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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
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IN THE MATTER OF:
PROPOSED EXTENSION OF ADJUSTED STANDARD
APPLICABLE TO ILLINOIS-AMERICAN
WATER COMPANY'S ALTON PUBLIC WATER
SUPPLY FACILITY DISCHARGE
TO
THE MISSISSIPPI RIVER
UNDER 35 ILL. ADM. CODE 304.124 AND 304.1 06
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AS 2007-2
(Adjusted Standard)
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TESTIMONY OF PAUL KECK
WITNESS IDENTIFICATION AND BACKGROUND
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Please state your name and business address:
My name is Paul Keck. I work at the Alton plant of Illinois-American Water Company at
4436 Industrial Drive in Alton, Illinois 62002.
What are your job title and your job responsibilities?
Since 2004, I have been employed by Illinois-American Water in the Environment
Management
&
Compliance group as a Water Quality Supervisor for Southern Illinois
with primary responsibilities overseeing the Alton District and the Cairo District.
My
primary role is to give treatment guidance at these facilities and ensure compliance to
state and federal regulations for drinking water and other regulations which are part
ofthe
water treatment process.
What is your educational background?
I earned a BA degree in Chemistry from Southern Illinois University at Edwardsville
with supporting courses in Environmental Science and Technology. I hold class
"A"
drinking Water licenses in Illinois and Missouri.
What is your business background?
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STLDO 1-1346260-1
Electronic Filing, Received, Clerk's Office, August 24, 2007
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A.
I have 25 years
of experience in laboratory water analysis, water treatment, and
regulatory compliance.
From 2000 to 2004 with American Water, I held the position of
Water Quality Superintendent of the Missouri-American Central Plant in Chesterfield,
Missouri and
then transitioned to Water Superintendent of all American Water
Company's facilities in Eastern Missouri. In the 18 prior years, I was a Chemist and a
Laboratory Supervisor with St. Louis
County Water Company.
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PURPOSE OF TESTIMONY
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What is the purpose
your testimony
this proceeding:
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The purpose of my testimony is to: (1) explain my role as Illinois-American Water's
representative to the Piasa Creek Watershed Project; (2) verify Illinois-American Water's
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answers to questions 1a, 1b, 1e and 2c posed by the Board to Illinois-American Water.
Describe your role as a representative of Illinois-American Water in monitoring the
activities at the Piasa Creek Watershed Project.
In September, 2004, when I was assigned to my present position, I started coordinating
the sampling and reporting
of monthly grab NPDES discharge samples at the Alton plant.
At about the same time,
but possibly a few months later, I became aware ofthe unique
permitting conditions set forth in the Alton NPDES Permit which were limited to the
adjusted standard in AS 99-6. In early 2005, I participated in the preparation and
submittal
of documents to IEPA for the routine five year NPDES renewal which was to
expire January, 2006. During this time I became aware
of the sunset clause in AS 99-6
which required IEP A to evaluate
PCWP's effectiveness in sediment erosion reduction
towards the ten year 2: 1 reduction goal. I participated in a series of meetings were held
with Great Rivers Land Trust ("GRLT") and Illinois-American Water to be updated on
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STLDO 1-1346260-1
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Did you provide reports to Illinois EPA on the progress of the PCWP?
Personally, no. We relied on Alley Ringhausen to provide progress reports. He sent
quarterly and annual reports to me and IEP
A's Scott Tomkins. I provided information to
Scott, too, but it was different from Alley'sreports.
the Piasa Creek Watershed Project ("PCWP") and its progress toward the ten year 2:1
goal. This included presentations by GRLT examinations ofpreviously accumulated
quarterly and annual reports. Two tours
of PCWP projects were held and numerous
projects were visited in various stages
of completion.
Not initially. But I became the primary liaison in late 2004.
What conclusions, if any, did you draw regarding the effectiveness of the soil savings
projects?
I was confident that the projects were achieving their intended results. Alley Ringhausen,
who manages the PCWP, uses calculation methods developed by the United States
Department
of Agriculture. I have personally visited some of the projects. The sites I
have observed showed obvious improvements and the logical evolutions to erosion
reductions.
Boy Scout Lake, one of GRLT largest projects, was viewed on three
occasions, the last being a celebratory dinner involving various stakeholders from
government and the community, the Boy Scout Council, engineering designers and
contractors. In my opinion, this project is an excellent model ofhow the PCWP not only
produced an environmental benefit but social and community benefits. A silted in, non-
usable lake was revived and re-engineered to last at least 100 hundred years for not only
local youth, but regional youth for water education activities.
Were you Illinois-American's primary liaison
GRLT?
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STLDO 1-1346260-1
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I sent him summaries of the plant's monthly required NPDES sampling data. This was
our data on TSS and total iron in the plant's effluent.
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thought the Agency needed it to determine the effectiveness ofthe offset project.
How could data from the plant be used to gauge effectiveness of the offset project?
It collaborated our discharge mass. GRLT's quarterly and annual reports covered soil
Tomkins?
you
Why did you send those summaries to
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savings, and the plant's discharge monitoring results covered TSS loading.
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VERIFYING CERTAIN ANSWERS OF ILLINOIS-AMERICAN WATER TO
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QUESTIONS POSED BY HEARING OFFICER WEBB IN HER ORDER OF AUGUST 6,
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2007
questions
Ia, Ib, Ie and 2c are true can correct to the best of your knowledge,
information
and belief.
Yes they are.
Did you participate in the preparation of Illinois-American Water's answers to the
questions presented in Hearing Officer Webb's Order of August 6, 2007?
Yes.
What was your role
the preparation of the Company's answers?
I read the questions in Hearing Officer Webb's Order and participated in a meeting with
other Company representatives and counsel to discuss those questions and answers. I
helped formulate
the Company's answers to questions 1a, 1b, 1e and 2c.
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I will ask you now to verify, Mr. Keck,
the answers attributed to you for
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I know that your Affidavit was signed under oath, but let me ask you now if the
other answers
questions?
affidavit is true
correct to
the best of your
response to
you provide
Yes. I also supplied an Affidavit which is attached the Company's Amended Petition.
My Affidavit explained a formula used for calculating the TSS
in
the Alton plant's
5b posed to the Agency.
effluent. My Affidavit was referred to in Illinois-American
Water's answer to question
information contained in
knowledge, information
and belief.
Yes, it is.
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STLDO 1-1346260-1
Electronic Filing, Received, Clerk's Office, August 24, 2007
STATE OF ILLINOIS
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COUNTY OF MADISON
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AFFIDAVIT
I, Paul Keck, after being duly sworn on oath, state that the foregoing Testimony is true
and correct to the best
of my knowledge and belief.
Pau1 Keck
SUBSCRIBED AND SWORN to
before me this
day
of August, 2007
NOTARv PUBtIC
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