BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
WATER QUALITY STANDARDS AND
EFFLUENT LIMITATIONS FOR THE
CHICAGO AREA WATERWAY SYSTEM
AND LOWER DES PLAINES RIVER
PROPOSED AMENDMENTS TO 35 ILL.
ADM. CODE 301, 302, 303, and 304
)
)
)
)
)
)
)
)
R08-9
(Rulemaking - Water)
NOTICE OF FILING
TO:
John Therriault, Clerk
Illinois Pollution Control Board
James
R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
Deborah J. Williams, Assistant Counsel
Stefanie
N. Diers, Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Marie Tipsord, Hearing Officer
Illinois Pollution Control Board
James
R.
Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
Persons included on the attached
SERVICE LIST
PLEASE TAKE NOTICE that I have today filed with the Office
of the Clerk of the
Pollution Control Board the Appearance of Jennifer A. Simon, a copy of which is herewith
served upon you.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Date: August 4, 2008
Jennifer
A.
Simon
Mayer Brown
LLP
71
South Wacker Drive
Chicago, lllinois 60606-4637
(312) 701-8407 (phone)
(312) 706-8117 (fax)
jsimon@mayerbrown.com
STEPAN COMPANY
Electronic Filing - Received, Clerk's Office, August 4, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN
THE MATIER OF:
WATER QUALITY STANDARDS AND
EFFLUENT LIMITATIONS FOR
THE
CHICAGO AREA WATERWAY SYSTEM
AND LOWER DES PLAINES RIVER
PROPOSED AMENDMENTS
TO 35 ILL.
ADM. CODE 301,302,303, and 304
)
)
)
)
)
)
)
)
R08-9
(Rulemaking - Water)
APPEARANCE
I hereby file my appearance in this proceeding, on behalf of Stepan Company.
STEPAN COMPANY
Date: August 4, 2008
Jennifer
A.
Simon
Mayer Brown LLP
71 South Wacker Drive
Chicago, Illinois 60606-4637
(312) 701-8407 (phone)
(312) 706-8117 (fax)
jsimon@mayerbrown.com
Electronic Filing - Received, Clerk's Office, August 4, 2008
CERTIFICATE OF SERVICE
I, the undersigned, certify that on this August 4, 2008, I have served electronically the
attached Notice of Filing and Appearance upon the following person:
John Therriault, Clerk
Illinois Pollution Control Board
James
R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago,
IL
60601
and by U.S. Mail, first class postage prepaid, to the following persons:
Marie Tipsord, Hearing Officer
Illinois Pollution Control Board
James
R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
The participants listed on the attached
SERVICE LIST
Deborah J. Williams, Assistant Counsel
Stefanie
N. Diers, Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Electronic Filing - Received, Clerk's Office, August 4, 2008
SERVICE LIST
Frederick M. Feldman
Ronald M. Hill
Margaret T. Conway
Metropolitan Water Reclamation District
of Greater Chicago
111 East Erie Street
Chicago, IL 60611
Bill Richardson, Chief Legal Counsel
Illinois Department
of Natural Resources
One Natural Resources Way
Springfield, IL 62702-1271
Keith Harley
Elizabeth Schenkier
Chicago Legal Clinic, Inc.
205 West Monroe, 4th Floor
Chicago, IL 60606
Katherine
D. Hodge
Monica T. Rios
Hodge Dwyer Zeman
3150 Roland Avenue
P.O. Box 5776
Springfield, IL 62705-5776
Dennis Duffield
Director
of Public Works
&
Utilities
City
of Joliet
921 E. Washington St
Joliet, IL 60431
Claire Manning
Brown Hay
&
Stephens LLP
700 First Mercantile Bank Bldg
205 S. Fifth St
Springfield, IL 62705-2459
Frederick Keady
Vermillion Coal Company
1979 Jolms Drive
Glenview, IL 60025
Matthew Dunn, Chief
Environmental Bureau
Office
of the Attorney General
100 West Randolph, 12th Floor
Chicago, IL 60601
Ann
Alexander
Natural Resources Defense Counsel
101 N. Wacker Dr., Ste. 609
Chicago, IL 60606
Susan
M. Franzetti
Franzetti Law Firm P.C.
10 South Lasalle St.
Suite 3600
Chicago, IL 60603
Albert Ettinger
Jessica Dexter
Environmental Law
&
Policy Center
35 E. Wacker Dr., Suite 1300
Chicago, IL 60601
Richard Kissel
Roy Harsch
DrinkerBiddle
191 N. Wacker Dr., Suite 3700
Chicago, IL 60606-1698
Charles Wesselhoft
James Harrington
Ross
&
Hardies
150
N. Michigan Ave
Chicago, IL 60601-7567
Fred
L.
Hubbard
P.O. Box
12
16
West Madison
Danville, IL 61834
Electronic Filing - Received, Clerk's Office, August 4, 2008
Georgia Vlahos
Naval Training Center
260lA Paul Jones St
Great Lakes, IL 60088-2845
W.C. Blanton
Blackwell Sanders LLP
4801 Main St, Suite 1000
Kansas City, MO 64112
Jerry Paulsen
Cindy Skukrud
McHenry County Defenders
132 Cass Street
Woodstock, IL 60098
Bernard Sawyer
Thomas Granto
Metropolitan Water Reclamation District
6001 W. Pershing Rd
Cicero, IL 60650-4112
Fredric Andes
Erika Powers
Barnes
&
Thornburg
1 North Wacker Dr
Suite 4400
Chicago, IL 60606
Bob Carter
Bloomington Normal Water Reclamation
PO Box 3307
Bloomington, IL 61702-3307
Kenneth W. Liss
Andrews Environmental Engineering
3300 Ginger Creek Drive
Springfield, IL 62711
Albert Ettinger
Jessica Dexter
Environmental Law
&
Policy Center
35
E.
Wacker
Suite 1300
Chicago, IL 60601
Kay Anderson
American Bottoms
One American Bottoms Road
Sauget, IL 62201
Robert VanGyseghem
City
of Geneva
1800 South
St
Geneva, IL 60134-2203
Lisa Frede
Chemical Industry Council
of lllinois
2250 E. Devon Ave
Suite 239
Des Plaines, IL 60018-4509
Jack Darin
Sierra Club
70 E. Lake
St
Suite 1500
Chicago, IL 60601-7447
Susan Hedman
Andrew Armstrong
Environmental Counsel
Suite 1800
69 West Washington Street
Chicago, IL 60602
TomMuth
Fox Metro Water Reclamation District
682 State Route
31
Oswego, IL 60543
Vicky McKinley
Evanston Environmental Board
223 Grey Avenue
Evanston, IL 60202
Marc Miller
Jamie S. Caston
Office
of Lt. Governor Pat Quinn
Room 414 State House
Springfield, IL 62706
Electronic Filing - Received, Clerk's Office, August 4, 2008
James
L.
Daugherty
Thorn Creek Basin Sanitary District
700 West End Avenue
Chicago Heights, IL 60411
Tracy Elzemeyer
American Water Company
727 Craig Road
St. Louis, MO 63141
Irwin Polls
Ecological Monitoring and Assessment
3206 Maple Leaf Drive
Glenview, IL 60025
Jeffrey C. Fort
Ariel J. Tesher
Sonnenschein Nath
&
Rosenthal LLP
7800 Sears Tower
233
S. Wacker Drive
Chicago, IL 60606-6404
Dr. Thomas J. Murphy
2325
N. Clifton St
Chicago, IL 60614
Cathy Hudzik
City
of Chicago
Mayor's Office
of Intergovernmental Affairs
121 North LaSalle Street, Room 406
Chicago, IL 60602
Brent Fewell
Kristy
A.
N. Bulleit
HUNTON
&
WILLIAMS LLP
1900 K Street, N.W.
Washington, DC 20006
Sharon Neal
Commonwealth Edison
125 South Clark Street
Chicago, IL 60603
Margaret
P. Howard
Hedinger Law Office
2601 South Fifth Street
Springfield, IL 62703
James Huff
Huff
&
Huff, Inc.
915 Harger Road, Suite 330
Oak Brook, IL 60523
Fredric
P. Andes
Carolyn S. Hesse
David T. Ballard
Barnes
&
Thornburg LLP
1 N Wacker Dr, Suite 4400
Chicago, IL 60606
Beth Steinborn
2021 Timberbrook
Springfield, IL 62702
Traci Barkley
Prairie Rivers Networks
1902 Fox Drive, Suite 6
Champaign, IL 61820
Stacy Meyers-Glen
Openlands
Suite 1650
25 East Washington
Chicago, IL 60602
Electronic Filing - Received, Clerk's Office, August 4, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
WATER QUALITY STANDARDS AND
EFFLUENT LIMITATIONS FOR
THE
CHICAGO AREA WATERWAY SYSTEM
AND LOWER DES PLAINES RIVER
PROPOSED AMENDMENTS TO 35 ILL.
ADM. CODE 301, 302, 303, and 304
)
)
)
)
)
)
)
)
R08-9
(Rulemaking
- Water)
NOTICE OF FILING
TO:
John Therriault, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
Deborah J. Williams, Assistant Counsel
Stefanie
N. Diers, Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Marie Tipsord, Hearing Officer
Illinois Pollution Control Board
James
R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
Persons included on the attached
SERVICE LIST
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the
Pollution Control Board the Pre-filed Testimony of Carl Adams and Robin Garibay, a copy of
which is herewith served upon you.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Date: August 4, 2008
Thomas V. Skinner
Thomas W. Dimond
Kevin Desharnais
Jennifer
A.
Simon
Mayer Brown
LLP
71 South Wacker Drive
Chicago, Illinois 60606-4637
(312) 701-8407 (phone)
(312) 706-8117 (fax)
jsimon@mayerbrown.com
STEPAN COMPANY
Electronic Filing - Received, Clerk's Office, August 4, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATIER OF:
WATER QUALITY STANDARDS AND
EFFLUENT LIMITATIONS FOR THE
CHICAGO AREA WATERWAY SYSTEM
AND LOWER DES PLAINES RIVER
PROPOSED AMENDMENTS TO 35 ILL.
ADM. CODE
301,302,303, and 304
)
)
)
)
)
)
)
)
R08-9
(Rulemaking - Water)
PRE-FILED TESTIMONY OF CARL ADAMS AND ROBIN GARIBAY
Pursuant to the Hearing Officer's May 19, 2008 and July 21,2008 Orders, Stepan
Company is submitting the pre-filed testimony
of Carl E. Adams, Jr., P.E., Ph.D., and Robin
Garibay, REM, of ENVIRON International Corporation in the report attached as Exhibit
A.
The
experience and qualifications
of Dr. Adams and Ms. Garibay are described in the attachment.
As set forth in greater detail in the report, Dr. Adams and Ms. Garibay have analyzed the
waste water treatment systems that would likely be necessary for Stepan's Millsdale plant to
comply with the water quality uses and standards proposed by the Illinois Environmental
Protection Agency ("IEPA") for temperature, dissolved oxygen, and disinfection, as well as the
costs and cross-media environmental impacts implicated by those technologies.
The Millsdale plant
is located about 2-3 miles upstream of the I-55 bridge in Elwood,
Illinois.
It discharges process wastewater, storm water, and sanitary discharges pursuant to a
NPDES permit into the portion
of the Lower Des Plaines River commonly referred to as the
Upper Dresden Island Pool in this proceeding.
Specifically, Dr. Adams and Ms. Garibay have estimated that capital costs
of $3,436,000
and yearly operating costs
of $2,600,000 would be required to attain consistent compliance with
an adequate margin of safety. Further, the technologies and equipment needed to comply with
IEP
A's proposal would generate significant additional electrical usage at the Millsdale plant.
Electronic Filing - Received, Clerk's Office, August 4, 2008
They estimate Stepan's electricity demand would increase by 117.8 million kW-hr/yr.
In
the
likely event that electricity demand is provided
by coal-fired electric generating units, the IEPA
proposal will generate 129,430 tons
of C02, the primary greenhouse gas linked to climate
change, 3,057 tons
of SOx, 236 tons of NOx, and 24.2 lbs of Mercury every year. This analysis
demonstrates that for a single industrial discharger (i.e. not an electrical generating station), the
cross-media impacts
of IEPA's proposal are significant.
While the impacts for other generators will depend upon their particular operations, a
substantial overall environmental impact is likeI
y, the extent of which the IEPA has not even
begun to consider. Instead, the IEPA truncated its analysis by looking only at the water quality
uses and standards without seriously considering the means and implications
of compliance. As
a result, the IEPA has not fully evaluated the use attainability standards as required
by 40 c.F.R.
§ 131.11. These regulations indicate federal intent to fully consider the impact of changes to
water quality designations - even impacts not directly related to water quality. Most critically, a
use attainability analysis directs the Agency's attention to whether a remedy "would cause more
environmental damage to correct than to leave in place" and whether "controls
... would result in
substantial and widespread economic and social impact." 40 C.F.R.
§131. 11(g)(3) and (6).
Clearly, in this case the resulting economic and environmental impacts
of the proposed
regulation would
be substantial and warrant further investigation and analysis than performed by
the IEPA.
In the Illinois Pollution Control
Board'srulemaking proceeding, it must now consider
what the IEPA has failed to analyze. Specifically, the Board should consider "the existing
physical conditions, the character
of the area, ... and the technical feasibility and economic
reasonableness
of measuring or reducing the particular type of pollution." 415 ILCS 5/27. In
Electronic Filing - Received, Clerk's Office, August 4, 2008
doing so, the Board must weigh whether modifications to the water quality standards are worth
the considerable financial and environmental sacrifices that would be required
of the dischargers
and
of all the local residents.
STEPAN COMPANY
If!~--
Date: August 4, 2008
Thomas
V.
SkiIUler
Thomas
W. Dimond
Kevin Desharnais
JeIUlifer
A.
Simon
Mayer Brown
LLP
71
South Wacker Drive
Chicago, Illinois 60606-4637
(312) 701-8407 (phone)
(312) 706-8117 (fax)
jsimon@mayerbrown.com
Electronic Filing - Received, Clerk's Office, August 4, 2008
CERTIFICATE OF SERVICE
I, the undersigned, certify that on this August 4,2008, I have served electronically the
attached Notice
of Filing and Pre-filed Testimony of Carl Adams and Robin Garibay upon the
following person:
John Therriault, Clerk
Illinois Pollution Control Board
James
R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
and by u.S. Mail, first class postage prepaid, to the following persons:
Marie Tipsord, Hearing Officer
Illinois Pollution Control Board
James
R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
The participants listed on the attached
SERVICE LIST
Deborah J. Williams, Assistant Counsel
Stefanie
N. Diers, Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Electronic Filing - Received, Clerk's Office, August 4, 2008
SERVICE
LIST
Frederick M. Feldman
Ronald M. Hill
Margaret T. Conway
Metropolitan Water Reclamation District
of Greater Chicago
111 East Erie Street
Chicago, IL 60611
Bill Richardson, Chief Legal Counsel
Illinois Department
of Natural Resources
One Natural Resources Way
Springfield, IL 62702-1271
Keith Harley
Elizabeth Schenkier
Chicago Legal Clinic, Inc.
205 West Monroe, 4th Floor
Chicago, IL 60606
Katherine D. Hodge
Monica T. Rios
Hodge Dwyer Zeman
3150 Roland Avenue
P.O. Box 5776
Springfield, IL 62705-5776
Dennis Duffield
Director
of Public Works
&
Utilities
City
of Joliet
921 E. Washington
St
Joliet, IL 60431
Claire Manning
Brown Hay
&
Stephens LLP
700 First Mercantile Bank Bldg
205 S. Fifth St
Springfield, IL 62705-2459
Frederick Keady
Vermillion Coal Company
1979 Jolms Drive
Glenview, IL 60025
Matthew Dunn, Chief
Environmental Bureau
Office of the Attorney General
100 West Randolph, 12th Floor
Chicago, IL 60601
Ann Alexander
Natural Resources Defense Counsel
101 N. Wacker Dr., Ste. 609
Chicago, IL 60606
Susan M. Franzetti
Franzetti Law Firm P.C.
10 South Lasalle St.
Suite 3600
Chicago, IL 60603
Albert Ettinger
Jessica Dexter
Environmental Law
&
Policy Center
35
E. Wacker Dr., Suite 1300
Chicago, IL 60601
Richard Kissel
Roy Harsch
DrinkerBiddle
191
N. Wacker Dr., Suite 3700
Chicago, IL 60606-1698
Charles Wesselhoft
James Harrington
Ross
&
Hardies
150
N. Michigan Ave
Chicago, IL 60601-7567
Fred L. Hubbard
P.O. Box
12
16 West Madison
Danville, IL 61834
Electronic Filing - Received, Clerk's Office, August 4, 2008
Georgia Vlahos
Naval Training Center
260lA Paul Jones St
Great Lakes, IL 60088-2845
W.C. Blanton
Blackwell Sanders LLP
4801 Main St, Suite 1000
Kansas City, MO 64112
Jerry Paulsen
Cindy Skukrud
McHenry County Defenders
132 Cass Street
Woodstock, IL 60098
Bernard Sawyer
Thomas Granto
Metropolitan Water Reclamation District
6001 W. Pershing Rd
Cicero, IL 60650-4112
Fredric Andes
Erika Powers
Barnes
&
Thornburg
1 North Wacker
Dr
Suite 4400
Chicago, IL 60606
Bob Carter
Bloomington Normal Water Reclamation
PO Box 3307
Bloomington, IL 61702-3307
Kenneth W. Liss
Andrews Environmental Engineering
3300 Ginger Creek Drive
Springfield, IL 62711
Albert Ettinger
Jessica Dexter
Environmental Law
&
Policy Center
35 E. Wacker
Suite 1300
Chicago, IL 60601
Kay Anderson
American Bottoms
One American Bottoms Road
Sauget, IL 62201
Robert VanGyseghem
City
of Geneva
1800 South St
Geneva, IL 60134-2203
Lisa Frede
Chemical Industry Council
of illinois
2250 E. Devon Ave
Suite 239
Des Plaines, IL 60018-4509
Jack Darin
Sierra Club
70 E. Lake St
Suite 1500
Chicago, IL 60601-7447
Susan Hedman
Andrew Armstrong
Environmental Counsel
Suite 1800
69 West Washington Street
Chicago, IL 60602
Tom Muth
Fox Metro Water Reclamation District
682 State Route
31
Oswego, IL 60543
Vicky McKinley
Evanston Environmental Board
223 Grey Avenue
Evanston, IL 60202
Marc Miller
Jamie S. Caston
Office
of Lt. Governor Pat Quinn
Room 414 State House
Springfield, IL 62706
Electronic Filing - Received, Clerk's Office, August 4, 2008
James L. Daugherty
Thorn Creek Basin Sanitary District
700 West End Avenue
Chicago Heights, IL 60411
Tracy Elzemeyer
American Water Company
727 Craig Road
S1. Louis, MO 63141
Irwin Polls
Ecological Monitoring and Assessment
3206 Maple Leaf Drive
Glenview, IL 60025
Jeffrey C. Fort
Ariel J. Tesher
Sonnenschein Nath
&
Rosenthal LLP
7800 Sears Tower
233 S. Wacker Drive
Chicago, IL 60606-6404
Dr. Thomas J. Murphy
2325 N. Clifton St
Chicago, IL 60614
Cathy Hudzik
City
of Chicago
Mayor's Office of Intergovernmental Affairs
121 North LaSalle Street, Room 406
Chicago, IL 60602
Brent Fewell
Kristy
A. N. Bulleit
HUNTON
&
WILLIAMS LLP
1900 K Street, N.W.
Washington, DC 20006
Sharon Neal
Commonwealth Edison
125 South Clark Street
Chicago, IL 60603
Margaret P. Howard
Hedinger Law Office
2601 South Fifth Street
Springfield, IL 62703
James Huff
Huff
&
Huff, Inc.
915 Harger Road, Suite 330
Oak Brook, IL 60523
Fredric P. Andes
Carolyn S. Hesse
David T. Ballard
Barnes
&
Thornburg LLP
1 N Wacker Dr, Suite 4400
Chicago, IL 60606
Beth Steinborn
2021 Timberbrook
Springfield, IL 62702
Traci Barkley
Prairie Rivers Networks
1902 Fox Drive, Suite 6
Champaign, IL 61820
Stacy Meyers-Glen
Openlands
Suite 1650
25 East Washington
Chicago, IL 60602
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
1
Pre-filed Testimony of Carl Adams and Robin Garibay of ENVIRON International Corporation
(ENVIRON)
I. Background of Experts
My name is Carl E. Adams, Jr., PE, PhD, and I have over 35 years of experience in Industrial
Wastewater Treatment Management. Since May 1, 2005, I have been the Global Practice Area
Leader of Integrated Industrial Wastewater Management for ENVIRON International
Corporation. Prior to that, for 20 years I was President and Chief Executive Officer of The
ADVENT Group, Inc., an international firm offering integrated industrial wastewater
management services to industry. Before founding The ADVENT Group, I spent 16 years with
Associated Water and Air Engineers, Inc. (first as Technical Director and, subsequently, as
President and CEO), which I established as one of the premiere industrial wastewater
management engineering organizations in the United States.
I have been a consultant to various industries and municipalities both in the United States and
globally, regarding design and operational aspects of wastewater management systems. Over
my career, I have consulted on over 900 wastewater management projects in 28 countries. I
hold three patents on technologies related to wastewater treatment, and I have authored or
coauthored three books and numerous articles and papers in industrial wastewater
management. In October, 2005, I was elected a Distinguished Alumni from the College of
Architecture and Environmental Engineering at The University of Texas-Austin.
In my role as Technical Director and Principal of many projects, I have had responsibility for
evaluating, designing or supervising the design of various technologies for management of
temperature in wastewater treatment facilities, especially in regard to increasing the efficiency of
biological treatment processes. I have been registered as a Professional Engineer in as many
as 17 states at one time and, as such, I had the responsibility to sign engineering documents for
final review, including heat reduction and addition processes.
My name is Robin L. Garibay, REM, and I am a principal of ENVIRON International Corporation
and the Manager for the Wastewater Management services of the Integrated Industrial
Wastewater Management Practice Area. I have over 20 years of experience in wastewater
management, including participation in the development of federal and state water quality
standards, NPDES permitting and establishment of water quality-based effluent limits based on
water quality criteria.
I am a Registered Environmental Manager (REM) with a B.S. in biochemistry from Rice
University and graduate work in biochemistry at Texas A&M University. Prior to joining The
ADVENT Group, Inc. (now ENVIRON) in 1987, I worked for the State of Kansas Board of
Agriculture Laboratories focusing on pesticide characterization in products, residues, and
groundwater. Since joining ADVENT, I worked on characterization studies of groundwater,
stormwater, process streams, effluents, and receiving waters in support of NPDES permits. My
work has been on behalf of both municipal and industrial clients. I have managed projects that
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
2
have pollutant minimization and source control of constituents to wastewater, options for end-of-
pipe treatment, and assessment of multi-media impact of control options.
I personally have worked on behalf of numerous industrial and municipal clients in the State of
Illinois on the development of elements of the Illinois water quality standards program and on
NPDES permitting issues. I have participated in the Illinois rulemaking process on adopting the
federal Great Lakes Water Quality Agreement ("GLI") into the Illinois Water Quality Standards,
revision to the antidegradation standard and implementation procedures, and revisions to the
sulfate and TDS water quality standards.
Our resumes are included in Attachment 1.
The Illinois Environmental Protection Agency (“IEPA”) has proposed to revise the water quality
use designations and the water quality standards for the Chicago Area Waterway System and
the Lower Des Plaines River. Our assistance was requested to assess the impact of several
aspects of the IEPA proposal on the Millsdale plant of Stepan Company located in Elwood,
Illinois, including the methodology and technology that the plant could adopt to meet the IEPA
proposed standards for temperature, fecal bacteria, and dissolved oxygen of the final treated
effluent (wastewater) prior to discharge into the Lower Des Plaines River near River Mile 280,
the cross-media impacts of the methodology and technology necessary to meet those standards
and the costs and technical feasibility of that methodology and technology.
As such, we have reviewed the Statement of Reasons, including the proposed revisions to the
Illinois regulations, filed by IEPA on December 20, 2007, appropriate documents and data
provided by Stepan Company staff or known to us based on our knowledge and experience in
the wastewater field and consulted with Millsdale plant staff to develop our findings. In addition,
we visited the Millsdale plant and observed the wastewater treatment system currently in place
at the plant. We have supervised and requested efforts from several individuals, working
directly for us in ENVIRON, to prepare supporting documentation to this testimony.
II. Company Background
Stepan Company is a global manufacturer of specialty and intermediate chemicals used in
consumer products and industrial applications, primarily in the soap and detergent industry.
Most of the chemicals Stepan produces are surfactants, which are the key ingredients in
consumer and industrial cleaning compounds. Stepan also produces other specialty products,
which are often custom-made to meet individual needs. In part, these include flavors,
emulsifiers and solubilizers used in food and pharmaceutical industries. Headquartered in
Northfield, Illinois, Stepan has over 1,500 employees worldwide and production facilities located
in North and South America, Europe and Asia.
Stepan’s Millsdale plant was initially constructed in 1954 and is located in an unincorporated
area at 22500 West Millsdale Road near Elwood in the southern half of Will County. The plant
employs about 400 people, of which about 230 are union members. The Millsdale plant
operates in many respects as a specialty chemical manufacturer, producing 1,200 to 1,500
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
3
somewhat varying products according to customer specifications. Among the chemicals
produced at Millsdale are alkoxylates, alpha sulfo methyl esters, amides, amine oxides, esters,
sulfonates, sulfates, soap and detergent blends, phosphate esters, quaternaries, phthalic
anhydride, polyols, and urethane systems.
The Millsdale plant employs a complex wastewater treatment system, which involves over
fifteen tanks and numerous processes, including decantation, equalization, two aeration stages,
clarification, two aerobic digestion stages, and activated sludge with dual media filtration. The
treatment system generates digested sludge that is land applied in accordance with the plant’s
land application permit. The effluent outflow is then discharged into a buried pipeline that
discharges to the Lower Des Plaines River approximately at river mile 280, which is 2 to 3 river
miles upstream of the I-55 Bridge. This discharge is in the segment of the Lower Des Plaines
River denominated as the Upper Dresden Island Pool in the IEPA Statement of Reasons.
Figure 1 presents a schematic of the wastewater treatment plant.
The NPDES Permit No. IL0002453 was renewed with an effective date of April 1, 2008. The
renewed Permit authorizes the discharge of wastewater generated from process operations,
cooling tower blowdown, sanitary waste and stormwater via Outfall 001 to the Lower Des
Plaines River. As present in the Permit, plant operation results in an average discharge of 0.88
MGD of treated process wastewater, sanitary wastewater and stormwater from Outfall 001. The
discharge quality is monitored and regulated through discharge limits for 68 parameters. The
majority of discharge limits are based on the use of the best available treatment technology for
the organic chemicals industry. Over a year, 600 results are generated to monitor the quality of
the effluent discharged to the River. Historically, the compliance record for this Plant has been
very good. Since permit renewal there have been no exceedences of discharge limits.
III. Temperature
IEPA has proposed a re-designation of the aquatic life use of the Lower Des Plaines River,
Upper Dresden Island Pool that would result in revisions to the current temperature standards to
seasonal period average and daily maximum temperature standards. Currently, Stepan’s
discharge is not subject to temperature limitations in its NPDES permit, and the applicable water
quality standard is a maximum (93°F) not to be exceeded more than 5 percent of the time and
an absolute maximum of 100°F, IEPA Statement of Reasons, pps. 11-12. The proposed
standards would reduce the daily maximum temperature to 88.7°F and would establish period
averages ranging from 85.1°F during most summer periods to 53.6°F during the month of
February. IEPA Statement of Reasons, p. 85 Stepan’s Outfall 001 would be subjected to these
proposed temperature standards likely without the option of a mixing zone due to upstream
sources of warm effluent and the general nature of the Lower Des Plaines River. If
implemented as proposed, the IEPA water quality standards would probably be imposed as
NPDES Permit discharge limits on the Millsdale plant’s Outfall 001 and would necessitate
radical temperature reduction/control efforts. Those efforts will be both costly to construct and
operate and are subject to complications due to the varying requirements throughout the
calendar year. Those efforts would also have significant cross-media impacts.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
4
The source of heat in the wastewater is from process water, RO reject water, and cooling tower
blowdown; however this heat is needed to assure a warm environment to maintain a healthy
biomass (activated sludge) in the Millsdale wastewater treatment plant (WWTP) for the
reduction of BOD in the effluent. Ideally, temperatures for effective biological treatment of this
type of wastewater water should consistently be above 70°F. Figure 2 presents daily influent
temperature (monitored at Tank 9 or the equalization tank) and daily effluent temperature
(monitored at Tank 8 or the final effluent tank).
It would be contradictory to cool the influent wastewater during cool weather months when this
is the most critical time period for the WWTP to maintain a warm environment for the WWTP
biomass for BOD treatment efficiency. The Stepan biological wastewater treatment plant is
operated to achieve discharge limits all year, operations are not adjusted or varied seasonally.
Although our opinions/conclusions do not address the impact on the river directly, it is very
evident that maintaining heat within the biological treatment process and then being required to
remove that heat prior to discharge of the effluent is contrary to most, if not all, laws of nature on
conservation and carbon footprint. The energy that creates the heat in the WWTP effluent
cannot be destroyed and can only be removed from the effluent by transferring it to some other
environmental media, for example ambient air, through processes that themselves require
energy resources and thus the production of more energy and heat.
In developing the options available to control temperature of the treated discharge, we have
framed the following conditions:
Due to upstream river temperatures and sources of heated discharges, it is
assumed that a mixing zone will not be available for implementation of the
temperature standards; i.e., the temperature standards will apply at end-of-
pipe.
Due to Stepan Company policy to always be in compliance with an adequate
margin of safety and the inability to significantly vary the temperature
conditions during the wastewater treatment process, engineering will be such
that the daily temperature will be at the proposed ‘period average
temperature standards’. Therefore, the potential Outfall 001 temperature
discharge limits are equal to the proposed ‘period average temperature
standards’. For engineering design, a margin-of-safety of 3°F would be
applied.
From a pure technological-economical standpoint, it would be most efficient to reduce the
wastewater temperature prior to biological treatment where the temperature is highest, thus,
improving the economics of heat reduction. However, this heat is required for maximum
biological activity particularly during cooler months of the year. Thus, all heat reduction
methods must be on the treated discharge, reducing the efficiency of the heat reduction
process.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
5
Current temperature results for the effluent (treated discharge) as monitored at Tank 8 as
compared to the IEPA proposed temperature discharge limits are presented in Figure 3. Based
on close to daily monitoring of the treated discharge for slightly over 2 years, the compliance
with the IEPA proposed temperature discharge limits would be achieved only about 22 percent
of the time without further treatment. Therefore, temperature reduction would be needed and as
presented in Figure 4, there are periods of time where significant removal of heat (as BTU/hr)
would be required, e.g., more than 6 million BTU/hr.
The technologies/processes commonly considered for end-of-pipe temperature reduction are:
1. Cooling ponds with surface aerators/sprayers
2. Flow augmentation, using a cooler water (such as ground water) to dissipate
the heat
3. Cooling towers
1. Open direct contact
2. Closed circuit
4. Heat exchange
1. Plate and frame
2. Tube and shell
5. Chillers (either directly or to supplement another option)
6. Cooling Air (from Blowers)
7. Surface Aeration in Tanks
We will touch briefly on the feasibility of the more commonly applied cooling technologies as it
applies to Stepan’s discharge and the cooling required (Figure 4).
1) Cooling Ponds and Larger Storage
Cooling ponds rely on the interaction of the water surface with the ambient air to
promote cooling. The larger the water surface area the greater the cooling
effectiveness. This could also be enhanced via the installation of aerators. For
the 0.88 mgd treated effluent discharge, the minimum amount of land necessary
to possibly achieve the cooling required with the use of 5 surface aerators would
be about 2.5 acre of land (to site a 3 million gallon cooling pond). The area
around the Stepan WWTP is severely restricted in additional area and given that
this size of pond and number of aerators have no allowance for any safety
factors, this option is considered to be infeasible for Stepan’s discharge.
Larger storage has been used successfully at other facilities. It consists of
storing the waters during periods that temperature standards would not be met,
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
6
such as during the winter months, and then discharging during times when the
discharge standards could be met. For Stepan, this would involve storing waters
until the discharge standards would be above 75
°
F in the summer months. As
such, Stepan could at times require up to 6 months of storage. Assuming a
discharge flow of 0.88 MGD and a pond depth of 12 feet, a pond size of over 40
acres would be required. In addition to this acreage not being available for the
Stepan plant, there are also times in the summer months where cooling would be
required, so consistent and complete compliance cannot be achieved with this
option.
2) Flow Augmentation
Flow Augmentation is the process in which the final treated effluent is mixed with
cooler waters from another source. The resulting mixed temperature is thereby
cooler than the original discharge. The current source of water supply for the
Stepan Plant is groundwater. Based on data summaries from the USGS, the
aquifer used by Stepan can range in temperature from 55°F up to as high 65°F.
These temperatures alone are higher than some of the proposed temperature
standards, thereby making this option technically infeasible for Stepan. Even if
the cooler ranges of the groundwater temperatures consistently existed, about 3
million gallons per day would be needed to cool the treated effluent. The Will
County aquifers are under scrutiny for allowing additional water withdrawals due
to the concerns with managing the availability of this valuable water supply
resource. Based on our recent experience in siting new manufacturing plants,
we are uncertain that use of groundwater to ‘cool’ a treated effluent would be
viewed favorably. We do not believe flow augmentation is a feasible technology
for application to the Stepan discharge.
3) Cooling Towers
Cooling towers is the process in which water is exposed to the air to promote
evaporation of the water to the atmosphere. Cooling towers can be open direct
contact or closed circuit.
For open direct contact towers, evaporation is utilized for cooling of the water
streams. Evaporation of water is extremely effective in cooling wastewater
streams in low humidity conditions (as an example, it is similar to the cooling
effects of a fan in your house on a hot day). However, like the ineffectiveness of
a fan on a very humid day, cooling towers can also be very ineffective during
humid days. Cooling towers can only cool down to a certain amount above the
temperature in which there is 100% saturation (which is called the wet-bulb
temperature).
The certain amount above wet bulb temperature is called
approach temperature.
Typical designs of cooling towers assume a 10 to 15°F approach to wet bulb.
Therefore, cooling tower discharge temperatures can be approximated by simply
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
7
adding the approach temperature to the wet bulb temperature.
For a
conservative evaluation of the anticipated cooling tower discharge temperatures
for the Stepan Plant, a wet bulb temperature of 78°F was used (based on the a
NOAA data).
The corresponding anticipated cooling tower discharge
temperatures (calculated by adding an approach temperature of 10 °F) would not
consistently and completely achieve the potential discharge limits.
Even
considering seasonal wet bulb temperatures and a specialized open cooling
tower design, discharge temperatures would not consistently and completely
achieve the potential discharge limits; thereby this option is technically infeasible
for application to the Stepan treated effluent. In addition, open cooling towers
applied to treated effluent can generate particulate matter and VOM emissions
that are subject to air emission regulation. Whether the additional emissions
from open cooling towers could be permitted is uncertain.
A closed circuit cooling tower operates by cooling a water source to the range of
an open tower and then cools the wastewater stream by heat exchange over
coils. They can be as efficient as open direct contact towers from the
perspective of temperature reduction. However, closed circuit cooling towers
tend to foul less than open towers, thereby being preferred for wastewaters that
may tend to foam or exhibit high suspended solids, which has been observed
with the influent to Stepan’s WWTP. Since a closed cooling tower is not
expected to reduce the temperature more effectively than open cooling towers,
closed towers are therefore also technically infeasible for the Stepan discharge
for the reduction of temperature.
4) Plate & Frame Heat Exchangers
Plate & Frame heat exchanges operate on the premise that the heat from a water
source that needs to be cooled is transferred to cooler water from a different
source. As discussed previously for the Flow Augmentation alternative, the other
source of water for the Stepan plant is groundwater, which as discussed
previously is not cool enough to meet temperature standards, thereby making
this option technically infeasible without pretreatment (i.e., additional cooling) of
the groundwater.
5) Chillers
This option would consist of using a water chiller to further cool waters from a
cooling tower. Since the water chiller utilizes a medium other than water (i.e.,
propylene glycol, ammonia), cooler water temperatures can be achieved for the
groundwater used for a heat exchanger or with a cooling tower alone. The water
chiller would be operated integrally with a heat exchanger (e.g., plate and frame)
that would remove heat from a cooling tower during those times of the year when
discharge temperatures from a cooling tower alone would not be successful in
meeting the proposed temperature standards. A cooling tower/chiller option
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
8
should thereby be able to achieve the proposed temperature standards from a
technical perspective.
6) Cooling Air (from Blowers)
This alternative would consist of utilizing air from the wastewater treatment plant
blowers that supply air to Tank 9 (Equalization Tank), Tanks 15 and 16 (Aeration
Tanks), and Tank 2 (Aeration Tank). Currently, the air supplied by the blowers is
warm to hot, installation of devices (e.g., water sleeves around piping) to cool the
air would provide some cooling of the wastewater. However, the cooling of the
wastewater in the tanks would be limited to the temperatures needed to provide
optimal biological performance (e.g, not less than 70°F). In addition, the
estimated ability of cooling air from the blowers is (maximum) about 1.6 million
BTUs/hr, far less that the required cooling of over 6 million BTUs/hr (and up to
9.68 million BTUs/hr). This option is technically infeasible.
7) Surface Aeration in Tanks
This alternative would consist of the installation of aerators within the final
effluent tank (Tank 8). The aerators would increase the air-water interaction to
promote cooling. The volume of this tank is only about 36,000 gallons with a
resulting retention time (< 1 hour) that would require a number and size of
surface aerators that cannot be accommodated in this size of tank. This option is
infeasible.
As briefly mentioned in the discussion outlining potential options, the technically feasible option
to achieve consistent and complete compliance with the IEPA proposed temperature discharge
limits would be a cooling tower in combination with a heat exchanger/chiller combination. As
discussed previously, for the Stepan discharge a closed-circuit cooling tower would be preferred
given the potential for fouling of an open-circuit cooling tower and the need to consider air
permitting issues for an open-circuit tower. The heat exchanger/chiller would be operated
during periods in which the cooling tower alone would not be sufficient to comply with the
proposed temperature standards. For this option to achieve the required cooling (Figure 4), we
have evaluated their financial and environmental impact.
The details of this evaluation, which included preliminary quotes from equipment vendors, can
be made available to interested parties.
Financial Impact
Capital Cost:
$1,640,000 (includes equipment, engineering,
installation)
O & M Cost:
$1,300,000/yr
(includes
labor,
electrical,
chemicals, maintenance)
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
9
Environmental Impact
Effluent Quality:
Will not change chemical or biological
characteristics of discharge
Land Use:
1,200 sq ft
Solid Waste:
Generation insignificant
Air Emissions:
Insignificant from closed-circuit cooling tower
(intentional consideration)
Electrical Usage:
117 million kW-hr/year
Equivalent Population:
9,065 residential customers or 31,728
people
1
CO
2
Emissions:
128,530 tons/year
2
SO
x
Emissions:
3,037 tons/year
3
NO
x
Emissions:
234 tons/year
4
Hg Emissions:
24 lbs/year
5
Back to top
IV. Effluent Bacteria Standards
IEPA has also proposed re-designation of the use of the Lower Des Plaines River, including the
Upper Dresden Island Pool, to “Incidental Contact Recreation” that would result in application of
a “technology-based value designed to assure that disinfection technologies are functioning
properly” during the months of March to November. The technology-based value or effluent
standard for the disinfection is 400 fecal coliforms (#) per 100 mL. IEPA Statement of Reasons,
p. 92.
Currently, Stepan’s Outfall 001 is not subject to NPDES permit discharge limits for fecal
coliforms and the current wastewater management does not include a disinfection system.
Because IEPA has proposed this standard as an effluent standard rather than a water quality
standard, compliance with the standard will be required at the discharge point from the WWTP.
Hence, installation of a disinfection system to achieve the effluent fecal standard will be
required. The source of fecal coliform in the wastewater is from the overflows from the about 15
septic systems located at distinct locations throughout the Stepan Plant. The septic systems do
not use and will not be able to use leach fields.
Based on a limited amount of treated effluent monitoring data, more than a 98 percent reduction
of fecal bacteria would be needed to achieve compliance with the bacteria effluent standard.
The technologies commonly considered for disinfection to ‘kill’ bacteria include:
1) Source Treatment (chlorination) prior to septic system overflows entering process
wastewater sewers.
2) End-of-pipe chlorination
2
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coal
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t
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an average of 3.5 people per residence
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
10
3) Other end-of-pipe applications (e.g., UV, ozonation, or peroxide)
We will touch briefly on the feasibility of these technologies as it applies to Stepan’s
wastewaters and discharge.
1. Our concern with source treatment at the individual septic systems is assuring
that the chlorine concentration is effective to kill bacteria, but not at such a level
that the residual chlorine could chlorinate organic material present in the
untreated process waters (with which the septic overflows commingle) or that the
residual chlorine could inhibit activated sludge. Given that specific information
and data are not available on the effectiveness and reliability of source treatment
and the potential detriment to overall wastewater management, this option is not
considered technically feasible.
2. The most common end-of-pipe process for disinfection of a treated effluent is
chlorination. It is known to be effective and has been proven to work well on a
variety of treated wastewaters. However, de-chlorination would be required to
assure that the total residual chlorine (TRC) standard proposed by IEPA for the
Lower Des Plaines River, which is the same as the General Use TRC standard,
Statement of Reasons, p. 65, would be attained. The TRC standard, as
discharge limits, in effect require complete destruction of residual chlorine.
These systems (chlorination followed by dechlorination) as applied to the Stepan
treated effluent are considered technically feasible.
3. Other end-of-pipe systems have been shown to be effective in destroying fecal
bacteria, e.g., ultraviolet light (UV), ozonation (facilitated with UV), hydrogen
peroxide (facilitated with UV). However, the effectiveness of these systems
would be limited as applied to Stepan’s treated effluent due to the type of TSS
present, the tendency for the effluent to contain materials that ‘foam’, the level of
BOD, and the ‘color’ of the treated effluent.
Though these wastewater
characteristics are controlled to more than acceptable levels for an organic
chemical facility, they are not at the levels that these disinfection systems would
have been engineered for e.g., municipal applications. For example, bio or
chemical (e.g., scaling) fouling of UV lamp banks would be anticipated to occur
excessively as applied to Stepan’s treated effluent. Therefore, use of other end-
of-pipe systems for disinfection of the treated effluent is not considered
technically feasible.
We consider the technically feasible option to achieve consistent and complete compliance with
the effluent bacteria standard to be chlorination followed by dechlorination to assure being in
compliance with the Illinois TRC limit. For this option to achieve compliance, we have evaluated
its financial and environmental impact.
The details of this evaluation, which included preliminary quotes from equipment vendors, can
be made available to interested parties.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
11
Financial Impact
Capital Cost:
$1,771,000 (includes equipment, engineering,
installation)
O & M Cost:
$650,000/yr
(includes
labor,
electrical,
chemicals, maintenance)
Environmental Impact
Effluent Quality:
Chloride will, on average, increase by about 19
percent
Sulfate will, on average, increase by about 31
percent
Potential formation of chlorinated organics, but
level of organics very low in treated effluent.
Land Use:
~5,700 sq ft
Solid Waste:
Generation significant
Air Emissions:
Insignificant from treatment systems
Electrical Usage:
0.784 million kW-hr/year
Equivalent Population:
61 residential customers or 213 people
6
CO
2
Emissions:
900 tons/year
7
SO
x
Emissions:
20 tons/year
8
NO
x
Emissions:
2 tons/year
9
Hg Emissions:
0.2 lbs/year
10
Back to top
V. Dissolved Oxygen
IEPA has also proposed re-designation of the use of the Lower Des Plaines River, Upper
Dresden Island Pool that would result in revisions to the dissolved oxygen (DO) criteria. Though
a DO criterion already does apply to these waters (4.0 mg/L, 35 IAC 302.405), IEPA has not
developed the data to assess the assimilative capacity of the Upper Dresden Island Pool water
for DO (e.g., DO sources, DO sinks, relationship between flow, DO, temperature, conductivity,
kinetics of BOD and ammonia, etc.). Normally, the assimilative capacity of a water (or a simple
DO model) is used to limit those substances that impact in-stream DO. Therefore, we are
assuming that IEPA will implement the proposed more stringent DO criteria as end-of-pipe
limits. This would mean that the discharge from Outfall 001 would be required to meet the DO
standards proposed by IEPA for the Upper Dresden Island Pool. For March to July, the
proposed standards are not less than 5.0 mg/L at any time and not less than 6.0 mg/L as a 7-
day mean of daily means. For August to February, the proposed standards are not less than
3.5 mg/L at any time, not less than 4.0 mg/L as a 7-day mean of daily minima and not less than
5.5 mg/L as a 30-day mean of daily means. IEPA Statement of Reasons, 56-60. As such, the
7
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-hr
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plaplacoal
wnnith
t
t
an average of 3.5 people per residence
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
12
temperature and conductivity of Stepan’s treated effluent impacts the ability of the treated
effluent to ‘saturate’ to a level to achieve potential DO limits. Currently, DO is not subject to
NPDES Permit discharge limits at Outfall 001. To assure consistent compliance with the
proposed DO criteria, the averaged daily mean (March through July or August through
February) DO will be the daily potential discharge limit as applied to Outfall 001.
The ‘source’ of DO (or DO sink) for the treated effluent is the aeration of the effluent to promote
activated sludge to biologically degrade organics. Aeration tanks are specifically operated at
DO levels between 2 and 4 mg/L to assure reliable yet cost-effective performance in attaining
BOD discharge limits. It would be detrimental to operations and to biological treatment to
operate the aeration tanks at higher levels of DO. Therefore, the treatment options to achieve
the potential DO limits will be at ‘end-of-pipe’ – after Tank 8.
Current DO results for the effluent (treated discharge) as monitored at Tank 8 as compared to
the IEPA proposed DO discharge limits are presented in Figure 5. Based on the close to daily
monitoring of the treated discharge for slightly over 2 years, the compliance with the IEPA
proposed DO discharge limits would be achieved only about 10 percent of the time without
further treatment. Therefore, treatment to add DO to the treated effluent would be needed with
as much as 5.2 mg/L DO needed to be added at some times and on average 2.2 mg/L
additional DO needed.
The technologies commonly considered for adding DO or supplemental aeration of a treated
effluent includes:
1) Pressurized Air Diffusers
2) Stair-step aeration
3) Surface aerators
4) Direct injection of oxygen
5) Hydrogen peroxide
We will touch briefly on the feasibility of these technologies as it applies to Stepan’s
wastewaters and discharge.
1) The use of air diffuser systems is generally a good solution to adding DO to
wastewater but for this wastewater there is a concern about causing foaming.
Also, the small size of the Tank 8 would not accommodate a diffuser system
(sized for the amount of DO addition needed). This option is not considered
technically feasible for application to the Stepan treated effluent.
2) A step aeration system would be difficult as it is normally incorporated into a
natural feature. The routing of the treated effluent from Tank 8 to the River is via
underground pipe. It would be possible to construct a large stand alone unit if
the land was available; however not enough land is available. This system would
also be very vulnerable to foaming over as the water cascades down the steps,
which would require the use of chemicals to control, and use of defoaming
chemicals at this point could be problematic. This option is not considered
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
13
technically feasible for application to Stepan treated effluent and the in-place
wastewater conveyance system.
3) Surface aerators are also a physical system commonly used to add more oxygen
in waters, however, similar to application to step aeration systems, there is a
concern with foam creation with the treated effluent. Another limitation of this
technology to the Stepan Plant is that the number of surface aerators needed to
add DO cannot be placed in Tank 8. This option is infeasible as applied to the
treated effluent.
4) Direct injection of oxygen to saturate the treated effluent requires very specific
and detailed safety measures as oxygen is a fire accelerant. These systems are
known to be extremely energy intensive and the injection of oxygen would have
potential to cause foaming issues. This option is not technically feasible for the
Stepan Plant.
5) We consider the technically feasible option to achieve consistent and complete
compliance with the potential DO limits to be hydrogen peroxide addition. For
this option to achieve compliance, we have evaluated its financial and
environmental impact.
The details of this evaluation, which included preliminary quotes from equipment vendors or
historical costs, can be made available to interested parties.
Financial Impact
Capital Cost:
$25,000 (includes chemical injection quill,
piping, in-pipe static mixer, engineering,
installation)
O & M Cost:
$650,000/yr
(includes
labor,
electrical,
chemicals, maintenance)
Environmental Impact
Effluent Quality:
Could change chemical composition by
oxidizing certain chemicals; will add oxygen (as
measured by DO as mg/L) to treated effluent
Land Use:
100 sq ft
Solid Waste:
Generation insignificant
Air Emissions:
Insignificant from treatment system
Electrical Usage:
~500 kW-hr/year (insignificant impact on
emissions)
Equivalent Population:
9,065 residential customers or 31,728
people
Solid Waste:
Air Emissions:
Electrical Usage:
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
14
VI. Findings
The proposed re-designation of use of the Lower Des Plaines River which in turn affects the
numeric standards and criteria for temperature, fecal bacteria, and dissolved oxygen will result
in significant financial and cross-media environmental impacts. Those impacts cannot be
understood at a theoretical level without considering the actual engineering steps that Stepan
and other dischargers will have to take to comply with the proposed standards. In managing the
wastewater to achieve consistent and complete compliance with the IEPA proposed discharge
limits Outfall 001, Stepan will have to install and operate technologies that are well beyond the
treatment considered “best” for organic chemical manufacturing plants and to achieve an
effluent quality that now is considered excellent based on the Millsdale plant’s NPDES Permit
compliance history. Control options deemed technically feasible to treat the effluent, beyond the
existing secondary treatment (biological) and tertiary treatment (filtration) as presented in Figure
1, are presented in Figure 6.
Based on our knowledge and experience, no chemical manufacturing facility in the USA has
installed all of these end-of-pipe control systems.
We offer the following summary of the impacts of all three additional control systems:
Financial Impact
Capital Cost:
$3,436,000 (+/- 50% includes equipment,
engineering, installation)
O & M Cost:
$2,600,000/yr
(includes
labor,
electrical,
chemicals, maintenance)
Environmental Impact
Effluent Quality:
Will be an increase in chloride and sulfate (and
salt overall). It is not known if the overall
increase in salt would cause issues with
complying with acute or chronic whole effluent
toxicity. There is also a small possibility that
chlorinated organics, not currently present in the
discharge, could form during the chlorination
process necessary to meet IEPA’s proposed
effluent disinfection requirement.
Land Use:
~7,000 sq ft (~0.2 acres)
Solid Waste:
Generation insignificant
Air Emissions:
Insignificant from treatment systems
Electrical Usage:
117.8 million kW-hr/year
Equivalent Population:
9,126 residential customers or 31,941 people
CO
2
Emissions:
129,430 tons/year
SO
x
Emissions:
3,057 tons/year
NO
x
Emissions:
236 tons/year
Hg Emissions:
24.2 lbs/year
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
15
In conclusion, Stepan’s ability to reliably comply with the temperature limits, effluent bacteria
standard, and DO limits proposed by IEPA would result in significant costs and significant cross-
media environmental impacts. Because the Millsdale plant does not have its own power plant,
the electrical usage needed to operate the treatment systems that would be necessitated by
IEPA’s proposed rules would have to be purchased from the electricity grid. Thus, electrical
demand is likely to be met primarily by coal-fired electrical generating plants, which are
themselves significant sources of thermal discharges and decreased DO.
We assume that time would be granted to design and construct controls to meet the proposed
discharge limits and effluent bacteria standard, but time will not reduce economic and
environmental impacts of the control systems. We understand that the IEPA believes that
technologies required for compliance with temperature, bacteria and DO are technically
feasible. However, that belief was apparently based on virtually no engineering analysis and did
not analyze the real economic and cross-media environmental impacts that would occur. In
addition, the impacts on the Millsdale plant, as analyzed in our report, will certainly be replicated
in varying degrees at other industrial dischargers. While we have not analyzed how other
industrial dischargers might comply with the proposed IEPA standards, they are also likely to
require treatment technologies requiring significant energy usage with substantial costs and
cross-media environmental impacts. The simple scientific truth is that the energy present in
wastewater that creates higher temperature discharges cannot be destroyed. It can only be
transferred to some other environmental media via the use of energy-intensive processes. In
our opinion, the IEPA proposal has failed to consider these environmental and economic
impacts and whether those impacts outweigh any projected benefits to water quality from the
proposal. In our experience, the economic reasonableness to “smaller dischargers” and the
overall significant multi-media impacts of technically feasible controls ought to be thoroughly
considered in any proposal to modify water quality uses or water quality standards.
We also understand that IEPA is not aware of any water quality standards, except DO,
temperature, and disinfection, that would require specific technology upgrades to achieve
compliance. Stepan is in the process of evaluating whether additional controls will be
necessary to assure compliance with certain metals and salt criteria that are being revised or
added in support of the proposed re-designation of use. As IEPA is aware, a biological
treatment system, even one with tertiary treatment like Stepan, is not designed to remove
metals or salts. As Stepan’s source of salts would be from process area cooling tower
blowdowns, process area reverse osmosis system reject water, seasonal use of salt for de-icing
for safety, and additional of acids or bases at the wastewater treatment plant to maintain pH and
alkalinity that is needed for optimal biological treatment, source controls are not an option.
Similarly, there are no specific sources of metals at this chemical manufacturing plant.
Therefore, any treatment would be at end-of-pipe and would likely have significant economic
and environmental impacts.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Figure 1. Stepan Wastewater
Treatment Flow Diagram
Notes: WW = Wastewater
T = Tank
T-9
EQUALIZATION
TANK
•
Add Air
•
Add ammonia/
•
Phosphorus
PROCESS WW
UTILITY WW
TREATED
SANITARY
STORMWATER
NON-
CONTACT
T-15 & T-16
1
ST
STAGE
AERATION
•
Add Air
•
Activated Sludge
SLUDGE BASIN
DECANT
T-1
1
st
STAGE
CLARIFIER
TANK
•
Solids Sep
•
Skimmer
T-10
HOLDING
TANK
SLUDGE
RECYCLE
PRESSURE
FILTERS (3)
DUAL MEDIA
FILTRATION
•
sand
•
coal
T-8
FINAL
EFFLUENT
TANK
POLYMER ADDITION
FLOW
METERING
AND
SAMPLING
OUTFALL 001
DISCHARGE TO DES
PLAINES RIVER –
NPDES PERMIT
#IL0002453
BACK WASH FILTER
RINSE WATER
SOLIDS
WASTED
T-2
2
nd
STAGE
AERATION
•
Add Air
•
Activated Sludge
T-3 & T-4
2
nd
STAGE
CLARIFIER
TANK
•
Solids Sep
•
Skimmer
Back
wash
Effluent
BACK WASH
EFFLUENT
DECANT WW
SLUDGE
RECYCLE
SOLIDS
WASTED
DECANT WW
20-22102A
04-Aug-08
Electronic Filing - Received, Clerk's Office, August 4, 2008
#20-21102A
04-Aug-08
Figure 2. Daily Effluent Temperature (Tank 8)
Back to top
& Daily Influent Temperature (Tank 9)
50
55
60
65
70
75
80
85
90
95
100
4
/
1
/
2
0
06
6
/
1
/
2
0
06
8
/
1
/
2
0
06
1
0
/
1
/
2
00
6
1
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/
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2
00
6
2
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1
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2
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07
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/
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/
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8
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07
1
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/
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00
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1
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2
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1
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2
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4
/
1
/
2
0
08
6
/
1
/
2
0
08
Date
Temperature (ºF)
0.0
0.5
1.0
1.5
2.0
2.5
3.0
3.5
4.0
4.5
5.0
Flow (MGD)
T9 ºF
T8 ºF
T8 MGD
Electronic Filing - Received, Clerk's Office, August 4, 2008
#20-21102A
04-Aug-08
Figure 3. Comparison of Tank 8 Effluent Period Temperature Averages
Back to top
with IEPA Proposed Temperature Averages
0
10
20
30
40
50
60
70
80
90
100
A
p
ril 1-1
5
A
p
ril 16
-3
0
M
a
y
1-15
M
a
y
16
-
3
1
Jun
e
1-1
5
Jun
e
16
-3
0
Jul
y
1
-
3
1
A
u
gu
s
t
1-31
S
e
pt
1
-15
S
e
pt
1
6-3
0
Oc
t
1-15
Oc
t
16
-
31
No
v
e
m
b
e
r
De
c
e
m
b
e
r
Jan
u
ary
1-31
Feb
ru
ary
1-28
M
a
r
c
h
1-37
A
p
ril 1-1
5
A
p
ril 16
-3
0
M
a
y
1-
15
M
a
y
16
-
3
1
Ju
n
e
1-1
5
Jun
e
16
-3
0
Jul
y
1
-
3
1
A
u
gu
s
t
1-31
S
e
pt
1
-15
S
e
pt
1
6-3
0
Oc
t
1-15
Oc
t
16
-
31
No
v
e
m
b
e
r
De
c
e
m
b
e
r
Jan
u
ary
1-31
Feb
ru
ary
1-28
M
a
r
c
h
1-37
A
p
ril 1-1
5
A
p
ril 16
-3
0
M
a
y
1-
15
M
a
y
16
-
3
1
Ju
n
e
1-1
5
Dates of Permit Temperature Periods
Temperature (ºF)
Proposed Period Average
Effluent Temperature
Electronic Filing - Received, Clerk's Office, August 4, 2008
#20-21102A
04-Aug-08
Figure 4. Cooling Required To Attain Discharge Limits
0.00E+00
1.00E+06
2.00E+06
3.00E+06
4.00E+06
5.00E+06
6.00E+06
7.00E+06
8.00E+06
9.00E+06
4
/
1
/
2
0
06
5
/
3
1
/
2
00
6
7
/
3
0
/
2
00
6
9
/
2
8
/
2
00
6
1
1
/
2
7/20
0
6
1
/
2
6
/
2
00
7
3
/
2
7
/
2
00
7
5
/
2
6
/
2
00
7
7
/
2
5
/
2
00
7
9
/
2
3
/
2
00
7
1
1
/
2
2/20
0
7
1
/
2
1
/
2
00
8
3
/
2
1
/
2
00
8
5
/
2
0
/
2
00
8
Date
Cooling (BTU/hr)
Electronic Filing - Received, Clerk's Office, August 4, 2008
#20-21102A
04-Aug-08
Figure 5. Tank 8 (Final Effluent) Characteristics:
Back to top
Flow, DO, Temperature
0
1
2
3
4
5
6
7
8
9
10
4
/
1
/
2
0
06
5
/
1
/
2
0
06
6
/
1
/
2
0
06
7
/
1
/
2
0
06
8
/
1
/
2
0
06
9
/
1
/
2
0
06
1
0
/
1
/
2
00
6
1
1
/
1
/
2
00
6
1
2
/
1
/
2
00
6
1
/
1
/
2
0
07
2
/
1
/
2
0
07
3
/
1
/
2
0
07
4
/
1
/
2
0
07
5
/
1
/
2
0
07
6
/
1
/
2
0
07
7
/
1
/
2
0
07
8
/
1
/
2
0
07
9
/
1
/
2
0
07
1
0
/
1
/
2
00
7
1
1
/
1
/
2
00
7
1
2
/
1
/
2
00
7
1
/
1
/
2
0
08
2
/
1
/
2
0
08
3
/
1
/
2
0
08
4
/
1
/
2
0
08
5
/
1
/
2
0
08
6
/
1
/
2
0
08
7
/
1
/
2
0
08
Date
DO (mg/L); Flow (MGD)
0
10
20
30
40
50
60
70
80
90
100
Temperature (°F)
T8 DO
T8 MGD
Proposed DO Limit
T8 deg F
Electronic Filing - Received, Clerk's Office, August 4, 2008
Electronic Filing - Received, Clerk's Office, August 4, 2008
Stepan Company
Millsdale Plant
Report for the Stepan Company on the Economic and
Environmental Impacts Of Complying With Water Quality Uses
and Standards Proposed By IEPA for the Lower Des Plaines
River, Upper Dresden Island Pool
#20-21102A
Attachment 1
Back to top
Resumes of ENVIRON Personnel
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
1
EDUCATION
1969
PhD, Environmental Health Engineering, The University of Texas, Austin, Texas
1966
MS, Sanitary and Water Resources Engineering, Vanderbilt University, Nashville,
Tennessee
1965
BS, Civil Engineering
REGISTRATIONS & CERTIFICATIONS
Professional Engineer: Alabama, Florida, Indiana, Kentucky, Louisiana, Mississippi, Ohio, Tennessee,
Virginia and Texas.
EXPERIENCE
Dr. Carl E. Adams, Jr., is considered one of the leading international experts on Industrial Wastewater
Management. In September 1969, Dr. Adams established Associated Water & Air Resources
Engineers, Inc. (The AWARE Corporation), which developed over 15 years into the largest industrial
wastewater management engineering organization in the United States with over 250 employees in
three countries (US, Venezuela and Italy).
In January 1985, Dr. Adams and a small group of experts from AWARE founded The ADVENT Group,
Inc. of Brentwood, Tennessee, an innovative high tech firm offering integrated wastewater management
services to industry. During ADVENT’s tenure, Dr. Adams developed and is the inventor and holder of
three patents involving advanced industrial wastewater treatment technology. These patents are installed
in over 44 applications in 13 countries. The ADVENT Group, Inc. had four offices in the US and four
international locations (Sao Paulo, Brazil; Brussels, Belgium; Beersheva, Israel; and Ahmedabad, India).
In May, 2005, Dr. Adams merged The ADVENT Group, Inc. with ENVIRON, a global environmental
consultancy. He became Global Practice Leader of Integrated Industrial Wastewater Management.
Dr. Adams has been a consultant/director to more than 1,000 US and foreign industrial wastewater
management projects; author of over 100 technical publications and presentations; co-author and editor
of four books and several engineering manuals regarding industrial wastewater treatment design and
management. Professional activities include over 100 technical seminars and courses in the United
States, Eastern and Western Europe (including Russia), South America, Asia (including China), the
Middle East and Australia. He also has served as a Visiting Adjunct Professor at Vanderbilt University
for Application of Advanced Wastewater Technology.
His special areas of technical expertise include: aerobic and anaerobic treatment of high strength and
high salt industrial wastewaters, nitrification-denitrification, membrane technology, chemical oxidation,
source control and water recycle and reuse.
In October 2005, he was inducted into the Academy of Distinguished Alumni in the Department of Civil
and Architectural Engineering at The University of Texas in Austin.
His major US and international clients have included: GE Plastics, ExxonMobil, MarathonAshland, Olin,
Monsanto, Solutia, DuPont, Huntsman Chemicals, Nova Chemicals, Formosa Chemicals and 3M.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
2
EMPLOYMENT HISTORY
2005 – Present ENVIRON, Princeton, New Jersey
Global Practice Area Leader, Integrated Industrial Wastewater Management
1985 – Present The ADVENT Group, Inc., Brentwood, Tennessee
Principal, Chief Executive Officer, Board Chairman
1969 – 1985 The AWARE Corporation, Nashville, Tennessee
Dr. Adams founded and held technical and management positions, including
President & Chief Executive Officer, Vice Chairman of the Board
1977
UNOP/W Project Environmental Pollution Abatement Center, Katowice, Poland
(Three-week assignment: Recycle of Industrial Wastewaters) - Special Consultant
1974
UNOP/W Project Environmental Pollution Abatement Center, Krakow, Poland
(Two-week assignment: Nitrification/Denitrification of Toxic Industrial
Wastewaters) - Special Consultant
1968 – 1969 Engineering Science of Texas, Austin, Texas - Project Manager
1967-1968
University of Texas, Austin, Texas - Research Associate
1966
US Corps of Engineers, Nashville, Tennessee - Project Engineer
PATENTS
Wastewater Treatment System with Enhanced Directional Flow, United States Patent 6,224,773,
Awarded May 1, 2001.
Integrated Wastewater Treatment System with Induced Sludge Velocity, United States Patent
5,766,459, Awarded June 16, 1998.
Biomass Conditioner, United States Patent 5,830,351, Awarded November 1, 1998.
PUBLICATIONS
Reducing the Cost and Area Footprint of Activated Sludge Treatment Using Integral Secondary
Clarification, Proceedings of Innovation 2000, Cambridge University, Churchill College UK, July 7-
10, 1998.
“Rapid Evaluation and Installation of a Low Cost Water Treatment Scheme at a Superfund Site,” with
Anu Singh, Environmental Progress, Vol. 16, No. 4, winter 1997.
“Carbon with a Twist: Granular Activated Carbon Reduces Toxicity at Chemical Manufacturing
Facility,” with S. Butterworth, R. Falco, and A. Pedigo, Industrial Wastewater, pp. 42-45, Mar/Apr
1994.
“Optimizing Design for Secondary Clarifiers,” Proc. Water Environment Federation, Anaheim, CA,
October 1993.
“Source Control for Wastewater Discharges for the Organic Chemicals Industry,” The National
Environmental Journal, pp. 28-34, Sept/Oct 1992.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
3
“Industrial Wastewater Treatment Options, “the National Environmental Journal, pp. 16-18, Sept/Oct
1991.
“Design of Activated Sludge Systems with Regard to High Salt Wastewaters,” with E.J. Reap, J.H. Koon,
and W.W. Eckenfelder, Jr. Proc. of 51st Annual Conference-Water Pollution Control Federation,
Anaheim, CA, October 1978.
“Design of Activated Sludge Systems with Regard to High Salt Wastewaters,” with W.W. Eckenfelder,
Jr. Proc of 9th IAWPR Conference, Stockholm, Sweden, June 1978.
“Sludge Handling Methodology for Refinery Sludge,” with R.M. Stein. Proc. Open Forum on
Management of Petroleum Refinery Wastewaters, sponsored by the Environmental Protection
Agency, The American Petroleum Institute, The National Petroleum Refiners Association, and The
University of Tulsa, Tulsa, OK June 1978.
“Operational Considerations for Aeration Systems.” Proc. of 17th Annual Conference, Texas Water
Pollution Control Association, Austin, TX May 1978.
“Oxygen Activated Sludge Considerations for Industrial Applications,” with W.W. Eckenfelder, Jr. Proc.
of 70th Annual AICHE Meeting, New York, November 1977.
“The Economics of Handling Refinery Sludges,” with J.H. Koon. Proc. of Second Open Forum on
Management of Petroleum Refinery Wastewater. Sponsored by EPA, The National Petroleum
Refiners Association and the University of Tulsa, Tulsa, October 1977.
“Treatment of Textile Dye House Wastewaters,” with G.M. Davis, J.H. Koon. Proc. 32nd Annual
Purdue Industrial Waste Conference, Purdue University, West Lafayette, IN, May 1977.
“Comprehensive Temperature Model for Aerated Biological Systems,” with Y. Argaman. Proc. of 8th
IAWPR Conference, Sidney, Australia, October 1976.
“Wastewater Treatment Concerns of the Organic Chemicals Industry in the United States,” with Billy T.
Sumner. USA-USSR Working Group of the Prevention of Water Pollution from Municipal and
Industrial Sources. Proc. of Symposium on Intensification of Biochemical Treatment of Wastewaters,
Vodgeo, Moscow, USSR, August 1976.
“Technical Preparation for Negotiating and Amending NPDES Permits.” Proc., Legal Implications of
Existing and Proposed Water Quality Control Legislation. Sponsored by Vanderbilt University of
Nashville, Tennessee and American University, Washington, D.C., June 1976.
“Startup and Initial Operational Procedures for Activated Sludge Facilities for Treatment of a Complex
Wastewater.” Proc. 31st Annual Purdue Industrial Waste Conference, Purdue University, Purdue,
May 1976.
“Sludge Handling Methodology for Refinery Sludges,” Proc. of First Open Forum on Management of
Petroleum Refinery Wastewaters. Sponsored by EPA, The American Petroleum Institute, The
National Petroleum Refiners Association, and The University of Tulsa, Tulsa, OK, January 1976.
“Design and Performance of Physical-Chemical and Activated Sludge Treatment for an Edible Oil Plant,”
with R.M. Stein and Joel J. Joseph. Proc. of 30th Ind. Waste Conference, Purdue University,
Lafayette, IN, May 1975.
“Biological Treatment for World’s Largest Acrylate Plant to Achieve BATEA of Houston Ship Channel,”
with G.M. Davis, Proc. 0f 30th Ind. Waste Conference, Purdue University, Lafayette, IN May,
1975.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
4
“Biological and Physical-Chemical Treatment of Waste from a Diversified Organic Chemicals Plant,”
with J. H. Koon. Proc. of 30th Ind Waste Conference, Purdue University, Lafayette, IN, May
1975.
“Analysis of Alternatives in the Removal of Suspended Solids in the Pulp and Paper Industry,” with O.D.
Smith and R.M. Stein, Proc. of 1975 TAPPI Environmental Conference, Atlanta, May 1975.
“Tertiary Ozonation of Industrial Wastewaters,” with R.M. Stein, G.M. David, and C.D. Magee (USA),
Proc. of Second International Ozone Symposium, Montreal, Canada, May 1975.
“Achieving BATEA on the Houston Ship Channel Using Biological Treatment,” Proc. of ASCE National
Structural Engineering Convention & Exposition, New Orleans, April 1975.
“A Kinetic Model for Design of Completely-Mixed Activated Sludge Treating Variable-Strength Industrial
Wastewaters,” with W.W. Eckenfelder, Jr. and Joe C. Hovious, Water Research, Vol. 9, pp. 37 to
42, Pergamon Press, January 1975.
“Equalization and Biological Treatment Techniques for a High Salinity, Complex Organic Wastewater,”
with W.W. Eckenfelder, Jr. and Vladimir Novotny, Proc. of 7th IAWOR Conference, Paris, France,
September 1974.
“Treatment of a High Strength Phenolic and Ammonia Wastestream by Single and Multi-Stage Activated
Sludge Processes, “Proc. of 29th Annual Purdue Ind. Waste Conf., Purdue University, Lafayette, IN,
May 1974.
“Physical-Chemical and Biological Treatability Investigations and Process Design for a Tall Oil
Wastewater,” with F.G. Ziegler, Proc. of the 27th Annual Purdue Industrial Waste Conference,
Purdue University, West Lafayette, IN, May 1974.
“Monitoring for Variability Control,” Proc. of International Conference on Effluent Variability from
Wastewater Treatment Processes and Its Control, Sponsored by the International Association of
Water Pollution Research, Tulane and Vanderbilt Universities, New Orleans, December 1974.
“The Effects and Removal of Heavy Metals in Biological Treatment,” with W.W. Eckenfelder, Jr., and
B.L. Goodman, Proc. of Heavy Metals in the Aquatic Environment. Sponsored by Vanderbilt
University, IAWPR and Sport Fishing Institute, December 1973.
“Planning for Industrial Wastewater Reuse in the Cleveland-Akron Area,” with J.H. Koon and W.W.
Eckenfelder, Jr., Complete Water Reuse, 1973.
“Nitrification Design Approach for High Strength Ammonia Wastewaters,” with W.W. Eckenfelder, Jr.,
Proc. of 46th WPCF Conference, Cleveland, October 1973.
“Design Alternative for Nitrogen Removal,” Environmental Science and Technology, Vol 7, No.8,
August 1973.
“Ozonation Procedures for Industrial Wastewaters,” with W.W. Eckenfelder, Jr. and R.M. Stein, Proc.
of First International Symposium and Exposition on Ozone for Water and Wastewater,
Washington, D.C., December 1973.
Multi-Stage Aerated Lagoon Design for a High Temperature Wastestream, Water and Waste
Engineering, 1972.
“Rational Design Approach for Aerated Lagoon,” with W.W. Eckenfelder, Jr. and C.D. Magee, Proc.
of 6th International Conf. on Water Pollution Research, Jerusalem, Israel, June 1972.
“A Study of Aerobic Sludge Digestion Comparing Pure Oxygen and Air,” with R. M. Stein and W.W.
Eckenfelder, Jr., Proc. of 27th Ind. Waste Conf., Purdue University, Lafayette, IN, May 1972.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
5
“Physical, Chemical, and Biological Treatment of a Latex Emulsion Wastewater,: with Vladimir Novotny,
Frank Smith and W.W. Eckenfelder, Jr., Proc. of 27th Ind. Waste Conf., Purdue University,
Lafayette, IN, May 1972.
“Treatability and Toxicity of a Tetraethyl Lead Wastewater,” with R.M. Stein and W.W. Eckenfelder, Jr.,
Proc. of Second Environmental Engineering Science Conf., University of Louisville, Louisville, KY,
April 1972.
“Partial Volatile Solids Destruction: Aerobic Digestion,” Environmental Engineers Handbook, Vol I,
Section 1.5.14, Pergamon Press Ltd., 1971.
“The Impact of Water Pollution on Man’s Environment,” The Mallinckrodt Magazine. Spring 1971.
“The Design and Economics of Joint Wastewater Treatment Facilities,” with W.W. Eckenfelder, Jr., Proc.
of National Specialty Conf.: Clean Water for Our Future Environment, sponsored by ASCE, Los
Angeles, 1971.
“Investigations into the Reduction of High Nitrogen Concentrations,” with P. Krenkel and E. Bingham,
Proc. of the 5th International Association of Water Pollution Research Conference, San Francisco,
1970.
“Response of Activated Sludge to Organic Transient Loading,” with W.W. Eckenfelder, Jr., J. Sanitary
Engr. Div., ASCE, April 1970.
The Response of Activated Sludge Systems to Transient Loading Conditions, Ph.D. Dissertation, The
University of Texas, Austin, January 1969.
Bioassay Methods, Procedures and Interpretations, Masters Thesis, Vanderbilt University, Nashville,
August 1966.
PAPER PRESENTATIONS
Expectations of Today’s Activated Sludge Systems, AICHE Baton Rouge Section, Baton Rouge,
Louisiana, March 14, 2008.
Comparative Overview Of Commercially Competitive Activated Sludge Configurations
For Industrial Wastewaters, AICHE Baton Rouge Section, Baton Rouge, Louisiana, March 14,
2008.
EI AIS – Una exitosa innovación en los procesos de lodos activados para el tratamiento de agua
residual, Enviro-Pro XIV Congreso Internacional Ambiental, Mexico City, Mexico, September 27-
29, 2006.
Cost Effective Wastewater Management for Industrial Applications and Global Wastewater Solutions,
General Electric European and Middle Eastern Environmental Managers, Seville, Spain, June 14,
2006.
Compliance Demonstration Program for Socmi 40 CFR Part 60 Subpart YYY Proposed Regulation, WEF
9th Annual Industrial Wastes Technical and Regulatory Conference, San Antonio, TX, April 14,
2003.
Reducing The Cost And Area Footprint Of Activated Sludge Treatment Using Integral Secondary
Clarification, BAT Seminar, Vanderbilt University, Nashville, TN, February 26, 2003.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
6
Reducing the Cost and Area Footprint of Activated Sludge Treatment Using Integral Secondary
Clarification, Innovation 2000, Cambridge University, Churchill College UK, July 7-10, 1998.
Wastewater Operator Recertification Training Program, Instructor for Kentucky Division of Water
Certification, Olin Chemicals, Brandenburg, KY April 9-11, 1997.
Source Control WWTP Operational Impact, American Institute of Chemical Engineers, Spring National
Meeting, Houston TX, March, 1997.
Rapid Evaluation and Installation of a Low Cost Water Treatment Scheme at a Superfund Site, with Anu
Singh and Pat Campbell, Industrial Waste Technical Conference, Water Environment Federation.
New Orleans, LA March 1997.
Optimizing Design for Secondary Clarifiers, Water Environment Federation. Anaheim, CA, October
1993.
Methods for Upgrading and Retrofitting Industrial Activated Sludge Plants: An Overview, Industrial
Waste Conference, Purdue University, West Lafayette, IN, May 1990.
Technical Aspects of Combined Wastewater Treatment, Presented at the Treatment of Combined
(Urban and Industrial) Wastewater International Environmental Engineers meeting, Liege, Belgium,
May 1978.
What’s Ahead for Best Available Treatment EPA Requirements, Pulp Chemicals Association, Savannah,
April 1978.
Operational Optimization of a 36-mad Activated Sludge Facility at Winston-Salem, North Carolina to
Meet Water Quality Standards, with C.D. Malign, R.M. Stein, P. Swann, T. Cornett, and Dan
Foster. 50
th
Water Pollution Control Federation Annual Conference, Philadelphia, October 1977.
New Developments in Industrial Wastewater Treatment in the United States, with W.W. Eckenfelder, Jr.
Presented at the Annual Conference of the Israel Ecological Society, Haifa, Israel, May 1977.
Cost-effective Operations, Logistics and Optimization of a Multi-Industrial Regional Activated Sludge
Treatment Facility, WWEMA Industrial Pollution Conference, Atlanta, April 1977.
Overview of Wastewater Management in the Pulp and Paper Industry in the United States, Design of
Wastewater Treatment Plants, Economic Reuse in Biological and Physical Chemical Processes,
International Symposium on Industrial Waste and Environment, Caracas, Venezuela, November
1976.
Design and Process Concepts Utilizing Flotation, Aeration, and Clarification, Infilco Degremont Field
Sales Meeting, Buford, GA, July 1976.
Permit Amending for Best Practical Treatment for 1977 and What’s Ahead for Best Available Treatment
in 1983, Pulp Chemicals Association Joint Committee Meetings: Technical, Environmental, and
Chemicals, Charleston, SC, March 1975.
Permit Amending for Best Practical Treatment, Pulp Chemicals Association Joint Meeting of Technical,
Environmental, and Chemical Recovery Committee, Charleston, SC, October 1975.
Biological Treatment, IAWPR Workshop on Design and Operation Interactions at Large Treatment
Plants, Vienna, Austria, September 1975.
Methodology for Evaluating Toxicity or Inhibition to Biological Systems, International Association for
Water Pollution Research, Birmingham, England, UK, April 1974.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
7
Ion Exchange and Air Flotation, IAWPR Continuing Education Meeting, sponsored by the International
Association for Water Pollution Research, Birmingham, England, UK, September 1974.
Physical-Chemical and Biological Treatment Alternatives for a Tall Oil Plant Effluent,” Annual ACS
Meeting, New Orleans, 1973.
In-Plant Modifications for Reduction of Nitrogenous Pollutional Input to Fertilizer Plant Effluent, with E.
Bingham and P. Krenkel, presented at the 63rd Annual Meeting of the AICHE, Chicago,
November-December 1970.
Literature and Laboratory Investigations into the Removal and Recovery of High Concentrations of
Nitrogen, with P. Krenkel and W.W. Eckenfelder Jr., International Congress on Industrial
Wastewater, Stockholm, Sweden, November 1970.
BOOKS
Nitrification/Denitrification Handbook, for the Chemical Industry Environmental Technology Projects,
LLC, September, 1999.
Development of Design and Operational Criteria for Wastewater Treatment, C.E. Adams, Jr., Davis L.
Ford and W.W. Eckenfelder, Jr., Enviro Press, Nashville TN, 1981..
Process Design Techniques for Industrial Waste Treatment, edited by C.E. Adams, Jr. and W.W.
Eckenfelder, Jr., Enviro Press, Nashville, 1974.
Handbook for Monitoring Industrial Wastewater, prepared by AWARE, Inc. for US EPA Technology
Transfer Div., August 1973.
SEMINARS & LECTURES (WITHIN THE UNITED STATES)
The ADVENT Integral System, Pfizer Environmental Engineering Seminar, Boston, MA, October 26,
2000.
Environmental and Energy Infrastructure Opportunities Seminar: A Case Study, East Tennessee
Environmental Business Association, Oak Ridge, TN May 1999.
Environmental and Energy Infrastructure Opportunities Seminar: A Case Study, American-Israel
Chamber of Commerce, Atlanta, GA February 1999.
Planning for Industrial Wastewater Management – Source Control, Water Quality Management for
Industrial Facilities in the Great Lakes Region, with Sonnenschein Nath & Rosenthal, Chicago, IL June
1998.
Wastewater Operator Recertification Training Program, Instructor, Kentucky Division of Water Operator
Certification, Olin Chemicals, Brandenburg, KY April 1998.
A Cost Effective, Innovative Approach to the Activated Sludge Process, National Meeting of the
American Institute of Chemical Engineers, New Orleans, LA, March 1998.
API Separator Maintenance and Operational Considerations, Petroleum Environmental Research Forum,
Houston, TX, October 1997.
Wastewater Operator Recertification Training Program, Instructor, Kentucky Division of Water Operator
Certification, Olin Chemicals, Brandenburg, KY, April 1997.
Source Control WWTP Operational Impact, American Institute of Chemical Engineers, 1997 Spring
National Meeting, Houston TX, March 1997.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
8
Wastewater Operator Recertification Training Program, Instructor, Kentucky Division of Water Operator
Certification, Olin Chemicals, Brandenburg, KY April 1996.
Master Planning for Industrial Wastewater Management, Water Quality Management for Industrial
Facilities, Charleston, WV, March 1995.
Wastewater Operator Recertification Training Program, Olin Chemicals. Instructor, Kentucky Division of
Water Operator Certification, Brandenburg, KY April 1995.
New Innovation for Biological Treatment of Industrial Wastewater and Groundwaters, EnviroExpo 94,
Charlotte, NC, October 1994.
Environmental Wastewater/Groundwater Master Planning for Industry, EnviroExpo 94, Charlotte, NC,
October 1994.
Wastewater Operator Recertification Training Program, Olin Chemicals. Instructor, Kentucky Division of
Water Operator Certification, Brandenburg, KY, April 1994.
Wastewater Operator Recertification Training Program, Olin Chemicals. Instructor, Kentucky Division of
Water Operator Certification, Brandenburg, KY, March 1993.
The Clean Water Act, Environmental Laws for Industries, Lake Area Industries/McNeese Engineering
Partnership, McNeese State University Campus, Lake Charles, LA, September 1992.
Biological Wastewater Treatment, Seminar sponsored by Auburn University, Birmingham, August 1981.
Wastewater Engineering, Seminar presented by Vanderbilt University to Union Carbide, Charleston, WV,
August 1981.
Operation, Control and Management of Activated Sludge Plants Treating Industrial Wastewaters,
Seminar sponsored by Vanderbilt University, Tampa, July 1981.
Wastewater Engineering, Seminar sponsored by Vanderbilt University, May 1981.
Development of Design Criteria for Wastewater Treatment Process, Seminar sponsored by Vanderbilt
University, April - May 1981.
Control, Operation and Management of Biological Wastewater Treatment Plants, Seminar sponsored
by Vanderbilt University, Nashville, October 1980.
Operation and Management of Activated Sludge Plants, Seminar sponsored by The AWARE
Corporation in conjunction with Sage Murphy and Associates, Inc., Denver, September 1980.
Process Design in Water Quality Engineering, Seminar sponsored by Vanderbilt University, Boston,
August 1980.
Operation, Control and Management of Activated Sludge Plants Treating Industrial Wastewaters
Seminar sponsored by Vanderbilt University, Boston, August 1980.
Operation and Maintenance, Seminar sponsored by AAWPC, Montgomery, July 1980.
Operation, Control, and Management of Activated Sludge Plants, Seminar sponsored by Vanderbilt
University, Nashville, June-July 1980.
Development of Design Criteria for Wastewater Treatment Processes, Seminar sponsored by Vanderbilt
University, Nashville, April 1980.
Pretreatment of Industrial Wastewaters, Seminar sponsored by Vanderbilt University, Chicago, March
1980.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
9
Operation, Control, and Management of Activated Sludge Plants, Seminar sponsored by Vanderbilt
University, Tampa, January 1980.
Principles of Biological Wastewater Treatment for Industrial and Municipal Applications, with W.W.
Eckenfelder, Jr. Seminar sponsored by Auburn Engineering Extension Service, Auburn University,
Birmingham, January 1980.
Industrial Wastewater Pretreatment for Discharge to Municipal Systems, Seminar sponsored by
Vanderbilt University, Nashville, December 1979.
Analytical Considerations, Technical Preparation for Negotiating and Amending NPDES Permits, Case
Histories: Legal and Regulatory Implications of Compliance and Non-compliance with NPDES Permits.
Seminar sponsored by Auburn University Engineering Extension Service, and Construction Advancement
Program of Alabama, Birmingham, November 1979.
Biological Treatment Process: Aerated Lagoons Advanced Waste Treatment: Biological Removal of
Nitrogen; Ammonia Stripping, Membrane Processes, Process Design in Water Quality Engineering:
New Concepts and Developments. Seminar sponsored by Vanderbilt University School of Engineering
Continuing Education, Environmental and Water Resources Engineering Program, Nashville, October
1979.
Performance Monitoring, Nitrification and Denitrification, Biological Sludge Handling: Operation,
Control and Management of Activated Sludge Plants Treating Industrial Wastewaters, Seminar
sponsored by Vanderbilt School of Engineering, Continuing Education, Environmental and Water
Resources Engineering Program, Philadelphia, October 1979.
Performance Monitoring, Nitrification and Denitrification, Operating Conditions for Nitrification and
Denitrification, Variables Affecting Nitrification Performance, Operating Mode to Enhance Nitrification:
Control, Operation and Management of Biological Wastewater Treatment Plants. Seminar sponsored
by Vanderbilt University School of Engineering Continuing Education, Environmental and Water
Resources Engineering Program, Nashville, September 1979.
Operation and Management of Biological Wastewater Treatment Plants, with W.W. Eckenfelder, Jr.
Short course sponsored by Auburn University Engineering Extension Service and Construction
Advancement Program of Alabama, Birmingham, August 1979.
“Operation and Management of Biological Wastewater Treatment Plants,” with W.W. Eckenfelder, Jr.
Short course sponsored by Auburn University Engineering Extension, Birmingham, June 1979.
Biological Treatment: Biological Removal of Nitrogen and Phosphorus, and Sludge Handling
Conditioning, Gravity Thickening, Centrifugation, Vacuum Filtration, Pressure Filtration, and Aerobic
Digestion, Management of Refining and Petrochemical Wastewaters, Seminar sponsored by the
University of Tulsa Continuing Education Division, College of Engineering and Physical Sciences, Tulsa,
OK June 1979.
Performance Monitoring and Nitrification and Denitrification: Operation, Control and Management of
Activated Sludge Plants Treating Industrial Wastewaters. Seminar sponsored by Vanderbilt University
School of Engineering, Dept of EWRE, New York, May 1979.
“Upgrading of Activated Sludge Systems,” with W.W. Eckenfelder, Jr. Presented for MIXCO, Rochester,
NY, May 1979.
Performance Monitoring and Nitrification: Operation, Control and Management of Activated Sludge
Plants Treating Industrial Wastewaters, Seminar sponsored by Vanderbilt University School of
Engineering, Dept. of EWRE, San Francisco, April 1979.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
10
Methodology for the Determination of Toxic or Inhibitory Effects, Pretreatment Procedures, Continuous
Treatment Studies: Aerated Lagoons, and Biological Sludge Handling Procedures: Aerobic Digestion,
Dissolved Air Flotation, Gravity Thickening, Thermal Content. Development of Design Criteria for
Wastewater Treatment Processes, Seminar sponsored by Vanderbilt University School of Engineering,
Dept. of EWRE, Nashville, April 1979.
Upgrading of Activated Sludge Systems, with W.W. Eckenfelder, Jr. Presented for MIXCO, Denver,
April 1979.
Performance Monitoring and Nitrification: Operation, Control and Management of Activated Sludge
Plants Treating Industrial Wastewaters, Seminar sponsored by Vanderbilt University School of
Engineering, Dept. of EWRE, Chicago, March 1979.
Operation of Activated Sludge System, with W.W. Eckenfelder, Jr. Presented for MIXCO, Boston,
March 1979.
Performance Monitoring and Nitrification-Denitrification: Operation, Control and Management of
Activated Sludge Plants Treating Industrial Wastewaters. Seminar sponsored by Vanderbilt University
School of Engineering, Dept EWRE, Houston, February 1979.
Aerated Lagoon Modifications: Upgrading of Wastewater Treatment Plants, Seminar sponsored by
Vanderbilt University School of Engineering, Dept EWRE, Nashville, February 1979.
Principles of Biological Wastewater Treatment for Industrial and Municipal Applications, with W.W.
Eckenfelder, Jr. Seminar sponsored by Auburn University Engineering Extension Service and Construction
Advancement Program of Alabama, Birmingham, January - February 1979.
Technical Preparation for Negotiating and Amending NPDES Permits: Legal and Regulatory Implications
of Compliance and Non-Compliance with NPDES Permits. Short course sponsored by Auburn
University, Birmingham, November 1978.
Biological Removal of Nitrogen: Processes for Wastewater Reclamation and Reuse, Short Course,
sponsored by University of California, Berkeley, October 1978.
Advanced Wastewater Treatment. Short course with W.W. Eckenfelder, Jr. Sponsored by Auburn
University, Birmingham, August 1978.
Aerated Lagoon Modifications: Redesign for Nitrification/Denitrification and Upgrading of Wastewater
Treatment Plants, Seminar sponsored by Vanderbilt University, Center for Environmental Quality
Management, Vanderbilt University, Nashville, August 1978.
Control, Operation and Management of Biological Wastewater Treatment Plants Seminar, with W.W.
Eckenfelder, Jr., A.W. Edwards, C.D. Malone, and K.C. Mills. Sponsored by
Vanderbilt University and AWARE, Inc. for the Commonwealth of Kentucky, Frankfort, KY, May 1978.
Technical Preparation for Negotiating and Amending NPDES Permits: Legal and Regulatory Implications
of Compliance and Non-Compliance with NPDES Permits. Short course sponsored by Auburn
University, Birmingham, March 1978.
Principles of Biological Wastewater Treatment for Industrial and Municipal Applications, with W.W.
Eckenfelder, Jr. Seminar sponsored by Auburn Engineering Extension Service, Auburn University,
Birmingham, January - February 1978.
Practical Aspects of Wastewater Management, with W.W. Eckenfelder, Jr., J.H. Koon, and R.M. Stein.
Seminary presented by AWARE, Inc. for Virginia Chemicals, Inc., Portsmouth, VA, January 1978.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
11
Technical Preparation for Negotiating and Amending NPDES Permits, Legal and Regulatory Implications
of Compliance and Non-compliance with NPDES Permits. Short Course sponsored by Auburn
University, Birmingham, November 1977.
Biological Treatment Processes, Advanced Waste Treatment: Nitrogen Removal, Ammonia Stripping,
Membrane Process, Process Design Considerations for Treatment of Industrial Wastewater. Sponsored
by Vanderbilt University, Dept of EWRE, Continuing Education Division, Nashville, November 1977.
Wastewater Treatment Plant Operations Training Program. Seminar presented by AWARE, Inc. for US
Navy, Washington, D.C., November 1977.
Coal Waste Technology Seminar, with W.W. Eckenfelder, Jr., J.H. Koon, F.G., Ziegler, G.M. David,
N.E. Olaya and A. Ramirez. Presented by AWARE, Inc. Nashville, TN for Gulf Coast Waste Disposal
Authority, Houston, November 1977.
Pretreatment of Industrial Wastewaters for Discharge into Municipal Systems, with W.W. Eckenfelder,
Jr., J.H. Koon, and R.M. Stein. Seminar sponsored by AWARE, Inc., Philadelphia, October 1977.
Sludge Handling Facilities, Performance Monitoring, Nitrification-Denitrification Process, Control,
Operation and Management of Biological Wastewater Treatment Plants. Seminar sponsored by
Vanderbilt University, Nashville, September 1977.
Advanced Wastewater Treatment, with W.W. Eckenfelder, Jr. Short Course sponsored by Auburn
University, Engineering Extension Division, Birmingham, August-September 1977.
Technical Preparation for Negotiating and Amending NPDES Permits, Legal and Regulatory Implications
of Compliance and Non-Compliance with NPDES Permits, Short Course sponsored by Auburn
University, Birmingham, June 1977.
Environmental Management Seminar, with W.W. Eckenfelder, Jr., J.H. Koon, R.M. Stein, and F.G.
Ziegler. Presented by AWARE, Inc., Nashville, TN for FMC Corporation, Fredericksburg, VA March
1977.
New Technology and Trends in Wastewater Treatment, with W.W. Eckenfelder, Jr. Seminar presented
for Proctor and Gamble Company by AWARE, Inc., Cincinnati, March 1977.
Methodology for the Determination of Toxic or Inhibitory Effects, Pretreatment Procedures, Continuous
Treatment Studies: Aerated Lagoons,” and “Biological Sludge Handling Procedures: Aerobic
Digestion, Dissolved Air Flotation, Gravity Thickening, Thermal Content. Development of Design Criteria
for Wastewater Treatment Processes. Seminar sponsored by Vanderbilt University School of
Engineering, Department of EWRE, Nashville, March 1977.
Principles of Biological Wastewater Treatment for Industrial Municipal Applications, with W.W.
Eckenfelder, Jr. Seminar sponsored by Auburn Engineering Extension Service, Auburn University,
Birmingham, February 1977.
Biological Treatment Processes: Aerated Lagoons, Advanced Waste Treatment: Biological Removal of
Nitrogen; Ammonia Stripping, Membrane Processes, Process Design in Water Quality Engineering:
New Concepts and Developments. Seminar sponsored by Vanderbilt University School of Engineering
Continuing Education, Environmental and Water Resources Engineering Program, Nashville, November
1976.
Pretreatment of Industrial Wastewaters for Discharge into Municipal Systems, with W.W. Eckenfelder,
Jr., J.H. Koon, and R.M. Stein. Seminar presented by AWARE, Inc., Minneapolis, October 1976.
Water Quality Engineering, with W.W. Eckenfelder, Jr. Short course sponsored by Auburn University
Engineering Extension Division, Birmingham, August 1976.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
12
Methodology for Determination of Toxic or Inhibitory Effects, Pretreatment Procedures, Computer Design
in Activated Sludge, Continuous Treatment Studies: Aerated Lagoons, Biological Sludge Handling
Procedures, Coagulation, Ozonation, The Development of Design Criteria for Wastewater Treatment
Processes. Seminar sponsored by Vanderbilt University, School of Engineering, Department of
Engineering, Department of EWRE, Continuing Education, Nashville, March-April 1976.
Design and Operation of Wastewater Treatment Processes-Pulp and Paper Industry, with W.W.
Eckenfelder, R.M. Stein, and J.H. Koon. Seminary presented by AWARE, Inc., Atlanta, April 1976.
Process Design of Industrial Wastewater Treatment, with J.H. Koon, W.W. Eckenfelder, Jr., and R.M.
Stein. Seminar presented by AWARE, Inc., Miami, October 1975.
Optimization of Activated Sludge Plant Operation for Industrial Wastewater, with J.H. Koon, W.W.
Eckenfelder, Jr., and R.M. Stein. Seminar presented by AWARE, Inc., Miami, October 1975.
Wastewater Treatment Technology Seminar, with W.W. Eckenfelder, Jr. and J.H. Koon. Presented by
AWARE, Inc. for Economic Analysis Div., Office of Planning and Evaluation, EPA, Washington, D.C. July
1975.
Pretreatment of Industrial Wastewaters for Discharge into Municipal Sewers, with W.W. Eckenfelder, Jr.,
J.H. Koon, and R.M. Stein. Seminary presented by AWARE, Inc., Chattanooga, June 1975.
Pretreatment of Industrial Wastewaters for Discharge into Municipal Sewers, with W.W. Eckenfelder, Jr.,
J.H. Koon, and R.M. Stein. Seminary presented by AWARE, Inc., Saddlebrook, NJ, June 1975.
Biological Treatment Processes: Aerated Lagoons, Advanced Waste Treatment: Biological Removal of
Nitrogen; Ammonia Stripping, Membrane Processes, Process Design in Water Quality Engineering:
New Concepts and Developments. Seminar sponsored by Environmental and Water Resources
Engineering and the Environmental Associates Program, Vanderbilt University School of Engineering,
Nashville, April 1975.
Pretreatment of Industrial Wastewaters for Discharge into Municipal Sewers, with W.W. Eckenfelder,
Jr., J.H. Koon, and R.M. Stein. Seminary presented by AWARE, Inc., Houston, November 1974
Wastewater Treatment Technology Seminar, with W.W. Eckenfelder, Jr. Seminar presented to
Environmental Protection Agency, Washington, D.C., October-November 1974.
Pretreatment of Industrial Wastewaters for Discharge into Municipal Sewers, with W.W. Eckenfelder,
Jr., J.H. Koon, and R.M. Stein. Seminary presented by AWARE, Inc., Denver, October 1974.
Biological Wastewater Treatment, with W.W. Eckenfelder, Jr. and G.L. Shell. Seminar presented by
AWARE, Inc. for The Proctor and Gamble Company, Cincinnati, September 1974.
Process Design Techniques for Industrial Wastewater Treatment, with W.W. Eckenfelder, Jr., J.H. Koon,
and R.M. Stein. Seminar Presented by AWARE, Inc., Chicago, June 1974.
Pretreatment of Industrial Wastewaters for Discharge into Municipal Sewers, with W.W. Eckenfelder,
Jr., J.H. Koon, and R.M. Stein. Seminary presented by AWARE, Inc., Chicago, June 1974.
Process Design Techniques for Industrial Wastewater Treatment, with W.W. Eckenfelder, Jr., J.H. Koon,
and R.M. Stein. Seminar Presented by AWARE, Inc., San Francisco, April 1974.
Process Design Techniques for Industrial Wastewater Treatment, with W.W. Eckenfelder, Jr., J.H. Koon,
and R.M. Stein. Seminar Presented by AWARE, Inc., New York, March 1974.
Pretreatment of Industrial Wastewaters for Discharge into Municipal Sewers, with W.W. Eckenfelder,
Jr., J.H. Koon, and R.M. Stein. Seminary presented by AWARE, Inc., Atlanta, January 1974.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
13
Pretreatment of Industrial Wastewaters for Discharge into Municipal Sewers, with W.W. Eckenfelder,
Jr., J.H. Koon, and R.M. Stein. Seminary presented by AWARE, Inc., New York, March 1974.
Pretreatment of Industrial Wastewaters for Discharge into Municipal Sewers, with W.W. Eckenfelder,
Jr., J.H. Koon, and R.M. Stein. Seminary presented by AWARE, Inc., San Francisco, April 1974.
Process Design Techniques for Industrial Wastewater Treatment, with W.W. Eckenfelder, Jr., J.H. Koon,
and R.M. Stein. Seminar Presented by AWARE, Inc., Atlanta, January 1974.
Multi-Stage Aerated Lagoon Design for a High Temperature Wastestream, Proc. of 19th Environmental
and Water Resources Engineering Conf., Vanderbilt University, Nashville, June 1971.
SEMINARS/LECTURES (INTERNATIONAL)
Innovative Environmental Solutions, Environmental Solutions In Various Industries Seminar, sponsored by
Ludan Engineering Group, Bucharest, Romania, 7-8 Oct 2004.
Development of Advanced Biological Treatment Reactor, Environmental Solutions In Various Industries
Seminar, sponsored by Ludan Engineering Group, Bucharest, Romania, 7-8 Oct 2004.
Implementations of Wastewater Treatment Technologies in Various Industries- Case Studies,
Environmental Solutions In Various Industries Seminar, sponsored by Ludan Engineering Group,
Bucharest, Romania, 7-8 Oct 2004.
Reducing the Cost and Area Footprint of Activated Sludge Treatment Using Integral Secondary
Clarification, 7
th
International Conference of the Israel Society for Ecology and Environmental Quality
Sciences, Tel Aviv, Israel, June 1999.
The ADVENT Integral Clarifier in conjunction with Baker Process, IFAT Conference. Munich, Germany,
May 1999.
The ADVENT Integral System: Innovative Technology for Industrial Wastewater, presented to various
Indian industries, Mumbai, India, March 1999.
The ADVENT Integral System: Innovative Technology for Industrial Wastewater, presented to various
European Industries, Milan, Italy, December 1998.
Innovative Technology for Pulp and Paper Wastewater Treatment: The Integral Activated Sludge
System, São Paulo, Brazil, October 1996.
Biological Methodology and Option Evaluations: Integral Activated Sludge System, Ahmedabad
University, Ahmedabad, India, October 1996.
Source Control and Wastewater Treatment, Envirotech 1996, Ahmedabad, India, October 1996.
State-of-the-Art Wastewater Technologies as Applied to India, Ahmedabad University, Ahmedabad,
India, September 1995.
Design for the Eighties, Seminar sponsored by The AWARE Corporation, Milan, Italy, May 1981.
Operation Control and Management of Activated Sludge Plants, Seminar sponsored by Vanderbilt
University, San Juan, Puerto Rico, March 1980.
Performance Monitoring, Nitrification and Denitrification, Biological Sludge Handling, Operation,
Control, and Management of Activated Sludge Plants Treating Industrial Wastewaters. Seminar
sponsored by Vanderbilt University, School of Engineering Continuing Education, Environmental and
Water Resources and Engineering Program, Toronto, Canada, September 1979.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Carl E. Adams, Jr., PE, PhD
14
Pulp and Paper Mill Wastewater Treatment Seminar, with W.W. Eckenfelder, Jr. and Y. Argaman.
Seminar sponsored by AWARE, Inc., Milan, Italy, May 1979.
Physical-Chemical Treatment of Industrial Wastewater, with W.W. Eckenfelder, Jr. and Y. Argaman.
Seminar sponsored by Aware, Inc., Milan, Italy, June 1979.
Principles and Practice of Biological Wastewater Treatment, with W.W. Eckenfelder, Jr. Seminar
sponsored by AWARE, Inc., Milan, Italy, January 1978.
Physical-Chemical Treatment of Industrial Wastewater, with W.W. Eckenfelder, Jr. and Y. Argaman.
Seminar sponsored by Aware, Inc., Milan, Italy, January 1978.
Dissolved Air Flotation, Breakpoint Chlorination, Ion Exchange for Nitrogen Removal, IRCHA, Paris,
France, May 1977.
Aerobic Biological Treatment, Physical-Chemical Treatment: Present Trends, Physical-Chemical
Treatment: Aerated Lagoons: Nitrification-Denitrification-Nitrogen Removal, Design of Wastewater
Treatment Plants: Economy and Reuse in Biological and Physio-Chemical Treatment Processes.
International Course in France for Engineers, sponsored by IRCHA, Paris, France, November-December
1976.
Process Design for Industrial Waste Treatment, with W.W. Eckenfelder, Jr. and Y. Argaman. Seminar
sponsored by AWARE, Inc., Tehran, Iran, October 1976.
Pretreatment Considerations: Sedimentation, Coagulation, Flotation, IAWPR Continuing Education
Courses, Melbourne, Australia, October 1976.
Theory and Practice of Biological Wastewater Treatment, with W.W. Eckenfelder, Jr., Advanced Study
Institute, Bogazici University, Istanbul, Turkey, July 1976.
Theory and Practice of Biological Wastewater Treatment, with W.W. Eckenfelder, Jr., NATO Advanced
Study Institute, Milan, Italy, June 1976.
Industrial Waste Treatment, Process Design, with W.W. Eckenfelder, Jr., and Y. Argaman. Short course
presented to Italconsult, Rome, Italy, February 1976.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Robin L. Garibay, REM
1
EDUCATION
1980 B.A., Biochemistry, Rice University
1983 Graduate Studies, Plant Physiology, Texas A & M University
REGISTRATIONS AND CERTIFICATIONS
Registered Environmental Manager No. 7599
EXPERIENCE
A Principal in ADVENT-ENVIRON’s (ENVIRON’s Integrated Industrial Wastewater Management Practice
Area) Herndon, Virginia, location, Ms. Garibay has over 25 years of experience in wastewater and
water quality management issues, particularly activities in support strategic planning for facility changes
and permitting, compliance planning for discharges, and providing technical advocacy in wastewater
and water quality rulemaking.
Ms. Garibay’s specific expertise includes source surveys, toxicity reduction evaluations, fate and effects
studies, bioavailability assessments, water quality criteria development, variance requests, removal credit
applications, antidegradation demonstrations, generating assessments of multi-media impacts, costs, and
benefits of wastewater control options, and regulatory agency negotiations.
Her project experience includes the following:
Reviews implementation of regulations by participating in work groups, and commenting on
guidance documents and methods, policy directives, compliance costs, and technical
databases.
Participated in stakeholder work groups in Illinois, Indiana, West Virginia, and Wisconsin on
various regulatory issues including adoption of GLI rules, establishment of anti-degradation rules
and procedures, development of TMDLs, creation of statewide mercury variance rules, and
derivation of state-specific water quality criteria.
Directed sampling and analytical tasks for the chemical identification, mixing zone delineation
studies, assimilative capacity studies, reviews of toxicology and fate information to determine
environmental risks, preparation of sampling and analysis plans for CWA and RCRA activities.
Preparation of 404 Applications, 401 Certifications, CZM Applications, NPDES Permit
Applications, IU Permit Applications, Land Application Permit Applications, and Plans in support
of BMP, SWP3, SPCC and/or FRP.
Directing and conducting in-plant sewer source surveys and development of water and mass
balances.
Assistance in wastewater management audits and wastewater management training.
Significant experience consulting with iron and steel mills, primary metals manufacturing, petroleum
refineries, organic chemical manufacturers, power generation stations, food manufacturing, and industrial
trade associations.
Electronic Filing - Received, Clerk's Office, August 4, 2008
Robin L. Garibay, REM
2
Previous experience includes the analysis of formulations and ground-water samples for
pesticide identity.
Served on an agricultural chemicals and ground-water task force for the development of a
ground-water protection act and chemigation rule.
Electronic Filing - Received, Clerk's Office, August 4, 2008
