BEFORE THE ILLINOIS
POLLUTION
CONTROL
BOA1N
ECEVED
CLERc’g
OFFICE
IN
THE
MATTER OF:
)
JUN
29
2009
WATER QUALITY
STANDARDS AJTD
)
STATE
OF
ILLINOIS
EFFLUENT
LIMITATIONS
FOR THE
)
R08-09
Pollution
Control
Board
CHICAGO AREA WATERWAY
SYSTEM
)
(Rulemaking - Water)
AND THE LOWER DES
PLAINES RIVER:
)
PROPOSED AMENDMENTS
TO 35 Iii.
)
Adm.
Code
Parts 301, 302, 303 and 304
)
NOTICE
OF
FILING
To:
John Therriault, Clerk
Marie Tipsord,
Hearing Officer
James R. Thompson
Center
Illinois Pollution
Control Board
100 West Randolph
Street, Suite 11-500
Chicago, Illinois 60601
SEE
ATTACHED SERVICE LIST
PLEASE TAKE
NOTICE
that I have filed today with the Illinois Pollution
Control Board Illinois EPA’s Pre-Filed Questions for
Corn
Products Witnesses Alan
J.
Jirik, James E. Huff, P.E.
and Joseph V. Idaszak, a copy of which is herewith served
upon you.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
Dated: June
25,
2009
ByQfr’49
Deborah J. illiams
CJ
1021 North Grand Avenue
East
Assistant Counsel
P.O. Box 19276
Springfield,
Illinois
62794-9276
(217) 782-5544
THIS
FILING
IS SUMBITTED ON RECYCLED
PAPER
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
ECEVE
LEAK’S
OFFICE
JUN
29
STATE
O
ILLINOIS
)
R08-09
POllution
Control
Board
)
(Rulemaking
— Water)
)
)
)
)
Illinois
EPA’s
Pre-Filed
Questions
for
Corn
Products
witnesses
Alan
J.
Jirik,
James
E. Huff,
P.E.
and
Joseph
V.
ldaszak
The
Illinois
Environmental
Protection
Agency
(“Illinois
EPA”
or
“Agency”),
by
and
through
its attorneys,
hereby
submits
its Pre-Filed
Questions
for
Corn
Products
witnesses
Alan J.
Jirik,
James
E.
Huff,
P.E.
and
Joseph
V. ldaszak
based
on
the
pre
filed
testimony
filed
on
April
20, 2009
in
the above-captioned
matter.
The
Agency
reserves
the right
to
ask additional
follow-up
questions
as
necessary.
P re-Filed
Questions
for
Alan
J.
Jirik
Your
testimony
indicates
that
Corn
Products
uses the
waters
of
the Chicago
Sanitary
and Ship
Canal
at
its Argo
Plant
for
non-contact
cooling
purposes.
a.
Does
Corn
Products
take
intake
temperature
measurements
of these
waters?
Does
Corn
Products
take
effluent
temperature
measurements?
How
frequently?
What
sampling
locations
are used?
b.
On
page
4, paragraph
I of your
testimony,
you
state,
“The
cooling
tower
enabled
Argo
to
avoid
adding
thermal
load to
its
existing
NPDES
discharge,
and
allows
Corn
Products
to
remain
in
compliance
with
the
thermal
limits
in its
NPDES
permit.
Thus,
it
is Corn
Products’
opinion
that
IN
THE
MATTER
OF:
WATER
QUALITY
STANDARDS
AND
EFFLUENT
LIMITATIONS
FOR
THE
CHICAGO
AREA
WATERWAY
SYSTEM
AND
THE
LOWER
DES
PLAIN
ES
RIVER:
PROPOSED
AMENDMENTS
TO 35111.
Adm. Code
Parts
301, 302,
303
and
304)
1
Argo is near
the approximate limit of
its allowable thermal discharge
to the
Sanitary
& Ship Canal water for cooling
purposes at Argo.” What
restrictions
are placed in Corn Products’
NPDES permit regarding intake
and effluent temperatures?
c.
How
is compliance with these
permit requirements determined?
d. Have the effluent temperatures
at Corn Products ever
exceeded the
proposed CAWS
Aquatic Life Use B daily maximum temperature
of 90.3
degrees Fahrenheit?
If so, did the exceedances occur “for
more than
2
percent of.the
hours in the previous twelve month period?”
e.
Does Corn
Products’ effluent temperature ever
exceed 93.9 °F?
f.
What is
your highest recorded effluent temperature
in the last five
years?
g.
Does Corn Products calculate monthly
average effluent temperatures?
Do these temperatures
exceed
the
proposed period averages?
If so,
during which
months?
h. Does Corn Products collect
temperature
data at the
edge of its mixing
zone? If not, why not?
If so,
can
you submit that monitoring data for
the
Record?
2.
What is the design average flow of Corn Products’
Argo Plant? What is
the
design maximum flow of the facility? What
is
the
average flow of the
Corn
Products facility? Do
you
know what the
7Q1
0 flow of the Chicago
Sanitary
and Ship
Canal
is at the Corn
Products
facility?
a. What portion of the Chicago Sanitary and Ship
Canal does Corn
Products
use
for
cooling
water?
2
b.
What proportion
of
the
Argo
Plant’s
effluent
is
discharged
to the
Chicago
Sanitary and
Ship
Canal?
What
portion
is sent
to
MWRDGC
for
treatment?
3.
On
page
7
of
your
testimony,
you
state
that
the
Chicago
Sanitary
and
Ship
Canal
is
a “relatively
recently
created
artificial
man-made
channel.”
“Recently
created”
in
relation
to
what?
4.
On
page
8
of
your
testimony
you
state
that
the
Chicago
Sanitary
and
Ship
Canal
is
more
like
an
aqueduct
than
a
natural
stream
or
river.
a.
How
would
you
define
a
“natural”
stream
or
river?
b.
Explain
how
this
is
different
from
the
Chicago
River,
North
Branch
Chicago
River
below
North
Avenue
Turning
Basin,
South
Branch
Chicago
River,
South
Fork
of
South
Branch,
Brandon
Pool,
Lake
Calumet
connecting
channel
and
the
CAWS
and
Brandon
Pool
Aquatic
Use
B
segment
of
the
Calumet
River?
c.
What
are
the
criteria
that
differentiate
an
“aqueduct”
from
a
stream?
d.
Where
in
the
proposed
use
designation
is the
Chicago
Sanitary
and
Ship
Canal considered
a
natural
river?
e.
Does
the
proposed
Aquatic
Life
Use
B designation
include
the
phrase
“..
.in
deep-draft,
steep-walled
shipping
channels?”
5.
Your
testimony
states
on
page
8
that
the
Chicago
Sanitary
and
Ship
Canal
provides
a
commercially
important
navigation
function.
Is
this
different
from
the
Upper Dresden
Island
Pool,
Brandon
Pool,
South
Branch
Chicago
River
3
and Cal-Sag Channel? Is it different than the Mississippi River or the
Illinois
River?
6.
In the first full paragraph on page 8,
you
state that MWRDGC leases land
along the Chicago Sanitary and Ship Canal to industrial users who do not
support or encourage public or
pedestrian
activities along the
Chicago
Sanitary
and
Ship Canal. Are you aware that there are public boat ramps
at
Archer Avenue
(river mile 313) and Western Avenue (river mile 320.6)?
7.
In your
updated testimony there
is no reference to your
position
on the
Agency’s Recreational Use
designation
for the Chicago
Sanitary
and Ship
Canal. Have you withdrawn your objection to the Agency’s Recreational
Use
designations for the Chicago Sanitary and Ship Canal?
8.
The
last
paragraph
on page
10 states,
“... Corn
Products’ testimony
supports
that applying a Use B
designation
to the Sanitary and Ship Canal is both
inappropriate and unwarranted.”
a.
Which aspects of the CAWS Use B definition in section 303._ are
unwarranted?
9.
Why do you
believe that the Chicago Sanitary and Ship Canal is
sufficiently
distinct to support a unique classification for aquatic life uses?
10.
On
pages 10 and 11, you suggested the creation of an appropriate
designation
such as a “Use
C”, but failed to provide
a
description
of this
use.
How would you define the CAWS Use C waters for regulatory purposes?
a.
What types of aquatic organisms, if any, would this “Use
C”
protect?
4
b.
Would
you
agree
that
it is
not
the
proposed
designated
use
that
you
disagree
with,
but
rather
the
proposed
water
quality
standards
for
that
proposed
designated
use?
11.
Will
you
be
proposing
language
to the
Board
for
aquatic
life
uses
of
the
Chicago
Sanitary
and
Ship
Canal?
12.
How
will
you
distinguish
the
use designation
for
the
Chicago
Sanitary
and
Ship
Canal
from
the
following reaches:
a.
North
Branch
Chicago
River
from
the
south
end
of the
North
Avenue
Turning
Basin
to its
confluence
with
the
South
Branch
Chicago
River
and
Chicago
River?
b.
From
the
Chicago
River?
c.
From
the
South
Branch
Chicago
River
to
its
South
Fork?
ci.
From
Calumet
River
from
Lake
Michigan
to Torrence
Avenue?
e.
From
the
Lake
Calumet
Connecting
Channel?
f.
From
the
Lower
Des
Plaines
River
from
its
confluence
with
the Chicago
Sanitary
and
Ship
Canal
to
the
Brandon
Road
Lock
and
Dam?
13.
In
the
last
paragraph
on page
4,
you
state
that
categorizing
the
Chicago
Sanitary
and
Ship
Canal
as
a
Use
B will
provide
no meaningful
improvement
of
fisheries
relative
to
current
conditions.
a.
What
types
of fish
(intolerant,
tolerant,
etc.)
are
currently
present
in the
Chicago
Sanitary
and
Ship
Canal?
b.
What
type
of
aquatic
life
is considered
to
be predominating
in
the
proposed
Aquatic
Life
Use B
waters?
5
14.
In reference
to the
end
of paragraph
I
on page
5, can
you
explain what
you
mean
by
fisheries
“above
average quality”
and “below
average
quality?”
15.
On
page
10,
paragraph
2,
you
state;
“As
our expert
will
testify,
the Sanitary
&
Ship Canal
fisheries
are not
limited by
the current
thermal
environment
. .
Does
the
presence
of only
thermally
tolerant
species
indicate
an
impact
to
the
aquatic
life?
16.
You
quote from
the Board
opinion
in
AS 96-10
to conclude
that
the Board
has
recognized
the
unique character
of the
Chicago
Sanitary
and
Ship
Canal.
Did
this
opinion
distinguish
the
Chicago
Sanitary
and Ship
Canal
from
the Lower
Des
Plaines River
or South
Branch
Chicago
River?
17.
Does AS
96-10
apply to
Corn Products?
Why
or
why
not?
18.
Does the
thermal
discharge
from
Corn Products’
Argo
facility
impact
compliance
with the
General
Use
thermal
standards
below
the
1-55 Bridge?
19.
On page
5,
paragraph
2, you
state, “There
is ample
evidence
in the record
that
demonstrates
that
the Sanitary
& Ship
Canal
does not
meet the
proposed
Use B
thermal
water
quality
standards.”
Which
stations
are
you
talking
about?
a. Have you
looked at
temperature
data from
Romeoville
Road
or River
mile
302.6?
b.
Why does
your
testimony
assume
that the
upstream
dischargers
will not
comply
with the
water
quality
standards?
20.
How
would
your facility
be
impacted
if the
electrical
generating
facilities
located upstream
were
required
to
add
supplemental
cooling
capacity?
6
21.
What
impact
would
the possible
shuttering
of
the
Crawford
and/or
Fisk
Generating
Stations
have
on
the
thermal
assimilative
capacity at the
point
of
Corn
Products’ intake
from
the
Chicago
Sanitary
and
Ship
Canal?
a.
How
far
upstream
from
Corn
Products
are
the discharges
of the
Midwest
Generation
Fisk
and
Crawford
plants
and
MWRDGC
Stickney MWWTP?
22.
Do you
work
at
the
Argà
Facility?
If so,
for
how many
years
have
you
worked
there?
23.
When
and
why
did
Corn
Products
decide
to hire
Mr.
James
E.
Huff
to review
the
Use
Designation
proposed
by
the
Illinois
Environmental
Protection
Agency
for the
Chicago
Sanitary
and
Ship
Canal?
24.
When
and
why
did Corn
Products
decide
to
hire Ambitech
Engineering
Corporation
to
evaluate
the
options
available
for
Corn
Products
to
maintain
its
current
use
of
noncontact
cooling
water
obtained
from
the
Chicago
Sanitary
and
Ship
Canal?
25.
Please
submit
the
data
referenced
in
Attachment I to
your
revised
testimony
for
the
Record.
Can
you
explain
why
some
of
the
period
average
intake
temperatures
are
higher
than
the
individual
samples
in Attachment
1?
7
Pre-filed
Questions
for James
E.
Huff, P.E.
1.
Beginning
in
the
final
paragraph
on
page
2 of
your testimony,
you
state, “Illinois
EPA
is
proposing
to
classify
the Sanitary
& Ship
Canal
as an
Aquatic Life
Use
B
Water,
a
group
that also
includes
the North
Branch
Chicago
River, the
Chicago
River,
the South
Branch
Chicago
River, the
Calumet
River
to
Torrence
Avenue,
the Lake
Calumet
Connecting
Channel,
and the
Lower Des
Plaines
River from
the Sanitary
& Ship Canal
to the
Brandon
Road
Lock and
Dam.” You
go
on to
state, “With
the exception
of the
Lake Calumet
Connecting
Channel
and the
Sanitary
&
Ship Canal,
all of the
waterways
in this
group
are natural
waterways.
A proper
consideration
of the uniqueness
of the
artificially
created
and physically
constrained
Sanitary
& Ship
Canal is
lost by including
it in
this grouping.”
a. Do
the following
waterways
resemble
their
natural
conditions:
North
Branch
Chicago
River,
the Chicago
River, the
South Branch
Chicago
River,
the
Calu met River
to Torrence
Avenue,
and the Lower
Des
Plaines
River
from
the Sanitary
&
Ship
Canal
to the Brandon
Road
Lock
and
Dam?
b. Is
there a significant
difference
between
the
list
of
segments
above
and
the
segments
you describe
as
artificially
created?
2. On
page 3
of your
testimony,
the last
paragraph
states,
“If
the Lower
Des
Plaines
River
(“LDPR”)
was
deemed
hopeless
due to the
contribution
from
the Sanitary
&
Ship
Canal,
what
does
that
imply about
the
potential
of the Sanitary
&
Ship
Canal
itself?”
Have
the
aquatic
communities
in the
Lower Des
Plaines
River
improved
8
since
this comment
was
made
in the
1970s?
How
about
in
the
Chicago
Sanitary
and
Ship
Canal?
3.
Do
you
believe
that
no
improvement
in the
aquatic
community
in
these
waters
is
attainable?
Why?
4. You
state on
page
4 that
“Taken
from
a
biological
perspective,
the Sanitary
&
Ship
Canal
therefore
essentially
terminates
at the
fish
barrier.”
Please
explain
what
is
meant
by
this
statement.
5.
You
also
indicate
on page
4
that
due
to
habitat
limitations
in the
Chicago
Sanitary
and
Ship
Canal
a
balanced
indigenous
population
of
fish cannot
be attained.
What
do
you
mean
by
“a
balanced
indigenous
population?”
6.
With regard
to Tables
3-2
and
3-3 of
your Thermal
Report,
for
each
year
and
river
mile,
what
were
the
number
of fish
collections?
a.
Do
you know
the temperatures
present
during
the
fish collections?
b. Was
the
water
temperature
warmer
or
cooler
than
the
proposed
water
quality
standards
at
the time
of
the fish
collection?
c.
Were
they
Spring
or
Fall
collections,
or were
they
taken
during
the
Summer?
7.
You
state
on page
6 of
your
testimony
that “In
essence,
Illinois
EPA
discounted
Mr.
Yoder’s
analysis,
and
set the
non-summer
temperatures
so that
the
MWRDGC
would
not have
to
install
cooling
towers,
Implicit
in this
decision
was
that
the
cost
of
such cooling
towers
could
not
be justified..
9
a.
What
evidence
do
you have
that
Illinois
EPA
considered
the
cost
of
installing
cooling towers
by
MWRDGC?
Do
you
have any
information
regarding
the
cost of installing
cooling
towers
by
MWRDGC?
b. Should
the
Agency have
relied
on the Route
83
CSSC
station
data
alone
in
setting background
temperatures
rather than
also
using MWRDGC
effluent
data?
c.
Should
the
Agency
have excluded
Route
83 CSSC
data
where
it
allowed
for
higher
background
temperature
values than
the
MWRDGC
effluent
data?
d. Should
the Agency
have relied
on data
from the
Cal-Sag
Channel
or
the
Des
Plaines
River
upstream
of the confluence
with the
CAWS?
e.
What
measure
of background
temperature
would you
recommend?
8.
On
pages
6-7 of your
testimony
you
state,
“No attempt
was
made to
look
at
the
Sanitary
&
Ship Canal
temperatures
at
the edge
of the mixing
zones
from these
industrial
discharges.”
Please
provide
any data you
have that
was collected
at
the
edge
of
a mixing
zone for
any of
the
industrial
dischargers
on the
CSSC
and
a
map of
the applicable
mixing
zones.
9.
You state
on page
7,
“Had Illinois
EPA factored
in the
thermal
loadings
on the
Sanitary
&
Ship
Canal
instead
of
arbitrarily
setting the
Spring/Fall
months
at
the
MWRDGC
effluent
temperatures,
a
very
different
regulatory
proposal
would
have
resulted.”
Please explain
how
to
go
about
‘factoring
in’
the
thermal loadings
on
the CSSC
into a regulatory
proposal
and
define
what
such
a proposal
would
look
like.
10
10.
Please
explain
why
you
conclude
on
page
7
that
“the Sanitary
&
Ship
Canal
will
be
determined
to
be
thermally
impaired
throughout
its
entire
length.”
a.
During
what
periods
did
you
find
the
temperatures
at
Route
83
on
the
CSSC to
violate
the
proposed
thermal
standards?
b.
Why
is
the
same
color
used
on
Attachment
I
for
Route
83
on
the
CSSC
and
the
Illinois
EPA
proposal?
Can
you
provide
a copy
of
this
Attachment
with
different
colors for
these
two
lines
on
the
graph?
c.
Why
does
the
figure
in
Attachment
I only
present
temperature
data
from
August
1998
through
2002,
when
data
is
available
through
June
2007?
d.
Did
you look
at
temperature
data
from
River mile
302.6
on
the
CSSC
for
compliance
with
the
proposed
standard?
What
about
the
Romeoville
Road
station?
e.
How
would
your
conclusion
about impairment
of
the
entire
CSSC
for
temperature
change
if Midwest
Generation
reduced
its
thermal
loadings
upstream
of
Corn
Products
to
comply
with
the
proposed
standards?
11.
On
page
7,
you
state
that
the
highest
temperatures
on
the
Sanitary
and
Ship
Canal are
downstream
of
the
Crawford
Power
Plant.
How
did
you
arrive
at
this
conclusion
since Attachment
6
does
not
contain
temperature
data
upstream
of
Cicero
Avenue?
a.
Are
fish
and
continuous
monitoring
data
available
on
the
South
Branch
Chicago
River
at
Loomis
Street
about
0.6
miles
downstream
of
the
Fisk
Power Plant?
11
b.
Is Loomis Street located about 0.2
miles
upstream of the Chicago Sanitary
and Ship
Canal?
c.
Why was your analysis limited
to only the Chicago Sanitary and Ship
Canal?
12.On
Figure
1
of your Thermal Report, you graphed
the average temperature for
July/August for 6
stations. Are
you
aware that the average
temperature
at
Cicero
Avenue, the
hottest station recorded, for July/August is below the proposed water
quality standard?
13.You state on page 8
of your testimony with regard
to the
CSSC and the Cal-Sag
Channel
that “There
are differences in historical
temperatures
between
these
two
deep-draft
waterways.. .“ Does this mean
that
the temperatures in the Cal-Sag
Channel are
lower at all stations thanthe
temperatures in the
CSSC?
14.On
page 8, you
stated that both the Chicago
Sanitary
and Ship Canal and Cal-
Sag
Channel have
limited shallow area along the banks and a high volume of
commercial traffic. You
further state that because of these similarities a
comparison
of the
fisheries quality between
these two water
bodies
would
be
expected
to identify thermal stress.
a. Is
it true that Ed Rankin’s
Report (Attachment R) indicated that the Cal
Sag
Channel
has fair habitat
quality primarily due to coarse material in the
littoral
areas?
b.
Did Mr. Rankin also
state that this littoral habitat is not isolated but is
present along much of
the
shoreline?
12
c.
As
you
indicated
on
page
4
of
your
testimony,
Mr.
Rankin
rated
the
habitat
in the
Chicago
Sanitary
and
Ship
Canal
as
poor
to very
poor.
Why
did
you
not include
Mr.
Rankin’s
fair habitat
rating
of the
Cal-Sag
Channel?
d.
Did
Mr.
Rankin
indicate
that
the
Chicago
Sanitary
and
Ship
Canal
at
Lockport,
Romeoville
and
Willow
Springs
Road
were
canal-like
in nature
with
steep
sides
and
little
functional
cover
or
substrates?
e.
Did
Mr.
Rankin
also
indicate
that the
site
at
Lockport
was wider
and
had
some
littoral
habitat,
but
that
these
were
very
limited
in scope
and
were
extremely
embedded
with
silty
mucks
and
sand
that
were
of
poor
quality?
f.
Did
Mr.
Rankin
also
state
that
the
Chicago
Sanitary
and
Ship
Canal
widened
out
between
Harlem
and
Cicero
and
gained
some
shoreline
shallows
that
provided
a
bit more
habitat
likely
to
support
a
slightly
better
assemblage than
in the
narrower,
more
canal-like
reaches?
15.
On
page
8
of your
testimony,
you indicated
that
the
Chicago
Sanitary
&
Ship
Canal
and
the
Cal-Sag
Channel
have
similar
fisheries
quality.
You
also
indicated
that
within
the Chicago
Sanitary
and Ship
Canal
the
warmest
site had
a
higher
than
average
species
diversity.
Is
it true
that
of
all the
sampling
sites
and
data
presented
in Attachment
6,
that
only
two
sites
on
the
Chicago
Sanitary
and
Ship
Canal
(Cicero
Ave.
and
Lockport)
and
one
site
on
the
Cal-Sag
Channel
(Cicero
Ave.)
had
both
fish
and
continuous
monitoring
temperature
data
for the
entire
2001
through
2005
period?
a.
Are
you
aware
that
if your
analysis
was
limited
to these
three
sites,
that
the Cal-Sag
Channel
at
Cicero
Avenue
consistently
had
higher
lBl values
13
(by as much
as 6 — 8 points)
than
the Chicago
Sanitary and
Ship Canal at
Cicero Avenue
and at
Lockport
during
four of these five
years?
b.
Could
the difference
in species diversity
within
the Chicago
Sanitary and
Ship Canal be
due in part
to habitat
differences
at Cicero
and Lockport
as
reported
by Mr. Rankin?
c. Are you
aware that although
Cicero
Avenue
tended
to have higher
numbers
of species
compared to Lockport,
181 scores
were generally
the
same,
being slightly higher
at Lockport
but
by no
more than 2 points?
16.Are
the average
IBI values presented
in Table
4-1
of your
Thermal
Report
based
on those from
MWRDGC?
a.
If this is
true,
do you
know what IBl was
used by
MWRDGC
(e.g. Illinois
181, Ohio EPA boatable
181)?
b.
What is
a
meaningful
difference
in IBI scores?
17.On page 8
of
your
testimony,
you quote
from the Board
Opinion in AS96-1O
regarding
the Agency’s
conclusion at
that time that additional
cooling
“may
not
be
economically
reasonable.”
Doesn’t that
same paragraph
in the Board
opinion
also
conclude
that
the Agency
found the installation
of cooling
towers to
be
technically
feasible?
18. Explain
why you believe
that the CSSC
is
sufficiently
distinct
to support
a unique
use
classification for aquatic
life
uses.
a. You
state
on page 9
that
“[such]
a use category
should recognize
the
existing
uses
and limitations of
the Sanitary
& Ship Canal...”
Isn’t
the
Board required to
adopt the “attainable”
uses
for
these
waters?
14
b.
When
you
refer
to
existing
uses
in
your
testimony,
are
you considering
waste
transport
or
assimilation
to
be
a
use?
c. How
do
the
proposed
thermal
standards
impact
“existing
uses”
as
you
indicate
on
page
9
of
your
testimony?
d. Will
you be
proposing
language
to
the
Board
for
aquatic
life
uses
of
CSSC?
15
Pre-filed
Questions for Joseph
V.
ldaszak
1. Your
analysis
of options
available
for Corn
Products
to
maintain
its
current
use
of
noncontact
cooling
water
obtained
from
the
Chicago
Sanitary
&
Ship Canal
was
done
with
the
expectation
that
Corn
Products’
Argo
Plant
would
need
to meet
water
quality
standards.
Why
then
does
your analysis
assume
that
other
upstream
dischargers would
not
need
to
meet the
water
quality
standards
in
the
receiving
stream?
a.
Would
your
analysis
change
if
the
water
quality
standards
were
met
upstream
of
Corn
Products
and
they
were
granted
a mixing
zone?
b.
Do you
think
the
price
would
come
down
from
your
original
analysis?
2. On
page
5 of
your
testimony,
paragraph
I states,
“More
importantly,
the
engineering
analysis
indicates
that
there
are
times
of
the year
when
the
period
average
standard
will
still
be
exceeded.”
a.
When
are
these
“times
of the
year?”
b.
How
much
will it
be
exceeded
by?
c.
How
close
to the
water
quality
standard
would
the effluent
be?
d.
What
frequency
of
monitoring
did
you
consider
would
be used
to calculate
the
period
average?
e.
Does
this
analysis
assume
that
the water
quality
standards
are met
when
the
water
is
withdrawn
from
the
CSSC?
f.
Does it
factor
in
any mixing
with
the
receiving
stream
and
the
effluent?
16
g.
How
would
reductions
in the
intake
temperature
at the
Corn
Products
intake
point
impact
your
analysis
of whether
mechanical
cooling
is
necessary?
3.
In your
testimony,
you
state,
“Four
options
were
evaluated
relative
to
the
feasibility
of
the
continued
use
of cooling
water
from
the
Sanitary
&
Ship
Canal
water
for process
cooling
in the
case
where
the
Illinois
EPA’s
proposal
is
adopted
by
the
Illinois
Pollution
Control
Board.”
Can
you
explain
how
you
narrowed
the
available
options
down
to
these
four?
4. If
option
2 would
result
in compliance
with
Corn
Products’
NPDES
limits
under
a
revised
permit
following
adoption
of the
proposed
thermal
limits
would
you
consider
that
option
technically
feasible?
If
not,
why not?
5. You
state
on page
5 with
regard
to
Option
3,
“Since
the capital,
operating
and
maintenance
costs
are
reasonably
expected
to be higher
than
with
Option
2,
along
with
the
unstudied
potential
processing
impacts,
this
option
was
eliminated.”
Please
explain
this
statement.
a.
Do you
believe
closed-cycle
cooling
is
technically
feasible
at the
Corn
Products
Argo
facility?
6.
Explain
why
construction
of
a
building
to
shelter
the
mechanical
cooling
system
is
required
in
Option
4.
7. What
method
did
you use
to determine
that
the
probable
cost
of Option
4
is
not
reasonable?
What experience
are
you
relying
on
to
estimate
the
cost
of
$20
million?
What
is the
confidence
level
of
this
estimate?
17
8. What
other open
or
closed-cycle
cooling
systems
have
you
worked
on? Where
are
the facilities
located?
9.
Explain
the heat balance
calculations
in
your report
(Attachment
1).
a. Did you
prepare
Attachment
1?
b. Who
prepared
Attachments
A
through
F?
c. Who
(from
Corn
.Products)
prepared
Attachment
B?
10.
What “available
historical
data”
are
you referring
to
on page
2
of Attachment
1?
a. What
intake
temperature
data
did you
rely
on?
b. Did
you
presume
that
future
intake
temperatures
will
be
similar to
past
intake
temperatures?
11 .Which
proposed
period
average
temperature
limits
would be
exceeded
using
option
2?
Where is
that found
in your report
or attachments?
12. Please
provide
the “system
operation
logs”
you refer
to
on
page 4 of
Attachment
1.
13. On
pages
4-5 you
state,
“Since the
average
discharge
water
temperatures
are
available
from
2/24/05
to
11/30/07,
and
average
Sanitary
&
Ship Canal
water
temperatures
are not
available,
daily maximum
and
Sanitary
& Ship
Canal
water
temperatures
are used...”
Please
explain.
18
Dated
June 25,
2009
1021 North
Grand
Avenue
East
P.O.
Box
19276
Springfield,
Illinois
62794-9276
(217)
782-5544
19
Respectfully
submitted,
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
BjU]JI/L
Deborah
J.
illiams
Assistant
Counsel
STATE
OF
ILLINOIS
)
)
SS
COUNTY
OF
SANGAMON
)
)
PROOF
OF
SERVICE
I,
the
undersigned,
on oath
state
that
I have
served
the attached
Illinois
EPA’s
Pre-Filed
Questions
for
Corn
Products
withesses
Alan
J.
Jirik,
James
E.
Huff,
P.E.
and Joseph
V. Idaszak
upon
the person
to whom
it
is directed
by
placing
it
an
envelope
addressed
to:
See
Attached
Service
List
and
mailing
it
by
First
Class
U.S.
Mail
from
Springfield,
Illinois
on
June
25, 2009,
with
sufficient
postage
affixed.
SUBSCRIBED
AND
SWORN
TO
BEFORE
ME
This
dayofjCA.Y12009
Notary
Public
OFFICIAL
SEAL
BRENDA
SOEHNER
::
NOTARYPIJBUG,
STATE
OFIWNOIS
MY
COMMiSSION
EXPIRES
11-3-2009
:
THIS
FILING
IS
SUBMITTED
ON RECYCELD
PAPER
Service
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R08-9
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