TIDE
    F:
    PROPOSED
    SI
    S POLLUTION
    CON"
    RULE FOR
    CITY O
    ILL
    R09-8
    (Si
    Office of Public
    Utilities,
    ?)
    nd Power
    collectively "Petitioners"),
    by and throe
    nee
    as a consultant in the powe
    Hearing
    Officer Order,
    e-Filed Testimony
    of Don Schilling
    the above-refs i
    rnatter.
    K ansas City,
    Science
    de
    chilling. I am employed
    at Burns
    ri, as a
    Senior Associate Chemical Engineer.
    I hold a Bachelor of
    -five years e
    itary District
    CAE
    DWY
    sas City.
    t imony t
    t reatment techno
    i
    Iic;i uncut, My
    current resume is attached.
    ncerns Burns`
    study that included the review
    of boron
    considered, their relative
    effectiveness, and their
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    costs,
    as well as Burns
    significant, either requiring
    greater than 95 percent
    removal or
    In
    March 2004, Burns was contracted
    to investigate
    options available to treat
    FGDS wastewater for the removal
    of boron from
    the FGDS purge stream. The level
    of
    boron redu
    requiring zero
    ") for
    CWLP's Dallman units.
    capital and operating
    cost
    study was a
    uat
    p ond system
    that was
    provided pot -ru al me
    rage from the FGDS. The purpose
    of this study was to identi
    igation
    of the sources of boron
    in the Dallman/La
    erformed by Hanson
    of the impact on the
    flue gas desulfurization
    system
    mart' source as the FG
    of
    in ýýii,
    ýý-art for consi&Lat.icn,
    but did not compare
    costs for
    the cost comparison, Burns did
    provide capital and annual operating
    cost
    A table summarizing these compa
    rovided
    by equipment su
    1's
    it 1 in this
    offered the lowest comparati
    cost.
    `.or ("B("')/spray dryer system
    removal processes that were evaluated included
    selective boron ion
    ange resin,
    2
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    /coagulation,
    reverse osmosis
    ("RO"), and mechanical
    evaporation. In
    addition
    to the above treatment processes,
    Burns investigated
    options available
    to dispose
    concentrated waste brine
    th at resulted from the
    atment
    Each of the
    uld produce a waste
    brine, which consisted of e
    neratron waste
    trom the ion exchange
    process, concentrated
    RO reject,
    from
    the BC evaporation process.
    Options that were considered
    included
    conditioning waste fly ash and
    disposal using an evaporation
    pond. At th
    study, there
    was very little literature or experience
    available regarding
    treatment
    or boron remova
    reduction and clarification.
    . Most
    of the FGDS treatment processes
    targeted metals
    h a review of availab
    Ie
    that b!
    _
    the
    removed
    using a weak base
    for the remova
    ron-selective resins
    are typically used
    1_
    r_
    Ily a few parts per million
    There was no literature that discussed
    treatment of waste streams
    containing several
    boron level seen it
    resin suppliers, high chlorides
    concentration and low
    ron from
    drinking water su
    val of'boron. The FGD wastewater
    shows both character];
    (high
    chlorides and low pH), thus boron
    ficiency was not expected
    to be high.
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    lutions of acid
    and caustic are used for
    the
    regeneration
    of the resin, produc
    waste stream
    containing a higher
    concentrat
    boron and neutralized
    salts from the regenerant
    chemicals. The
    amount of wastewater
    boron level of 400
    ppin in 175 gallons per
    m
    oron i
    owdown. Based
    on a
    gallons per minute
    ("gpzn") of FCDS
    blowdown, the volume of wastewater generated
    was
    ated to be about 80 gpm.
    This
    wastewater stream would then
    be treated using a BC
    and cry
    waste product. This
    treatment option was not
    recommended because
    of the lack of
    operating experience tre
    I
    the large
    amount of demine
    1' r
    a erated.
    Comparative
    tionable and would reel
    M :
    o f boron is un
    company that produced this mate
    recipitation, but indicated that it
    is more applicable at
    also unlikely. Hanson reported a commercial
    ial
    is no longer ma
    perform. Thus,
    this option was not recommended for
    further inves
    of boron (2.7 percent
    at 32 T, and 40 percent
    at 212
    ur at the concentration
    igh levels
    roduct failed to
    aluation, a program was
    initiated in the summer of 2007 to
    sample the
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    t
    plant at the Homer City Power
    nt. The treatment process consisted of a two-stage lime
    softening/coagulation process. The inlet boron concentration was reported
    to
    be 224 ppm
    with a treated effluent boron concentration being reduced
    to 191 ppm. This removal rate
    of about 15 percent does not provide the boron removal needed to achieve the boron level
    to discharge the wastewater from CWLP's Dallman units. This removal
    also consistent with the boron removal achieved using the Dallman FGDS blo
    clarifier.
    atment
    evaluated. Because the FGDS blowdown is saturated with calcium sulfate as well as
    ntial foulants, the convention
    the study
    1
    0
    treatment with the RO. Beg
    the waste stream from the HERO process contains
    sodium salts
    and not
    calcium
    and magnesium chloride, the waste steam could be treated
    tallizer in
    lieu
    of the spray dryer. Because the HERO process does not
    produce as concentrated of a brine as would be produced losing the BC, the brine flow
    rate would be considerably higher. Like the other treatment
    options, there
    was
    no
    not
    ended due to
    higher
    evaluated cost.
    declined to offer this treatment process for this ap
    for the HERO
    t fouling of the
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    wastewater, and the
    supplier has decided not to offer this
    process for FGDS treatment
    ations.
    n
    50 percent BCs
    followed
    by two 50 percent spray dryers, BCs use
    an evaporation process to
    separate and recover
    clean water (condensate)
    froze the wastewater brine solution.
    The recovered water is
    high-quality, and may be reused in many power
    Ii
    aporated in
    a spray dryer. The most
    mechanical vapor compression ("MVC")
    cycle to pr
    be bundle
    ,!."Js ("TDS")
    and total suspon.!,.:! lids
    . A strean'i
    of the concentrated brine is continuously bled from the
    system in order to
    content so that tllý . ,tcrn
    scaling is minimized and the uni
    ation approach
    wh
    ors are available.
    One uses a lime/soda
    ash softener to pretreat the evaporator feedwater.
    exchanges the hardne
    ions. The concentrated
    of these
    use a
    The brine is recirculate
    ost of t
    for sodium. The advantage
    of softeni
    ing
    ed from the crystallizer recirculati
    if the feedwater
    were
    a
    6
    onal capital cost, of the lime
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    oda ash feed equipment,
    softener, and softener
    sludge dewatering
    equipment. This
    process also requires
    more space, which was
    not available and
    produces an additional
    solids
    waste product from the so
    uses
    con
    . The second
    aporation
    method
    feedwater
    to the BC without soften
    of calcium and magne
    eadily form
    crystals. A crystallizer can be used
    to further concentrate
    the brine
    but the final
    bri disposal would require the
    use of a spray dryer.
    Some previous experience
    using
    w it
    f'.
    The
    goals
    of the FGDS treatmen
    brine.
    re
    r.
    c d
    fro
    chloride. These
    salts are very soluble
    and
    owdown was
    ne of the
    at was used in the design
    of
    oblems,
    the conclusion
    "[t]he unit ra
    such
    as boron, in t
    tier
    than allowed by product specifications.
    )ject. However, if the
    impurities levels can be reduced,
    trld be achieved." The failure
    of this
    demonstration was
    that a commercial
    rrr
    chloride brine) was not
    achieved.
    vended
    by Burns and purchased
    by CWLT' frorn
    Demonstration
    Proje
    aced modifications designed
    to overcome problems
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    encountered
    during the Milliken
    uded:
    roject.
    of
    " Low speed vapor compressors
    that operate
    at 4,000 rpm in
    wo-stage mi
    inators
    to eliminate brine droplets from
    becoming
    r.
    " Improved solids removal
    scheme to allow the
    operator to easily
    olved ar
    Upgraded materials of constru
    n
    -.;
    a 1 pirient
    suppl
    D ual perforated plate distribution
    system for improved flow
    distribution o
    ater ti catment options
    ) ltiI
    ,;s
    e,ý'4_
    )
    I [ý:d
    to have the most
    poten
    s tream with
    the
    fewest
    problem
    eatment process and
    the desi
    of the
    I 11
    tat
    n ot to generate the addition
    solids from
    y dryer in lieu
    of
    r. During the detailed design,
    -ay dryer.
    onside
    ned major modifications
    the
    higher grade
    chloride resistant
    s determined that the sol
    generated would have
    a relatively low density and the r
    ificantly larger than first anticipated.
    'The difficulty of handling and
    disposal of
    duct resulted
    in the abandonment of this treatment
    option. Thi
    8
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    osal issue
    would be applicable to all
    treatment options considered.
    Althouh
    ri the
    solid waste from the l3C/crystallizer
    would consist
    calcium and magnes
    m the lime/soda
    for pretreatment.
    the volume would
    be much greater
    due to the sludge
    the Illinois Environmental
    Protection Agency
    requested
    CWLP investigate the use of electrocoagulation
    ("EC") to remove
    boron from the FGDS
    waste stream. EC uses
    charged plates to introduce an
    ele
    es a driving force
    for chemi
    stable compounds or coalescing
    charged parti
    method of removing
    t; how,.. vci
    ec
    instead
    of
    the
    wastewate
    ing more
    larger settleable solids.
    be fully explained
    by the suppliers
    o
    n
    (acmonstration r1lot was performed in late spring
    of 2007 to
    ý1",
    volts,
    plate m;-iL:i
    i<<1.,,,
    gated variable such as
    amps,
    not a preferential
    o n) .
    p ilot test demonstrated that
    this proces
    ially in
    onstration
    and the plating of the
    electrodes with
    salts will cause the system to fail within a
    short amount of time.
    l be happy to answer any
    questions. Thank you.
    Respectfully submitted,
    and
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    Date: October 20, 2008
    DISTRICT,
    a S ANITARY
    B y:
    _/s/
    Christine G. Zeman
    ý
    One of Their
    Katherine D. 1-lodge
    Z ernan
    3 150 Roland Avenue
    P.O. Box
    5776
    Springfield,
    (217) 523-4900
    is
    62705
    CWtP.002/F0/Pre-Filed Testimony of Schilling
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    Project
    Consultant
    for Water Supply & Wastewater
    s r,rlciate Chemical Engineer
    with more than thirty years of
    cc in water
    and
    ý ý'aýtCtý.ater
    treatment. His areas of e ýperti5e i
    s peci(wation, and procureinci t
    of
    Cheniical Ti-catntcnt
    Sj
    sterns For
    Industrial Facilities
    and PtlNer Phint Water Treatment and Wast>:ý+ater
    Trcmnicni Sý st:cms.
    He has
    speclalllcd i"\perience in material selectloci, ctrrmtilou (ontrol,
    do>alination systems,
    waferlrcatnwnt systems, ion exchanirc hroýr.;c<,,
    avid walci cheiitical conditioning.
    Mr. ScIitIIint_liasliartisi1)medinIll ir,I ;itinumerouspower
    projects andprovided
    dc-ýl
    i, 1l al
    i rFri-Iliý r t-;il"l( if"'.
    RcýI)un
    ihlc° Ikir the dc,,l,tn .tnd proýt+rcmcnt of v.-ater,ind ý..I-;tc?atcr
    irk. atment systems
    " 1". ,IIý L'
    Treatment
    for ýa ne\N- 8ý0 Nlltv'
    coal tits
    Iced
    ýLCaiu ;ýcnk-r if ill unit- TI i. nc ,ti unit
    &ý,ign incni Ixirates
    lý aý:ir Water
    Treatinent
    an F61)
    I,Ioýý
    do%vn treatinc'lit system if h) I-J ikf
    t i,ý
    fin-
    tu,.ccI bl<Iwdo n trN-lclII,-
    +ý ChclnicalCondititlnin,2
    zero liquid dr,clar --
    " VvaterQuality
    CoIiirot
    " Material
    Selection
    7
    tic crlng,
    ý ,' I I".<irll l
    ý .(IhcICrij
    Unit,
    Cmrtnd\
    I 11 '( t
    ;' o
    s ystems
    t l":I ;tll;r
    burning
    J:"
    ,1
    I
    ia'ln
    ( I'R
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    ) ;Ii
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    t ;w!c_-Plll<ll studlcý: t it ýt,t.'rlrýIU2
    ý
    : d ditiOft 1l %,3t t (r.'atm.rlt,, i ci ii
    U ili`tni'lf',
    1ora new f
    -;()
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    ' Cu- 7I
    f tlý..'li j ;
    tC'linl ? Cnk_'ratmgunit.
    Prep!,'t'J F'
    c iic:at
    W
    , ,,
    for the procii liicut
    of tfC
    ýý;t(ý't i I k;af,iciit
    equi
    !I
    e nd r1,-< h. I,iyd
    fitn f?()ýv r
    ( i" Idlli°
    . -Itý`
    i
    t,'t711:Ct11llal
    _ 'ii itlr lh`_ r,iCýCIU1?Ilil'tll:
    of R 7. t1M\V
    I wail l 1iGd 1!illt.
    .I
    Itc ý,,
    ;1es a zen., di,ccorlccl,,t
    fllr the new
    K cspunsi(ýIc
    fbrille
    il'+eik:ýý
    ýý of J I'! C. irtl:iý-i(ýr ýIhri iýl.l, 1,,( the
    ticimient
    s ;
    stý'il1<.
    far two 750 %lW
    coal fueled unity
    ýlajur ýs;iiertrc
    atnt,'nt ct.ti±i,)in;ýnt
    includes
    r<m wafer
    Clarifier/softener, reverse osmosis iw;rament with niised hi°d.
    drniilirralirý'r,
    A -,
    t l
    o ý'I CKCS: L .nfLrIU::CI _
    i
    lk-'
    d C',Wltc`d, md pro ctifoti
    vt.iwr ti ca
    il
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    'llt
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    1 lrlift ifn(.'1?' Ii':ctt;ý: ý ,lrtt'J<
    I0ll<il,ýA h
    \
    elCC trodc iorlllation, C 1,:
    and,
    : ..I.-
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    ý r c hcnuc.li Iixx1- aru! dl,` i;tmple
    alit
    a
    nalysis ;tk°Ili
    Elc
    t`,'a^, 7iýsr
    ' ýý 1: a t'",
    tit _
    I rlýllli:cr.
    He reviewed,
    o",ign
    o f
    water
    irC-Eiinre
    nt,
    ".3v;tco.ilcr treatment,
    and c bc-ntlc;d
    < oiiift loiiing
    systems as the ()`brier's I l i¢
    iir for
    i
    ltccomltitiedcycle
    gaspmvcrh6nt, IIl-.
    dksignincluded
    vva,,iý.-,vatertreaunt'!!.
    l;icilil ii:; to
    allow zero di chýth.:. ortt
    ri(tioia.
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    the combined c kýcle
    ,:AtnVcrs
    1n _
    Cl do
    il
    klcJt_I I c i1 a i i . 1 jocured water
    treatment
    e
    o
    n,
    inc 11(dir} , ?-pass
    reverse osmosis system, camp
    d
    :md t ir, ul;1tii0
    ,.;;lier ii+-lili(,tl
    )l ý ýl,.
    l-fe \ý'as assi:..neAl as ti Prc,ject I'rocesc Engineer. He provided envýineeri
    di°`,iý_ n c)1-'v+ttu r trc° ttn'+cnt :Ind
    ý!tcr conditioning systems as the CIý> ncr`,
    Fagincer
    for
    I)
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    _ i,
    _c+l m
    i1!
    A s a
    I'rowct
    fýr(AýCýý I_nsiiwcr. Ile ( I C';i"-rler.i tII)d p rOCUrcd
    % k-<
    ti t:r t I_airrnentsystem
    con,,(Stu l,_, U hf=rCý`ný.1i91i'1 Illtý'r:; iv'-'!w t!,nio,; , tt't';1t11wni !,sl!t?<tt'(1 by
    electrode
    iomýittiun.:,artlt)Iine tArld ;trial`.ý,i ,`.>tt!rI. ci!'c.tti,rtltle }::Ier ¬;Ilt`Irtic,al feed, and
    chemical hcýl ;`:stair`; lur[hc C'iAnilý+inecl (
    lcic
    1'rý!jcct.
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    I1 I!in lin+ý tit:.3 c!c-týrrl
    of
    ýtar:r llrhl t, ,
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    follo',girl" ctt;tl-lirti'ii+-mlts;+ýthcI:I,("t:t+ntlctct,,r
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    procuft'Cr7Crll, '-;it+SttI1L (tl)(l C
    t-+t'!1nfi:ý.tiinrlitlL-
    JAU'--A Tinier, I'sitwi Povi:i l'rctjcct: I'aitan.-
    lndonesi;r
    -lIle
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    elcctn,A:hlvrirlatitm. chemical Ic c;1. sarnlt(irl:_ ýý,stzm . s rld t ,.ýt,lc°s4atcl treatment
    for
    he,ivM
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    etal:, r c
    mc týa
    l
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    Ixkrt O ý o
    ;'11k
    :o I1-h r+'d tink",. M r- `ýchilline <Ilsi)
    provided ( w-S ite ,tarwp a nd comrrl I f,Sro nin^ : A"-ýIVfý1nCe
    1tlr
    i111 1t:r l -'r rrv:!rment
    systems.
    a PovcrCompany
    -Taichunl Pover-tit;aictr,: Taichun!ý, `l
    aiv,iin:
    'The EPC
    scope
    inclttidoi
    tr°f°<rf(rtclit oil-tllr
    c,.ati;tetý°lrcr
    ýrcneratý+l ht'tiiý 1lrlt' +,=aý
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    t lnllit, '1;;}It±J
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    t',C :I¬l,=_o, .<,r c ieyl, .rlidwli.'velopwater
    n l;trl,lý'cnlrlit
    pt w?r;]llr, or ln,+
    sii,ý;ctc
    pr-,
    lbl rn r!s!+t-ý
    i;.tlt,(f
    a-itll
    ('nr,t)siun (,,r plant
    nl'r,_r°atiftrls,
    l ý(I<Ie+Ir i,, all eý,;tnlpl<' rýf
    ,.lu(iv
    p+ riitru+Cci tora! tldii-tu1if hrc
    Chimt Li ilt
    ý,,
    Ii C(iIllpztn;: -- C;r,!k Pi,
    ,I!ý
    Poo,: r Station; Hon;,! Kaltg.
    prcil:rrtil,,i ý.ýa',tl llrrllawr., nr¬`ui:-.ttlfr,l
    a4.`.tjfJlMLi g¬'rtet;ltin! facility.
    The
    I tYrl V ,lt9i';tc:`d ¬ 3fCIti11t.
    r:(&
    !l-f1.!Cled k ttlll`" t ir!tl
    nlllýfil`I:
    '
    ,ý'aSfC+
    II fiR"li: al S_'()I'lll)t1ýStEOn
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    eater mmiagement
    c ONIYpliance
    with new
    . Schi}lin!ý
    r
    nýrTaýýcdthe
    Study.
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    BEFORE TII LAOIS P OLLUTION C O NTROL BOA
    RINGFIELD,
    BLIC
    IGHT
    )
    R09-8
    FROM 35
    ILL.
    SECTION
    302.208(g)
    tilities,
    LED TESTIMONY OF
    collectiv
    0
    1y "Petitioners'
    of Springfield,
    is
    ")
    and
    Springfield Metro Sanitary District
    their attorneys, HODGF D
    loved at Crawford,
    Murphy & Tilly, Inc,
    my-e ight
    years
    of
    e r treatment, engineering and management. I hold a Bachelor
    of
    ity (which is now known
    of Illinois at
    ek Wastewater Treatment
    ORT OF P
    tration
    from
    a nt ("Spring Creek Plant") operations; the
    S
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    utant Discharge
    Elimination System ("NPDES")
    Permit anal
    econ
    the beneficial impact
    to CWI-P of utilizing
    SMSD's operations;
    and the
    ilizing SMSD's operations
    on CWLP.
    SD owns and operates the
    Sugar Creek Wastewater
    Treatment Plant ("Sugar
    x)73, a
    fro
    as. T
    was constructs
    eld,
    Illinois. The Sugar
    Creek Plant
    stewater
    and storm water
    from the southeast
    1t
    astewater
    t, west and northern parts
    of Springfield and
    ice
    areas. The last major improvements
    to i
    0,300
    and
    increased just over one percent per year
    on average for the previous
    hzdge treatment
    plant
    a, and
    -ing main unit processes:
    Grit removal for removing heavier
    sand and grit particles;
    removing somas anct wotogical
    matter;
    4.
    particles
    olo
    clarifiers
    for removing the remaining fine
    solids
    from these clarifiers
    to the
    n tanks);
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    Anaerobic
    sludge digestion to
    stabilize primary and
    secondary
    Excess
    flow clarifiers to pr
    flow storm events.
    The
    Spring Creek Plant
    stored (biosolids
    are land applied
    when
    the River, flows
    into a 72-inch diameter
    is conveyed
    approximately 5,9'
    all sewer was
    constructed in 1973. The
    7-day 10-year low flow
    Plant discharge is
    54.5
    ilion
    gallons per day
    of the Spring
    Creek
    seasonal disinfec
    of
    ays per
    and is
    operators fiom 7 a.m.
    to I 1 p.m. There is a separate
    design capacity
    of 20 M
    2004
    through 2006 have ranged from
    11.8
    The
    design maximum flow of the
    S
    Plant for.- complete treatment
    is currently 50
    ours
    per day, five days per week. It has
    an average
    005 peak
    of
    98
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    On average,
    the discharge of the Spring
    Creek Plant is less than the
    7-day 10-year
    low flow
    of the receiving stream, the
    River, which is 54.8 cfs
    or 35.4 MGD. A Spring
    7-day low flow
    of 11.31 MGD has been used
    for calculating the boron
    r the scenario for the proposed
    Site Specific Rule.
    This flow rate is
    based
    on the 7-day low flow presented
    on the 2002 1SWS map,
    the latest available.
    effluent flows as low
    as 9.
    2007.
    observed
    during an atypically dry September
    The requirement
    for complete treatment of flows to
    the Spring Creek Plant is
    ("NPDES Permit"), which
    expires
    , 2009. MSD anticipates there
    will be change
    upon renewal.
    By July 31, 2009, its current expiration
    date, construction of a new
    it: hf,uld be underway, which
    will require
    Permit due
    the reducti
    tion Agency requirement
    uncut facil
    influent data, the carbonaceous
    BO
    concentration ranged from 157 to 214 milligrams
    per liter ("mg/L") with an average
    of
    172 mg/L. The
    CBODS removal after primary, secondary and tertiary
    treatment is about
    ent CBOD5 of approximately
    3 mg/L.
    ation ha
    307 1ng/L with an average
    of 198 rug/L for 2
    .Ltý:aal had
    only 7.3
    SS on average.
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    eek
    r e
    nfluent value of 12 mg/L to 1.35 mg/L in the tertiary effluent
    percent removal. At the present time, ammonia nitrogen loath
    -ing Creek
    um capacity, but recommended plant improvements will be designed to
    provide ammonia nitrogen
    Total phosphorus remo
    ES
    so influent and effluent data values are not available, but plant expansion
    uirements expecte
    low of 50"1i to
    a high
    of 78'F
    in 2006.
    5.0, on a,rer:ý
    plant
    i 1T,ý
    Spring Creek
    gas
    desulfurization system
    ") wastewater
    1.31 MG
    not be si
    process, and there
    ational adjustments to the
    sonal h1PDES Permit
    ammonia nitrogen. Data from 2006 shows
    a reduction in ammonia from
    he 7-day low effluent flow
    7
    concentration. Thus, the Spring
    Creek
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    ed to be 1 1.0 mg/L.
    The boron concentration
    downstream in the
    River is
    estimated to be approximately
    4.5 mg/L under
    this scenario,
    ently meets NPDLS regulated
    parameters,
    to the Spring
    Creek Plant is not
    expected to have
    any effect on the
    Spring Creek Plant, other
    than the increase in
    boron concentra
    effluent. While granting this
    Site Specific Rule will
    not reduce, with any level
    of
    ty, the need for
    the previously-granted 11.0
    mg/L adjusted
    standard for boron,
    rather, granting
    t
    ay enable CWLP to meet
    compliant levels is
    the FG17S
    wastewater stream, at a
    00,000/m
    1) ,, of the
    estimated
    by CWLP. TI
    1 cost
    o control odor
    to the
    nce
    ficantly less
    than the brine concentrator
    other
    O & M costs will likely e c;lý,t.ý.
    Using a $10,000 per year
    escalati
    which is estimated
    to be at least $1 .6 million,
    factor, a pretreatment life of 30 years,
    and an interest rate of 8 percent,
    this equates to a
    present value of $36,100,000,
    a present value per electric
    service of $544. In addition,
    the plumping
    station will occupy significantly
    less space than other alternative
    1
    or hazardous waste product would
    be generated.
    6
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    For the pretreatment
    system, operation of
    the patented ClariConeTM
    has been
    ClariConeTM
    over 300 installations nationwide.
    Mixing, tapered
    flocculation and
    all take place within
    a completely hydraulically
    driven vessel.
    The
    s
    a dense, suspended, rotating
    slurry blai
    contact,
    accelerated floc formation and
    solids capture. The conically
    shaped concentrator
    d allows plant personnel
    to visually
    monitor slurry
    discharge. The large mass
    of retailed slurry and
    unique helical flow
    iting
    and resists process upsets. While
    laboratory jar tests have
    shown in some instances that
    ten percent of the
    boron in the
    wastewater
    can be removed with solids
    settlin
    n
    urposes of
    calcu
    Plant:,
    fiberglas
    n this
    I ?,I Ird pump
    in ate,
    1
    ý...... A 10" diameter
    g station to a sanitary sewer
    generally
    west of
    ,astdale
    Avenu
    part o
    crossing
    Stevenson Drive and Sugar Creek,
    to the CWLP Tansey Road
    electric
    substation. The main then
    turns northwest, bored under
    1-55, and along
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    is
    ant icipa
    a nd sever
    release valves will
    be required. Sealed and lined
    size
    odors and corrosion.
    Lining of the receiving
    manhole
    t of the existing
    sewer is anticipated at a minimum,
    or more chemical feed
    sites or stations as deemed
    ing
    Creek
    wastewater
    from a large area which
    Thus,
    the
    WLP wastewater
    will typically be a small
    y two-
    ill not requi
    I
    will be happy to an
    ction of the total treated
    any capital expenditures
    by SMSD.
    respectfully submitted
    2008
    nd Avenue
    P.O. Box 5776
    7
    ;TRO SANITARY
    e of Their
    Attorneys
    :002/riliFlre-
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    William A.
    Brown
    S
    enior Project Manager " Crawford, Murphy
    & Tllly, Inc.
    M
    r. Brown recently
    retired as Su-
    perintendent of Water
    Supply
    & Treatment
    at City Water, Light and
    Power,
    Springfield, Illinois, where
    he
    was employed
    for 20 years. He has a
    to-
    tal of 28 years experience
    in water treat-
    ment,
    engineering and
    management.
    He
    has a keen understanding
    of
    city, county
    and
    state codes and
    regulations. He was
    responsible for
    operations
    in water re-
    sources, water quality
    and water puri-
    fication.
    including lake and watershed
    management, new
    water source devel-
    opment and dealing with property
    and
    agricultural
    issues. He taught chemistry,
    mathematics and
    principles of operation
    for
    waterworks operators
    at the local
    community
    college. Prior to working
    at
    the treatment plant, he
    performed chemi-
    cal
    and microbiological analyses
    on
    wa-
    ter and wastewater
    with State of Illinois
    certification,
    technical project
    manager
    for various
    lake
    and river water quality
    studies,
    water main
    and sewer
    design,
    facilities
    planning reports and
    construc-
    tion inspection.
    Professional
    Credentials
    Illinois
    State American Water
    Works
    Association:
    - Recipient
    of the Thurston E. Larson
    "Best Paper
    Award"
    1999
    - Recipient of the "Operator's
    Merito-
    rious
    Service Award" 2001
    Illinois
    Potable Water Supply
    Opera-
    0
    0
    tors Association
    " American Water
    Works Association
    " Horse
    and Brush Creek Watershed
    Planning
    Committee
    " Class "A" Water Works
    License in the
    State
    of Illinois
    State certified for
    microbiological
    analysis,
    State of Illinois
    0
    R
    elevant Project Experience
    City of Aurora,
    Illinois
    Assisted
    the City in resolving operation-
    al problems and problematic
    treatment
    of Fox
    River water.
    City of West
    Chicago, Illinois
    Assisted the City in start
    up of new 9
    mgd lime
    softening
    water treatment
    plant. This is the
    City's
    first ever water
    treatment
    facility.
    City of Springfield,
    Illinois
    A s part of an alternate
    water supply
    study,
    ran a
    ClariCone pilot plant
    on the
    Sangamon River
    to determine treatment
    requirements
    and techniques
    during
    drought
    conditions.
    Sampled and tested
    the
    Sangamon Riv-
    er and adjacent gravel pits to determine
    water
    quality
    during drought conditions,
    normal and flood flows. Discussed
    fu-
    ture
    lease/purchase options of the gravel
    pits with
    the
    owners.
    ..%f:
    s
    ýjýbý
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    1 THE ILLINOIS P
    OLLUTION CONTRO
    I N THE MATTER
    OF:
    pecific Rule - Water)
    NOW
    COMES the Petitioners, City
    of Springfield, Illinois, Office of
    Utilities, City Water, Light and Power
    ("CWLP") and Springfield
    Metro Sanitary D
    , by and through their
    attorneys, H
    i ill ý'-r I
    r
    eferenced matter.
    ssional
    Ser
    ("flanson") in
    Springfield, Illinois. I have thirty years of professional
    experience.
    helor of Science degree in Chemical and
    Petroleum Refining Engineerin
    the Colorado School of Mines, a Master
    of Business Admini
    Illinoi
    iversity
    at Edwardsville. My current resume
    i
    ny today concerns the
    ny of Deborah
    ion from
    Southern
    of Science in Environmental
    Science
    lard for
    boron; the condition of the receiving
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    streams; the historical
    flow and boron data for the receiving
    streams; the entities
    presently discharging
    to the affected water
    segments, as well as the
    entities using water
    downstream; and the investigation
    of the flue gas desulfurization
    system ("FGDS")
    blowdown
    as it relates to boron and its
    chemistry. I am the principal
    author and
    "Techn i
    No.
    esponsible for the development
    of Exhibit 1 to the Petition,
    entitled
    ipport
    Dvcranent fbr Site-SI)ecific Boron
    Standard for the Springfield Metro
    4767,
    ational Pollutant Discharge Elimination System
    ("NPDES") Permit,
    ring Creek.Plant,
    Sangamon County, Illinois" ("TSD").
    ecember 5, 2001, regulates
    16 outfalls at the
    CWLP facility,
    charges from Outfall 003 and
    Outfall 004 contain high concentrations
    of boron.
    WLP to
    s of boron in Outfalls 003 and
    004 to
    boron was 1,0 nxg/l.,
    with c
    iance to be achieved by Decem
    Sugar Creek
    a
    with the general water quality
    standard
    of 1.0 mg/L. The "Technical Support .Document
    fear Petition for Adjusted Boron
    Stanclar
    was, at that
    Sugar Creek and the Sangarnon
    River" was prepared by Hanson (which
    d the A
    mhe
    h
    ibit 2 to the Petitio
    lusted Standard From
    35
    1:11. Adrn,
    Code
    quality
    standard for boron already
    2
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    aters at issue in
    this Petition. Figure
    1 atta
    shows the surface waters
    covered by the Adjusted
    Standard
    and the surface waters and
    other features
    at
    posed site
    specific water quality
    standard for boron
    would include at
    of dispersion
    with boron concentrations
    ranging between 4.5
    and 11.0 milligrams per 1
    g/L") from SMSD's
    Spring Creek Sanitary Treatment
    Plant ("Spring
    Creek Plant")
    Outfall 007 to 182 yards
    downstream in the
    Sangamon River, 4.5
    mg/L in the Sangamon
    River, a distance
    of 3
    confluence of Salt Creek with t
    h the
    uence of Salt
    Creek with the Sangamon
    1.6 mg/L
    in the Sangamon River
    from the
    fluence
    o
    e of 36,1 river
    miles; and 1.3 mg/L in
    the Illinois
    from
    the con lug i iý.
    ý_
    of the
    d oNvr,
    st rt. um
    The proposed site
    specific
    ,,.,
    ,iicr
    quality standard is
    54.
    concentration in the Sangamon
    I
    to discharge frot
    Oil
    " ) having a boron
    concentration of 2.0 mg/L
    in
    the
    ron concentration
    of 11.0 mg/L.
    s based
    on the Adjusted Standard granted
    to
    u e
    t he
    terms of
    the proposed site
    specific
    rule
    as set forth in t
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    The
    Sangamon River watershed comprises
    about 5,419
    square miles, all of which
    part of Illinois.
    Practically all of
    the area is tillable and,
    for the most
    part, is cultivated. The
    Sangamon River originates
    in central McLean
    County, east of
    Bloomington,
    flowing such that it
    is joined by Salt Creek,
    its largest tributary, and
    then
    joins the Illinois River north
    of Beardstown. The
    total length of the
    Sangamon River is
    iles. The whole length
    of the Sangamon River is
    characterized by a series
    of
    pools and shoals, including
    five impoundments in
    its basin. Lake Decatur
    is
    the deepest p
    n in October 2007
    to characterize the general
    features o the San
    ownstreani
    ed it to
    Results reported to me
    from this held survey were
    as follows. The lower section,
    below the confluence
    o ý;; -t ii,rttion
    ý ý1.=ýCJ71lýn
    u psti-cam of the Spring
    near Petersbur
    at
    -,
    p ringfie
    ly
    d, and
    two rock check darns located
    ared
    by the Illinois State Water
    Survey
    ("ISWS")
    in 2007, the mean flow
    at the
    2,120 cfs for the base period from
    1948 to 1997.
    During
    There are eight
    m dischar
    Sangamon
    ges to the Sangamoi
    d Gravel Company;
    4
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    Park; Riverton Sewage
    Treatment Plant; Illinois Department of Transportation, Interstate
    Treatment Plant; Petersburg Sewage Treatment
    Plant; and Petersburg Water Treatment
    Lion. County North; SMSD, Sprint;
    Greek Plant; Pleasant Plains Water
    Plant. Other generally known uses of the Sangamon Ri
    an
    eation (bo
    fishing, swimming).
    The reach of the Sangamon River at issue
    to specific rulemaking is not reported as used for irrigation of agricultural
    land,
    golf courses, nurseries, etc.
    ations in the Sangamon River from
    "IEPA") for 1999 through 2004
    for three
    ions on the Sangamon
    fs from
    the
    United
    Icy,
    :Iti ý,]01,:1,
    f ihtý
    hi
    four-
    s
    total boron
    .o ý cdcd 1.0
    mg/L in nine percent of the sampling events at thi
    boron value c "ceeded the adj
    aiida
    on at Riverton was 0.394 in
    tion, no
    The mean boron
    over the five-year period from 1999 to
    2004.
    s of the Sangamon River at issue show that
    eluded on IEPA's 2006 list of waters where uses are impaired,
    the Sect
    the Sangamon River from the South Fork of the Sangamon River to pr
    k (E-26), the Sangamon River from Spring Creek to Richland Greek (E-04),
    the
    Sangamon River from Richland Creek to Salt Creek (E-24), and the Sangamon
    from Salt Creek to the Illinois River (E-25). All four segments are identified as impaired
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    1 cause
    of fish consumption
    rment is polychlorinated
    bipllenyls from an unknown
    source. TI
    identified as impaired for the designated
    use of primary contact recreation.
    A potential
    cause of primary contact recreation
    impairment is fecal coliform
    from an unknown
    source. Stream segment E-26 is identi
    potential causes of
    aquatic life impairment are boron, nitrogen,
    phosphorus, silver,
    total dissolved
    solids, and total suspended solids. Potentia
    discharges, on-site treatment
    systems, ru
    ýtration
    of
    0.25
    ni
    I included
    in the fo;, ..l,:ýarý .
    rý;r
    at
    0.27
    fl, =v and a boron concentration
    of
    450
    rng/L, the
    gated that the
    boron will not
    I rC c
    1,
    r sely affect the
    process and therefore
    the effluent boron concentration is
    nt concentration. Thus, the Sprin
    1.0 mg/h,. The
    boron concentration
    182 yards downstream in t
    eek Plant
    rameters. Pun
    L
    imated to be 4.5 in
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    expected
    to have any effect
    on the Spring Creek Plant,
    other than the increase in
    concentration in the
    effluent.
    on of
    the boron concentration
    in the wastewater
    stream anticipated
    for discharge by S
    's dischar
    economy
    is a crucial power supply for
    Springfield. Consistent with
    the testimony of
    educe, wit
    m ion River
    or thý. III
    m-J,
    River as a result
    of the proposed site specific
    ives studied by
    CWLP.
    lard for
    boron in Sugar
    Creek, rather,
    should enable CWLP to meet complaint
    levels in
    in comparison to
    the concentration in
    of make its removal by
    SMSD any more feasible
    or
    asonable
    than the removal
    d 11.0 mg/L a
    Creek, as was typical prior
    to operation of the Selective
    Catalytic Reduction. The
    CWLP
    antici
    tandard; thus, the proposed
    site specific boron water
    quality standard is
    be happy to answer any questions.
    Thank
    You.
    and
    LD
    October 20, 2008
    By:
    _,/s/
    Christine C. Zcnl1,u
    _
    (one of Their
    Attorneys
    D. Hodge
    l of
    certainty, the need for the
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    Roland Avenue
    P.O. Box
    5776
    (217) 523-4900
    05
    P :002/Fil/Pre-Fited Testimony of
    Ramsey
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    Deborah A. Ramsey, P .E
    Chemical Engineer
    Education.,
    *
    B.SJ197&Chemi
    t
    &
    P etroleum Refining
    Enyineerir
    WC*Wado
    School
    of W#M
    M.SJf9WErMronmentae
    swwosouthwn Illinois
    amity
    rat Ed
    r<fsvilte
    R
    egistrations:
    ProteWortal
    Engk*WIL
    P
    al
    r00
    Frv68kr"
    rfrX
    +ý CIO" 4W4$tq*ete
    zrýtirrieýt tit ratýýCL
    0
    CCM
    Cow
    off",
    EtrVkOnMWteJ Committee
    Arriericart Insfitute oaf
    Chernk.w Frtgineem
    Publlicatirno:
    +
    . "Controlling Sulfur
    m frns
    from
    ",1985
    Ms. Ramsey Joined Hanson in 190-3. She was previously employed
    as
    city
    engineer for the city of Staunton, Ill., and as a process
    engineer acid production supervisor
    for Monsanto. Ms. Ramsey
    has distinguished herself as a budget-conscious,
    client-oriented
    project
    and
    task
    manager. Her involvement in the Illinois
    Emergency Management Agency"s Kerr McGee
    technical
    oversight, FEMA (Fluor) Technical Assistance
    Contract
    for disaster
    recovery and AmerenCIPS groundwater treatment programs
    exemplify
    her
    versatility acid bath technical and management skills.
    City
    Water, Light and Power (CWLP) ash pond recycling study,
    Springfield, Ill. Project
    engineer
    responsible
    for oval Uating efforts
    to treat ash pond effluent andlor Springfield
    Metropolitan Sanitary
    District (SMSD) treatment plant effluent for ash sluicing at the
    CWLP power
    stations.
    The
    evaluation
    included
    a bench scale
    simulation
    ¬3f
    the recycle and reuse of CWLP effluent
    for ash
    sluicing. Evaluated the recycling of CWLP and SMSD effluent
    back
    to Lake Springfield.
    City
    Water, tight and Power (CWLP), investigation of
    mitigation; strategies for boron Increase,
    Springfield, fit.
    Project manager responsible for investigations
    into the source of
    increase in
    boron concentration at outfall 01}4 from the ash ponds.
    It was discovered that the
    significant boron contributor to the ash
    pond system was the gypsum dewatering stream from the
    Dallinan
    Power
    Station
    flue gas
    desufferization system.
    CILCO Duck Creek facility permitting services,
    Canton,
    Ill.
    Project
    engineer
    responsible for
    ,assisting in the preparation
    of
    a
    technical support document used with a
    petition for art adjusted
    water quality standard for boron. Also prepared
    a technical support
    document used with a petition for a five-year variance to
    the
    adjusted water quality standard for
    boron.
    Kerr-McGee
    closure
    application, West
    Chicago, Ill, Assistant
    program manager responsible for preparing
    environmental analysis
    and safety evaluation reports, reviewed cast, environmental
    permitting, process
    and
    treatment facility
    design; and planned utility
    renovations for an Illinois Department of Nuclear Safety (IDNS)
    closure application. Responsible
    for
    daily coordination
    with and
    supervision of on-site construction
    observer. The project consists
    of remedial design, remedial action oversight
    and
    review
    of
    technical
    documents.
    Kerr-McGee West Chicago Industrial
    wastewater facility
    design review, West
    Chicago,
    Ill.
    Project manager responsible
    for reviewing drawings, specifications and
    startup plan for Kerr-
    McGee's industrial wastewater treatment
    facility, which is
    designed
    to remove
    suspended solids, soluble radium and fluoride. Soluble
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    {"MMsey, cant.)
    r adium and fluoride are removed via a coprecipitation process.
    Observed
    initial facility
    startup as a representative for
    the Illinois
    Department of Nuclear Safety (IDNS).
    FEMA disaster assi
    , Mobile
    County,
    Ate. Worked as a
    FEMA project officer during a FEMA-declared disaster to prepare
    project
    worksheals that detailed damages from Hurricane Ivan and
    estimated associated
    repair
    costs
    in
    Mobile County.
    Majority of
    worksheets prepared were related to public
    entities
    ten Dauphin
    island, a barrier island south of Mobile Ray that received significant
    damage from hurricane force
    winds and flooding due to the
    associated tidal surge. Damages were
    assessed
    for roads,
    sewers, sewage lift stations, water treatment plant, potable water
    boaster tank, buildings,
    docks,
    park facilities Including
    an historic
    fort, and an historic lighthouse. Additionaltr, project worksheets
    were prepared to
    document
    emergency work performed by the
    Town of Dauphin Island
    and the Dauphin Island Park and Beach
    Board and debris collection and
    dill,
    including hazardous
    waste,
    related
    to Hurricane Ivan.
    AmerenCIPS groundwater treatment
    design,
    Taylorville, Iii.
    Project
    engineer responsible for coordinating design, construction
    and startup services
    for
    a ground-water pump-and-treat system at
    a National Priority List Superfund
    site.
    The treatment
    system
    included
    pH adjustment to reduce the precipitation potential of the
    ground water; oxidation
    of the
    ferrous
    iron in the ground water bra
    the
    ferric state
    with potassium permanganate; filtration to remove
    the Iron precipitate; and removal
    of organics from the ground water
    using a two-stage, granular-activated
    carbon (GAC) adsorption
    system.
    American Bottom* Regional Wastewater Treatment
    Facility
    environmental audit services, Sauget, tit. Worked for
    the
    Illinois
    Environmental Protection Agency. Conducted annual independent
    audits to monitor industrial
    user compliance with the pretreatment
    program and regulatory requirements,
    monitored operations and
    maintenance at industrial pretreatment
    facilities; and reviewed
    quality control
    and
    assurance
    procedures
    followed
    by Sauget in
    monitoring and tasting oaf industrial users. Completed
    US.
    Environmental Protection Agency
    Control Authority Pretreatment
    Audit Checklist for each audit.
    Staunton
    water
    treatment plant operations, Staunton, Ill.
    Oversaw potable water treatment plant operation
    far
    more
    than six
    years. Process Improvements that were designed,
    permitted and
    installed included replacing
    a
    prechlorination
    system with
    potassium permanganate. The
    sand
    filters
    were upgraded to dual
    media,
    and
    the water
    treatment plant's monitoring and
    control
    systems were significantly improved.
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    (Rarnsay, coat.)
    Staunton wastewater
    treatment plant, page Itft station and
    collection system, Staunton, Ill. Provided
    grant administration,
    project
    management anti resident inspection for
    a $4.5
    million
    wastewater
    treatment
    plant,
    a 10.8-million-gallors-per-city (rra
    sewage lift station, and
    a
    collection
    system. Interacted with federal
    and state agencies as
    required
    by grant
    agreement. Suggestions
    for
    design modification of collection system resulted
    in
    savings of
    U.S, Ukraine Foundation,
    SvMovodsk, Ukraine. Provided
    technical review and recommendations for
    improvement of portable
    water treatment system to Svitkavodsk,
    Ukraine (Springfield,
    Illinois'
    sister city).
    Also reviewed Svitlovodsk's municipal wastewater
    treatment plant operations.
    Central
    National
    Bank Diamond
    "E" Packers demolition,
    Mattoon, III. Project manager for "turn-key"
    services associated
    with demolition of a former manufacturing facility.
    Environmental
    services performed included
    removing one underground storage
    tank and two aboveground
    storage tanks: excavating and disposing
    of stained soils observed at three locations;
    and packaging,
    disposing and
    recycling
    miscellaneous chemicals,
    special
    wastes
    and hazardous wastes located
    at the facility. Clean up in areas of
    stained soils evaluated with remediation
    objectives obtained from
    35 IAC 742
    (TACO) regulations. Used remedlation objectives
    obtained
    from 35 IAC 742 (TACO) regulations
    to evaluate the
    cleanup
    in
    areas that had stained soils.
    Raynor Hotels design and construction
    services, Holiday Inn
    East,
    Springfield, Ill. Project engineer responsible for
    preparing
    plans and specifications, conducting
    bid letting and providing
    construction
    observation. Oversaw the demolition of
    the hotel and
    adjacent gas station. Also participated in the removal of
    asbestos-
    containing material and in
    the collection and disposal of hazardous
    and special waste. Characterized portion of facility
    contaminated
    front service station operations.
    U.S. Army Corps of Engineers,
    Rock Island District, Lock and
    Dom 12
    Storage Yard, lillooia. Project manager. Prepared
    a
    Preliminary Assessment
    (PA)
    for the
    Lock and Dam 12
    Storage
    Yard
    which has been discovered to contain lead.
    The U ICE was
    currently
    under an Illinois EPA enforcement action. The
    PA was
    developed following
    superfund
    guidance
    documents as the first
    step in site investigation and cleanup.
    Subsequently selected to
    perform
    a site invesigation (SQ for the Lock and Darn 12
    Storage
    Yard seeking to quantify lead
    contamination at the site.
    U.S.
    Army Corps of Engineers, Rock Island District,
    East
    Peoria, Ill. Project manager. Performed
    a
    limited
    phase IIA soil
    sampling at
    a
    3.2-mile
    levee
    in
    East Peoria, Ill. The purpose
    of the
    sampling was to determine if environmental
    issues were present in
    soil at the levee prior to a floral control project
    upgrading the levee.
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    smvm LIM 1 :100,000 ORG FOo,
    L%woK rooms, r..ao.o ma spbprre. /n,
    0
    COPY
    eigU! Hone Prohrbid swiew
    tie. 2006
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    BEFORE THE ILLINOIS
    POLLUTION
    CONTROL, BOARD
    THE
    MATTER
    IFIC
    }
    OF SPRINGFIELD, )
    OFFICE OF PUBLIC
    LITIES,
    CITY WATER, LIGHT
    )
    R09-8
    WER AND
    SPRINGFIELD
    )
    (Site Specific Rule
    - Water
    TESTIMONY OF
    JEFF BUSH
    ity
    Water, Light and Power ("C
    OMES the Petitioner,
    City of Spr
    etively "Petitioners"),
    by and tlu°ougl
    l.
    wing
    Pre-Filed Testimony
    o
    ublic
    icr,
    at the November
    3, 2008 hearin,i,
    ?.Ii,
    ',led in
    the aboN,_-r,
    P'-iý_nced
    matter.
    is Jeff Bushur.
    rs of
    experience in environmental health, water
    and wastewater treatment,
    and
    1/engineering
    consulting.
    Environmental
    Biology from Eas
    nce
    a ttached.
    1
    oday concerns the toxicological
    effects of boron and
    a description
    oncerning such
    effects, especially to aquat
    the receiving
    streams and t
    ial effects
    of boron on the water downstream
    from
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    ary Treatment Plant
    ("Spring Creels Plant")
    discharge; and
    assessments of the receiving
    stream. Further, based
    on reviews of existing
    stu
    rts, I will testify that the proposed
    site specific
    standard for boron,
    based upon the 7-day low flow
    conditions, can be granted
    out any anticipated
    adverse effects to either
    aquatic life uses or other known
    uses of the Sangamon
    River, and
    that
    r biological community
    would not be observably
    affected by the
    oron concentration under this
    scenario.
    The methodology and approac
    quality
    data, biological studies and
    stream flow information that
    ;ies, existing published literature
    re,ýzardiny, possible
    ical effects of boron,
    and studies and technical documents
    ht Company
    ndards for boron, and a variance
    to an adiusted water qual
    stn Standard for the
    ant, 4S an n on County, Illinois"
    ("T
    ition fled in
    resources
    of the Sangan
    the TSD.
    to how we developed information
    for
    ding, on which
    my testimony is based.
    a field survey along with another Hanson
    biologist in October 2(}07 to
    ores of the
    Sangamon River downstýc;irii -)f the
    CWLP Plant
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    discharge. Three
    areas were visited
    by canoe including:
    north of Springfield
    front
    k to downstream
    of the confluence
    of Spring Creek, Petersburg
    at Illinois
    Route 123, and
    Oakford at Illinois Route
    97. The survey showed
    the Sangamon
    River
    north
    of Springfield and at Petersburg
    to be a low gradient,
    meandering
    stream. The
    of the
    Salt Creek, appears
    to have been channel
    floodway in
    the sandier soils. Three
    structures
    in the survey
    that create riffle areas
    which are a source
    of oxygenation for
    the
    Spring
    Illinois. According
    to the
    2,120 c
    ed 7,00
    tired by the fill
    ring Creclr
    was
    S tLcutl1
    h e confluence of the
    Sand and
    Treatment
    Plant; Illino
    ant
    hese NPDES discharges
    include: Clear
    Interstat
    lant.
    Otl
    nclude
    aquatic life habitat and
    recreation (boating,
    fishing,
    The reach of the Sangamon
    River at issue in this site
    specific rulemaking i,
    rid,
    golf
    courses, nurseries, etc.
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    a including
    boron concentrations in
    the Sangamon River from
    Environmental Protection
    Agency ("IEPA")
    for 1999 through 2004
    for three
    of the monitoring
    station
    am and downstream
    of the
    olumes in cfs from
    the
    ited States
    Geological Survey National Water Information
    System were
    also reviewer
    The
    station at Riverton (closest downstream
    of the existing
    CWLP NPDES discharge
    location) had the highest
    total boron concentrations over
    the four-year period. While
    total
    boron exceeded 1.0 milligrams per
    liter (mg/I_,) in nine percent
    of the sampling
    no boron value
    exceeded the adjusted
    standard of 2.0 mg/L of
    boron,
    rton was 0.394 mg/L over the five
    year
    sir,,ýrnj sý.,gments of the Sangamon
    River
    list
    o
    om 1999 to 2004.
    -26), the Sangamon
    for the designated use of fis
    tial cause of fish
    consumption
    t is polychlorinated biphenyls from an unknown
    source. Three segments
    are
    identified as impaired for the
    des
    cause of primary
    contact recreation impairmen
    ,,k.'N
    where uses are impa
    A potential
    1
    coliform from an unknown
    al causes of aquatic
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    total dissolved
    and total suspended
    solids. potential
    sources of these impairments
    are
    industrial and/or irtunicipal
    point source discharges,
    on-site treatment
    systems, runoff,
    channelization,
    crop production, dams or impoundments,
    and strearnbank
    mod
    ontaining laundry products
    and sewage, while another,
    although very
    environment is
    due to the relatively high water
    solubility of all boron
    compounds,
    Regarding boron,
    it is an element that is
    widespread in the environment,
    and is
    distributed in surface and groundwater.
    Most boron
    that occurs in the fresh water
    ons/destabilization. (Ex.
    1, pp. 3-9, 3-11.)
    rce of boron to the
    aquatic environment is coal
    ash. Many commercially-
    mined coal seams
    contain significant concentrations
    of boron. Of the total
    boron in coal,
    lie atmosphere upon
    combustion, though more
    th
    of boron
    d
    c
    ity.
    In mammals, while exposure to excessive
    boron may result in reduced
    xposed to 120 mg/h of boron, nor
    at 300
    ducks and
    chickens, with results of chronic feeding
    studies using
    in birds have
    been
    ely studio
    iets containing 13 mg
    of boron per kilogram of feed
    weight
    cts. While boron rapidly
    accumulates in mallard tissues,
    it also is
    5
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    rap
    laminated. After
    boron was removed from
    the mallards' diet,
    it was completely
    cleansed from the liver
    and blood within
    one day,
    effects of boroi
    ome species of fish,
    one researcher
    studied the
    pounds upon rainbow
    trout and guppies, and
    determined these
    compounds
    to be relatively non-toxic
    using 24-hour bioassay
    procedures. In mosquito
    fish (Gamhusia affinis),
    which are native to Illinois,
    using 96-hour bioassay
    procedures,
    of boric acid
    up to 1,800 mg/L
    ed t
    orted an 11-day
    lowest-observed-effect concentration
    of 12.17 mg/
    ibryo-
    i.u
    of channel catfish r<r- ti lwm
    1,0 to 25.9 mg 13/L, depending
    on water
    hardness and boron comp
    consi
    for fish. While
    some boron compounds were
    Stu
    and larvae than to adult amphibians, no
    effects occurred on embryos
    of Fowler's toad
    leri) until
    53 mg/L of boron was applied, while
    leopard frog (Rang pipiens)
    embryos
    suffered 100 percent lethality or teratogenesis
    in water treated with
    boron
    compounds at levels of 200
    and 300 mg/L of boron, respectively.
    life, boron i
    ic.
    Studies have shown that optimal growth in
    plants
    occurs at 2
    to 5
    mg/L,
    while toxic effects are evident
    at 5 to 12 mg/L.
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    species, such as
    citrus,
    stone
    fruits, and nltt trees, are more sensitive. No use of irrigation,
    however, has been reported to
    each of the
    Sangamon River at issue in this site
    effects have
    been observed in aquatic plants at various
    concentrations, one blue green alga exhibited no adverse effects with respect
    to
    cell
    growth or organic constituents at 50 m.g/L of boron and significant
    adverse e
    greater than 100 mg/L over a 72-hour exposure. A British Columbia study found a
    lowest-observed-effect-level for growth of inhibition on a green alga of 12.3
    mg
    B/
    Boron effects on aquatic life are h
    life stage and environment. Studies show that early stages are more sensitive to boron
    than later o
    reconstituted lab water.
    Boron i
    early life
    ýt:i
    inistering boron in natural water is less toxic
    g/L
    of
    boron have been reported. A 20-day no-observed-effect
    concentration of
    has provided a table summarizing our literate
    I
    life in the Sangamon and Illinois
    Rivers
    at page 5-7 of the
    TSD.
    A
    British
    Columbia
    government study considered two related studies which found low concentration boron
    ety
    of aquatic
    species
    to
    be
    outliers since the results could
    not be
    reproduced by other studies. Similarly, it has been suggested that the low-level effects
    ry water may not accurately predict the effects under
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    natural
    water exposure conditions.
    And,
    candy by
    organ
    that boron is bioconcentrated
    granted an adjusted
    standard for boron
    in 1994. The "Technical
    S'upkaort Document for Petition
    for Adjusted Boron
    Standards for
    Sugar
    Creek
    and the
    Sangarnon River," (Hanson
    Engineers Inc.,
    March 1994), presented
    scientific evidence
    showing no detectable
    degradation to Sugar
    Creek receiving discharges having
    boron
    levels as high
    as 18 mg/L of boron. The 1994
    Hanson document
    demonstrated the
    gical effects of
    boron at varying concentrations on
    the biological community
    of
    an aquatic ecosystem.
    Overall, the results indicate
    that the Sangamon River
    biolo
    i
    Id not be observably affected
    by the anticipated maximum
    boron
    or by the maximum
    boron concentration
    of 1 l .O
    pcr;ý0n.
    not be observably
    ,i1 fý,
    i,,
    d
    by the anticiln,ii,,1 rnývximum boron
    concentration.
    relent,
    a quatic Ii
    the
    anganlon River or the
    adverse effects are
    anticipated to the
    Respectfully
    submitte
    and
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    Date:
    October 20, 2008
    therine D. Hodge
    Christine G. Zernan
    0 Roland Avenue
    P.O. Sox
    5776
    Illinois
    9
    N
    MELD
    METRO SANITA
    CT,
    CWLP:002Til/Pre-Filed "testimony of Bushur
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    Jeffrey L,. ushur
    Environmental Biologist
    Education:
    B,S.1199ý11Epvlrorýmentat
    siotogy/Eestem RIO*
    U nivortityy
    M .&f'l
    M r. Ru tur joined Hanson in
    2000, An environmental biologist, he
    primarily
    serves the
    local
    government market. His experience
    includes conducting water quality analyses,
    habitat assessments,
    wetlands
    delineations, Section 404
    permitting
    and wetland
    mitigation design.
    He has previous experience in water and
    wastewater treatment,
    environmental health and laboratory
    analysis. He has been trained in
    wetlands delineation by
    the
    U.S,
    Array
    Carps
    of Engineers
    and Geographic Information Systems
    Aftfli+eiti0technology.
    its Lake Mwwvemnt
    A saoctabon
    +ý WeW Environnuertt
    F
    ederatim
    lNtnais
    sic
    l
    "
    n ýyatems
    Awards:
    r
    P
    AVxtitlt
    r
    t ' p,:.
    kit
    .
    noted
    :.
    .
    Publications:
    .
    T hesis: A PmWmlnery Study
    Using ft Willow
    Cutting
    Method to Reduce
    Lake
    Stroonetine
    Erosion, 1993
    A M
    4
    ON
    Raccoon
    Lake
    Restoration
    Study, Centraf fit. Environmental
    scientist. Assisted in the preparation
    of ills diagnostic amid
    feasibility
    study of the lake through sediment
    sampling, data
    analysis,
    and
    report
    preparation. Raccoon Lace, with 4,WO-acre-
    feet volume, is tote primary water
    source
    for
    Centralia, Ill. Hanson
    provided the bathymetric, survey data,
    coordinated take water anti
    sediment sampling
    amid analysis with city anti
    state agencies,
    and
    analyzed sources of water quality
    and aesthetic problems and
    proposed
    solutions. The phase I diagnostMeasibility
    study of the
    94(t-acre surface
    area
    is funded
    through the Illinois Environmental
    Protection Agency Clean takes 2000 Program.
    Charleston Water Treatment Plant,
    Charley, Ill. Graduate
    research assistant.
    Assisted
    in
    the preparation and completion of
    the IEPA Clean Lakes Program Diagnostic and
    FessiWy Study of
    the
    Charleston Side-Channel Reservoir. The hypereutrophic
    reservoir is the primary water source
    far the city of Charleston
    and
    has problems
    of algal blooms, high ,gizzard
    shad population, low
    dissolved
    oxygen, nutrient loading, shoreline
    erosion, and
    sedimentation. The study addressed
    the water quality and
    recreational
    problems of the reservoir and
    outlined feasible
    solutions for improving the lake
    quality.
    Lake: Decatur dredging, Decatur, Ill.
    Assessed the
    environmental impacts
    associated with the
    site
    selection
    of a
    sedimentation basin for
    the dredging of Lake
    b atur.
    Responsibilities included
    sediment sampling
    anti
    water
    quality
    analysis to support
    Section 4131 water quality certificatiort
    through
    the
    Illinois Environmental Protection Agency,
    Additional duties
    included
    preparing and obtaining art individual
    section 4134 permit
    from
    the
    U.S,
    Army
    Corps of Engineers, Rock Island District.
    TR-61 improvement,
    Cumberland County, Ill.
    Conducted a
    preliminary environmental
    resource review and prepared
    the
    environmental survey requests
    for
    the rural roadway
    improvement
    anti bridge
    construction over the Etnbarras River.
    Potential
    resource
    impacts included
    wetland, floodplain, threatened
    and
    endangered
    fish and mussel species.
    archaeological resources,
    and
    river
    habitat.
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    (gushur, c orm)
    U .S. 34 roadway widening, Plano, Iii. Environmental scientist
    responsible for
    preparing the
    resource
    impacts far an
    environmental
    class
    of action
    deterrnination (EGAD) document for
    the U.S. 34 roadway widening. Resources and issues having
    potential impacts
    Included
    relr
    tions, econombs. noise, special
    waste, section 4(f) lands and surfer water quality.
    Veteran's Memorial Drive Overpass, Mount Vernon, Ill.
    Environmental scientist responsible for preparing the anvironmental
    class of action determination
    (EGAD)
    fur
    a
    new
    roadway overpass
    at
    Interstate
    57164 and
    Veteran's
    Memorial Drive. Resource
    impacts included forested
    wefnx:ls, a
    re '
    ntiat displacement.
    agricultural conversion, and a surface water
    crossing,
    Located
    a
    wetland :mitigation site and
    developed a wetlands compensation
    plan for 12 acres of wetland impacts.
    Fairfield RoadfOltmer Road grade
    a#on, Lake
    county,
    ill.
    Environmental scientist
    involved
    in
    conducting
    a
    wetlands
    determination survey,
    air
    quality
    and
    r
    analysis,
    floristic quality
    assessment acrd tree survey, a
    habitat coverage;
    and
    prepared the environrr*ntal survey request
    for a
    proposed grade
    separation
    at the intention of Fairfield and Gilmer roads. Utilized
    GIS and GPS technology for
    environmental resource data
    gathering
    and mapping.
    MaccArthur
    Boulevard extension, Springfield, Iii.
    Environmental
    scientist
    responsible for preparing
    the resource impacts
    for
    an
    environmental class of action determinakoon
    (EGAD) docent
    fix
    the MacArthur
    Bouteaarti extension projea The
    smerd
    included
    wetland and strearn crossing impacts,
    threatened species
    habitat concerns, and the
    preparation of a programmatic
    section
    4(f)
    evaluation for a public recreational facility.
    Chicago Region Environmental and Transpodation
    Efficiency
    (CREATE) Program, Chicago, Ill. Environmental
    scientist
    responsible for
    assessing
    the
    environmental impacts for five
    railroad/highway improvement
    projects within the
    beltway corridor
    of Chicago.
    Each project required the prepay*tion
    of
    an
    environmental class of action determination
    (EGAD) document for
    the FHWA. Illinois
    Department of Transportation, and various
    railroad
    companies.
    Rock Creek
    Public Seer Dishict, tm#wdai, Into.
    Laboratory
    ckrector. Created and managed
    the wastewater oratory for the
    District
    which treated a total of twit MGD of
    wastewater in Jefferson
    County. Operated
    and
    troubisshooted
    several treatment
    facilities
    including
    contact stabilization. oxidation
    ditch, extended aeration,
    sand filter,
    and
    lagoon
    systems. Managed regulatory tastes of
    NPDES permit renewal applications
    anti
    reporting
    requirements,
    s
    ludge reporting,
    biosoficfs
    tend
    application,
    and lagoon
    closure
    c ompl
    iance.
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    IM 1:106,600 M F 1m WK'OY6 -
    u. wnab.w sa s
    aw.
    M jkojL
    CC
    " podswo d s,".
    IML 2006
    Electronic Filing - Received, Clerk's Office, October 20, 2008

    I, Christine
    G.
    Zeman,
    the and
    FILED
    ed, certify
    that
    I have served the attached PRE-
    ONY OF DAVE FARRIS, IN SUPPORT
    OF
    PROPOSED SITE
    SPECIFIC
    NY
    FINIGAN,
    IN SUPPORT
    OF
    PROPOSED S
    ULE; PRE-FILED TESTIMONY
    OF DOUG BROWN,
    IN SUPPORT OF
    E;
    PRE-FILED TESTIMONY
    OF DON SCHILLIP
    SUPPORT OF PROPOSED S:
    BROWN,
    IFIC RULE; PRE-FILED
    TESTIMONY OF WILL
    PROPOSED SITE SPECIFIC RULE, PRE-FILED
    TESTIMON
    ITE SPECIFIC RULE; and
    PRE-
    F JEFF
    BUSHUR, IN SUPPORT
    OF
    PROPOSED SITE
    SP
    E, 'upon:
    Mr.
    John
    Thciri;iult
    Albert F. Ettirý ,,cr, Es
    lcrl.. ,,fth( hoard
    for Prairie I?i\, -I
    11iflois
    PO!liIýýi-,,
    Conir-[ Poard
    c/o 1-n-.
    iromw
    in,d Law a
    R. I hi iiý[ý.;w t ý:i,iý r
    `?5 f :,ýf
    l (
    Ipl.-1
    .--L>'_t
    Si;ii"
    ;unc 11-500
    I1lino
    I
    llfi-ý cl'G:
    ,
    lpc,o
    ogan-Wilkey, Assistant Counsel
    of Legal Counsel
    Illinois Environniental Protection
    Agency
    1021 North Grand Avenue East
    Post Office
    Box 19276
    Chicago,
    Illinois
    62794-9276
    Marie E. Tipsord
    Illinois Department of Natural Resources
    Illinois
    Pollution Control Board
    I Resources Way
    James R. Thompson
    Center
    524
    S. Second Street
    100
    West
    Springfield, Illinoi
    00
    inois
    60601
    tes Mail, postage prepaid,
    in Springfield, Illinois
    on October 20, 2005.
    Lay: /s/
    I_
    1ýri
    s,
    Cj. U(,nuin
    i )fan
    / NOF-COS
    -- Pre-Filed Testimonies
    Electronic Filing - Received, Clerk's Office, October 20, 2008

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