BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

PRN Notice of Filing Jan. 29th
PRN boron Comments Jan 29 2009 jad
PRN Certificate of Service Jan. 29th
PRN Service List Jan. 29th

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

PROPOSED SITE SPECIFIC

)

RULE FOR CITY OF SPRINGFIELD,

)

ILLINOIS, OFFICE OF PUBLIC

)

UTILITIES, CITY WATER, LIGHT

)

AND POWER AND SPRINGFIELD

)

PCB No. 2009-008

METRO SANITARY DISTRICT

)

(Rulemaking-Water)

FROM 35 ILL. ADM. CODE

John Therriault, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph St., Suite 11-500

Chicago, IL 60601

Marie Tipsord, Hearing Officer

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph St, Suite 11-500

Springfield, Illinois 62705-5776

Persons included on the attached

SERVICE LIST

PLEASE TAKE NOTICE that the Prairie Rivers Network today has electronically filed

COMMENTS OPPOSING PROPOSED SITE-SPECIFIC BORON STANDARD FOR CWLP &

SMSD in R2009-008, a copy of which is herewith served upon you.

Respectfully Submitted,

Traci L. Barkley

Water Resources Scientist

Prairie Rivers Network

1902 Fox Drive, Suite G

Champaign, Illinois 61820

(217) 344-2371

DATED: January 29

, 2009

Electronic Filing - Received, Clerk's Office, January 29, 2009

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

PROPOSED SITE SPECIFIC

)

RULE FOR CITY OF SPRINGFIELD,

)

ILLINOIS, OFFICE OF PUBLIC

)

UTILITIES, CITY WATER, LIGHT

)

AND POWER AND SPRINGFIELD

)

PCB No. 2009-008

METRO SANITARY DISTRICT

)

(Rulemaking-Water)

FROM 35 ILL. ADM. CODE

)

SECTION 302.208(g)

)

PRAIRIE RIVERS NETWORK’S COMMENTS OPPOSING PROPOSED SITE-

SPECIFIC BORON STANDARD FOR CWLP & SMSD IN R2009-008

The Prairie Rivers Network hereby files comments regarding R2009-008:

Prairie Rivers Network (PRN) hereby submits these comments in opposition to the City

of Springfield City Water, Light and Power’s (CWLP) and Springfield Metro Sanitary

District’s (SMSD) Petition for Site Specific Rule (the Petition) to establish an alternative

water quality standard for Boron. Prairie Rivers Network is the state affiliate of National

Wildlife Federation, a non-profit organization that strives to protect the rivers, streams

and lakes of Illinois and to promote the lasting health and beauty of watershed

communities. Much of our work focuses on how policies such as the Clean Water Act

and Safe Drinking Water Act are used in Illinois - laws intended to protect our waters,

our environment, and, ultimately, our health. PRN opposes the Petition for the following

reasons:

A. Petitioners Have Failed to Demonstrate That Treatment of Boron to Meet

the Illinois Water Quality Standard is Technically Infeasible

The burden is on the Petitioners to demonstrate that they are unable to meet the boron

water quality standard due to technical infeasibility.

35 Ill. Adm Code §§ 102.202 and

102.210.

This burden has not been met. As demonstrated below, there are treatment

alternatives that are technically feasible.

Electronic Filing - Received, Clerk's Office, January 29, 2009

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Alternative 1: Dry ash disposal at facilities currently discharging to Sugar Creek has not

been given due consideration as an alternative to proposed site specific rule.

The existing ash ponds, both Dallman Ash Pond and the Lakeside Ash Pond, at the

CWLP facility have been discharging under an adjusted standard of 11 mg/L since 1994.

The boron source for those discharges is due to coal ash from wet ash handling and

disposal and the flue-gas desulphurization (FGDS) blowdown waste stream. In 2003, a

selective catalytic reduction (SCR) system was added, resulting in increased

concentration of boron (and other pollutants) in the wastewater. The addition of this

increasingly concentrated wastestream plus the pollutants already in and being added to

the ash ponds have been causing violations of the NPDES boron permit limit and in-

stream water quality standards. The FGDS wastestream is now proposed for transfer to

Springfield Metro Sanitary District’s (SMSD) Spring Creek Facility. CWLP has the

option of switching to dry ash handling and disposal, which would save unspecified, yet

great, amounts of power plant waste from entering the Sugar Creek and Sangamon River

system. Page 92 of Hanson Engineering’s technical support document (TSD) (included

in petitioners’ initial filing) explains that conversion to dry ash handling could eventually

reduce total boron loading to the Sangamon River.

The Petition states that switching to dry ash disposal will not affect boron concentration

in the FGDS stream. True, but by reducing or eliminating the amount of boron and other

pollutants in the ash ponds that is eventually flushed to Sugar Creek, the overall amount

of boron going into the Sangamon River is reduced. A switch to dry ash disposal and

clean up of the ponds would allow the FGDS wastestream to meet the adjusted standard

already granted for Sugar Creek. Moreover, switching the CWLP facilities to dry ash

handling and disposal could ultimately reduce loading to the Sangamon of several

additional pollutants.

Besides the obvious problem with high boron concentrations and loading, power plant

waste in the form of fly ash, bottom ash and scrubber sludge contains concentrated levels

of contaminants like arsenic, mercury, chromium and cadmium that can damage the

nervous systems and other organs, especially in children. Further, these wastes have

Electronic Filing - Received, Clerk's Office, January 29, 2009

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degraded our public ground and surface waters impacting many uses including

consumptive, agricultural, industrial and environmental. Studies have also documented

multiple developmental, physiological and behavioral abnormalities in many species of

amphibians and reptiles inhabiting wetlands near coal ash disposal sites.

It appears that CWLP may have intentionally foreclosed the option of dry bottom ash

handling. Hanson’s Technical Support Document (TSD) refers to Burns’ (New

Generation Project Water Study, (2005), (Attachment B to Petitioners Post-Hearing

Document Submittal) conclusion that dry fly ash handling is costly, and dry bottom ash

handling is “not favored” due to lack of space. However on p.40, Burns notes that space

requirements could be an adverse factor in planning for the new unit. Note, however, that

the Lakeside unit is being demolished, and that the water treatment plant is being

massively renovated, especially the pumphouse, possibly opening new opportunities for

locating equipment for dry bottom ash. Burns also notes that earlier studies (Sargent &

Lundy 2003, and Hanson 2004

)

disregarded the possibility of pumping ash pond

discharge back to the lake or to the power plant, because it contained the extremely high-

boron FGDS stream. Burns recommended treating the FGDS wastestream separately

(brine concentrator/spray dryer) thus making pond discharge clean enough to recycle or

re-use.

Burns proposed two other options (4 and 5) that would, respectively, recycle or re-use

sluice water. Option 4 would recycle the bottom-ash sluice water, as originally suggested

by the S&L report as a feasible alternative to dry bottom ash handling. Recycling would

increase the concentration of the small fraction discharged as blowdown. Instead of

discharging the blowdown into ponds, it could be used in the FGDS. Option 5 would

pump the sluice water back to the plant for pretreatment, and then use it (instead of raw

lake water) to evaporate in the new Unit 4 cooling tower. These options are viable and

must be considered by CWLP.

Option 5 might occasionally need to discharge to ponds during rare Unit 4 outages,

unless the pretreated sluice water could be used elsewhere on the site or stored

Electronic Filing - Received, Clerk's Office, January 29, 2009

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temporarily. These possibilities led Burns to refer back to earlier Hanson and S&L

studies that discussed groundwater contamination at the unlined ash ponds. For purposes

of broadening the scope of the interrelatedness of these choices with protection for more

than just the 100 miles of river at issue, we include the following from Sargent and

Lundy, p 6-5 (2003) (Attachment C to Petitioners’ Post-Hearing Document Submittal).

Burns notes on page 32 that boron leaching from ash ponds could still be a problem

unless all fly ash sluicing is terminated. Continuing on p. 36, Burns notes that Hanson

and S&L studies refer to possible need for “repermitting or lining” the ash ponds to

comply with groundwater standards if, for any reason, concentration in sluice water

should increase. This could occur as, for example, a result of greater water recycling and

concentration of the ash pond water.

As expressed at the December 16

hearing, PRN is concerned that there might be a loss

of boron and other dissolved pollutants through the groundwater which would create a

lower effluent concentration from the ash ponds. If this is the case, then the values used

in modeling and evaluating boron mitigation and treatment options might be skewed and

ultimately underestimated. Additionally, this would allow an artificial estimate of

loading of boron and other pollutants to Sugar Creek and the Sangamon River.

In addition to keeping many pollutants out of the Sangamon River system, the dry ash

alternative would save more than 4 MGD of raw water now being used to sluice ashes

from existing plants. We have learned from the Final Environmental Impact Statement

(Section 2.2.6.1) for the proposed dam and reservoir also known as Hunter Lake, that

nearly 3.3 MGD is lost from CWLP’s unlined ash ponds due to evaporation and seepage

Electronic Filing - Received, Clerk's Office, January 29, 2009

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into the ground. The water seeping into the ground is likely draining towards

groundwater and Sugar Creek, thereby contributing to increased boron concentrations

and loadings to water resources.

Finally, as noted in the transcript for the December 16th hearing (p. 16-18), several other

coal-fired electric generating stations in Illinois sell their coal combustion waste to be

used as beneficial by-products. Currently, CWLP sells 85% of their ash from Unit 33 for

fill material on construction projects and 85% of the ash from Units 31 and 32 for use by

asphalt and roof shingle companies. The remaining 30% of the total ashes sluiced to the

ash ponds are not currently considered usable. When asked why the remaining material

was not considered usable, Mr. William Murray explained that local markets did not

exist. PRN would like to see the Board encourage or promote CWLP to identify markets

that could use the remaining 30% of generated ash waste. Not only would this cost

nothing for CWLP, it would actually generate funding for other projects at the facility,

possibly appropriate boron treatment technology.

Alternative 2. The use of brine concentrator/spray dryer equipment for a zero liquid

discharge from the CWLP facilities has not been adequately considered.

CWLP abandoned equipment purchased that would have concentrated and dried the brine

solution, ultimately sending the pollutants to a landfill. Reasons cited include high cost,

difficult disposal of solid waste generated and new application of technology. These

reasons are unsubstantiated by the Petitioner and there is evidence that the technology

remains a feasible alternative. In a letter dated December 29, 2006 from William A.

Murray, Regulatory Affairs Manager for the City of Springfield to Albert Ettinger, Senior

Staff Attorney for Environmental Law and Policy Center, Mr. Murray states “Burns and

McDonnell’s study provided a recommendation to CWLP to pursue a brine

concentrator/spray dryer system for the treatment of wastewater from the new and

existing plant facilities. Though this system has a slightly higher capital cost over the

other technologies, the

proven

(emphasis added) application coupled with the more

simple operation would provide a more effective and reliable system for treating

wastewater from the plant facilities.”

Electronic Filing - Received, Clerk's Office, January 29, 2009

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In 2005, CWLP purchased the brine concentrator, spray dryer and related components

from Aquatech for $7M. This equipment would remove the salts (including boron) from

the wastestream by first concentrating it (brine concentrator stage) and then evaporating

the water out of it (in spray dryer). At one point, Aquatech recommended using a

softener/crystallizer, as used in several plants located in Italy, which would replace the

spray dryer and work to precipitate the salts and squeeze the water out. This process

produces a solid waste that is relatively easy to handle and very pure water that is then

recycled to the power plant. It is not clear why CWLP chose the energy-intensive spray

dryer option for their second stage when the same vendor was designing plants elsewhere

in the world to use the softener/crystallizer option. It is our understanding that the

crystallizer option is cheaper at the second stage, but it does requires pre-treatment

(softening) of the FGDS waste stream before it enters the first stage (brine concentrator).

CWLP already conducts conventional treatment (lime and soda ash softening),

converting the calcium salts in the purge water to sodium, thus paving the way for

treatment in the brine concentrator/crystallizer system.

Petitioners claim that use of the Aquatech equipment is a new application of the

technology and is yet unproven. On the contrary, the equipment is being used

successfully at five power plants in Italy and is scheduled for one additional facility in

Italy and for Kansas City Power & Light (KCPL) in 2009. Although the Petition states

that brine concentrators have not been used to treat an FGDS stream, these facilities have

the same SCR/FGDS technology as CWLP. In fact, a paper demonstrating the technical

feasibility of the Aquatech alternative for treating FGDS wastewater from coal-fired

power plants was presented at the International Water Conference in San Antonio in

October of 2008. The submitted abstract states the following:

Zero Liquid Discharge Systems Installed for ENEL Plants in Italy

M. N. Rao, Aquatech International Corporation (

Canonsburg, PA, USA

);

Sergio Donadono, ENEL (

Milano, Italy

)

Aquatech International Corporation was awarded the contract to supply and install

ZLD systems to treat FGD waste water from five coal-fired power projects for

ENEL (Ente Nazionale Energie Electtrica) in Italy. Each plant receives a wide

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variety of coal that throws challenges in the treatment of this wastewater. Some of

the challenges include high concentrations of suspended solids, dissolved ionic

impurities e.g. calcium, magnesium, sulfate, heavy metals and chloride ions as

well as large fluctuations in the FGD wastewater blowdown quantity and quality.

Company has supplied the systems with softening the FGD waste stream as a

pretreatment step before it is routed into the ZLD systems. This paper discusses

design considerations and concept applied and compares the initial operational

data from the plants commissioned.

At the time of this letter, the formal published paper was not available for distribution.

A webinar by Devesh Mitall of Aquatech International entitled “FGD Purge ZLD”

(attached as Exhibit 1) also demonstrates the technical feasibility of this alternative.

Items to note include the following:

Slide 4: Four coal fired power plants in Italy have converted to a “zero liquid

discharge” system. One more is under construction. Each facility has employed

a brine concentrator and crystallizer designed by Aquatech.

Slide 5: The range of concentrations of boron for these facilities includes the

approximate boron concentrations of 450ppm produced by CWLP facilities.

Slide 17: Pictures provided show that the byproduct can be handled, bagged and

disposed of, in contrast to the opinion expressed by CWLP’s Doug Brown at both

the November 3 and December 16 hearings (transcripts, p. 51 and p. 36,

respectively)

Slide 23:

Burns and McDonnell have served as consultants to Kansas City Power

& Light (KCPL) and have recommended the brine concentrator system that will

be installed at the new facility going on line in 2009.

Several other documents describing Aquatech’s technology are attached as Exhibits 2, 3,

4, 5, and 6. Other companies are also designing plants to use this technology in Italy and

elsewhere, for example HPD, a Veolia Water Solutions & Technologies company based

in Plainfield, Illinois:

Shaw, William A. 2008. “Benefits of Evaporating FGD Purge Water.”

Power

. (March). 59-63. Available online at:

http://www.powermag.com/powerweb/archive_article.asp?a=60-

F_WM&y=2008&m=march.

Electronic Filing - Received, Clerk's Office, January 29, 2009

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We encourage Petitioners and members of the Illinois Pollution Control Board to contact

the authors of these papers (W. A. Shaw, M.N. Rao or D. Mitall) with additional

questions regarding the application of this technology at the CWLP Dallman facility.

B. Petitioners Have Failed to Show that Treatment of Boron to Meet the Illinois

Water Quality Standard is Economically Unreasonable.

Petitioner must provide economic justification for the proposed rule as well as a

demonstration that the general rule is economically unreasonable.

35 Ill Adm Code §§

102.202 and 102.210.

As shown below, Petitioner has failed to meet these burdens and

the Petition must be denied.

The long term operating expense of the proposed transfer and acceptance of the

FGDS wastestream to the SMSD Spring Creek Plant is the second most expensive

option and has virtually no realized environmental protection.

SMSD has contracted with CWLP to accept the FGDS wastewater stream, at a cost to

CWLP of $100,000/month, provided that its acceptance does not upset normal plant

operations. (Petition, p. 36) The estimated capital cost of the pretreatment system

including the pipeline to transfer the pretreated FGDS wastewater and chemical feed

system(s) to control odor to the SMSD Spring Creek Plant is $15.5 million. The annual

operating and maintenance cost, including the monthly payment to SMSD is $1.6 million.

Assuming that the monthly payment to SMSD will remain fixed and other annual

operating and maintenance costs will escalate by $10,000 per year, a pretreatment system

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). (TSD, p.18) Comparing these

values with those presented in Table 6-2 from the TSD entitled “Cost of Treatment

Alternatives for the Removal of Boron” we see that the alternative proposed by this

petition is the second most expensive option and does not actually treat or remove any

pollutants other than suspended solids.

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CWLP has squandered $7M in equipment purchases (now abandoned) and

consulting fees to arrive at their ultimate solution of dilution.

In December of 2005, CWLP entered into a contract with Aquatech International

Corporation to provide equipment and technology for the wastewater treatment process at

CWLP’s power plant. CWLP requested a brine concentrator and spray dryer system and

was informed by Aquatech that high energy consumption of the spray dryer would

impact operating expenses. Aquatech proposed the installation of a crystallizer after the

brine concentrator instead of a spray dryer to address calcium chloride issues and produce

a solid waste stream that is easier to handle. According to Aquatech, the crystallizer could

significantly lower operating costs and allow CWLP to recoup the cost of the crystallizer

within a few years. Despite this recommendation, CWLP did not purchase the crystallizer

and instead moved forward with bidding for the brine concentrator and spray dryer.

Further, the equipment package (supply only) presented to CWLP by Aquatech was only

approximately 15% of the capital cost of $50 million that CWLP has cited in support of

this petition.

3) Failure to implement water conservations measures at CWLP’s power generation

facilities results in increased loadings of boron and unnecessarily increases the cost of

boron treatment.

Water conservation at CWLP’s power generating facilities would allow CWLP to meet

the water quality standard for boron. By conserving water as suggested by the consultants

Sargent & Lundy and Burns & McDonnell, Petitioner CWLP could substantially reduce

its boron loadings to the Sangamon River system and eliminate the need for an adjusted

standard. Burns’ analysis of the water conservation benefits of alternative ash handling

technologies was biased by their assumption (apparently at CWLP’s direction) that

conserved water was worth only $1.39/million gallons, which appears to be the cost of

pumping it out of Lake Springfield (Burns, p. 7-2). Elsewhere in their report Burns noted

that the benefit of water conservation would be greater if additional supplies had to be

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procured. In fact CWLP has for 20 years been seeking a Clean Water Act permit to

spend more than $108M on a supplemental water supply.

C. Petitioners Have Failed to Provide an Accurate Assessment of the

Environmental Impacts of the Proposed Site-Specific Standard for Boron.

Petitioner must provide sufficient environmental justification for the proposed site-

specific rule in accordance with

35 Ill. Adm. Code § 102.202

, including a detailed

assessment of the environmental impacts of the proposed change. As shown below, the

environmental impacts will be far greater than revealed by Petitioner, making the

proposed rule unjustifiable.

1) FGDS wastestream will contain more than just boron.

First, it is important to note that all four stream segments of the Sangamon River at issue

in this Petition are considered impaired by the Illinois EPA and as such are unable to

support their designated uses. Of particular concern is stream segment E-26, impaired for

the designated use of aquatic life due to excessive levels of boron, total suspended solids,

total dissolved solids, silver, total phosphorus, total nitrogen, fecal coliform and

polychlorinated biphenyls (PCBs). Segment E-26 is the Sangamon River from the South

Fork of the Sangamon River to Spring Creek. This is the segment immediately

downstream of where Sugar Creek, also impaired, empties into the South Fork of the

Sangamon River.

Second, the discharge will contain a plethora of pollutants in addition to the boron

loadings. According to the Petition, “The FGDS blowdown is a means to remove

chlorides and other contaminants that would otherwise buildup in the system and cause a

corrosive environment in the stainless steel towers.” (p. 15). We know from other similar

facilities and from the Petitioner’s technical support documents that the FGDS

wastestream will contain boron, sulfates, TDS, TSS, nitrate, ammonia, selenium, iron,

cadmium, mercury, and manganese. Despite the presence of these additional pollutants,

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Petitioners have stated that the wastestream from CWLP will not receive any additional

treatment at the Springfield Metro Sanitary District Spring Creek Facility, other than

dilution.

See

December 16, 2008 Transcript of Hearing IPCB, pp. 41-43.

2) Organisms sensitive to boron are present in the receiving stream and must be

protected.

Aquatic plants play an important role in providing habitat, forage and breeding protection

for several types of aquatic residents in river systems. Although the Petitioners have

conducted a macrophyte survey at three locations within the 100 mile section of the

river(s) for which the adjusted boron standard is proposed, it appears that the survey does

not provide sufficient study of the affected stream and river beds or of the existing

macrophyte stands. The macrophyte study was conducted at Illinois EPA’s established

monitoring sites E-24, E-25 and E-26 located at Petersburg, Oakford and Riverton

respectively. A review of the material submitted in support of this Petition does not make

clear how much square footage of the stream and river beds were examined. It is

important to note that even if 5280 linear feet (1 mile in length) were surveyed on both

sides of the river, which is extremely doubtful, only 3% of the entire study length would

have been surveyed (3 miles out of 100 miles). Further, without a more thorough

examination of what other habitat, forage materials and breeding sites are available for

aquatic life to utilize, it is impossible to determine how critical a role existing macrophyte

stands play in the growth, reproduction and survival of the macroinvertebrates, mussels,

reptiles, amphibians, mammals and fish currently residing there.

In addition, there is no evidence that Petitioners conducted a wetland survey in the 100

mile length of river proposed for increased boron concentrations. Considering that many

plants are sensitive to low levels of boron, it is essential that Petitioners complete such a

survey to accurately determine the impact of boron on wetlands and to avoid their illegal

destruction.

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In 1994, an adjusted standard of 11mg/l was granted for CWLP and SMSD process

discharges to Sugar Creek for effluents high in boron, among other pollutants. This

adjusted standard has been in existence for nearly 15 years and provides an opportunity to

study the biota quality and quantity prior to and since the adjusted standard was granted.

When asked if the Petitioners or the Illinois EPA had conducted such a study to help

inform assumptions and predictions likely to result from the higher concentrations of

boron, etc in the Spring Creek and Sangamon River system from an adjusted standard,

the reply was no.

Further, Mr. Mosher of IEPA asserted that, because of the permit violations and levels of

boron exceeding 11mg/L to Sugar Creek, that any results of such a study would not be

comparable to anticipated conditions if an adjusted standard of 11mg/L were granted for

Spring Creek. After reviewing the concentrations of boron for segment EOA-01 on

Sugar Creek (IEPA’s Post-Hearing Document Submittal), downstream of Outfalls 003

and 004, Mr. Mosher’s opinion is unfounded. Of 72 values provided for the period

spanning January 1999 to February 2007, only six values exceeded 11.0mg/L and were as

follows: 14.0mg/L, 12.0mg/L, 15.0mg/L, 13.0mg/L, 16.0mg/L, 17.0mg/L. The average

concentration of boron during this period was 4.71 mg/L.

The Petition (p. 27) claims that “The

Technical Support Document for Petition for

Adjusted Boron Standards for Sugar Creek and the Sangamon River

(Hanson Engineers

Incorporated, 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 study demonstrates the toxicological effects of boron at

varying concentrations on the biological community of an aquatic ecosystem.” This

report does not demonstrate

anything, however, it only predicts. Now, Petitioners and the

Agency have the opportunity to examine whether their predictions played out as expected

in order to inform the Petition at hand and its anticipated outcome. To not do so is

unscientific and irresponsible.

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Boron water quality standard should be upheld and applied as enacted, until a

literature review and additional toxicity work is completed and determines that

existing uses can be protected with a revised standard.

IEPA personnel have asserted that the water quality standard is overprotective for aquatic

life and that the Illinois WQS was set at the level of 1 mg/L to protect irrigated crops

sensitive to boron. There are a number of problems with this argument. First, the

rationale behind establishing the water quality standard for boron has not changed.

Boron is an essential nutrient required especially at the early stages of the plant's growth.

At slightly higher concentrations, more than about 0.3 mg/L in the irrigation water, boron

can be toxic to boron-sensitive plants. Boron is adsorbed by the oxide surfaces of

particles of soil and is not readily leached, and may accumulate to toxic levels in the root

zone. Agricultural crops such as stonefruit trees, grapes, garden vegetables, berries,

wheat, beans and corn (p. 219, Table 3 in Boron and Its Role in Crop Production

Umesh C. Gupta, available online at http://books.google.com/books?id=TmusnFj-

0zoC&printsec=frontcover&source=gbs_summary_r&cad=0), are still sensitive to boron,

still grown in Illinois and still have the potential to be irrigated with Sangamon River

water. In fact, in consideration of future modeled scenarios in which irrigation may

become critically important as a result of climate change, we ought not to foreclose the

option of irrigating from 100 miles of river in some of the state’s most important

farmland.

Second, the Illinois EPA has announced that they will be contracting with the Illinois

Natural History Survey to further develop the boron toxicity database with the intention

of revising the boron standard. We do not agree with the Agency that the existing

toxicity database summarized by CWLP is adequate for the site-specific demonstration,

and maintain that the requisite information for deriving a revised water quality standard

must apply in all instances of a standard change, site-specific or not.

Prairie Rivers

Network asserts that until the Illinois EPA has completed their literature review and the

INHS has completed their additional toxicity work, the boron water quality standard

should be upheld and applied as intended.

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It should be noted that the federal criteria for boron is 750ppb. The Ministry of Water,

Land and Air Protection for the Canadian Council of Ministers of the Environment

(CCME) have set the ambient water quality guideline to protect freshwater life at 1.2

mg/L and to protect the water use of irrigation between 0.5 mg/L and 6.0 mg/L

(http://www.env.gov.bc.ca/wat/wq/BCguidelines/boron/boron.html). The State of

California publishes a notification limit of 1 mg/L for boron. The USEPA is considering

boron as a candidate of future regulation (EPA, 2005) and currently recommends average

lifetime exposure to boron be kept below a concentration of 0.6 mg/L (EPA, 1992).

D. The Illinois Pollution Control Board Cannot Grant a Site-Specific Water Quality

Standard That is Inconsistent With Federal Law

The Petition must demonstrate that the Board may grant the requested relief consistent

with federal law.

35 Ill Adm. Code § 102.210 (e).

Revisions to or adoptions of new water

quality standards must be submitted to the Administrator of the United States

Environmental Protection Agency (EPA) for review and approval in accordance with the

Clean Water Act.

33 U.S.C. § 1313(c), 40 C.F.R. § 131.20(c) (2)

A water quality standard

is a legally binding norm that describes the desired ambient condition for a waterbody

and includes “the magnitude (e.g. concentration), duration, or frequency that the State

would use to determine whether a waterbody is attaining any applicable water quality

criteria.

EPA Region 10. “Water Quality Standards: Authorities, Definitions &

Considerations.”

(January 13, 2009).

Clearly, a site-specific standard for boron is a water quality standard. As such, it must be

submitted to EPA for review and approval in accordance with the federal Clean Water

Act and its implementing regulations. A new or revised water quality standard has no

effect until EPA approves the change.

40 CFR § 131.21(c)

. Should the Board grant this

Petition, the change in water quality standards must then be submitted to EPA for its

review and approval.

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* * * * * PC #4 * * * * *

In addition, while the Board is not charged in this proceeding with determining whether

the necessary NPDES permits will be granted, the whole point of obtaining an adjusted

standard is to allow Petitioners to obtain the permits and to discharge additional

pollutants in accordance with those permits. Because Petitioners will be seeking to

discharge additional pollutant loadings into the Sangamon, the additional loadings of

boron and other pollutants must comply with the state’s antidegradation regulations.

See

35 Ill Adm. Code

302.105 (requiring a demonstration that existing uses will be fully

protected.)

35 Ill Adm.Code § 302.105 (c) (2) (B).

As noted above, however, Petitioners

have inadequately demonstrated that the increased loadings of boron will protect the

existing uses in the Sangamon River. At this point, Petitioners have not even fully

accounted for the existing uses in the receiving streams. Both federal law and the Illinois

Administrative Code call for a detailed assessment of existing uses and the environmental

impact of the requested relief on those uses. The requested relief cannot be granted until

Petitioners can show the full extent of those impacts and provide a scientifically

supported assurance that those uses will be protected despite the increase in boron

loadings.

Federal law also prohibits a new discharge of pollutants to impaired water bodies where

the discharge would cause or contribute to a violation of water quality standards.

C.F.R. § 122.4 (i)

. In this case, CWLP is seeking to send a new wastestream to SMSD’s

sewage treatment plant. As noted above, that wastestream would contain pollutants such

as TSS, TDS and ammonia that will ultimately be discharged to the Sangamon River, a

river that is already impaired by TSS, TDS, total phosphorus and total nitrogen. Adding

additional loadings of TSS, TDS and a deoxygenating waste such as ammonia will place

additional strains on an already impaired water body that could cause a violation of water

quality standards. By granting the site-specific standard requested without further

evidence of the impact on water quality, the Board would be setting the stage for a

possible violation of federal law. The requested relief should not be granted without

further study and assurances that the diverted waste stream will not cause or contribute to

the impairments in the Sangamon.

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Additionally, it is not clear how SMSD will be able to meet other parameters in their

NPDES permit with the addition of the FGDS wastestream. In March 2004, SMSD

informed CWLP that it would not accept the wastestream from CWLP due to high

concentrations of chloride. Nevertheless, the Petition (page 14) states that "pumping the

CWLP FGDS wastewater to the SMSD Spring Creek Plant is not expected to have any

effect on the Plant, other than the increase in boron concentration in the effluent.” Given

this discrepancy, we urge the IPCB to further investigate how the SMSD will be able to

meet their NPDES permit limit for chlorides of 500 mg/L (35 Ill Adm. Code

302.208)

with the additional wastestream.

Moreover, although SMSD now claims that CWLP’s 270,000 GPD wastestream will be

insignificant compared to the 20 MGD flowing through the Spring Creek plant, it will be

difficult to meet the proposed adjusted standard of 11 mg/L during times of drought when

enough water may not be available for dilution. CWLP’s proposed solution is to use

holding tanks. The Petition states CWLP proposes collecting the FGDS wastestream in

a 250,000 gallon influent holding tank. This tank will provide about 22 hours of holding

time for the wastestream, anticipated to be approximately 187 gpm. Though Petitioners

assert that it is not their burden to characterize drought conditions for the last 25 years

(December 16 hearing transcript, p. 33), we disagree. The most recent significant drought

for the Springfield area occurred in 1988-89, 20 years ago. Any plans to meet NPDES

permit conditions and water quality standards should take into account possible and likely

conditions. It is precisely during these drought conditions, when the proposed adjusted

standard for boron of 11 mg/L is unlikely to be met, that river water will be used for

irrigating adjacent agricultural fields.

Petitioners further state that the system can be cycled through or cycled up as the water is

reused in the process to allow for an additional two days’ worth of storage time. When

wastewater is recycled and reused, any constituents in that water would continue to be

concentrated to greater concentrations with each cycle. Further, drought conditions often

persist for weeks, if not months, so an additional two days worth of storage hardly seems

adequate. Another potential option offered by CWLP was to reduce flow of water

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

through the power plant. Droughts, however, typically occur in the summertime, when

temperatures are high— precisely the time of peak power production and the greatest

time of need for cooling of the power plant rendering this option impracticable.

E. CWLP should have anticipated and remedied this problem years ago.

Finally, Prairie Rivers Network would like to call attention to the fact that the problem of

high concentrations of boron in the flue gas desulphurization blowdown wastewater

should have been anticipated at the time additional air pollution control technology, such

as the selective catalytic reduction system components, was installed on the Dallman

units. CWLP was provided with enough information to be able to understand, prior to

upgrading the air emissions control equipment, what had been released into the air and

what would, after installation of the SCR’s, be collected and disposed of in the

wastewater. Further, the concentration of boron, along with many other pollutants, has

been monitored on at least a monthly basis for Outfalls 003 and 004 to Sugar Creek since

1993. CWLP was equipped with the necessary information to be able to anticipate that

boron concentrations in both the ash pond discharge and FGDS blowdown would exceed

the water quality standard and should have remedied this problem several years ago with

a more sophisticated (and less environmentally damaging) solution than dilution.

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

CERTIFICATE OF SERVICE

I, Traci L. Barkley, the undersigned, hereby certify that I have served Prairie Rivers

Network’s COMMENTS OPPOSING PROPOSED SITE-SPECIFIC BORON STANDARD

FOR CWLP & SMSD in R2009-008 upon:

Mr. John T. Therriault

Assistant Clerk of the Board

Illinois Pollution Control Board

100 West Randolph Street

Suite l1-500

Chicago, Illinois 60601

via electronic filing on January 29

, 2009; and upon the attached service list by depositing said

documents in the United States Mail, postage prepaid, in Chicago, Illinois on January 29

, 2009.

Respectfully Submitted,

Traci L. Barkley

Water Resources Scientist

Prairie Rivers Network

1902 Fox Drive, Suite G

Champaign, Illinois 61820

(217) 344-2371

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

SERVICE LIST- R2009-008

January 29

, 2009

Marie E. Tipsord

Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

Michael D. Mankowski

Assistant Attorney General

Office of the Attorney General

Environmental Bureau

500 South Second Street

Springfield, IL 62706

Joey Logan-Wilkey, Assistant Counsel

Illinois Environmental Protection Agency

1021 North Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

Springfield, Illinois 62705-5776

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Reality At

Presentation By

Devesh Mittal |&| Greg Mandigo

McIlvaine Webinar November 12

2008

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

“Ccrai”

A Solution To Pollution!

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

ENEL, Italy

Torrevaldaliga

Locations

LaSpezia

Fusina

Sulcis

Brindisi

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Enel

Locations

ENEL

Location

Power MW

(Wet FGD)

ZLD Cap.

in GPM

Date Stopped

Discharge

Brindisi

Fusina

Sulcis

LaSpezia

Torrevaldaliga

BC = Brine Concentrator FC = Crystallizer GPM = Gallons / Minute MW = Megawatt

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Total dissolved solids:

*dependent on usage of buffers like DBA or Formic acid

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Quality of coal

Make up water source

Scrubber design

Scrubbing agent composition

Scrubber additives (DBA, other organics)

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

FGD

Purge

Treatment

Treated

Wastewater

Discharge

Biological

Process (Aerobic

/ anaerobic)

Evaporator

Concentrate

Disposal on

Fly Ash

Crystallizer

Spray

Dryer

Zero

Liquid

Discharge

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Physical Chemical (Well Established)

Calcium Sulfate desaturation & clarification

Sulfide precipitation & clarification

Biological treatment (Developing)

Selenium & heavy metal reduction

BOD & or N reduction

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Is this really a complete solution?

Limited number of constituents reduced

High salinity still being discharged

What about tightening regulation?

Coal

Burning

FGD

Scrubber

Clean

Air!

Purge WW

Treatment

Clean

Water?

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Constituent Key Issue /

Discharge Limit

Impact by physical chemical or biological

treatment

Calcium

Scaling

Reduction by precipitation

Sulfate

Scaling w/hardness

Settling in clarifier w/hardness

No reduction; likely to increase

Mercury

Limits getting

stringent i.e. in ppt

Reduction possible; requires elaborate process

including ion selective ion exchange resins

Selenium

Limits getting

stringent i.e. ppb

Selenites can be reduced in physical chemical;

lower limits require biological treatment

Nitrates

Some cases have seen

3 ppm total nitrogen

Requires nitrogen reduction via biological

process; difficult in high TDS environment

Trace metals Site specific issues

Depends on the trace metal

Boron

Site specific issues

No reduction

TDS = total dissolved solids ppt = parts per trillion ppb = parts per billion

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Purge WW

Tank

Physic0/Chemico

+ Biological

Treatment

Liquid

Discharge

Purge WW

Tank

Physic0/Chemico

+ Zero Liquid

Discharge

Sludge

to landfill

Dilution Water

(for process control)

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Technology does not exist

Existing technology

Does not work

Is extremely expensive

Is difficult to operate

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Technology does not exist

Existing technology

Does not work

Is extremely expensive cost comparable to physico

chemical & biological treatment

Is difficult straight forward to operate

No liquid discharge; complete solution

Process simplicity; elimination of biological

treatment possible

N ily g i’i

biologist or biochemist to run the unit

Higher operating reliability

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Corporate social initiative (ENEL)

Permitting issues

Discharge not allowed

Discharge limits stringent or not achievable by physical

chemical or biological treatment

Waste water characteristics

Variation due to variety of coal used

Constituents not treatable by other processes e.g. boron

Cost of waste water treatment

Cost comparison with biological treatment

Capacity of waste water treatment unit

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Parameter

as ppm

Brindisi

Fusina

LaSpezia

Sulcis

Torrevaldaliga

Each power plant uses multiple sources of coal; worst value from several

coal values reported above for each parameter

Each ZLD plant designed for over 30,000 ppm TDS in feed

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Lime Clarifiers

Brine Concentrator

Crystallizer

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Belt Press

Sludge Handling

Sludge For Disposal

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Fusina

Sulcis

LaSpezia

Torrevaldaliga

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Coal

Imported from several countries

Variability in purge waste water

Evaporator

Operated in seeded slurry mode

WW feed variability managed by local operators

Sludge

Calcium carbonate sludge recycled to scrubber

Evaporator sludge

Approx. 85% plus dry solids

Non classified; disposed through authorized agency

Passed leachability (TCLP)

Distillate recycled to scrubber and cooling tower

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Requires prior experience

Careful consideration of waste water data

Proper selection of metallurgy

Proper selection of operating parameters i.e.

pH, concentration factors, etc.

Design safety margin important

Once properly designed,

operating issues are straight forward

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Clean tubes after 6 months of operation

Equipment operated by local operators

Operating parameter controls already set

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Aquatech evaporators in IGCC units

operating for 20 to 25+ years

North Dakota Gasification (Lurgi Process)

Tampa Electric (Texaco Process)

Demkolec IGCC (Shell Process)

Upcoming IGCC projects

CO2 capture retrofits or new units

Coal plant cooling tower ZLD

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Purge

Settling

Clarifier

Distillate

for reuse

Brine

Concentrator

Clarifier

Sludge

Concentrate

to fly ash

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

“Trly ar ”

Clean Coal

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Devesh Mittal 281.794.3113 or mittald@aquatech.com

Aquatech Technical Material

International Water Conference Papers

IWC 06 Hoskin & Mittal

IWC 06 Bjorklund

IWC 07 Mandigo

IWC 08 Donadono & Rao

Project profiles

Technical write ups and flow diagrams

Project specific design assistance

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation 2008 (DM Nov 10, 08)

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation

One Four Coins Drive; Canonsburg, PA 15317 USA

T: 724-746-5300 F: 724-746-5359 aic@aquatech.com

www.aquatech.com

PROJECT PROFILE SERIES #39

Coal Fired Power Plant Achieves ZLD

for FGD Wastewater

The Facility

Illinois’ City of Springfield’s Dallman Power Station’s

three coal-fired units and soon to be installed fourth unit,

are equipped with flue gas desulfurization (FGD) systems

(scrubbers) to control sulfur dioxide (SO

) emissions.

The Problem

A sharp increase in boron concentration in the FGD

wastewater required that The City of Springfield Office of

Public Utilities and the Illinois Environmental Protection

Agency develop a boron mitigation strategy to remove

the boron from the waste streams at the power genera-

tion facility. This meant including a new FGD wastewa-

ter treatment (Zero Liquid Discharge or ZLD) plant for

the power plant. The elevated boron levels are caused

from ammonia carryover due to the Dallman Unit’s

Selective Catalytic Reduction (SCR) systems’ nitrogen

removal process.

The Solution

In December 2005, Aquatech received a ZLD contract

for the mitigation of boron from the FGDWastewater

generated at the Dallman Power Plant from the City of

Springfield in Illinois.

Under this contract Aquatech will provide a ZLD

system comprising of 2 x 60% Brine Concentrators

(total treated flow of 240 gpm) followed by spray

dryers that will treat blowdown from the FGD scrub-

bers installed at the coal fired power plant. At full

load, the ZLD facility will treat wastewater generated

by the existing unit and the new one under construc-

tion.

The ZLD Evaporation System is a fully integrated

automated system incorporating a mechanical

vapor compression falling film seeded slurry brine

concentrator and a spray dryer system. The high

purity distillate produced in this system will be used as

makeup to the cooling tower or boiler feed water

treatment system.

The ZLD System is designed for automatic steady state

operation and will minimize operator attention. The

materials of construction have been selected to resist

corrosion and ensure a long plant life.

Features and Benefits of Aquatech Brine

Concentrator Design in FGD Service

Optimized Materials of Construction for FGD service

FGD Blowdown contains elevated levels of calcium

and magnesium chloride and other similar salts. As

these salts concentrate in an evaporator they be-

come increasingly corrosive because of which

the evaporator materials of construction need

to be upgraded to expensive materials such as

titanium and nickel based alloys. Aquatech has

provided an innovative design in these brine

concentrators. The design innovations limits the

concentration of chlorides within levels that

allow the use of more conventional materials of

construction.

Optimized Vapor Compressor for FGD Service

Another benefit of limiting the chloride concen-

tration in the brine concentrator is on the selec-

tion of vapor compressor. The vapor compressor

selected is less likely to be subjected to corrosive

conditions and vibration problems that could

exist in systems deployed in FGD service.

Superior Brine Distribution System

Aquatech’s

proprietary dual perforated plate distribution

system has a proven track record of superior flow

distribution of brine to the tubes practically

eliminating chances of tube plugging. Unlike

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

PROJECT PROFILE SERIES #39

Design Feed Chemistry

Flow Rate, gpm ........................................................... 200

Chemical Composition, m/l

Calcium, as Ca ............................................................ 8702

Magnesium, as Mg ...................................................... 1764

Barium, as Ba .............................................................. 1

Boron, as B ................................................................. 881

Sodium, as Na ............................................................. 159

Potassium, as K ........................................................... 53

Iron, as Fe ................................................................... 44

Bicarbonate, as HCO

........................................................................... 300

Chloride, as Cl............................................................. 15000

Sulfate, as SO

............................................................................................ 3525

Nitrate, as NO

............................................................................................ 98

Fluoride, as F .............................................................. 35

Total Dissolved Solids, mg/l .......................................... 30,561

Total Suspended Solids, mg/l ....................................... 206

Total Oil and Grease, mg/l ............................................ <1

pH ............................................................................... 7.3

Process Flow Diagram

individual tube inserts which routinely plug up in high

suspended solids brines like FGD blowdown,

Aquatech’s distributor assures uniform flow of brine

across the entire tube bundle and down the inside

wall of each tube.

Superior Mist Elimination System

Aquatech’s design

include mist eliminators that prevent droplets

containing concentrated chloride salts from pass-

ing into the vapor compressor thus preventing

pitting corrosion of compressor impeller and suc-

tion expansion joints. Aquatech’s unique design of

the mist eliminators provides easy access and

cleaning of internal sump mist eliminators eliminat-

ing the need for complicated shutdown of evapo-

rator equipment and the need to install temporary

scaffolding inside the sump.

Aquatech employs a proprietary two-stage external

mist eliminator using horizontal flow chevrons for

the brine concentrator which is very efficient at

eliminating brine droplets which become entrained in

the water vapor. The distillate produced typically

contains less than 10 ppm nonvolatile solids, even

with very high TDS levels in the evaporator sump. In

Aquatech’s brine concentrator design for FGD ser-

vice, the efficiency of the mist eliminator combined

with the low chloride salt concentration maintained

in the evaporator sump and high alloy construction

of the vapor compressor plus the ability to rinse the

compressor rotating assembly with water during

operation means that corrosion potential on the

vapor side of the evaporator is practically eliminated.

Inspection and access to the external type mist

eliminator is very straightforward as the entire mist

eliminator assembly is directly accessible from the

platform manway.

Wastewater

Feed

Preheater

Deaerator

Falling Film

Evaporator

Mist

Eliminator

Vapor

Compressor

2 x 60%

Solids

Spray Dryer

Bag Filter

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

The Solution

To overcome the problem, ENEL selected the Softening

–Evaporation – Crystallization (SEC) process to treat the

wastewaters and reuse/conserve fresh waters.

Aquatech supplied, installed, commissioned the ZLD

plant as an EPC contractor with local associates.

The SEC plant comprises of 2X50% Softener Clarifiers

(calcium reduction by soda ash dosing), 2x50% Falling

film type Brine Concentrators (each equipped with two

vapor compressors operating in series), 1x100%

Crystallizer (equipped with Thermocompressors) and

2x50% Belt Filter Presses. The plant also includes several

chemical dosing systems, storage tanks, pumping

systems, electrical works (MCC, cable trays, cabling

etc), Controls & Instrumentation.

The Zero Liquid Discharge (ZLD) plant is a fully integrated

automated system. The Brine Concentrators operate in

seeded slurry mode. Each Brine Concentrator is

equipped with external mist eliminator for ease in

maintenance. The Crystallizer operates in forced

circulation method.

The industrial grade soft water and high purity distillate

produced in the system will be used in the main power

plant.

PROJECT PROFILE SERIES # 51

ENEL Power, Italy – Brindisi Project – ZLD Plant for

FGD Wastewater Treatment

The Facility

The Brindisi Sud Power Plant is equipped with four coal-

fired units each of 660 Mwe capacity. Units normally

fire imported coal with < 1% Sulphur. The flue gases are

treated sequentially by SCR-DeNOx with ammonia as

reagent, High efficiency ESP to remove fly ash and

wet limestone gypsum forced oxidation DeSOx. Each

unit is equipped with a 2x50% DeSOx lines each with a

prescrubber for final dedusting and gas saturation and

an absorber. The blow down from both prescrubber

and absorber along with other wastewaters are sent

to a Wastewater treatment plant where in the first

stage lime and sodium sulphide are added to remove

metals; in the second stage ferric chloride is added to

remove suspended solids and in third stage hydrogen

peroxide us added to remove oxidizing agents. The

prescrubbers are fed with sea water and at the WWTP

the brine was treated and discharged into the

Adreatic Sea.

The Problem

Wastewaters from FGD treatment plant can no longer

be discharged into the sea due to tough Italian and

EU environmental regulations. In order to overcome

this major environmental problem, ENEL decided to

feed the prescrubbers with fresh and recirculated

waters and install the Zero Liquid Discharge (ZLD) plant

so that no industrial wastewater discharges are

allowed by the entire power plant.

Aquatech International Corporation

One Four Coins Drive; Canonsburg, PA 15317

T: 724-746-5300 F: 724-746-5359 aic@aquatech.com www.aquatech.com

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

PROJECT PROFILE SERIES # 51

PROCESS FLOW DIAGRAM

DESIGN FGD WASTEWATER ANALYSIS

Design Flow ............... 140 M3/hr

(PT Plant)

Calcium: ..................... 4200 ppm

Magnesium: …………..200 to 250

ppm

Potassium .................. Balance

Sodium: ...................... 1757 ppm

TSS ............................. 80 ppm

pH................................ 9.5 to 10

Bicarbonate ............... 80 ppm

Phosphates ................. 25 ppm

Chlorides .................... 22800 ppm

Nitrates ....................... 300 ppm

Sulfate………………….1700 ppm

SiO2 …………………….10 ppm

Aquatech International Corporation

One Four Coins Drive; Canonsburg, PA 15317

T: 724-746-5300 F: 724-746-5359 aic@aquatech.com www.aquatech.com

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation

One-Four Coins Drive; Canonsburg, PA 15317 USA t) 724 746 5300

f) 724 746 5359

www.aquatech.com

Zero Liquid Discharge System

Overview

The Aqua-Chem ICD Zero Liquid Discharge System is a fully integrated automated system incorporating a mechanical

vapor compression brine concentrator, a forced circulation crystallizer, and solids dewatering. High purity distillate

produced in this system can be used for cooling tower or boiler makeup water.

The Aqua-Chem ICD Zero Liquid Discharge System typically follows a reverse osmosis (RO) preconcentrator. High TDS

and saturation in low solubility scaling salts such as calcium sulfate (CaSO

) and silica (SiO

) limit the percentage of water

which can be recovered by an RO system. Feedwater saturated in CaSO

and/or SiO

is also very difficult to concentrate

in a normal evaporator but can be handled in the Aqua-Chem ICD brine concentrator. The process, also called seeded

slurry evaporation, involves establishing and maintaining a slurry of calcium sulfate seed crystals in the circulating brine in

the evaporator. With careful thermal and mechanical design, the SiO

and CaSO

will precipitate preferentially on the

recirculating crystals instead of on the tubes. The brine concentrator is capable of concentrating the wastewater to near

saturation in the sodium salts without scaling the heat transfer tubes.

The remaining water is evaporated in the forced circulation crystallizer. This evaporator easily handles the crystallization

of the remaining salts regardless of the exact chemical analysis. The salts are removed as a cake by a (filter press,

centrifuge).

The Aqua-Chem ICD Zero Liquid Discharge System is designed for automatic steady state operation and will require little

operator attention. The materials of construction have been selected to resist corrosion and ensure a long plant life. The

system is very reliable. The pumps and compressor typically operate years without significant problems, given periodic

maintenance typical for rotating equipment. Almost any problem can be fixed in a day. The system is designed to

minimize scaling of the heat transfer surfaces; however, it is also designed to operate in a slightly fouled condition, so

normal fouling or scaling will not affect the design capacity of the unit. Chemical cleaning of the system is typically

required once or twice per year.

Process Description

The feed is acidified with H

to a pH of 5.5 which converts bicarbonate to dissolved CO

for removal in the deaerator.

The bicarbonate is removed to prevent scaling of the brine concentrator tubes with calcium carbonate (CaCO

). A small

amount of scale inhibitor is metered into the feed to avoid scaling in the feed/distillate plate heat exchanger. Depending on

the amount of calcium in the feed, the anti-scale may be reduced or eliminated.

The feed/distillate heat exchanger, a plate and frame type with titanium plates, preheats the feed with outgoing hot

distillate. The heated feed flows to the deaerator to remove dissolved carbon dioxide and oxygen, to minimize corrosion in

the system. Aqua-Chem ICD uses a flashing deaerator which does not utilize packing, thereby avoiding plugging

problems. The feed is sprayed into the pressurized, barometric half of the deaerator which further heats the feed with low

pressure evaporator vent vapors. The feed then flashes into the low pressure portion of the deaerator. A small fraction of

water from the feed is vaporized, along with the dissolved carbon dioxide and oxygen, which are virtually eliminated by

this step. Typical dissolved oxygen content in the deaerated feed is 10 ppb.

The feed then flows to the brine concentrator vessel. Calcium sulfate scale is managed in this vessel by proper feed

pretreatment and by providing adequate seed crystal surface area dispersed homogeneously in the brine slurry. The seed

crystals prevent supersaturation extremes and promote crystal growth rather than scaling on the heat transfer surface.

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation

One-Four Coins Drive; Canonsburg, PA 15317 USA t) 724 746 5300

f) 724 746 5359

www.aquatech.com

The seed crystals are added as gypsum to the seed makeup tank at startup to establish the circulating slurry. As the brine

is concentrated and some is pumped to the crystallizer, seed crystals are replenished by natural generation from calcium

and sulfate ions in the incoming feed water. A seed thickening tank is provided to recycle seed crystals back into the brine

concentrator if the natural seeding level is too low. A CaCl

injection system is provided to add Ca+2 directly into the feed

line if the incoming Ca+2 concentration is too low. Both of these systems are used to maintain adequate seed crystal

concentration in the brine concentrator.

The brine concentrator vessel is designed with a long bottom channel to provide sufficient residence time for crystal

growth. A vapor separator with mist eliminators is used to remove entrained droplets of brine from the vapor before it

flows to the compressor. The mist eliminators are periodically sprayed with hot distillate to dissolve any accumulated

solids.

Vapor generated in the brine concentrator flows to a mechanical compressor, which increases its saturation pressure and

temperature. Then the compressed vapor flows to the shell side of the brine concentrator in lieu of external heating steam.

The vapor is condensed on the outside of the tubes, transferring heat to the circulating brine on the tubeside. Condensed

vapor (distillate) is pumped out of the system. Some of the distillate is sprayed into the compressor discharge duct to

desuperheat the compressed vapor.

The brine concentrator is designed with a very low delta-T (temperature difference between the heating medium and the

boiling brine) and a high recirculation rate. The two main benefits are reduced scaling rate and a lower compressor power

requirement. Energy economy is maximized by utilizing distillate and vent stream heat. The system is designed for low

make-up steam at steady state operation.

The brine is concentrated to approximately 25% total solids in the brine concentrator. To maintain a solids balance in the

system, part of the concentrated brine is continuously pumped from the brine concentrator to the forced circulation

crystallizer.

Recirculated brine is pumped through the forced circulation heat exchanger where it is heated with steam from the brine

concentrator to above its normal boiling temperature. Boiling of the brine in the heat exchanger is suppressed due to

sufficient static head. Boiling in the heat exchanger would cause scale formation on the heat transfer surface. The heated

brine then enters a flash tank operating at a slightly lower pressure, causing flash evaporation of water and formation of

salt crystals in the brine. High recirculation rates are used to keep the contact time on the heated surface low, reducing

the scaling rate of the heat transfer surface.

Once every eight hours the a batch of slurry is discharged from the crystallizer to the filter press feed tank. This slurry is

fed to the filter press, which separates out the salt crystals as a cake. The liquid portion, saturated in dissolved salts, is

returned to the forced circulation crystallizer. The salt cake is dumped at 8 hour intervals into a hopper for disposal. This

sequence is manually initiated, and requires an operator to be present to assure that the plates have properly released

the salt cake.

Vertical Tube Falling Film Evaporator (Brine Concentrator)

Falling film vertical tube evaporators use vertical tube bundles with brine evaporating from a thin film on the inside of the

tubes. Brine is distributed in a thin film down the inside of the tubes. The brine absorbs heat from condensing water vapor

on the outside of the tubes. The latent heat of vaporization transfers from the water vapor through the tube wall to the thin

brine film on the inside of the tube. For every kilogram of water vapor that condenses, approximately one kilogram of

water is evaporated from the brine film.

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation

One-Four Coins Drive; Canonsburg, PA 15317 USA t) 724 746 5300

f) 724 746 5359

www.aquatech.com

The vapor condensing on the tube bundle is primarily water vapor but can also contain air and other non-condensables.

These non-condensables will stay in the vicinity of the tube walls and impede heat transfer unless swept away by

sufficiently high vapor velocities. A vent on the evaporator body continuously removes the non-condensables to maintain

high heat transfer coefficients and to prevent loss of driving force (differential temperature) through excess subcooling of

the heating vapor.

The brine is introduced at the top of the vessel and flows in a downward direction as a falling film. The brine is uniformly

and generously directed to the full circumference of each tube as a thin film. Because the recirculation rate is many times

greater than the evaporation rate, only a small change in concentration occurs down the tube length as evaporation takes

place. The recirculation rate is chosen conservatively to ensure that the heat transfer surface is well wetted and localized

drying is not encountered.

A proprietary dual perforated plate distributor ensures that the liquid is evenly distributed to the tubes. The plates have

holes larger than 13 mm and have been proven to be much less susceptible to plugging than other designs including

individual weir inserts or swirler inserts.

Careful design eliminates areas where the solids and impurities may collect and impede liquid flow and heat transfer.

Design features include large holes in the distribution system, sloped bottoms, and smooth entrance to pump suctions.

Mechanical Vapor Compression (VC)

Vapor compression is a highly efficient process using mechanical energy input to achieve evaporation and condensation.

The fundamental difference between the vapor compression unit and the conventional evaporator is that the latent heat of

vaporization is fully utilized in the VC evaporator. Since the evaporator also serves as the condenser, essentially all of the

latent heat is recycled, with no rejection of heat to cooling water.

The evaporated vapor flows through the mist eliminator to the suction of the compressor. The compressor does work on

the water vapor increasing the saturation pressure of the water vapor so that when it condenses, it does so at a higher

temperature. The compressed vapor flows to the heating side of the evaporator. As it condenses, it transfers the latent

heat of vaporization back to the liquid film on the tubeside.

The compression process produces discharge vapors that are superheated (i.e. hotter than the corresponding saturation

temperature). Scaling, excessive fouling, and stress corrosion can occur if the superheated vapor is allowed to condense

on the evaporator tube bundle. This scaling would occur as the sensible heat is transferred through the tube. To remove

the superheat in the compressed vapor discharge, desuperheating water (in the form of distillate) is sprayed into the vapor

stream. This distillate is very near the saturation temperature so latent heat is not removed from the vapor stream and can

be used for the evaporation process.

A multi-stage centrifugal blower is used for the brine concentrator. It is coupled to a motor-driven gearbox. This type of

compressor is very simple and easy to maintain. System turndown is achieved by the adjustment of the blower discharge

damper valve. Turndown to 65% of rated capacity can be attained in this manner.

Control

The system is designed for automatic cascade control. Evaporation rate in the brine concentrator is based on an operator

setpoint. The damper valve at the compressor discharge controls vapor flow to the brine concentrator based on the

distillate flow rate out of the system. All other flow rates automatically adjust based on this setpoint. The feed rate is based

on distillate outflow and brine level in the brine concentrator. Pressure (and indirectly temperature) in the brine

concentrator is controlled by venting excess steam to the atmosphere or by allowing external steam into the system. The

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation

One-Four Coins Drive; Canonsburg, PA 15317 USA t) 724 746 5300

f) 724 746 5359

www.aquatech.com

concentrated brine flow rate is remotely set based on feed and distillate flows. Operational parameters of system

pressure, sump level, distillate level, and concentrate flow will be automatically controlled based on changes to the

desired evaporation rate.

Operation

The system is designed for manual start-up and automatic operation. The feed chemistry should be monitored

periodically. Sufficient safeguards and interlocks to prevent unsafe conditions or equipment damage are included in this

design. When the system is shut down it is important to either keep the system pressurized with steam to keep oxygen out

or drain and flush the system to remove the chlorides. Chlorides in the presence of oxygen will accelerate corrosion and

reduce equipment life.

Maintenance

The required maintenance for this Aqua-Chem ICD Zero Liquid Discharge System is typical for commercial process

equipment containing high quality industrial duty components. The unit's rotating equipment, such as pumps and

compressors, require periodic adjustment, lubrication, and servicing of components such as seals. Instrumentation was

specifically chosen to be durable and trouble free, but will require periodic adjustment and recalibration. If recommended

spare parts are kept on hand and a preventative maintenance program is implemented, then the net availability (operating

factor) can be expected to exceed 95%. The required maintenance procedures, recommended spare parts, and

recommended preventative maintenance program will be provided by Aqua-Chem ICD.

Washing

The heat transfer surface has been designed to operate at capacity with lightly scaled heat transfer surfaces. An

occasional manual adjustment of the compressor valve will maintain the system capacity as the evaporators slowly scales

and loses performance. When this valve has been fully opened and the necessary capacity can no longer be maintained,

a chemical wash will be required to restore performance. A complete chemical cleaning procedure will normally take

between 12 and 24 hours. The evaporators are normally cleaned by recirculating a hot 10% EDTA solution (diluted Nalco

760 for example) with the recirculation pumps. The cleaning solution is injected into the recirculation line. The solution is

maintained hot (70

C) by using a small amount of steam flow through existing controls. Cleaning frequency for an

evaporator of this type is typically once or twice per year.

It may be economical to hydroblast prior to cleaning with EDTA. This reduces the amount of EDTA required. We

recommend a professional hydroblast crew do this work. Two 600 mm manholes on the top channel facilitate easier

distribution plate removal and tube blasting.

Materials of Construction

Due to the relatively high chloride content the major vessels wetted materials are 6% molybdenum stainless steel such as

254 SMO or AL6XN. Tubes are titanium grade 2. Other materials used for brine service include fiberglass, CD4MCu,

Hastelloy C, and 316L Stainless Steel as applicable. Use of these materials will assure equipment life beyond 20

operating years.

Spare Parts

Installing spare pumps in brine service would lead to stagnant areas and potential corrosion. Considering the high

reliability of these pumps, it is better not to install spares but keep shelf spares. In the event a pump replacement is

necessary, the feed storage tank would be used to collect the feed flow as it would be when the unit was shut down for

cleaning. Upon startup the excess capacity designed into the unit will process the stored feed.

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Raw Water Treatment

Ion Exchange

Membrane Processes

Recycle/Reuse

Zero Liquid Discharge

Industrial Concentration

Desalination

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

Aquatech International Corporation, a leading supplier of industrial

water and wastewater treatment systems and services located in

Canonsburg, Pennsylvania in the USA, has provided Technology

Leadership and Performance Excellence to the industry since 1981.

Backed by cutting edge technologies and supported with offices

worldwide, Aquatech is well suited to be your preferred partner for

optimal water and wastewater systems, a fact well demonstrated at

thousands of operating systems in 45 countries.

Aquatech is a Full Scope company offering solutions from Concept

to Commissioning and Troubleshooting in:

• Power Generation • Refineries

• Pulp & Paper • Semiconductor

• Automotive

• Steel

• Food & Beverage

Aquatech provides a full spectrum of water and waste-

water treatment. Whether the feed source is Surface

Waters, Well, Sea or a Wastewater Stream, Aquatech

offers the expertise and experience to purify it to your

industry’s specific need-- for cooling tower makeup or

boiler feed, process hosts or electronics grade.

Aquatech offers a strong product portfolio in optimal

treatment systems customized to satisfy specific needs

for a project. Whether the factors governing project

requirements are process or regulatory, Aquatech pro-

vides the products and technologies to offer a cost-effective treatment

scheme from pretreatment to zero liquid discharge or a combination.

As a designer and supplier of water and wastewater treatment

systems and services worldwide, Aquatech has developed an unpar-

alleled global sourcing capability providing our customers with the

same unmatched quality and maximum value through elimination of

non-value added expenses.

Aquatech’s highly trained field service engineers, located strategically

in different geographical areas around the globe, ensure quality service

in a timely and expeditious manner to help us realize our core value

of Customer Satisfaction.

Aquatech can be your single

source supplier, offering one

or several technologies for an

optimal system configuration

suiting specific project

requirements, or combining

select processes to recycle

waste and offer a zero liquid

discharge facility.

Canonsburg Plant

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

PRETREATMENT

Regardless of the feed source – Surface Water, Well Water, Sea Water or Wastewater

– Aquatech provides any of the following processes or a combination to make it

suitable for the downstream processes:

EMBRANE PROCESSES

Aquatech provides a complete range of membrane processes. In addition to

conventional reverse osmosis, Aquatech offers systems incorporating HERO

technology. A HERO

-based system can tolerate silica levels in excess of 2000 ppm in

reject and operates at recoveries exceeding 90%. This, coupled with its tolerance to

biological and organic fouling, makes systems incorporating HERO

the technology

of choice for difficult-to-treat water sources.

ON EXCHANGE

Aquatech offers expertise and experience in providing different types of ion exchange

processes. As a Licensee of UPCORE™ packed bed ion exchange technology, Aquatech

has provided some of the largest ion exchange installations in the world.

DESALINATION

Aqua-chem ICD, a division of Aquatech, pioneered MSF and MED technologies in the 1960s.

Since then, Aquatech has supplied several thermal desalination systems based on MSF and

MED technology with different energy alternatives. Aquatech’s expertise and experience

also extends to membrane based desalination systems, a unique qualification by which

we can evaluate both technologies and offer our

customers the most

cost-effective option

for their specific needs.

• Water Treatment

- UPCORE

™

-Split Flow

Counter Current

- Co-Current

- Layered Bed

• Condensate Polisher

- External Regenerated

- Powdered Resin

-Amine Cycle

- Sodium Zeolite

- Oily Condensate

• Specialty Applications

-Glycol Purification

-Brine Purification

- Metals Removal

-WAC Softening

• Filtration (Pressure & Gravity):

-Media Filtration

- Activated Carbon

- Iron Removal

-Mill Scale Removal

•Microfiltration

•Ultrafiltration

• Nanofiltration

• Conventional RO

• HERO

• Electrodeionizaton

• Chemical Feed Systems

•Clarification:

- Turbidity Removal

- Softening

ECHNOL

Pretreatment Processes

Membrane Processes

Ion Exchange Processes

• Spray Film

Multiple Effect

Distillation (MED)

•Multi Stage Flash (MSF)

• Vapor Compression (VC)

• Sea Water Reverse Osmosis

Desalination Technologies

• Oxidation

•Sludge Handling:

- Thickener

- Filter Press

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

INDUSTRIAL CONCENTRATION

Aqua-chem ICD, a division of Aquatech represents 40 years of experience in providing

evaporative systems for the concentration of various industrial products. This experience

includes a wide range of technologies to meet your specific applications.

RECYCLE / REUSE

Whether industrial wastewater or produced water from oil fields,

Aquatech offers the expertise and technologies to provide an integrated

system, with single point responsibility, for treatment of waste streams

and make them suitable for recycle / reuse in your plants.

ZERO LIQUID

DISCHARGE

To comply with stringent regulatory discharge requirements, Aquatech has several installations

for the treatment of industrial wastewater leading to a Zero Liquid Discharge system. Aquatech

meets these requirements in several different ways depending upon the logistics and economics

of the specific project.

Aquatech supplies systems based

on either membrane processes,

evaporative processes or a

hybrid combining the two

processes to achieve Zero Liquid

Discharge from the plants in a

cost-effective manner. The hybrid approach, combining the membrane and evaporative

technologies, results in systems having low life-cycle costs compared to other available technologies.

LABORATORY & PILOT STUDIES

Aquatech operates a well-equipped laboratory and provides pilot test capabilities for

bench scale or on-site testing of various technologies in order to establish design and

performance parameters for specific applications. Our laboratory testing includes

analytical, boil-up tests, and on-site tests using the actual configuration of a

commercial scale system.

On-site testing can be performed on any

of the following technologies either for

stand alone units or a combination:

• Forced Circulation Crystallizer

• Submerged Tube Evaporator

• Rising Film Evaporator

•Multiple Effect Evaporator

OGY

TREAM

Industrial Concentration Technologies

•Vertical Tube Falling Film Evaporators

- Seeded Slurry (Brine Concentrators)

- Non-seeded Evaporators

• Forced Circulation Crystallizers

• HERO

Technology

• Sludge

Dewatering

- Filter Press

- Centrifuge

- Drum Dryers

Pilot Plants

•Petroleum Refining

• Power Generation

• Gray Water

• Cooling Tower Blowdown

•Oilfield Produced Water

• Semiconductor

Recycle/Reuse Applications

• Automotive

• Electronics

• Petrochemical

•Vertical Falling Film

Evaporator

• Horizontal Spray Film

Evaporator

ZLD Technologies

•Vertical Tube Falling Film Evaporator

• Forced Circulation Crystallizer

• Spray Film

Evaporator

• HERO

Technology

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

WATER MANAGEMENT SERVICES

Aquatech is more than just a systems supplier. Our Water Management

Services Group (WMS) is focused on supporting plant personnel and end

user organizations to get the most out of their water treatment system —

whether it is a system originally

supplied by Aquatech or

PERFORMANCE

PRODUCTS

In addition to custom engineered water treat-

ment solutions, Aquatech has a line of standard

products already engineered to fit your smaller

water treatment requirements.

Many times our clients have water treatment

needs that don't require a custom engineered

solution, but still demand a quality product.

Aquatech Performance Products were

designed for that customer.

• Spare Parts Supply

• Operation & Maintenance Contracts

• Technical Audits

• Leased Water Treatment Systems

• Technical Training

• Annual, Quarterly, and Monthly Maintenance Contracts

• Remote Monitoring

• Build Own Operate Contracts (BOO)

For more information please visit our website at www.aquatech.com

For over two decades, Aquatech

has provided industry

worldwide with proven

installation, and industrial

services, we develop total

water solutions that work together

seamlessly.

Our wide range of products address

everything from ultrapure water

requirements for microelectronics

and pharmaceutical industries, to

workhorse installations for steam

generation in power and chemical

processing plants, to the recycle and

reuse of sewage or cooling tower

blowdown. Innovative, integrated

solutions translate into superior

products and unmatched value for

our customers.

From Innovation

Flows Leadership

Recomax™

A high efficiency membrane system suitable for

wastewater recycle / reuse applications flow range

of 50 to 150 gpm.

Crystal™

A forced circulation crystallizer for flow rates

up to 10 gpm to provide a cost effective

Zero Liquid Discharge (ZLD) solution.

WaterTrak™

Demineralization (DI), reverse osmosis (RO),

and electrodeionization (EDI) systems based on

a functional design derived from 20+ years of

experience in the industry. Watertrak is the most

cost-effective and fast solution for pure water

treatment in the industry today.

Flow ranges from 50 gpm to 300 gpm.

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

CORPORATE OFFICE

Aquatech International Corporation

One Four Coins Drive

Canonsburg, PA 15317 USA

Telephone: 724-746-5300

Fax: 724-746-5359

E-mail: aic@aquatech.com

U.S. LOCATIONS

Texas

3535 Briar Park Drive

Suite #207

Houston, TX 77042 USA

Telephone: 832-251-9339

Fax: 832-251-9341

E-mail: mittald@aquatech.com

Contact: Devesh Mittal

Senior Sales Manager

Florida

238 E. Davis Boulevard

Suite #203

Tampa, FL 33606 USA

Telephone: 813-251-4991

Fax: 813-251-3320

E-mail: randallp@aquatech.com

Contact: Patrick Randall

Regional Sales Manager

Aqua-chem ICD

1120 James Drive

Suite B-105

Hartland, WI 53029 USA

Telephone: 262-369-9595

Fax: 262-369-9494

Aqua

tech

www.aquatech.com

WORLDWIDE

LOCATIONS

Aquatech Systems (Asia) Pvt. Ltd.

Plot No. 3 Survey No. 250/5

Sankalp Park, (End of D.P. Road)

Aundh, Pune 411 007 India

Telephone: 91-20-2729-9105

Fax: 91-20-2729-8805

E-mail: asa@aquatech.com

Contact: Sachin Kukade

General Manager-Sales

China

Aquatech (Guangzhou) Water Treatment Company Limited

Room H, 15 Floor, Huihua Building

80 XianLie Zhong Road; Guanzhou

People’s Republic of China 510 070

Telephone: 86-20-376-16285

Fax: 86-20-376-16787

E-mail: kfwong@aquatechgz.com

Mexico

Ejercito Nacional #57-302

Col. Veronica Anzures

Mexico DF 11300

MEXICO

Telephone: 52-55-5260-6357

Fax: 52-55-5260-1530

E-mail: barriosf@aquatech.com

Contact: Francisco Barrios

Regional Sales Manager

Canada

259 Midpark Way S.E.

Suite 205

Calgary, Alberta T2X 1M2

CANADA

Telephone: 403-256-8700

Fax: 403-256-8745

E-mail: kulkarnim@aquatech.com

Contact: Milind Kulkarni

Regional Sales Manager

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

EU environmental regulations. In order to overcome this

problem, ENEL decided to install the Zero Liquid

Discharge (ZLD) plant so that no industrial wastewater

discharges are allowed.

The Solution

To overcome the problem, ENEL selected the Softening

–Evaporation – Crystallization (SEC) process to treat the

wastewaters and reuse/conserve fresh waters.

Aquatech supplied, installed, commissioned the ZLD

plant as an EPC contractor with local associates.

The SEC plant comprises of 2X50% Softener Clarifiers

(calcium reduction by soda ash dosing), 2x50% Falling

film type Brine Concentrators (each equipped vapor

compressor ), 1x100% Crystallizer (equipped with

Thermocompressors) and 2x50% Belt Filter Presses. The

plant also includes several chemical dosing systems,

storage tanks, pumping systems, electrical works (MCC,

cable trays, cabling etc), Controls & Instrumentation.

The Zero Liquid Discharge (ZLD) plant is a fully integrated

automated system. The Brine Concentrators operate in

seeded slurry mode. Each Brine Concentrator is

equipped with internal mist eliminator. The Crystallizer

operates in forced circulation method.

The industrial grade soft water and high purity distillate

produced in the system will be used in the main power

plant.

PROJECT PROFILE SERIES # 52

ENEL Power, Italy – Fusina Project – ZLD Plant for

FGD Wastewater Treatment

The Facility

The Fusina Power Plant is equipped with four coal-fired

units with a total capacity of 975 MW capacity (1x165

MW + 1x170 MW + 2x320 MW). The Environmental

Refurbishment (Flue Gas Desulpharization, FGD)

project includes a new DeSOx system for common for

units # 1 &2; two DeNOx systems, one each for unit # 1

& 2. Units # 3 & 4 are already equipped with DeSOx

and DeNOx systems.

For units # 1 & 2, Industrial grade water is used as FGD

make-up. Flue gases in the FGD are treated with

limestone in the scrubber. The FGD blow down

wastewaters are treated in the dealkalizer clarifier with

lime treatment.

For units # 3 & 4, the flue gases are treated

sequentially by SCR-DeNOx with ammonia as reagent,

High efficiency ESP to remove fly ash and wet

limestone gypsum forced oxidation DeSOx. Each unit

is equipped with DeSOx system with a prescrubber for

final dedusting and gas saturation and an absorber.

The FGD blow down wastewaters along with units #1

& 2 are treated in the dealkalizer clarifier with lime

treatment and being discharged into the surface

waters.

The Problem

Wastewaters from FGD treatment plant can no longer

be discharged

into the sea due to tough Italian and

Aquatech International Corporation

One Four Coins Drive; Canonsburg, PA 15317

T: 724-746-5300 F: 724-746-5359 aic@aquatech.com www.aquatech.com

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *

PROJECT PROFILE SERIES # 52

PROCESS FLOW DIAGRAM

DESIGN FGD WASTEWATER ANALYSIS

Design Flow ............... 70M3/hr (PT

Plant)

Calcium: ..................... 8400 ppm

Magnesium: …………..1700 ppm

Sodium: ...................... Balance

TSS ............................. 80 ppm

pH................................ 9.5 to 10

Chlorides .................... 25000 ppm

Nitrates ....................... 300 ppm

Sulfate………………….1200 ppm

Aquatech International Corporation

One Four Coins Drive; Canonsburg, PA 15317

T: 724-746-5300 F: 724-746-5359 aic@aquatech.com www.aquatech.com

Electronic Filing - Received, Clerk's Office, January 29, 2009

* * * * * PC #4 * * * * *