seeks relief,

as theBoard deemsnecessary,

from the effluent standard

ofSection

304.106 and the water quality standard of Section 302.203.

In

1972, the Board promulgated a general eftluent

standard

for

“Offensive

Discharges,”

now codified at Section

304.106.

Opinion of the Board,

PCB

R

70-8

et a!.,

Ian.

6,

1972,

at

5;

35

Ill

Adm.

Code

304.106.

This

effluent standard

was

adopted

from

the earlier Sanitary

Water Board

prohibition

on the discharge of nuisance materials to any waters,

which required the equivalent

of-primary-treatment-for

all

discharges.

Opinion of the Board,

PCB

R

70-8

eta!.,

Jan.

6,

1972, at

5.

In support

of the prohibition

of Offensive

Discharges,

the

Board stated

that

“a

nuisance

anywhere is unacceptable.”

Id.

Specifically,

the Offensive

Discharge

effluent

standard, now codified

at

Section

304.106,

provides that:

No effluent shall contain

settleable solids,

floating debris,

visible oil, grease,

scum

or

sludge

solids.

Color,

odor

and

turbidity

must

be

reduced

to

below

obvious

levels.

35111. Adm.

Code

304.106.

In the same

1972 rulemaking,

the Board adopted

an analogous water quality

standard for

“Offensive

Conditions,” which

similarly

restricted

nuisance conditions, and which

is

now

coditied at Section

302.203:

Waters of

the

State

shall

be free

from sludge

or

bottom deposits,

floating debris,

visible

oil,

odor,

plant

or

algal

growth,

color

or

turbidity

of

other

than

natural

origin.

35

III.

Adm.

Code 302.203.

In

1990,

the

Board

amended

the Offensive

Conditions water quality

standard.

See

Opinion and Order

of the

Board,

PCB

R88-21(A),

Jan.

25,

1990.

The

Board

determined

that

the

water

quality

standard

of Section

302.203

is

equivalent

to (“no more restrictive than”) the effluent standard of Section 304.106.

Id.

at

12.

The proposed discharge

will

not

create

a

“nuisance”

as

understood

by

the

Board

when

it

adopted

the

Offensive

Conditions

and

Offensive

Discharge

rule.

The Water Company’s Particle

Deposition Study

shows

that the proposed discharge

will

not

result in

an Offensive

Condition

as defined in Section

302.203.

SSIS

at

5-22

to

5-23;

Appendix

F.

9

---

Relationship of the Regulation of General

Applicability

to Federal Environmental

Requirements

13.

Section

106.705(b) of the Procedural Rules provides that the petition must

state whether

the regulation

of general

applicability

was

promulgated

to

implement,

in

whole

or

in

part,

the

requirements

of certain

federal

environmental

laws

or

programs

under

such laws.

The effluent

standards

were reviewed in

1975

and

1976 by

the Illinois

Effluent

Standards

Advisory Group (“JESAG”),

which

was

formed

at

the request of the

Director

of

the

State

of

Illinois

Institute

for

Environmental

Quality,

which

was

subsequently

renamed the

Illinois

Department of Energy

and

Natural Resources.

IESAG

has concisely

explained

the

ways

in

which

the Illinois effluent

standards

differ

from

the

subsequently

enacted

federal

effluent discharge control

legislation:

The

federafl

...

law

required

...

that the U.S.

Environmental Protection

Agency

promulgate by

industrial

category

(and

subcategory

if necessary)

effluent

limitations

guidelines

for

existing

sources

and

standards

of

performance for new

sources.

Thus,

PL

92-500

f

the

federal

law

differs

from

Illinois

law,

in

requiring

industrial

category-specific

guidelines

whereas

the Illinois

standards

apply

equally

to

all

dischargers.

Evaluation of Effluent Regulations of the State of Illinois

(“IESAG Evaluation”),

Illinois

Institute for Environmental Quality,

Document No. 76/21,

(1976), Attachment

FT

hereto,

at

pp.

4-5

14.

The

United

States

Environmental

Protection

Agency

(“U.S.

EPA”)

has

never

enacted

effluent standards

for public

water

supply

treatment

facilities.

See,

e.g.,

Opinion

and

Order of the

Board,

PCB

R85-11,

February

2,

1989,

attachment I hereto,

at p.

10.

As a

result, the Illinois effluent

limitations and subsequent amendments thereto,

including the standards for iron and TSS for which the Water Company seeks an adjusted

standard,

were

not

promulgated

to

implement,

either

in

whole

or

in

part,

the

10

---

requirements of the federal

Clean Water

Act,

the NPDES

program,

or any

other federal

environmental

laws

or

programs.

Similarly,

U.S.

EPA

has

never

enacted

federal

pretreatment

regulations

for public

water

supply

treatment

facilities

which

discharge

to

publicly

owned

treatment

works.

The Illinois

legislature implicitly

recognized the

lack

of categorical pretreatment standards

by

enacting Section 28.3

of the

Act.

Level of Justification Required

for an Adjusted

Standard

15.

Section

106.705(c) of the Procedural Rules provides that the petition must

state the

level ofjustification

as

well as other information or requirements

necessary for

an adjusted standard as specified by the regulation of general

applicability,

or a

statement

that the regulation of general applicability

does not specify a

level ofjustification or other

requirements.

16.

The

regulation

of general

applicability

--

that

is,

the

Board’s

effluent

regulations, including Sections 304.124 and 304.106, and

water quality criteria ofSection

302.203

--

does

not

specify

a

level of justification

or other requirement for an

adjusted

standard.

17.

The

level of justification required

for the adjusted standard

sought

by

the

Water

Company

is,

however,

specified

at Section

28.1(c) of the

Act:

1.

factors relating to

the

Water Company

are substantially

and significantly

different

from the factors

relied upon by the Board

in adopting

the general

regulation applicable

to

all

industrial

dischargers;?’

2.

the existence of those

factors justifies

an

adjusted

standard;

As noted

in paragraph

7

above, Section 28.3(c) of the Act lists a number of the unique

factors

that are relevant

to

determining

adjusted

standard

relief for

public

water

supply

facilities.

As

discussed below,

the

Water

Company

addressed

all

of these

factors

in

detail

in the SSIS.

11

---

3.

the

requested

standard

will

not

result

in

environmental

or

health

effects

substantially and

significantly more adverse than the effects considered by

the

Board

in

adopting

the rule of general

applicability;

and

4.

the adjusted standard

is

consistent

with

any

applicable

federal

law.

415

Ill.

Comp.

Stat.

5/28.1(c).

Nature of the Activity for Which the Proposed Adjusted

Standard

is

Sought

18.

Section

106.705(d) of the Procedural Rules provides that the petition must

describe

the

nature

of the

petitioner’s

activity

which

is

the

subject

of

the

proposed

adjusted standard.

The operations of the replacement facility will

be

very

similar

to

the

existing

facility and,

except

for being

moved

up

to

the bluff to

reduce future flooding,

will

be

in

the same general location.

As

a

result, operational information regarding the

existing

facility will

also

be

relevant

to

the operations of the replacement facility.

The

SSIS

provides a detailed description of both

current and anticipated future operations as

a

prerequisite

for

the

SSIS’

analysis

of

their

site

specific

impacts.

Much

of

the

information

in

the following

sections

is

also

addressed

in

the

SSIS,

and

the

following

sections

will provide citations

to

the

SSIS

for reference

and

completeness.

19.

The Water Company’s existing public water supply water treatment facility

is

located along the River at approximately

River Mile 204

in

Alton,

Illinois.

The River

is

the

sole

public water supply

source

for the community.

There are approximately

265

miles

of water

main

in

the

distribution

system

and

the

system

serves

a

population

of

approximately

76,430

people and

17,480 households/businesses.

20.

The

existing

facility

has

been

supplying

water

to

the City

of Alton

and

nearby residents

--

and

discharging to

the River in

the same general

location

--

since the

12

---

1890s.~~

The original

Main

Service

facility was

expanded

in

the

1930s

to

13.3

MOD.

An

additional

5

MOD High

Service

facility was constructed

in

1981,

at the same

site.

The

Main

Service

facility

consists

of

two

mixing

tanks,

one

circular

clarifier,

two

rectangular sedimentation basins,

sand filters, 650,000

gallons

of filtered water storage

and

raw and

filtered water pumping stations.

The

High

Service facility

consists of one

mixing

tank,

two

clarifiers,

four filters,

raw, transfer,

and

filtered water pump

stations,

and one million gallons of filtered water storage.

The

two facilities

share

a common side

channel

intake structure at the River.

At

the existing

facility,

water

is

taken

from

the

River through

a

side channel intake

into two

wet wells

in the facility

Gate

House.

Two

travelling

screens

are

located

at

these

wet

wells

to

strain out

debris.

The screens

are

regularly

cleaned

with

finished water,

and

the expelled materials and

screen wash water

are returned

directly

to

the River.

Three

pumping units

transmit raw

water

to

the

two

flocculation

tanks

in the

Main

Service facility.

Three pumping

units

convey

raw water

to

the mixing

tank

in

the

High

Service facility.

21.

At

the

Main

Service facility,

open rectangular steel

channels convey raw

water

from

the mixing

tanks to

the circular clarifier where

sand and

heavy

sediment

are

removed.

From

the

clarifier,

the

water

is

split

into approximately

equal

proportions.

The

clarified

water

enters

the

lower

chamber

of each

of

the

two

parallel

rectangular

sedimentation basins.

From

the

lower

chamber,

the water rises to

the upper

chamber.

From

the

sedimentation basins

the

treated

water

enters

the

former

recarbonation

tank

In

the event

that adjusted

standard

relief

is

granted in

this

proceeding,

the

Water Company

plans

to

continue

to use

the same

general

area of the River

for

the

replacement facility

discharge.

13

---

where

additional

treatment

chemicals

are

added.

From

the

recarbonation

tank,

the

treated water

flows

to

nine

sand filters.

22.

At

the

High

Service

facility,

flocculation

occurs

in

the

mixing

tank

in

which

one

side

wall mixer

is

mounted.

From

the mixing

tank,

water

flows

by

gravity

to

two

Claricone

sludge

blanket

type

clarifiers.

From

the clarifiers,

water

flows

by

gravity to

fours/and/anthracite filters.

Treatment to

aid

in sedimentation begins as water

leaves

the intake,

where

the

primary

coagulant,

Clar+Ion®,

is

added

to

coagulate

the

sediment

in

the water.

Powdered activated

carbon may

be

added at the intake

in

order

to

control

odor

and

taste.

Lime

or

caustic

may

be

added

at

this

point

as

well

when

alkalinity

is

low.

Based

on historical records,

alkalinity is low during high

flows or high

turbidities.

In

the

mixing

tanks,

the

retention

time

and

gentle

mixing

promote

coagulation.

The coagulated sediment

will then

settle

in

the clarifier and

sedimentation

basins

in

the

Main

Service

facility

or

in

the

Claricone

clarifiers

at

the

High

Service

facility.

Disinfection is provided by chlorine addition immediately

after flocculation

and

again

after

clarification

in

the

sedimentation

basins.

Ammonia

is

added

before

clarification

to

promote

chloramine formation.

SSIS

at

3-1

and

3-2.

Current Effluent Discharges

23.

As

discussed

in

detail

in

paragraph 6,

the existing

facility discharges

its

effluent

directly

to

the

River pursuant

to

the

site

specific

rule codified

at

35

111.

Adm.

Code

304.206.

Effluent

discharges

from

the

existing

facility’s

treatment

system

are

operational

and

maintenance

discharges.

Operational

discharges

are

those

flows

that

occur regularly,

on a daily

or weekly

basis,

during periods

when the facility

is

treating

14

---

raw water.

Maintenance discharges occur during

the cleaning of accumulated

solids

in

the clarifier, sedimentation basins,

and

mixing tanks.

Residuals

from

the existing

Alton

facility are stored

in

a dedicated

wet

well

at the Gate

House.

They can

be

discharged

by

gravity

or can

be

discharged

by

using

a

dedicated

transfer

pump

during

high

river

levels.

All

facility residuals are discharged

from

this

location.

SSIS

at 3-2.

24.

The

two

Main

Service

operational

discharges

consist

of

intermittent

clarifier

blowdown

and

filter

backwash.

Id.

Approximately

30,000

gallons

per

day

(“gpd”) of blowdown are

discharged two

days a

week

from

the clarifier;

however,

the

frequency

and

duration

of blowdowns

are

variable,

because

they

are

dictated

by

raw

water turbidity.

In

addition,

approximately

630,000

gpd

of backwash

are discharged

from

nine

sand filters

used at the

Main

Service

facility.

The

sand

filters

used at

the

Main

Service facility

are backwashed

daily

for

approximately

15

minutes.

Each

filter

runs approximately

24

to

30

hours between

backwashings.

Id.

25.

Maintenance discharges from the Main Service facility arise from cleaning,

three times

per

year,

accumulated

solids

from

the clarifier,

sedimentation

basins,

and

mixing tanks.

SSIS

at 3-3.

The two

sedimentation basins do

not include sludge removal

equipment,

so

the basins

are dewatered

prior to manual

sludge removal.

Approximately

72,000

gpd

of

carrier

water

with

residuals

are

discharged

during

the

five

day

long

maintenance

activity

(i.e.,

total

annual discharge

is

1,080,000

gallons).

Id.

26.

The

High

Service

operational

discharges

include

Claricone

clarifier

blowdown,

filter

backwash

and

cleaning of the

Claricone

clarifier.

Operators

release

clarifier

residuals

based

on

the

condition

and

thickness

of

the

sludge

blanket.

15

---

Approximately

12,000

gpd

of

carrier

water

with

residuals

are

discharged

from

the

clarifier.

Two

of

the

four

sand/anthracite

filters

at

the

High

Service

facility

are

backwashed daily for approximately

15 minutes.

Each filter runs approximately 48 hours

between backwashings.

Approximately 210,000

gpd of backwash

are discharged from

the

filters.

Finally,

the

Claricone

clarifiers

are cleaned

once

a

year.

Approximately

24,000 gpd of cleaning residuals are discharged during two days of maintenance activity.

SSIS

at 3-3.

Existing

Facility History

and

Replacement

Facility

27.

The existing facility

is located within a physically

restricted parcel of level

land approximately

twenty feet

above the

normal River

summer

level.

The

facility

is

bounded directly to the northeast by

the Norfolk Southern Railroad and Illinois Route 100

and

bounded

to

the southwest

by

the River.

Across

the railroad and

highway corridor,

the land

slopes

steeply up

to

the bluffs overlooking the River.

Due

to

its

proximity

to

the

River,

the existing

facility

is

subject

to

occasional

flooding.

In

August

1993,

the

entire

site

was

flooded

and

both

the

Main

Service

and

High

Service facilities

were

out

of service for four days.

Consumers

in

the Alton

service area were

required

to boil tap

water over

a ten day

period.

Limited service was provided initially

by

the High

Service

facility.

Full

service was

reinstated

soon thereafter.

Sandbagging

to protect the facility

from

flooding

was required

in

1973,

1986,

1993,

1994

and

1995.

SSIS

at 3-3.

28.

In order

to

avoid

future

flooding and

to

replace the aged existing

facility,

the replacement facility will

be constructed approximately

sixty

(60) feet higher than the

existing

facility on

property located

directly

across Illinois Route

100

in

Alton,

Illinois.

16

---

The Water

Company evaluated

nine

sites

for

replacing the water supply

facility

before

choosing

this

alternative.

The

site

was

selected

because

of

its

industrial

zoning,

proximity

to

the

existing

facility

and

infrastructure,

favorable

site

topography

for

construction,

size,

and

proximity

to

the existing raw water intake location.

SSIS

at 3-4.

Replacement

Facility

Design,

Capacity,

Flows

and

Discharges

29.

The replacement facility

is designed

to

treat

sufficient raw

water to make

available,

on

average,

10.5

MOD2’ of potable

water for the

Alton

area.

The hydraulic

design

capacity

of the

replacement facility

is

16

MOD.

Based

on

an

internal

facility

demand

(i.e.,

not

going

into the Water

Company’s

distribution

system)

of

1

MOD (for

Superpulsator® blowdowns,

filter backwash,

etc.),

at a peak potable

water demand of

15

MOD, the

actual distribution

capacity

is

15

MOD.

The estimated average proportional

internal facility demand

is

0.7

MOD

for the average potable

water flow of 10.5

MOD.

The

combined

flow,

10.5

+

0.7

=

11.2

MOD,

was

therefore

used

for

purposes

of

evaluating potential

discharge

impacts

in

Section

5.0

of the

SSIS,

discussed below.

30.

The

replacement

facility

will

consist

of

a

new

raw

water

intake

and

pumping

station,

clarification and

filtration

units,

filtered

water storage,

and

chemical

feed facilities.

Clarification of raw water at the replacement facility will be provided

by

four Superpulsator® units (high rate sludge-blanket type clarifiers manufactured by

Infilco

Degremont,

Inc.).

SSIS

at 3-4 and

3-5.

The

10.5

MGD value was

selected as the average

daily

potable water demand based

on projectionsof

future

water demand

conducted as part of the

Water Company’s Comprehensive

Planning

Study

(5515

at Appendix

E).

The

study estimated water

demand by

using predicted

demographic

trends

through the

year 2Ol0~whichpredict a modest

growth

in population

in

Madison County.

Population

growth is

likely

to be influenced

by

the newly constructed multi-

lane highway bridge across

the River at Alton,

highway improvements, continued downtown development in Alton, and

increased tourist

attractions.

17

---

31.

Filtration

will

be

provided

by

six

gravity

dual

media

(sand/granular

activated

carbon)

units.

Each filter will be

equipped with

a rate of flow controller, filter

to

waste

piping,

an

air wash system

and

automatic monitors for flow rate, head

loss

and

water

level.

SSIS

at 3-5.

32.

One additional

maintenance discharge will occur at the new facility.

This

discharge

will

be

from

periodic

wet

well

cleaning

(once

every

five

(5)

years).

This

discharge,

however,

will

be

minor

in

amount

and

duration,

will

use

raw

water

for

cleaning,

and

will

not

contain

process-generated

chemicals

(i.e.,

coagulant)

and,

therefore,

it has been eliminated

from

further consideration

in analysis

of potential new

facility impacts.

Id.

33.

Operation

of

the

replacement

facility

will

be

highly

automated.

The

required equipment

will

include

an

analyzer,

controller,

flow proportioning

system,

an

automatic

switchover device,

diffuser,

scale

for cylinders,

and

an

SQ detector.

Id.

at

3-6.

Residual

discharges

from

the

replacement facility

will

consist of Superpulsator®

blowdown, filter backwash,

and

Superpulsator® cleaning water.

Id.

at 3-5.

The quantity

of residuals discharged will

be equal to the sum of the suspended solids introduced

in the

influent

River water

and

those

added

as coagulant

aids.

Id.

34.

Chlorine may be used at a variety of points within the replacement facility.

Chlorine

may

be

added

on

a

seasonal basis

prior to

Superpulsator® or

filter

backwash

treatments.

Ammonia

and chlorine

will

be

applied

at rates necessary

to

achieve

a

TRC

sufficient

for

disinfection

in

the

treatment

process

and

to

provide

a

final

TRC

for

disinfection

in

the potable

water

distribution

system.

The Water

Company

will use the

18

---

process

of chloramination

at

the replacement

facility.

Ammonia

is

applied

just

after

chlorine

treatment

in

order

to

form

chloramines

rather

than

free

chlorine

residual.

Chloramines

may

be

added

to

the

raw

water

prior

to

the

Superpulsator®.

Based

on

similar

treatment

facilities,

a

TRC

of 3.0

to 4.0

mg/I

could

be

expected

at

this

point.

Alternatively,

if chlorine

is

added,

the Superpulsator® TRC

could range

from

1.0 to

1.5

mg/I.

The

settled

solids

will

be

continuously

removed

from

the

Superpulsator®

and

routed

to

the effluent discharge.

Id.

at 3-5 and

3-6.

35.

Water

from

the Superpulsator®

will

flow

to

six

carbon/sand

dual

media

filter units.

This

filtration will

cause

substantial

reduction

in

free

chlorine residuals and

TRC.

TRC

would be expected in

the filter backwash water, which constitutes

nearly half

of the total

effluent discharge.

Id.

Chlorine and ammonia will

be

applied

to

the filtrate

to

maintain

a

disinfectant

residual

in

the potable

water distribution

system;

however,

these application points will not affect the discharge, because the discharge stream is split

away

prior

to

this

part of the process.

Id.

at 3-6.

36.

The replacement facility will prevent unacceptable TRC

concentrations in

the

effluent

discharge through

dechlorination

with

sulfur dioxide.

Two

dechlorination

systems

will

be

used

to

treat

the

Superpulsator®

and

filter

backwash

discharges,

respectively.

Separation of the filter

backwash

water

from

the other effluent

volumes

will

allow

the

Water

Company

to

apply

dosages

that

are

appropriate

for

the

residual

chlorine

in

each stream.

SSIS

at 3-6.

19

---

Characteristics of Replacement

Facility

Site

37.

The

replacement facility

site

consists

of approximately

22

acres

located

within the

City of Alton,

Illinois

in

Madison County;

the suitable

area for construction

is limited

due to

existing topography.

Alton

is located in

southwestern Illinois

on

a bend

in

the Mississippi River north

of St.

Louis,

Missouri.

The property

is a

former quarry

site,

with

residential

subdivisions

located

along the western

and

northeastern

corners of

the property.

The site

is composed of both

hilly

and

flat areas.

The central flat portion

of the site, which

is

the old quarry

floor,

is largely

bedrock with

sparsely

vegetated open

areas.

Portions of the site are covered with trees and woody vegetation overlying quarry

debris.

SSIS

at 4-2.

38.

18

acres

of

the

area

are

zoned

M-2,

Heavy

Industrial

District.

The

remaining four acres are zoned

residential

and

would need

to

be

rezoned if construction

of treatment

facilities

were

to

occur.

In the immediate vicinity of the site, other

zoned

uses include

mostly residential areas.

The site is abutted by both single

and multi-family

residences.

Land uses near the

site

include

moderate

and

higher

income

single

family

residences,

apartments

and

industrial

sites.

Barges

tie

up

along

the

River

banks just

downstream of this

area prior

to

or after

traveling through

the Melvin

Price

Locks

and

Dam.

SSIS

at 4-2.

20

---

Hydrologic Characterization of Mississippi

River at

Alton

39.

Hydrologic

data are

available

for

the

River

near

Alton

from

four

local

United States

Geological

Survey (“USGS”)

gaging stationsJ’

The stations measure flow

emanating

from

a

171,300-171,500

square

mile

drainage

basin.

Based

on

sixty

(60)

years of USGS data,

the average

mean monthly

flow of the River is

106,859

cubic feet

per

second

(“cfs”).

Id.

at 4-3.

Data

were

collected

at

USGS gaging station #05587500

(Alton) from

April

1933

through September

1988

and at USGS gaging station #05587450

(Grafton)

from

October

1990

through

September

1995.

Recorded mean monthly

flows

ranged

from

20,200

to

469,300

cfs

(July

1947

and

July

1993,

respectively).

The

minimum

seven

day,

ten year flow (“7Q10”)

is

21,500

cfs.

The data demonstrate that

March

to

June

are

typical

peak

flow

months

and

August

to

January

are

lower

flow

months.

SSIS

at 4-3.

40.

River depths

in

the vicinity of the proposed facility

range

to

30

feet.

The

normal

high

water

level

for

this

section of the River

is

419

feet

above mean

sea

level

(“MSL”)

with

a

low

water

level of 413

feet above MSL.

SSIS

at 4-3.

Water

Ouality

of the Mississippi River at

Alton

41.

The raw water quality

of the River

at

the intake

point

is

highly variable.

Based

on

data

from

the

existing

facility

(January

1990

through

December

1995),

the

turbidity

of the influent varies dramatically on

a daily

basis.

For example,

in

May

1990

the

influent

turbidity

changed

from

39

nephelometric

units

(“NTU”)

to

964

NTU

(the

~‘

l’he Alton

stations (#05587500

and #05587550)

were discontinued after

1989,

following

relocation and construction

of Lock and Dam

No.

26.

Hydrologic and water quality

measurements were resumed at the Grafton stations (#05587450

and

#05587455).

21

---

maximum

value

over

the six-year period

of record)

during

one

month.

The minimum

daily

turbidity

value

for

the period

of record

was

8

NTU

in

January

1994.

Similarly,

the mean of annual averages

and

the monthly

averages differ

substantially.

The mean

of annual averages for the

six

year period of record

is

90

NTU,

while the maximum of

monthly

averages

is 430

NTU.

SSIS

at 3-6.

42.

To

account

for the

natural

variability of River water quality,

three River

turbidity

conditions

were

evaluated

for conceptual

design

purposes

and

to

support

the

potential impact evaluation conducted

for the

SSIS.

The turbidity values were correlated

to

suspended

solids

concentrations

(“mg/I TSS”)

using

a

ratio

of 1:2

NTU/TSS.

The

ratio of

turbidity

to

suspended

solids

in

rivers

similar

to

the Mississippi

River ranges

from

1:1.8

to

1:2.

For

purposes

of the

SSIS,

in

order

to

consider

maximum

solids

production, the ratio of 1:2

was

selected.2’

SSIS

at 3-7.

43.

The long-term River water quality is represented by the mean of the annual

turbidity

averages,

or

90

NTU

(180

mg/I

TSS).

Discharges

calculated

based

on

this

condition

were

used

to

design long-term

treatment units,

such as lagoons.

The medium

term River water quality

is

represented

by

the maximum of the monthly

turbidity

values

or 430

NTU (860 mg/l

TSS).

Discharges

calculated

based

on

this

condition

were

used

to

design

all

the residual handling

equipment

such

as belt

filter presses.

The

short term

River water quality

is

represented

by

the maximum daily

value or 964

NTU (1928 mg/I

TSS).

Residual

discharges calculated

based

on

this

condition

were

used

to

design

the

2’

Due

to the

importance of this

value for determining potential

residual

loads,

this

value was

peer-reviewed

by

two

engineering firms:

flaxen

&

Sawyer and Burns and

McDonnell.

22

---

initial equalization basins

so

that

storage volume

would be

provided

to

handle this

worst

case condition.

SSIS

at 3-7.

44.

The

Company

conducted

modeling

of anticipated

exceedances

of water

quality

standards

using

the discharge

values

in

paragraphs 29-36,

above.

These

values

include

discharge flows

and

concentrations under

defined

ambient flow

TSS

and

flow

conditions.

These

values

were

used

to

model

potential

worst-case

and

average

flow

scenarios

to

evaluate the potential

for the

discharged effluent

to

exceed

Illinois

Water

Quality

or Effluent

Standards.

SSIS

at 3-7.

45.

Water quality data were obtained

from

the USGS District Office

in Rolla,

Missouri.

Data

for

TSS

were

available

for

the

four

USGS

gaging

stations

noted

in

paragraph

8,

n.8,

above.

Data

were

available

from

two

of

the

four

gaging

stations

(#05587450

and

#05587455)

in

the period following the relocation

and

construction

of

Lock

and

Dam

No.

26.

The average

mean

monthly

TSS

value over

the period

from

October

1989

to

September

1995

ranged from

29

to

605

mg/l

with

an

average monthly

value of

171

mg/l.

SSIS

at 4-3.

The

USGS District Office

in

Rolla

also

collected

data

from

individual

sampling events.

During the period after the relocation and construction

of Lock

and

Dam

No.

26,

TSS concentrations

for single

grab

samples

ranged

from

17

to

506

mg/I

(January

1990

and

April

1994,

respectiveIyY’-~’ 5515

at 4-4.

Despite the

greater

range of TSS concentration

for single grab

samples, the mean value of TSS from

these data

is

156 mg/I,

which

is

consistent

with

the average

monthly

value of

171

mg/I

12’

Data are available from

both

before and after

the relocation and construction

of Lock and Dam

No.

26,

from

1975

to

1994.

During

the period prior

to

the

relocation and

construction

of

Lock and

Dam

No.

26,

TSS

in

grab

samples

ranged

from

3

to

1,310

mg/I

(July

1987

and June

1981,

respectively), with

a

mean value of

175

mg/I.

23

---

and

that

found

in

a

more

intensive

sample

collection.11’

The

raw

intake

TSS

for

the

current

Alton

facility

(as

estimated

by

turbidity)

is

180

mg/L.

Therefore

the

four

estimates

of annual

average

TSS

at

Alton

(156,

171,

175,

and

180

mg/L)

are

fairly

consistent

and

representative.

Id.

46.

The data also

suggest

that

TSS concentrations

fluctuate seasonally.

Peak

months for TSS correlate with peak flow months

(i.e.,

March through June).

March has

the

highest TSS,

due

to

spring

thawing

action

and

subsequent

mobilization of eroded

clays

and

silts

in

the watershed.

SSIS

at 4-4.

The applicable regulations do

not

specify

any

water quality

standard

for TSS,

and

the

general use water quality

standard

for total

dissolved

solids

(“TDS”)

is

1,000

mg/I.

35

III.

Adm.

Code

302.208.

47.

Dissolved

iron

concentrations in

the River near Alton were also

available

from

USGS data

records.

The

daily

values over

the period

from

March

1989

through

September

1994 (based on data collected on individual days in a

scheduled month) ranged

from

3

to

710

micrograms

per

liter

(“ug/l”)

(May

1993

and

November

1992,

respectively),

with

an

average

value

of 36

ug/I.11’

SSIS

at 4-4.

The general

use water

quality

standard

for

dissolved

iron

is

I

mg/I

--

i.e.,

1,000

ug/I.

35

III.

Adm.

Code

302.208(g).

USGS

records

of

daily

aluminum

values

from

March

1989

through

September

1994

ranged

from

10

to

220

ug/l

(the

latter

on

only

one

occasion

in

fl~The mean

value of TSS

from grab sample data both before andafter the relocation and construction of Lock and Dam

No.

26

(the years

1975

to

1994)

is

175

mg/I.

which also

is

consistent

with

the average monthly

value of

171

mg/I.

~

The daily

values for dissolved

iron over the period

both

before and after

the

relocation and construction

of

Lock and

Dam

No.

26,

based

on

sampling

from January

1975

through

September

1994

ranged

from

3

to

1,000

ug/l

(July

1985

and January

1985,

respectively),

with

an average

value of

63

ug/l.

24

---

November

1993),

with

an

average

of 26

ug/l.11’

SSIS

at

4-4.

Illinois

has

no

water

quality

standards

for

aluminum.

Mussel

Habitat

Near

the Replacement Facility

Site

48.

Discussions

with

Illinois

EPA

in

August,

1997

identified

the

need

for a

characterization of the potential mussel

habitat near River

Mile

204

in the vicinity of the

proposed

intake

and

discharge pipes.

Based

on

a

protocol

reviewed

and

approved

by

Illinois EPA, the survey was undertaken to characterize the potential

mussel habitat found

offshore

of

the

replacement

facility

site

and

to

determine

the

potential

presence

of

protected

(i.e.,

threatened and endangered)

mussel

species.

Sampling

was conducted

at

six

(6)

transects

bracketing

the

existing

Alton

facility.

The

upstream

limit

was

100

meters upstream of the existing intake

location and the downstream limit was 400 meters

below

the proposed

discharge location.

Diver

surveys

were

conducted

along

these

six

transects.

5515

at 4-5.

49.

The

survey

results

show

that

the

area

does

not

support

a

unionid

community.

See

5515 at Appendix B (“Unionid Survey”),

p.

5.

No

living animals were

found

in the

study

area and only

the

shells of eight

species

were

collected.

None of the

collected

species

were

federal

or

Illinois

protected

mussel

species.

Only

the

shells

of

Leptodea fragilis

were

represented

by

freshly

dead

shells;

the

remaining

shells

were

weathered

or

sub-fossil.

SSIS

at

4-5.

The

Unionid

Survey

concludes:

“Given

that

habitat conditions

within

the

study

area are unsuitable

for unionid

colonization,

and

no

~

Daily

aluminum

values

from

both

before

and

after

the

relocation

and

construction

of

Lock

and

Dam

No.

26,

including

samples between November

1982 and September

1994,

also ranged

from

10

to

220 ug/l,

but

with

an average

of 42

ug/I.

25

---

unionids

were

found,

construction

and

operation

of

the

water

intake

and

treatment

discharge

should

not

impact

unionids.”

Id.

at

Appendix

B,

p.

8.

A

follow-up

communication

from

the

consultant

who

performed

the

study

confirmed

that

both

upstream

and

downstream

of

the

facility,

silt

deposition

was

similar

at

comparable

depths.

Id.

at 5-16 to

5-17.

Compliance Alternatives

and

Efforts Which

Would

Be

Necessary

to

Achieve Compliance

50.

Section

106.705(e) of the Procedural

Rules

provides

that the petition must

describe the efforts

which

would be

necessary if the petitioner were

to

comply

with

the

regulation

of general

applicability.

Further,

the

petition

must

discuss

all

compliance

alternatives,

with

the

corresponding

costs

for each alternative.

The discussion of costs

shall

include

the

overall

capital

costs

as

well

as

the

annualized

capital

and

operating

costs.

Illinois

EPA

suggested,

and

the

Water

Company

agrees,

that

the

SSIS

should

evaluate

treatment

technologies

for

residual

control

in

detail

and

determine

which

treatment

technology

provides

the

best

degree

of

treatment

(“BDT”)

for

the

Superpulsator®

and

filter

residuals

using

the

factors

identified

in

35

III.

Adm.

Code

304. lO2.~’

This

Board

regulation

also

encompasses

several

integral

BPJ

factors,

including

examination

of the

process

employed, the engineering aspects

of

the application of various types

of

control techniques, process changes,

and a cost-

benefit

analysis.

It

requires

that

dischargers

must

provide

the

Best

Degree

of Treatment

(BDT”)

consistent

with

technological

feasibility,

economic

reasonableness

and

sound engineering judgment.

BDT

factors

considered

in

this

context

are:

1)

the

degree

of

waste

reduction

that can

be

achieved

by

process change,

improved housekeeping

and

recovery

of individual

waste

components

for

reuse;

and 2)

whether

individual process wastewater

streams

should

be

segregated or

combined.

26

---

51.

As

a

first

step

in

the determination of BDT,

it

is

necessary

to

identify

available

treatment

technologies

and

select

appropriate

candidate

technologies

for

application at the proposed replacement

site.

The

5515

identifies

a

number of residuals

management control technologies as available treatment

technologies for residual control.

One

major

consideration

in

the

selection

of candidate

technologies

is

the

turbid

and

hydrologically variable

nature

of the

River near Alton.

This

variability

is documented

in

Section

4.3

of the

SSIS,

based

on

over

20

years of USGS

data and

available

intake

water turbidity of the current

Alton

facility.

The records

indicate average

TSS

levels of

180

mg/l,

average

turbidity

at

90

NTU

and

extremely

dynamic

variation

on

a

daily,

seasonal,

and

yearly basis.

These

environmental conditions

constitute a

scenario which

had

been

recognized

as

problematic

during

the

development

of

proposed

national

guidelines.

The

fact

that

EPA

never

promulgated

industry-wide

effluent

standards

indicates that water supply facilities and their source waters are too different for industry-

wide

standards

to

be

useful.

Consequently,

ability

to

deal

with

a

highly

dynamic

TSS

load

is

an

important selection

factor.

SSIS

at 6-2.

52.

Six technologies were screened to select

appropriate candidate technologies

for application

at the replacement facility

site:

I)

direct discharge

to

the River;

2) land

application;

3) temporary

storage and

dewatering

in

lagoons,

and

off-site landfilling;

4)

permanent

storage

in

monofills;

5)

discharge

to

the

Alton

Publicly

Owned

Treatment

Works (“POTW”); and

6)

sludge

dewatering

and

subsequent

landfilling.

SSIS

at

6-2 to

6-7.

The technologies

were

screened based

on

site-specific factors

including

the nature

27

---

and

quantity

of

settled

solids

produced,

climatic

factors,

land

availability,

and

past

performance

history

of various

technologies.

53.

The

SSIS

provides

the

following

discussion

of

the

respective

control

technologies.

1)

Direct Discharge

to

River

Direct

discharge

of

all

residuals

from

the proposed

replacement

facility

to

the

River

will

serve

as

the

base

case.

It

is

predicted

that

an

estimated average of 3,358

dry tons

of solids

will be

discharged from

the

replacement

facility

each

year.

Of

the

total

solids

discharged

annually

(based on a coagulant dosage rate of 40

ppm),

approximately 8.7

percent,

or 580,000

pounds,

are coagulant residuals.

That

is,

they are produced

by

the addition of the chemical

coagulants

themselves.

Of this

amount,

metals

only

constitute

a

small

fraction.

For

example,

CIar+Ion®

is

approximately

20 percent organic polymer and

about

80 percent alum,

of

which

aluminum

accounts

for

5

percent

(based

on

molecular

weight).

Therefore,

the amount of coagulant-based aluminum

in the effluent

is

8.7

percent

X 0.8

X

0.05

=

0.348

percent,

which

constitutes

a

very

minor

percentage

(and

is

comparable

to

the

East

St.

Louis

drinking

water

facility).

As

noted

above,

the production

rates of total

suspended

solids

are highly

variable,

depending

on

River

suspended

solids.

The current

practice of direct

discharge

to

the

River provides

operational

flexibility

28

---

when

dealing

with

the

wide

variations

expected

in

the

rate

of

solids

generation.

2)

Land Application

The

management

of

residuals

by

land

application

includes

temporary

storage

of residuals at

the proposed

replacement facility

site,

followed by transportation and application of residuals to

local agricultural

land.

The

residuals

would

be

applied

either

as

a

liquid

form

or

as

dewatered

residuals termed

“cake.”

For the

former application

method,

liquid

residuals

(e.g.,

5

solids)

would

be

stored,

loaded

into

6,000

gallon

tanker

trucks

and

hauled

to

the

application

area.

The

liquid

residuals would

then

be

injected into the

soil

(fallow

or

with

crops)

by

specialized equipment or applied to

the soil

surface with

spray equipment.

Residuals applied

to

the

soil

surface would

then be

disked

or plowed

into

the

soil

within

24

hours

of

application.

Land

application

of

liquid

residuals (including hauling and application) can cost between $70

to $300

per

dry

ton

(depending

on

the

hauling

distance).

Since

significant

agricultural

land

is

not

available

in

the immediate vicinity

of the

facility

and

is

less

likely

to

be

available

in

the future

(as

there

is

an

increasing

trend

for residential

growth

in

the area),

the

high

end

of the

cost

range

was

considered

more

appropriate.

The

total

cost of

land application

of

liquid

residuals,

including

on-site

holding

facilities,

was

considered

29

---

comparable

to

the

cost

of dewatering

lagoons

or

belt

press

dewatering

followed

by

landfilling

(see

Option

6B

or

6C

discussed below).

Application

of dewatered

cake was

also

considered.

Dewatered

residuals

(e.g.,

25

solids)

would

be

stored,

loaded

into

lined

dump

trucks

and hauled to

the application area. Weather permitting

(i.e.,

ground

not

frozen or saturated),

the residuals could then be

applied

in

thin layers

to

the

soil

directly

from

the

truck or

by

using

equipment

like

a manure

spreader.

Similar

to

the

liquid

form,

the cake residuals

would

then

be

incorporated

into

the

soil

via disking

or plowing.

Land

application

of

dewatered

residuals (including

hauling

and

application)

can

cost

between

$20

and

$68

per dry

ton.

This

method

is

very

similar

to

that

of Option

6C

(i.e.,

landfill

disposal

after mechanical

dewatering),

except

that

the

final

destination

is

widespread

application

to

farm

fields

rather

than

to

a

landfill

facility.

For

either

land

application

method,

weather,

public

acceptance,

permit

requirements,

and

land

availability

can

limit

feasibility.

In

the

Alton

area,

inclement

weather

does not

seriously

limit

land

application,

hut

application

or injection

to

frozen

soil

may

not

be

feasible for some

winter

months.

Biosolids

from

the

Godfrey

wastewater treatment

plant

have

been successfully

applied

to

nearby

land ten months of the

year for

the

last

10

years;

however,

public

acceptance

of

residuals

may

be

considerably

less

than for biosolids (considered a

soil

enhancement

due to

30

---

carbon and

nutrient content)

because the residuals

add

little

to

(or detract

from)

soil

fertility.

Land

application

is

further

complicated

by

permit

regulations

concerning

the content of applied

materials.

Based

on

the

estimated

average

annual

mass

of

approximately

3,358 tons of residual solids

from outfalls potentially containing coagulant

residuals,

and

a

representative

drinking

water

facility

residual

metals

content,

an

estimate

of

annual

metals

loading

was

made.

Due

to

the

manganese

content

of these

solids

(1760

ppm)

and

the

Illinois

(35

Ill.

Adm.

Code

391.420(c))

lifetime

recommended

cumulative

mass

loading

of 900

pounds

of manganese

per

acre,

263

acres acquired

every

twenty

years

for land

application of these residuals

to

soils

would

be

required.

Potential concerns with other heavy

metals and

elements may

also exist in

a

land application

scenario.

Due

to

the potentially

large amount

of land

required

for

every

twenty

years

of

operation

(basei

on

the

maximum

potential

manganese

load),

this

technology

would

be

less preferable.

While

land

application

of

residuals

is

technically

feasible,

it

is

associated with considerable uncertainty, due

to the highly variable nature

of the River

and

the

resulting

variability

of the residuals.

Further,

the

potential

costs

appear to

be

similar

to

other

more conventional

residuals

management

techniques.

Given

these

factors,

land

application

was

eliminated

from

further consideration.

31

---

3)

Temporary

Storage

and

Dewatering

in Lagoons,

and

Offsite Landfilling

This

technology would

involve

the construction

of on-site lagoons

for dewatering of the water treatment

residuals.

Residuals flow would be

diverted

into

the

dewatering

lagoons

and

would

be

dewatered

to

approximately

4

solids.

Then,

the

residuals

would

be

removed

and

further

dewatered

by

a

mechanical

dewatering

system

to

approximately

25

solids.

Following

the

second

dewatering,

the

residuals

would

be

shipped

to

an

offsite landfill.

4)

Permanent

Storage

in

Monofills

This

technology

involves

the

construction of

impoundments

for

permanent

storage

of

the

residual

solids.

The

supernatant

from

the

impoundment

can

either

be

recycled

to

the head

of the treatment

facility

or

it

could

be

treated

if

necessary

prior

to

discharge.

Based

on

the

average

loading

of 92

tons

of wet

residuals

(10

solids)

per

day

over

a

typical 20 year operating

period,

a 40-acre monofill (14 foot depth) would

be

required.

The proposed Alton

facility property

is

not

large enough for

such a

facility.

Additional

farmland

offsite

would

have

to

be

purchased

(at $6,000

to

$10,000 per

acre)

to

implement

this

option.

However,

the

construction

of

a

large,

lined

impoundment

would

cost

at

least

$20

million,

based

on

preliminary

estimates.

Annual

operation

and

maintenance

costs

would

be

approximately

$1.3

million.

Further

drawbacks ofthis

technology are that disposal in monofills will

likely limit

32

---

the

future use of the

land

and

replacement monofills

will be

continually

required.

Due

to

these

factors,

this

technology

is

less

preferable

and

has

been eliminated

from

further consideration.

5)

Discharge

to

Alton

POTW

This option

was

investigated because it

is commonly used by

many

other potential

NPDES dischargers; however,

the estimated flow and mass

of solids could

not be treated at the relatively

small POTW without POTW

expansion.

The flexibility of POTW future operations would

be

severely

curtailed by

accepting the water treatment

facility

residuals.

This

option

has been explored on

a

preliminary basis

with the Alton

POTW staff who

have indicated that

it

is

not feasible,

based on potential hydraulic overload

of the

adjacent

sewer

system,

inadequate

slope

of

the

inceptor

sewer,

elimination

of the

POTW’s

reserve

capacity,

and

a

quadrupling of

the

solids loading

(see

letter

from

James

Blame

to

Kim Gardner

in

Appendix

A of the

SSIS).

The cost and

technical feasibility

of expansion of the POTW would

be similar

to that of the petitioner constructing

an on-site treatment facility

(such

as

the

lagoon

or

belt

press

systems

described

here).

Based

on

consideration of the above factors, the POTW alternative is less preferable

and

has been eliminated from

further consideration.

33

---

6)

Sludge

Dewatering

and

Subsequent

Landfilling

In the screening ofthis

family of technologies, non-mechanical and

mechanical

dewatering

techniques

were

reviewed

as methods

to

prepare

the settled

solids

for

offsite

landfilling.

Analysis

of residuals handling

methods

was

based

on

industry

experiences

with

alum-based

residuals.

The proposed replacement

facility will use

a Clar+Ion® type alum-organic

polymer coagulant.

However,

these methods are expected

to

be

directly

applicable

for treatment

of Clar+Ion®_based

residuals.

6)A)

Non-Mechanical Dewaterin~Processes

Either

non-mechanical dewatering

or

mechanical

dewatering

(6B,

below) would be required for sludge dewatering and subsequent landfilling

(alternative 6).

Non-mechanical dewatering relies on drainage, decanting,

evaporation,

and

freezing processes.

It

is commonly

used for dewatering

residuals,

because

of its

simplicity

and

low

operational costs.

However,

non-mechanical

processes

are often subject to

disruptions,

due to

climatic

fluctuations.

Also,

non-mechanical processes, perhaps even more

so than

mechanical processes, could be

plagued by having a low overload capacity

in

the

event

that

the

rate

of solids

production

were

to

be

higher

than

planned.

Potential non-mechanical

technologies

include sand drying beds

and

natural

freeze-thaw

drying

beds.

The

most

efficient way

to

utilize

a

drying

bed

system

is

to

combine

the

freeze-thaw

operation

and

conventional

sand drying

operations

during the course of the year.

This

34

---

option

is

similar

in

feasibility

and

cost

to dewatering

lagoons.

However,

because

it

requires

more

area than dewatering

lagoons

and

construction

costs

are

slightly

higher

(based

on

preliminary

unit

cost

estimates),

the

drying

beds

were

not considered

further.

6)B)

Mechanical Dewatering Processes

A variety of mechanical dewatering

methods have been

screened.

These

processes

are

typically

utilized

in

the

water

industry

when

insufficient

space

is

available

for

non-mechanical processes,

high

solids

concentrations are required

for disposal,

or

when economics dictate their

use.

Mechanical

processes

are

less

susceptible

than

non-mechanical

processes

to

inclement

weather

conditions.

The

mechanical

processes

included in this

initial screening included vacuum filtration,

filter pressing,

and

centrifugation.

(i)

In

the

vacuum

filtration

of

residuals,

a

pre-coated

rotating

drum

surface

is

subjected

to

a

vacuum

to

dewater the

solids

and

to

form

a

cake.

While

vacuum filters have been routinely

used

in

the wastewater

treatment industry,

they have been reportedly evaluated only on pilot scale

for a sludge

application

due

to

problems

with

the conditioning

chemicals

and the poor cake yield.

Therefore,

no further consideration will

be given

to

vacuum filtration.

(ii)

The

belt

filter

press

utilizes

a

well

known

and

reliable

technology

which

has

been

used

in

the

water

industry

for

25

years.

35

---

Conditioning

of

residuals

is

required

prior

to

press

operations,

and

operational data indicate that

a

solids

concentration of

15

to

25

percent is

typically

achieved.

Despite

the

higher

capital

and

operating

costs

associated

with

a

filter

press compared

to

certain non-mechanical means,

the higher density

sludge may translate

into cost

savings,

due

to

the lower

volume

of material

to

be

landfilled.

As

a

result

of the

belt

filter

press

method’s reliability

and

operational

characteristics,

further

analysis

was

performed

for

the

filter

press

dewatering

process

and

subsequent

landfilling

of the dried

cake.

Land

is

available

at

the proposed

site

to

house the required filter

press

units

and

associated

tankage.

(iii)

Centrifugation

is

the

final

mechanical

process

considered.

Several

different

varieties

of

centrifuges

are

commercially

available.

However, the solid bowl

centrifuge is the most

common.

These

units

can

operate

in

either

the

co-current

or

counter-current

flow

modes.

Centrifuges have become an acceptable mechanical

dewatering technology

and

have proven to

be

capable of dewatering

sludges.

The centrifugation

and

filter press technologies would require similar auxiliary equipment and

the resulting

costs

would

likely

be

the

same.

However,

due

to

the

fact

that

mechanical

belt

filter

presses

are the more common

technology,

are

in

use at other

public

water

supply

facilities

to

which

Illinois-American

has direct

technical

access

(i.e.,

“sister”

operations

in

other locations

in

the U.S.)

and

centrifugation has had

a poor success record

in dealing with

36

---

Mississippi

River silts,

the belt

filter press technology was selected as the

mechanical

dewatering

technique

for

which

further

analysis

would

be

performed.

6)C)

Landfilling

of Dewatered Residuals

Not

an

alternative

in

itself,

this

technology

was

considered

as

a

potential component of several

technology alternatives,

such as temporary

storage and

dewatering

in

lagoons

with

offsite landfilling

(alternative

3),

and the mechanical

and non-mechanical dewatering processes (alternatives

6A

and

6B).

The

landfilling

of

dewatered

water

treatment

facility

residuals

in Illinois

is permissible.

Provided that the dewatered

solids are

not

hazardous

waste

under

Resource

Conservation

and

Recover

Act

(‘RCRA”)

regulations,

the

dewatered

solids

can

be

landfilled

in

a

permitted non-hazardous

special

waste

landfill.

Preliminary

discussions

with

the

operator of

the

nearest

landfill

(Waste Management

Inc.) which accepts water treatment

facility residuals,

located

in

Granite

City,

Illinois,

indicate

that

there

is

sufficient

landfill

capacity

to

receive

these

residuals

for

30

years.

However,

as

landfill

capacity

diminishes

and

tipping

fees

escalate,

it

is

likely

that

it

may

become

more

economical

to

construct

dedicated

landfills

solely

for the

management

of the

water

treatment

facility

residuals.

As

noted

in

the

discussion

of

monofills

(i.e.,

Treatment

Technology

Number

4),

the

37

---

diminishment

of existing

landfill

capacity

and

the

high

capital

cost

of

constructing new landfill capacity are major drawbacks to landfill disposal.

54.

Based

on

their

technical

feasibility

and

economic

reasonableness,

two

candidate technologies

were selected for further evaluation along with the direct discharge

option.

Application

of either

of

the

two

candidate

technologies

would

result

in

the

estimated Alton effluent discharges meeting Illinois water quality

standards for TSS.

The

two

selected

technologies are:

•

Construction

of four on-site sludge

storage

lagoons

for dewatering of the

solids by

non-mechanical means,

and

subsequent offsite landfilling of the

dewatered

residuals;

•

A belt filter press for dewatering of the solids by mechanical means, at the

facility,

and

subsequent

offsite

landfilling

of the dewatered

residuals.

5515

at

6-7.

Temporary

Storage

and

Dewatering

in

Lagoons was selected

for the following

reasons:

•

Reliable operation

with

minimal

maintenance

requirements;

and

•

Site

is

large enough

to

construct lagoon

system.

Belt

Filter

Press

Dewatering was

selected

for

the following

reasons:

•

Site

is

large enough

for buildings required

to

house the press dewatering

system;

and

•

Reliable operation

which

produces

consistently

dense

residuals.

55.

In order

for

the

facility

to

produce

an

average of 10.5

MGD

of potable

water

(forecasted demand

in

15

years),

11.2 MGD of water must

be

withdrawn from the

38

---

River.

Under

average

river

sediment

conditions

(TSS

=

180

mg/I)

at

the

flows

described above,

the facility will produce approximately 3,400 tons of dry solids per year

from

proposed

discharges which

will

require

treatment

for

removal

of solids.

Under

these conditions,

the average discharge flow rate of this

effluent will

be

1.0

MGD.

SSIS

at 6-8.

56.

It

is

anticipated

that

temporary

storage

and

dewatering

in

lagoons

(non-

mechanical dewatering)

with

subsequent

off-site

landfilling

would

require construction

of four

on-site

lagoons

for

dewatering

the

water

treatment

residuals.

Residuals

flow

would

be

diverted

into

one

of the

four dewatering

lagoons.

Residuals would

be

stored

in

the

lagoons

to

allow

dewatering

to

approximately

four

percent

(4)

solids.

The

residuals

would

then

be

removed

and

further

dewatered

by

a

temporary

mechanical

dewatering

system

which

would

dewater the

lagoon

residuals

to

approximately

twenty

five percent (25)

solids.

Following

the dewatering

the residuals

would

be

transported

to

an

off-site landfill.

SSIS

at 6-4.

57.

The second

candidate technology

involves

belt

filter

press dewatering

--

a

permanent

mechanical

dewatering

process

which

would

involve

conditioning

the

residuals prior

to press operations.

Operational data indicate that

a

solids

concentration

of

15

to 25 percent is typically achieved through this process.

This

candidate technology

also

requires

off-site

landfilling

of the dewatered

residuals.

58.

Originally

each each of the candidate technologies

(lagoons alone and belt

filter

press

dewatering

alone)

was

considered

separately.

The

original

lagoon

design

called

for

two,

three-acre

lagoons.

Upon

consideration

of additional

site

information

39

---

(i.e.,

required site preparation),

the lagoon design

was refined

to

include

four, one-acre

lagoons

combined

with

additional

mechanical dewatering equipment.

The

four lagoons

require

less

subsurface

exacavtion and

less

land area than the previous

design.

5515

at

6-8.

Cost

estimates were

made for the lagoon

(non-mechanical) dewatering

technology

alone,

for the belt

filter

press (permanent mechanical)

dewatering

technology

alone,

and

for

the combination

of the

two.

For purposes

of comparison,

cost

estimates

for

both

non-mechanical and

mechanical

dewatering

technologies,

as

well as

the combination

of

the

two

are presented

in

Appendix

D

of the

SSIS.

59.

The

cost

estimate

for

non-mechanical dewatering

as

originally

designed

(two,

three-acre

on-site

lagoons

and

off-site

landfilling)

is

detailed

in

Table

D-1

of

Appendix

D

of

the

SSIS.

Major

cost

items

associated

with

this

option

are:

(1)

construction of two

on-site

solids

dewatering

lagoons;

(2) collection

of the supernatant

from

the

lagoons

and discharge of water

to the River;

and

(3)

landfilling

dried sludge at

a

local

landfill.

The

annualized

total

cost

for

this

option

is

approximately

$1 ,580,000)-~’ The

overall

capital

cost

for

this

option

is

approximately

$4,580,000,

the annualized capital cost

is

approximately $450,000,

and

the annualized operation cost

is

approximately $1,130,000.

60.

The

cost

estimate

for the

refined

(combined)

technology

of four

on-site

lagoons,

permanent

mechanical

dewatering

by

belt

filter

presses,

and

subsequent

landfilling

is

detailed

in

Table

D-1A

of