PROPOSED ADJUSTED STANDARD

APPLICABLE TO ILLINOIS-

AMERICAN WATER COMPANY'S

ALTON PUBLIC WATER SUPPLY

REPLACEMENT FACILITY

DISCHARGE TO THE MISSISSIPPI

RIVER

To: Attached Service List

PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the Pollution

Control Board the Petition for Adjusted Standard of Illinois-American Water Company and

Appearances of Nancy J. Rich and James E . Mitchell, copies of which are herewith served

upon you.

,AO

March 19, 1999

Katten Muchin & Zavis

525 W . Monroe Street

Suite 1600

Chicago, 1111nois 60661-3693

312-902-5200

Doe 9:CH0 2 (033Y9.OO905) 9249251

;3/1 B/1999lnme :14:24

u . . y

BEFORE THE ILLINOIS POLLUTION CONTROL BOARDRECEIVED

CI FRK'S C)FF1rp

MAR 1 9 1999

STATE OF IWNOIS

pollution Control Board

NOTICE OF FILING

AS 99-

1,

(Adjusted Standard)

THIS FILING IS SUBMITTED ON RECYCLED PAPER

---

Dorothy M

. Gunn

Illinois Pollution Control Board

James R

. Thompson Center

100 W . Randolph St ., Ste . 11-500

Chicago, Illinois 60601

IEPA Division of Legal Counsel

1021 North Grand Avenue East

Springfield, Illinois

62794

Attn : Lisa E. Moreno, Esq

.

Assistant Counsel

Robert Lawley, Esq.

Chief Legal Counsel

Illinois Department of Natural Resources

524 S . 2n° Street Room 400

Springfield, Illinois 62701

SERVICE LIST

---

RECEIVED

CLERK'S OFFICE

MAR 1

9 1999

BEFORE THE ILLINOIS POLLUTION CONTROL

BOARDPollution

STATE

OF

Control

ILLINOIS

Board

IN THE MATTER OF:

)

PROPOSED ADJUSTED STANDARD

)

APPLICABLE TO ILLINOIS-

)

AMERICAN WATER COMPANY'S

)

ALTON PUBLIC WATER SUPPLY )

REPLACEMENT FACILITY

)

DISCHARGE TO THE MISSISSIPPI

)

RIVER

)

APPEARANCE

AS 99-~0

(Adjusted Standard)

I hearby file my appearance in this proceeding, on behalf of Illinois-American Water Company

.

Katten Muchin & Zavis

525 W

. Monroe Street

Suite 1600

Chicago, Illinois 60661-3693

312-902-5200

DoC #

:CH02 (03979-00005) 924845v

1

;3H&1999?ime:14 :27

---

IN THE MATTER OF

:

)

PROPOSED ADJUSTED STANDARD

)

APPLICABLE TO ILLINOIS-

)

AMERICAN WATER COMPANY'S

)

ALTON PUBLIC WATER SUPPLY

)

REPLACEMENT FACILITY

)

DISCHARGE TO THE MISSISSIPPI

)

RIVER

)

-ames

W

E

. Mitchell

Katten Muchin & Zavis

525 W

. Monroe Street

Suite 1600

Chicago, Illinois 60661-3693

312-902-5200

R£ c

CL FR'

MAR 1 9 1999

BEFORE THE ILLINOIS POLLUTION CONTROL BOAR

1 STATE

n

OF

intro/a

/

L

/NOts

Onrd

APPEARANCE

I hearby file my appearance in this proceeding, on behalf of Illinois-American Water Company

.

AS 99-

(Adjusted Standard)

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOARS

RECEIVED

"""

r1FF'r`F

IN THE MATTER OF :

MAR 19 1999

)

STATE OF ILLINOIS

PROPOSED ADJUSTED STANDARD APPLICABLE

)

AS 9?o

llgtlon Control Board

TO ILLINOIS-AMERICAN WATER COMPANY'S

)

(Adjusted Standard)

ALTON PUBLIC WATER SUPPLY REPLACEMENT

)

FACILITY DISCHARGE TO THE MISSISSIPPI

)

RIVER

)

PETITION FOR ADJUSTED STANDARD

Petitioner, Illinois-American Water Company ("Water Company"), by its

attorneys, Katten Muchin & Zavis, pursuant to Section 28

.1 of the Illinois Environmental

Protection Act ('the Act"), 415 111 . Comp. Stat . 5/28

.1 (formerly III . Rev . Stat .

1991,

ch . I11 'h, para . 1028 .1), and Part 106 of the Procedural Rules of the Illinois Pollution

Control Board ("Board"), 35 III . Adm . Code Part 106, respectfully requests the Board

to grant an adjusted standard from 35 Ill . Adm . Code 304.124

for discharges of total -

suspended solids

("TSS") and total iron ("iron") for the Water Company's proposed

replacement public water supply treatment facility ("replacement facility") located in

Alton, Madison County, Illinois . The Water Company also requests the Board to grant,

to any extent it deems necessary to fashion complete relief, an adjusted standard from

two additional sections of

its

regulations : 1) 35 111 . Adm

. Code 304 .106, which provides

in relevant part that no effluent shall contain settleable solids or sludge solids, and that

turbidity must be reduced below obvious levels ; and 2) the analogous water quality

provision, 35 111 . Adm . Code 302

.203, which provides in relevant part that waters of the

State shall be free from sludge or bottom deposits and turbidity of other than natural

---

origin

.!!-' In support of its Petition for an Adjusted Standard ("Petition"), the Water

Company states as follows :

BACKGROUND

1 .

Section 28.1 of

the Act enables the Board to approve adjusted standards

to regulations of general applicability for persons who can justify such an adjustment

consistent with subsection (a) of Section 27 of the Act . Section 27(a) provides that :

In promulgating regulations under this Act, the Board shall

take into account the existing physical conditions, the

character of the area involved, including the character of

surrounding land uses, zoning classifications, the nature of

the existing air quality, or receiving body of water, as the

case may be, and the technical feasibility and economic

reasonableness of measuring or reducing the particular type

of pollution .

415 III . Comp . Stat. 5/27(a) .

2 .

Pursuant to this grant of

authority, the Board promulgated procedural

regulations for the approval of adjusted standards . See 35 Ill . Adm. Code 106 .701 et

seq . Specifically, Section 106 .703 of the Board's Procedural Rules provides that any

person may singly or jointly with the Illinois Environmental Protection Agency ("Illinois

EPA") file a written petition for an adjusted standard .

In addition, Section 106 .705

identifies the content requirements of the adjusted standard petition

. Those requirements

None of the four public water supply facilities to which the Board has previously granted relief (the existing

Alton facility, and the facilities which serve Rock Island, East Moline, and East St

. Louis) have sought relief fromxithex

of these regulatory provisions

. As discussed herein, the Water Company also believes that the replacement facility's

discharge will not be substantively different from those of the public water supply facilities to which the Board has

already granted relief

. The Water Company is also unaware that exemptions from these sections have been sought by

any of

the other dischargers to waters of the State whose effluent contains settleable solids

. Nonetheless, at the

suggestion of Illinois EPA

the Water Company seeks relief from these regulatory provisions in order to .ensure :complete

relief .

2

---

and other relevant regulatory provisions are discussed under the applicable headings

below .

3 .

The Water Company files this Petition because it intends to construct a

public water supply treatment facility in Alton, Madison County, Illinois to replace the

existing facility in Alton ("existing facility"), which was inundated by the Mississippi

River (the "River") in 1993 and threatened again in 1995 . The Water Company seeks

to relocate its existing facility to minimize the potential for future flooding and to replace

the aged facility . The severity of the 1993 flood, which shut down the facility for four

days and required consumers to boil their water for ten days, is documented in the

photographs provided as Attachment A hereto .

4.

The Water Company has conducted a. Site-Specific Impact Study ("SSIS"),

attached hereto and incorporated by reference as Attachment B, to address the site

-

specific / adjusted standard factors enumerated in Section 27(a) of the Act . These factors

include the character of the raw water (i.e., Mississippi River), environmental impact,

technical feasibility, and economic reasonableness of potential alternatives

.!' In

September, 1996, the Water Company met with Illinois EPA to discuss a draft workplan

for conducting the SSIS . The Water Company thereafter developed the draft workplan

11

In addition to the adjusted standard factors listed in the Act, the 5S1S also anticipated and addressed the Best

Professional Judgment

("BPJ") standard that, during any future permit process

. Illinois EPA must apply pursuant to

Section 402(a) of the federal Clean Water Act's National Pollutant Discharge Elimination System ("NPDES") program,

33 U .S .C . § 1342(a) . Please note that even though BPJ is a permit requirement, it provides a means of setting effluent

standards for an individual discharger, which is exactly what the Water Company is asking the Board to do here for the

replacement facility

. As applied to public water supply discharges, the BPI permit factors overlap many of the adjusted

standard factors--

e.g ., the technical feasibility and economic reasonableness of reducing the particular type of pollution,

and other unique factors such as existing physical conditions

. Also note that, with the exception of the Section 28 .3 and

Best Degree of Treatment ("BDT") (35 III. Adm . Code 304

.102) factors discussed below, there arc no other directly

relevant standards for evaluating the merits of a public water supply facility's request for relief from the Board's general

industrial effluent standards .

3

---

and forwarded it to Illinois EPA for review and comment . The Water Company

incorporated Illinois EPA's comments in the final SSIS workplan . Due to a change in

project location from Godfrey, Illinois to Alton, Illinois to capture a greater than six

million dollars savings in pipeline and construction costs, the Water Company met with

Illinois EPA in August, 1997 to revisit the SSIS workplan to identify any additional site-

specific factors for the replacement facility . As a result of this meeting, a habitat

characterization/protected species survey for mussels was added to the workplan . See

SSIS at Appendix B . Pursuant to a follow-up meeting and subsequent correspondence

with Illinois EPA, the Water Company performed and incorporated into the SSIS a

Discharge TSS Modeling Evaluation, which also included a Particle Deposition Study .

See SSIS at Appendix F.

5 .

The SSIS provides a brief description of the existing facility and a general

design of the proposed replacement facility . The design, together with the results of pilot

facility testing, was used to develop estimates of effluent flows and concentrations

anticipated from the replacement facility . The proposed 10 .5 million gallons per day

("MGD") annual average flow replacement facility will have two processes generating

effluent discharges (plus a periodic cleaning-related maintenance discharge), which were

identified as potentially requiring treatment to meet TSS and iron standards

.

6.

Pursuant to the site-specific rule codified at Section 304

.206 of the

regulations, the existing facility has no effluent limitations for TSS and iron . The Board

granted this site specific relief in 1984 as follows :

Section 304 .206

. Alton Water Company Plant Discharges .

4

---

This Section applies to the existing 18

.3 million gallons per day potable drinking

water treatment plant owned by the Alton Water Company which is located at,

and discharges into, river mile 204

.4 on the Mississippi River . Such discharges

shall not be subject to the effluent standards for total suspended solids and total

iron of 35 111 . Adm . Code 304.124

.

35 111 . Adm . Code 304.206

.

A copy of the Board's final Opinion and Order in that case, PCB 82-3, is appended

hereto as Attachment C

.

The Board subsequently granted relief from its general

industrial effluent standards to all of the other public water supply facilities located on

the River in Illinois that do not use lime to soften the raw water

-- i.e., Rock Island,

Moline and East St

. Louis . Copies of the Board's final Opinions and Orders in those

cases are appended hereto as Attachment D (Rock Island, PCB AS 91-13, October 19,

1995), Attachment E (East Moline, PCB AS 91-9, May 19, 1994) and Attachment F

(East St. Louis, PCB AS 91-11, May 20, 1993)

.

7.

Rock Island, East St

. Louis and East Moline all obtained adjusted

standards pursuant to Section 28

.3 of the Act, 415 III . Comp. Stat

. 5/28 .3 . Section 28 .3

was intended to prompt a quick resolution of existing public water supply facilities'

inability to meet the general effluent standards absent installation of potentially

economically infeasible technology and thus the filing deadline relief under Section 28

.3

has passed

. Nonetheless, the factors that the legislature directed the Board to consider

under Section 28

.3 continue to be relevant to public water supply facilities which do not

use lime softening and receive their raw water supply from the highly turbid and variable

River

. These highly relevant Section 28 .3 factors include :

An adjusted standard . . .

shall be based upon water quality effects, actual and

potential stream uses, and economic considerations, including those of the

5

---

discharger and those affected by the discharge

. . . . Justification based upon

discharge impact shall include, as a minimum, an evaluation of receiving stream

ratios, known stream uses, accessibility to stream and side land use activities

(residential, commercial, agricultural, industrial, recreational), frequency and

extent of discharges, inspections of unnatural bottom deposits, odors, unnatural

floating material or color, stream morphology and results of stream chemical

analyses.

Where minimal impact cannot be established, justification shall also

include evaluations of stream sediment analyses, biological surveys (including

habitat assessment), and thorough stream chemical analyses that may include but

are not limited to analysis of parameters regulated in 35 Ill . Adm . Code 302.

415 111 . Comp. Stat. 5/28.3 .

The National Pollution Discharge Elimination System ("NPDES") permit

for the existing facility requires daily monitoring of flow and monthly monitoring of pH,

TSS, iron and total residual chlorine ("TRC").

An effluent limitation exists for pH of

6 .0 to 9 .0 standard units ("SU") .

As a result of the site-specific rule applicable to the

existing facility, no treatment is required for the discharge effluent except for

dechlorination, which was implemented in November 1998 as required by the facility's

NPDES permit .

9.

The existing facility directly returns to the River the residual natural silts

and sediments contained in the raw River water, along with a very small percentage of

water treatment additives used to treat the raw water

-- i.e., the percentage of naturally-

occurring material in the total solids returned to the River is typically 91% or greater

.

SSIS at 6-2

. The remaining 8 .7% of total solids are contributed by the coagulant

. Of

this, only a trace amount is comprised of any of metals of concern (aluminum), and this

is only about one third of one percent (0.348 %n)

of the facility's solids discharge

. This

percentage is comparable to that achieved at the Water Company's East St

. Louis water

treatment facility, which uses these same coagulants and, pursuant to an adjusted standard

6

---

codified at 35 Ill . Adm . Code 304 .220, also returns its discharge solids to the River

.

The other 99 2/3 percent of the discharge solids are derived directly from the raw River

water or are from coagulant constituents that are not comprised of any of the metals of

concern

-- i.e.,

non-metal, biodegradable polymer constituents, and trace amounts of

inorganics (primarily sulfates) . SSIS at 6-2. In addition, the mussel habitat

characterization found that the area does not support any unionid communities (Id. at

4-4 and 5-21), and that there are no discernable impacts from silt deposition (Id. at 5-

10) . The Discharge TSS Modeling Evaluation also found no adverse impacts from the

discharge of the residuals into the River

.

Id.

at 5-22 to 5-23 .

10. Rather than subject the replacement facility to Board regulations with

which no other similarly situated public water supply facility has ever been required to

comply, an adjusted standard should be developed through analysis of the site-specific -

factors specified in Sections 28

.1, 27(a) and 28.3 of the Act and pursuant to the Best

Professional Judgment ("BPJ") requirements of Section 402(a) of the federal Clean Water

Act ("CWA"), 33 U .S .C. § 1342(a))'

-"

BPJ for public water supply facilities is established by applying the factors listed in 40 C .F.R . § 125 .3(c)(2),

which applies to facilities or categories of facilities for which there are no federal effluent standards . BP) is reached by

considering : (i) the appropriate technology for the category or class of point sources of which the applicant is a member

(e .g ., public water supplies on large, turbid rivers), and (ii) any unique factors relating to the applicant (e

.g ., it does not

use lime softening)

. Two other elements must also be considered in determining BPJ : best practicable control lectmoingy

currently available ("BPT") and best conventional pollutant control technology ('BCT")

. 40 C .F

.R

. § 125 .3(d) .

BPT factors are

: (i) the total cost of application of technology in relation to the effluent reduction benefits to be achievd

from such application ; (ii) the age of equipment and facilities involved

; (iii) the process employed ; (iv) the engineering

aspects of the application of various types of control techniques

; (v) process changes ; and (vi) non-water quality

environmental impact (including energy requirements) . 40 C .F .R . § 125 .3(d)(1)

. The BCT analysis includes the BPT

issues and one additional factor

: the comparison of the cost and level of reduction of such pollutants from the discharge

from publicly owned treatment works to the cost and level of reduction of such pollutants Frunra ctass is categwytif

industrial sources .

7

---

INFORMATIONALREQUIREMENTS

Description of the Regulation of General Applicability

11 . Section 106 .705(a) of the Procedural Rules provides that the petition must

describe the standard from which

an adjusted standard is sought . This shall include the

Administrative Code citation to the regulation of general applicability imposing the

standard as well as the effective date of that regulation

.

The regulation of general

applicability, Section 304 .124 of the Board's Water Pollution Regulations, 35 III . Adm .

Code 304 .124, establishes effluent standards which are applicable to dischargers to the

waters of the State of Illinois .

The Water Company seeks an adjusted standard for

discharges of iron and TSS . Section 304 .124 establishes a discharge limitation of 2 mg/I

for total iron and 15 mg/I for TSS . Section 304

.106 of the Board's effluent standards,

35 III . Adm . Code 304 .106, provides in relevant part that no effluent shall contain

settleable solids or sludge solids, and that turbidity must be reduced below obvious

levels.

The analogous water quality provision, Section 302 .203, 35 111 . Adm . Code

302.203, provides in relevant part that waters of the State shall be free from sludge or

bottom deposits and turbidity of other than natural origin

.

12 . The effluent limitations provided in Section 304.124

apply to all discharges

to waters of the State of Illinois, regardless of the nature of the receiving stream or the

environmental impact of the discharge

. The Board's effluent standards, including the

iron and TSS limitations now codified at Section 304

.124, became effective on January

6, 1972 . See Opinion of the Board, PCB R 70-8

et al., Jan . 6, 1972, a copy of which

8

---

is appended hereto as Attachment G .=' These standards were not developed on an

industrial category basis like the subsequent federal effluent standards . As a result,

certain dischargers, such as public water supplies located on large rivers, are subject to

two potentially contradictory standards for obtaining their NPDES discharge permit -- the

generally applicable Illinois effluent standards and the federal BPJ requirement under the

CWA

.

°] As noted on page 1, above, the Water Company seeks relief, as the Board deems necessary, from the effluent standard

of Section 304 .106 and the water quality standard of Section 302 .203 . In 1972, the Board promulgated a general effluent

standard for "Offensive Discharges," now codified at Section 304 .106 . Opinion of the Board, PCB R 70-8 ei al., fan .

6, 1972, at 5 ; 35 111 Adm . Code 304 .106 . This effluent standard was adopted from the earlier Sanitary Water Board

prohibition on the discharge of nuisance materials to any waters, which required the equivalent of primary treatment for

all discharges . Opinion of the Board, PCB R 70-8 el al., Ian. 6, 1972, at 5 . In support of the prohibition of Offensive

Discharges, the Board stated that "lal nuisance anywhere is unacceptable ." Id.

Specifically, the Offensive Discharge effluent standard, now codified at Section 304 .106, provides that :

No effluent shall contain settleable solids, floating debris, visible oil, grease, scum

or sludge solids . Color, odor and turbidity must be reduced to below obvious

levels .

35 111 . Adm . Code 304 .106 .

In the same 1972 rulemaking, the Board adopted an analogous water quality standard for "Offensive Conditions," which

similarly restricted nuisance conditions, and which is now codified at Section 302 .203

:

Waters of the State shall be free from sludge or bottom deposits, floating debris,

visible oil, odor, plant or algal growth, color or turbidity of other than natural

origin .

35 111, Adm . Code 302 .203 .

In 1990, the Board amended the Offensive Conditions water quality standard . See Opinion and Order of the

Board, PCB R88-21(A), ]an . 25, L990 . The Board determined that the water quality standard of Section 302

.203 is

equivalent to ("no more restrictive than") the effluent standard of Section 304

.106

.

Id. at 12 . The proposed discharge

will not create a "nuisance" as understood by the Board when it adopted the Offensive Conditions and Offensive

Discharge rule . The Water Company's Particle Deposition Study shows that the proposed discharge will not result in

an Offensive Condition as defined in Section 302 .203 . SSIS at 5-22 to 5-23

; Appendix F.

9

---

Relationship of the Regulation of General

Applicabilityto Federal Environmental Requirements

13 . Section 106

.705(b) of the Procedural Rules provides that the petition must

state whether the regulation of general applicability was promulgated to implement, in

whole or in part, the requirements of certain federal environmental laws or programs

under such laws . The effluent standards were reviewed in 1975 and 1976 by the Illinois

Effluent Standards Advisory Group ("IESAG"), which was formed at the request of the

Director of the State of Illinois Institute for Environmental Quality, which was

subsequently renamed the Illinois Department of Energy and Natural Resources . IESAG

has concisely explained the ways in which the Illinois effluent standards differ from the

subsequently enacted federal effluent discharge control legislation

:

[The federal]

. . . law required . . . that the U .S . Environmental Protection

Agency promulgate by industrial category (and subcategory if necessary)

effluent limitations guidelines for existing sources and standards of

performance for new sources

. Thus, PL 92-500 [the federal law] differs

from Illinois law, in requiring industrial category-specific guidelines

whereas the Illinois standards apply equally to all dischargers .

Evaluation of Effluent Regulations of the State of Illinois ("IESAG Evaluation"), Illinois

Institute for Environmental Quality, Document No . 76121, (1976), Attachment H hereto,

at pp . 4-5

14 .

The United States Environmental Protection Agency ("U .S . EPA") has

never enacted effluent standards for public water supply treatment facilities .

See, e.g.,

Opinion and Order of the Board, PCB R85-11, February 2, 1989, attachment I hereto,

at p. 10 . As a result, the Illinois effluent limitations and subsequent amendments thereto,

including the standards for iron and TSS for which the Water Company seeks an adjusted

standard, were not promulgated to implement, either in whole or in part, the

10

---

requirements of the federal Clean Water Act, the NPDES program, or any other federal

environmental laws or programs . Similarly, U .S . EPA has never enacted federal

pretreatment regulations for public water supply treatment facilities which discharge to

publicly owned treatment works

. The Illinois legislature implicitly recognized the lack

of categorical pretreatment standards by enacting Section 28

.3 of the Act

.

Level of Justification Required for anAdjusted Standard

15 . Section 106.705(c) of the Procedural Rules provides that the petition must

state the level of justification as well as other information or requirements necessary for

an adjusted standard as specified by the regulation of general applicability, or a statement

that the regulation of general applicability does not specify a level of justification or other

requirements .

16.

The regulation of general applicability -- that is, the Board's effluent

regulations, including Sections 304 .124 and 304

.106, and water quality criteria of Section

302.203 -- does not specify a level of justification or other requirement for an adjusted

standard

.

17.

The level of justification required for the adjusted standard sought by the

Water Company is, however, specified at Section 28

.1(c) of the Act :

factors relating to [the Water Company] are substantially and significantly

different from the factors relied upon by the Board in adopting the general

regulation applicable to [all industrial dischargers] ;5'

2.

the existence of those factors justifies an adjusted standard ;

-"

As noted in paragraph 7 above, Section 28 .3(c) of the Act lists a number of the unique (actors that are relevant

to determining adjusted standard relief for public water supply facilities

. As discussed below, the Water Company

addressed all of these factors in detail in the SSIS .

11

---

3 .

the requested standard will not result in environmental or health effects

substantially and significantly more adverse than the effects considered by

the Board in adopting the rule of general applicability ; and

4.

the adjusted standard is consistent with any applicable federal law

.

415 Ill . Comp . Stat

. 5/28 .1(c)

.

Nature of the Activityfor Which the Proposed Adjusted Standard is Sought

18. Section 106

.705(d) of the Procedural Rules provides that the petition must

describe the nature of the petitioner's activity which is the subject of the proposed

adjusted standard . The operations of the replacement facility will be very similar to the

existing facility and, except for being moved up to the bluff to reduce future flooding,

will be in the same general location . As a result, operational information regarding the

existing facility will also be relevant to the operations of the replacement facility

. The

SSIS provides a detailed description of both current and anticipated future operations as

a prerequisite for the SSIS' analysis of their site specific impacts

.

Much of the

information in the following sections is also addressed in the SS1S, and the following

sections will provide citations to the SSIS for reference and completeness .

19. The Water Company's existing public water supply water treatment facility

is located along the River at approximately River Mile 204 in Alton, Illinois . The River

is the sole public water supply source for the community . There are approximately 265

miles of water main in the distribution system and the system serves a population of

approximately 76,430 people and 17,480 households/businesses

.

20.

The existing facility has been supplying water to the City of Alton and

nearby residents -- and discharging to the River in the same general location -- since the

12

---

18900'

The original Main Service facility was expanded in the 1930s to 13

.3 MGD .

An additional 5 MGD High Service facility was constructed in 1981, at the same site

.

The Main Service facility consists of two mixing tanks, one circular clarifier, two

rectangular sedimentation basins, sand filters, 650,000 gallons of filtered water storage

and raw and filtered water pumping stations

. The High Service facility consists of one

mixing tank, two clarifiers, four filters, raw, transfer, and filtered water pump stations,

and one million gallons of filtered water storage

. The two facilities share a common side

channel intake structure at the River

. At the existing facility, water is taken from the

River through a side channel intake into two wet wells in the facility Gate House

. Two

travelling screens are located at these wet wells to strain out debris

. The screens are

regularly cleaned with finished water, and the expelled materials and screen wash water

are returned directly to the River

. Three pumping units transmit raw water to the two

flocculation tanks in the Main Service facility

. Three pumping units convey raw water

to the mixing tank in the High Service facility.

21 .

At the Main Service facility, open rectangular steel channels convey raw

water from the mixing tanks to the circular clarifier where sand and heavy sediment are

removed .

From the clarifier, the water is split into approximately equal proportions

.

The clarified water enters the lower chamber of each of the two parallel rectangular

sedimentation basins

. From the lower chamber, the water rises to the upper chamber

.

From the sedimentation basins the treated water enters the former recarbonation tank

w

In the event that adjusted standard relief is granted in this proceeding, the Water Company plans to continue

to use the same general area of the River for the replacement facility discharge

.

13

---

where additional treatment chemicals are added

. From the recarbonation tank, the

treated water flows to nine sand filters .

22.

At the High Service facility, flocculation occurs in the mixing tank in

which one side wall mixer is mounted

. From the mixing tank, water flows by gravity

to two Claricone sludge blanket type clarifiers . From the clarifiers, water flows by

gravity to fours/and/anthracite filters . Treatment to aid in sedimentation begins as water

leaves the intake, where the primary coagulant, Clar'lon®, is added to coagulate the

sediment in the water

. Powdered activated carbon may be added at the intake in order

to control odor and taste. Lime or caustic may be added at this point as well when

alkalinity is low . Based on historical records, alkalinity is low during high flows or high

turbidities . In the mixing tanks, the retention time and gentle mixing promote

coagulation . The coagulated sediment will then settle in the clarifier and sedimentation

basins in the Main Service facility or in the Claricone clarifiers at the High Service

facility

. Disinfection is provided by chlorine addition immediately after flocculation and

again after clarification in the sedimentation basins

. Ammonia is added before

clarification to promote chloramine formation . SSIS at 3-1 and 3-2 .

Current Effluent Discharges

23. As discussed in detail in paragraph 6, the existing facility discharges its

effluent directly to the River pursuant to the site specific rule codified at 35 Ill . Adm .

Code 304.206 . Effluent discharges from the existing facility's treatment system are

operational and maintenance discharges . Operational discharges are those flows that

occur regularly, on a daily or weekly basis, during periods when the facility is treating

14

---

raw water . Maintenance discharges occur during the cleaning of accumulated solids in

the clarifier, sedimentation basins, and mixing tanks

. Residuals from the existing Alton

facility are stored in a dedicated wet well at the Gate House . They can be discharged

by gravity or can be discharged by using a dedicated transfer pump during high river

levels. All facility residuals are discharged from this location . SSIS at 3-2.

24. The two Main Service operational discharges consist of intermittent

clarifier blowdown and filter backwash . Id

. Approximately 30,000 gallons per day

("gpd") of blowdown are discharged two days a week from the clarifier

; however, the

frequency and duration of blowdowns are variable, because they are dictated by raw

water turbidity . In addition, approximately 630,000 gpd of backwash are discharged

from nine sand filters used at the Main Service facility . The sand filters used at the

Main Service facility are backwashed daily for approximately 15 minutes

. Each filter

runs approximately 24 to 30 hours between backwashings . Id.

25.

Maintenance discharges from the Main Service facility arise from cleaning,

three times per year, accumulated solids from the clarifier, sedimentation basins, and

mixing tanks . SSIS at 3-3

. The two sedimentation basins do not include sludge removal

equipment, so the basins are dewatered prior to manual sludge removal

. Approximately

72,000 gpd of carrier water with residuals are discharged during the five day long

maintenance activity (i .e.,

total annual discharge is 1,080,000 gallons) . Id.

26. The High Service operational discharges include Claricone clarifier

blowdown, filter backwash and cleaning of the Claricone clarifier . Operators release

clarifier residuals based on the condition and thickness of the sludge blanket

.

15

---

Approximately 12,000 gpd of carrier water with residuals are discharged from the

clarifer. Two of the four sand/anthracite filters at the High Service facility are

backwashed daily for approximately 15 minutes. Each filter runs approximately 48 hours

between backwashings . Approximately 210,000 gpd of backwash are discharged from

the filters. Finally, the Claricone clarifiers are cleaned once a year . Approximately

24,000 gpd of cleaning residuals are discharged during two days of maintenance activity .

SSIS at 3-3 .

Existing Facility History and Replacement Facility

27. The existing facility is located within a physically restricted parcel of level

land approximately twenty feet above the normal River summer level . The facility is

bounded directly to the northeast by the Norfolk Southern Railroad and Illinois Route 100

and bounded to the southwest by the River . Across the railroad and highway corridor,

the land slopes steeply up to the bluffs overlooking the River

. Due to its proximity to

the River, the existing facility is subject to occasional flooding

. In August 1993, the

entire site was flooded and both the Main Service and High Service facilities were out

of service for four days . Consumers in the Alton service area were required to boil tap

water over a ten day period

. Limited service was provided initially by the High Service

facility . Full service was reinstated soon thereafter . Sandbagging to protect the facility

from flooding was required in 1973, 1986, 1993, 1994 and 1995 . SSIS at 3-3 .

28 . In order to avoid future flooding and to replace the aged existing facility,

the replacement facility will be constructed approximately sixty (60) feet higher than the

existing facility on property located directly across Illinois Route 100 in Alton, Illinois

.

16

---

The Water Company evaluated nine sites for replacing the water supply facility before

choosing this alternative . The site was selected because of its industrial zoning,

proximity to the existing facility and infrastructure, favorable site topography for

construction, size, and proximity to the existing raw water intake location . SSIS at 3-4 .

Replacement Facility Design, Capacity, Flows and Discharges

29. The replacement facility is designed to treat sufficient raw water to make

available, on average, 10 .5 MGD'-' of potable water for the Alton area. The hydraulic

design capacity of the replacement facility is 16 MGD .

Based on an internal facility

demand

(i.e.,

not going into the Water Company's distribution system) of 1 MGD (for

Superpulsator® blowdowns, filter backwash, etc.), at a peak potable water demand of 15

MGD, the actual distribution capacity is 15 MGD

. The estimated average proportional

internal facility demand is 0 .7 MGD for the average potable water flow of 10 .5 MGD

.

The combined flow, 10.5

+ 0.7

= 11 .2 MGD, was therefore used for purposes of

evaluating potential discharge impacts in Section 5

.0 of the SSIS, discussed below .

30 . The replacement facility will consist of a new raw water intake and

pumping station, clarification and filtration units, filtered water storage, and chemical

feed facilities

. Clarification of raw water at the replacement facility will be provided by

four Superpulsator® units (high rate sludge-blanket type clarifiers manufactured by Infilco

Degremont, Inc .)

. SSIS at 3-4 and 3-5 .

'-'

The 10 .5 MGD value was selected as the average daily potable water demand based on projections of future

water demand conducted as part of the Water Company's Comprehensive Planning Study (SSIS at Appendix E)

. The

study estimated water demand by using predicted demographic trends through the year 2010, which predict a modest

growth in population in Madison County

. Population growth is likely to be influenced by the newly constructed multi-

lane highway bridge across the River at Alton, highway improvements, continued downtown development in Alton, and

increased tourist attractions .

17

---

31 .

Filtration will be provided by six gravity dual media (sand/granular

activated carbon) units

. Each filter will be equipped with a rate of flow controller, filter

to waste piping, an air wash system and automatic monitors for flow rate, head loss and

water level . SSIS at 3-5 .

32

. One additional maintenance discharge will occur at the new facility . This

discharge will be from periodic wet well cleaning (once every five (5) years)

. This

discharge, however, will be minor in amount and duration, will use raw water for

cleaning, and will not contain process-generated chemicals (i .e., coagulant) and,

therefore, it has been eliminated from further consideration in analysis of potential new

facility impacts . Id.

33

. Operation of the replacement facility will be highly automated . The

required equipment will include an analyzer, controller, flow proportioning system, an

automatic switchover device, diffuser, scale for cylinders, and an SO 2

detector. Id . at

3-6. Residual discharges from the replacement facility will consist of Superpulsator

®

blowdown, filter backwash, and Superpulsator® cleaning water. Id . at 3-5

. The quantity

of residuals discharged will be equal to the sum of the suspended solids introduced in the

influent River water and those added as coagulant aids . Id.

34 . Chlorine may be used at a variety of points within the replacement facility

.

Chlorine may be added on a seasonal basis prior to Superpulsator

® or filter backwash

treatments

. Ammonia and chlorine will be applied at rates necessary to achieve a TRC

sufficient for disinfection in the treatment process and to provide a final TRC for

disinfection in the potable water distribution system

. The Water Company will use the

18

---

process of chloramination at the replacement facility .

Ammonia is applied just after

chlorine treatment in order to form chloramines rather than free chlorine residual

.

Chloramines may be added to the raw water prior to the Superpulsator ®. Based on

similar treatment facilities, a TRC of 3 .0 to 4

.0 mg/I could be expected at this point .

Alternatively, if chlorine is added, the Superpulsator ® TRC could range from 1 .0 to 1 .5

mg/1 . The settled solids will be continuously removed from the Superpulsator ® and

routed to the effluent discharge . Id. at 3-5 and 3-6 .

35 . Water from the Superpulsator®

will flow to six carbon/sand dual media

filter units. This filtration will cause substantial reduction in free chlorine residuals and

TRC. TRC would be expected in the filter backwash water, which constitutes nearly half

of the total effluent discharge

.

Id .

Chlorine and ammonia will be applied to the filtrate

to maintain a disinfectant residual in the potable water distribution system ; however,

these application points will not affect the discharge, because the discharge stream is split

away prior to this part of the process . Id. at 3-6 .

36.

The replacement facility will prevent unacceptable TRC concentrations in

the effluent discharge through dechlorination with sulfur dioxide

. Two dechlorination

systems will be used to treat the Superpulsator®

and filter backwash discharges,

respectively . Separation of the filter backwash water from the other effluent volumes

will allow the Water Company to apply dosages that are appropriate for the residual

chlorine in each stream . SSIS at 3-6.

19

---

Characteristics of Replacement Facility Site

37 . The replacement facility site consists of approximately 22 acres located

within the City of Alton, Illinois in Madison County; the suitable area for construction

is limited due to existing topography

. Alton is located in southwestern Illinois on a bend

in the Mississippi River north of St . Louis, Missouri

. The property is a former quarry

site, with residential subdivisions located along the western and northeastern corners of

the property . The site is composed of both hilly and flat areas

. The central flat portion

of the site, which is the old quarry floor, is largely bedrock with sparsely vegetated open

areas

. Portions of the site are covered with trees and woody vegetation overlying quarry

debris. SSIS at 4-2

.

38 . 18 acres of the area are zoned M-2, Heavy Industrial District

. The

remaining four acres are zoned residential and would need to be rezoned if construction

of treatment facilities were to occur

. In the immediate vicinity of the site, other zoned

uses include mostly residential areas

. The site is abutted by both single and multi-family

residences . Land uses near the site include moderate and higher income single family

residences, apartments and industrial sites

.

Barges tie up along the River banks just

downstream of this area prior to or after traveling through the Melvin Price Locks and

Dam . SSIS at 4-2.

20

---

Hydrologic Characterization of Mississippi River at Alton

39.

Hydrologic data are available for the River near Alton from four local

United States Geological Survey ("USGS") gaging stations

. The stations measure flow

emanating from a 171,300-171,500 square mile drainage basin

. Based on sixty (60)

years of USGS data, the average mean monthly flow of the River is 106,859 cubic feet

per second ("cfs") . Id . at 4-3

. Data were collected at USGS gaging station #05587500

(Alton) from April 1933 through September 1988 and at USGS gaging station #05587450

(Grafton) from October 1990 through September 1995, Recorded mean monthly flows

ranged from 20,200 to 469,300 cfs (July 1947 and July 1993, respectively)

. The

minimum seven day, ten year flow ("7Q10") is 21,500 cfs

. The data demonstrate that

March to June are typical peak flow months and August to January are lower flow

months . SSIS at 4-3

.

40.

River depths in the vicinity of the proposed facility range to 30 feet

. The

normal high water level for this section of the River is 419 feet above mean sea level

("MSL") with a low water level of 413 feet above MSL

. SSIS at 4-3 .

Water Quality of the Mississippi River at Alton

41 .

The raw water quality of the River at the intake point is highly variable

.

Based on data from the existing facility (January 1990 through December 1995), the

turbidity of the influent varies dramatically on a daily basis

. For example, in May 1990

the influent turbidity changed from 39 nephelometric units

("NTU")

to 964 NTU (the

ai

'the Alton stations (#05587500 and #05587550) were discontinued after 1989, following relocation and construction

of Lock and Dam No . 26

. Hydrologic and water quality measurements were resumed at the Grafton stations (#05587450

and #05587455) .

21

---

maximum value over the six-year period of record) during one month . The minimum

daily turbidity value for the period of record was 8 NTU in January 1994

. Similarly,

the mean of annual averages and the monthly averages differ substantially . The mean

of annual averages for the six year period of record is 90

NTU, while the maximum of

monthly averages is 430 NTU . SSIS at 3-6 .

42.

To account for the natural variability of River water quality, three River

turbidity conditions were evaluated for conceptual design purposes and to support the

potential impact evaluation conducted for the SSIS

. The turbidity values were correlated

to suspended solids concentrations ("mg/I TSS") using a ratio of 1 :2 NTU/TSS . The

ratio of turbidity to suspended solids in rivers similar to the Mississippi River ranges

from 1:1.8 to 1 :2. For purposes of the SSIS, in order to consider maximum solids

production, the ratio of 1 :2 was selected ." SSIS at 3-7 .

43. The long-term River water quality is represented by the mean of the annual

turbidity averages, or 90 NTU (180 mgll TSS) . Discharges calculated based on this

condition were used to design long-term treatment units, such as lagoons

. The medium

term River water quality is represented by the maximum of the monthly turbidity values

or 430 NTU (860 mg/I TSS) . Discharges calculated based on this condition were used

to design all the residual handling equipment such as belt filter presses

. The short term

River water quality is represented by the maximum daily value or 964

NTU (1928 mg/I

TSS)

. Residual discharges calculated based on this condition were used to design the

-°'

Due to the importance of this value for determining potential residual loads, this value was peer-reviewed by two

engineering firms

: Hazen & Sawyer and Burns and McDonnell .

22

---

initial equalization basins so that storage volume would be provided to handle this worst

case condition . SSIS at 3-7

.

44. The Company conducted modeling of anticipated exceedances of water

quality standards using the discharge values in paragraphs 29-36, above . These values

include discharge flows and concentrations under defined ambient flow TSS and flow

conditions- These values were used to model potential worst-case and average flow

scenarios to evaluate the potential for the discharged effluent to exceed Illinois Water

Quality or Effluent Standards

. SSIS at 3-7 .

45.

Water quality data were obtained from the USGS District Office in Rolla,

Missouri .

Data for TSS were available for the four USGS gaging stations noted in

paragraph 8, n .8, above. Data were available from two of the four gaging stations

(#05587450 and #05587455) in the period following the relocation and construction of

Lock and Dam No. 26

. The average mean monthly TSS value over the period from

October 1989 to September 1995 ranged from 29 to 605 mg/I with an average monthly

value of 171 mg/l . SSIS at 4-3

. The USGS District Office in Rolla also collected data

from individual sampling events . During the period after the relocation and construction

of Lock and Dam No

. 26, TSS concentrations for single grab samples ranged from 17

to 506 mg/I (January 1990 and April 1994, respectively) .''-n' SSIS at 4-4

. Despite the

greater range of TSS concentration for single grab samples, the mean value of TSS from

these data is 156 mg/l, which is consistent with the average monthly value of 171 mgll

10'

Data are available from both before and after the relocation and construction of Lock and Dam

No . 26,

from 1975

to 1994 . During the period prior to the relocation and construction

of Lock and Dam No

. 26, TSS in grab samples

ranged from 3 to 1,310 mg/l

(July 1987 and June 1981, respectively), with a mean value of

175 mg/1 .

23

---

and that found in a more intensive sample collection

.!" The raw intake TSS for the

current Alton facility (as estimated by turbidity) is 180 mg/L

. Therefore the four

estimates of annual average TSS at Alton (156, 171, 175, and 180 mg/L) are fairly

consistent and representative

. Id.

46. The data also suggest that TSS concentrations fluctuate seasonally

. Peak

months for TSS correlate with peak flow months

(i.e., March through June)

. March has

the highest TSS, due to spring thawing action and subsequent mobilization of eroded

clays and silts in the watershed

. SSIS at 4-4 . The applicable regulations do not specify

any water quality standard for TSS, and the general use water quality standard for total

dissolved solids ("TDS")

is 1,000 mg/1 . 35 Ill . Adm . Code 302 .208.

47.

Dissolved iron concentrations in the River near Alton were also available

from USGS data records

. The daily values over the period from March 1989 through

September 1994 (based on data collected on individual days in a scheduled mouth)-ranged

from 3 to 710 micrograms per liter ("ug/1") (May 1993 and November 1992,

respectively), with an average value of 36 ug/1

.'-

2'

SSIS at 4-4 . The general use water

quality standard for dissolved iron is I mg/I

-- i .e.,

1,000 ug/l . 35 111 . Adm . Code

302

.208(g) .

USGS records of daily aluminum values from March 1989 through

September 1994 ranged from 10 to 220 ug/1 (the latter on only one occasion in

"The mean value of TSS from grab sample data both before and after the relocation and construction of Lock and Dam

No . 26 (the years 1975 m 1994) is 175 mg/l

. which also is consistent with the average monthly value of 171 mg/1 .

127 The daily values for dissolved iron over the period both before and after the relocation and construction of Lock and

Dam No . 26, based on sampling from January 1975 through September 1994 ranged from 3 to 1 .000 ug/l (July 1985

and January 1985, respectively), with an average value of 63 ug/l .

24

---

November 1993), with an average of 26 ug/1 .'-"

SSIS at 4-4 . Illinois has no water

quality standards for aluminum .

Mussel Habitat Near the Replacement Facility Site

48 . Discussions with Illinois EPA in August, 1997 identified the need for a

characterization of the potential mussel habitat near River Mile 204 in the vicinity of the

proposed intake and discharge pipes . Based on a protocol reviewed and approved by

Illinois EPA, the survey was undertaken to characterize the potential mussel habitat found

offshore of the replacement facility site and to determine the potential presence of

protected (i.e., threatened and endangered) mussel species . Sampling was conducted at

six (6) transects bracketing the existing Alton facility

. The upstream limit was 100

meters upstream of the existing intake location and the downstream limit was 400 meters

below the proposed discharge location . Diver surveys were conducted along these six

transects . SSIS at 4-5 .

49 .

The survey results show that the area does not support a unionid

community .

See SSIS

at Appendix B ("Unionid Survey"), p . 5 . No living animals were

found in the study area and only the shells of eight species were collected . None of the

collected species were federal or Illinois protected mussel species

. Only the shells of

Leptodea fragilis were represented by freshly dead shells

; the remaining shells were

weathered or sub-fossil

. SSIS at 4-5. The Unionid Survey concludes :

"Given that

habitat conditions within the study area are unsuitable for unionid colonization, and no

1i" Daily aluminum values from both before and after the relocation and construction of Lock and Dam No

. 26,

including samples between

November 1982 and September 1994, also ranged from 10 to 220 ugll, but with an average

of 42 ug/I .

25

---

unionids were found, construction and operation of the water intake and treatment

discharge should not impact unionids ." Id. at Appendix B, p . 8 . A follow-up

communication from the consultant who performed the study confirmed that both

upstream and downstream of the facility, silt deposition was similar at comparable

depths . Id . at 5-16 to 5-17 .

Compliance Alternatives and Efforts Which

Would Be Necessary to Achieve Compliance

50 .

Section 106 .705(e) of the Procedural Rules provides that the petition must

describe the efforts which would be necessary if the petitioner were to comply with the

regulation of general applicability .

Further, the petition must discuss all compliance

alternatives, with the corresponding costs for each alternative . The discussion of costs

shall include the overall capital costs as well as the annualized capital and operating

costs . Illinois EPA suggested, and the Water Company agrees, that the SSIS should

evaluate treatment technologies for residual control in detail and determine which

treatment

technology provides the best degree of treatment ("BDT") for the

Superpulsator® and filter residuals using the factors identified in 35 I11

. Adm . Code

304

.102 .'!-^t

N,

This Board regulation also encompasses several integral BP3 factors, including examination of the process

employed, the engineering aspects of the application of various types of

control techniques, process changes, and a cost-

benefit analysis .

It requires that dischargers must provide the Best Degree of Treatment ("BDT")

consistent with

technological feasibility, economic reasonableness and sound engineering judgment

. BDT factors considered in this

context are : 1)

the degree of waste reduction that can be achieved by process change, improved housekeeping and

recovery of individual waste components for reuse ; and 2) whether individual process wastewater streams should be

segregated or combined .

26

---

51 .

As a first step in the determination of BDT,

it is necessary to identify

available treatment technologies and select appropriate candidate technologies for

application at the proposed replacement site . The SSIS identifies a number of residuals

management control technologies as available treatment technologies for residual control

.

One major consideration in the selection of candidate technologies is the turbid and

hydrologically variable nature of the River near Alton

. This variability is documented

in Section 4.3 of

the SSIS, based on over 20 years of USGS data and available intake

water turbidity of the current Alton facility

. The records indicate average TSS levels of

180 mg/l, average turbidity at 90 NTU and extremely dynamic variation on a daily,

seasonal, and yearly basis . These environmental conditions constitute a scenario which

had been recognized as problematic during the development of proposed national

guidelines .

The fact that EPA never promulgated industry-wide effluent standards

indicates that water supply facilities and their source waters are too different for industry-

wide standards to be useful

. Consequently, ability to deal with a highly dynamic TSS

load is an important selection factor

. SSIS at 6-2 .

52 .

Six technologies were screened to select appropriate candidate technologies

for application at the replacement facility site

: 1) direct discharge to the River

; 2) land

application

; 3) temporary storage and dewatering in lagoons, and off-site landflling

; 4)

permanent storage in monofills

; 5) discharge to the Alton Publicly Owned Treatment

Works ("POTW")

; and 6) sludge dewatering and subsequent landfilling

. SSIS at 6-2 to

6-7

. The technologies were screened based on site-specific factors including the nature

27

---

and quantity of settled solids produced, climatic factors, land availability, and past

performance history of various technologies

.

53 .

The SSIS provides the following discussion of the respective control

technologies .

1)

Direct Discharge to River

Direct discharge of all residuals from the proposed replacement

facility to the River will serve as the base case

. It is predicted that an

estimated average of 3,358 dry tons of solids will be discharged from the

replacement facility each year

. Of the total solids discharged annually

(based on a coagulant dosage rate of 40 ppm), approximately 8

.7 percent,

or 580,000 pounds, are coagulant residuals

. That is, they are produced

by the addition of the chemical coagulants themselves

. Of this amount,

metals only constitute a small fraction

For example, Clar*Ion ®

is

approximately 20 percent organic polymer and about 80 percent alum, of

which aluminum accounts for 5 percent (based on molecular weight)

.

Therefore, the amount of coagulant-based aluminum in the effluent is 8

.7

percent X 0 .8 X 0

.05 = 0

.348 percent, which constitutes a very minor

percentage (and is comparable to the East St

. Louis drinking water

facility)

. As noted above, the production rates of total suspended solids

are highly variable, depending on River suspended solids

. The current

practice of direct discharge to the River provides operational flexibility

28

---

when dealing with the wide variations expected in the rate of solids

generation,

2)

Land Application

The management of residuals by land application includes

temporary storage of residuals at the proposed replacement facility site,

followed by transportation and application of residuals to local agricultural

land

.

The residuals would be applied either as a liquid form or as

dewatered residuals termed "cake." For the former application method,

liquid residuals (e.g., 5% solids) would be stored, loaded into 6,000

gallon tanker trucks and hauled to the application area .

The liquid

residuals would then be injected into the soil (fallow or with crops) by

specialized equipment or applied to the soil surface with spray equipment

.

Residuals applied to the soil surface would then be disked or plowed into

the soil within 24 hours of application . Land application of liquid

residuals (including hauling and application) can cost between $70 to $300

per dry ton (depending on the hauling distance)

. Since significant

agricultural land is not available in the immediate vicinity of the facility

and is less likely to be available in the future (as there is an increasing

trend for residential growth in the area), the high end of the cost range

was considered more appropriate

. The total cost of land application of

liquid residuals, including on-site holding facilities, was considered

29

---

comparable to the cost of dewatering lagoons or belt press dewatering

followed by landfilling (see

Option 6B or 6C discussed below) .

Application of

dewatered cake was also considered

. Dewatered

residuals

(e.g.,

25% solids) would be stored, loaded into lined dump

trucks and hauled to the application area

. Weather permitting (i .e., ground

not frozen or saturated), the residuals could then be applied in thin layers

to the soil directly from the truck or by using equipment like a manure

spreader

. Similar to the liquid form, the cake residuals would then be

incorporated into the soil via disking or plowing

.

Land application of

dewatered residuals (including hauling and application) can cost between

$20 and $68 per dry ton

. This method is very similar to that

of Option

6C (i.e.,

landfill disposal after mechanical dewatering), except that the

final destination is widespread application to farm fields rather than to a

landfill facility .

For either land application method, weather, public acceptance,

permit requirements, and land availability can limit feasibility

. In the

Alton area, inclement weather does not seriously limit land application,

but application or injection to frozen soil may not be feasible for some

winter months

. Biosolids from the Godfrey wastewater treatment plant

have been successfully applied to nearby land ten months of the year for

the last 10 years

; however, public acceptance of

residuals may be

considerably less than for biosolids (considered a soil enhancement due to

30

---

carbon and nutrient content) because the residuals add little to (or detract

from) soil fertility

.

Land application is further complicated by permit

regulations concerning the content of applied materials

.

Based on the estimated average annual mass of approximately

3,358 tons of residual solids from outfalls potentially containing coagulant

residuals, and a representative drinking water facility residual metals

content, an estimate of annual metals loading was made

.

Due to the

manganese content of these solids (1760 ppm) and the Illinois (35 Ill

.

Adm . Code 391

.420(c)) lifetime recommended cumulative mass loading

of 900 pounds of manganese per acre, 263 acres acquired every twenty

years for land application of these residuals to soils would be required

.

Potential concerns with other heavy metals and elements may also exist in

a land application scenario

. Due to the potentially large amount of land

required for every twenty years of operation (based on the maximum

potential manganese load), this technology would be less preferable

.

While land application of residuals is technically feasible, it is

associated with considerable uncertainty, due to the highly variable nature

of the River and the resulting variability of the residuals

. Further, the

potential costs appear to be similar to other more conventional residuals

management techniques

.

Given these factors, land application was

eliminated from further consideration

.

31

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3)

Temporary Storage and Dewatering in Lagoons, and Offsite Landfilling

This technology would involve the construction of on-site lagoons

for dewatering of the water treatment residuals

. Residuals flow would be

diverted into the dewatering lagoons and would be dewatered to

approximately 4% solids .

Then, the residuals would be removed and

further dewatered by a mechanical dewatering system to approximately

25% solids .

Following the second dewatering, the residuals would be

shipped to an offsite landfill .

4)

Permanent Storage in Monofills

This technology involves the construction of impoundments for

permanent storage of the residual solids

. The supernatant from the

impoundment can either be recycled to the head of the treatment facility

or it could be treated if necessary prior to discharge

. Based on the

average loading of 92 tons of wet residuals (10% solids) per day over a

typical 20 year operating period, a 40-acre monofill (14 foot depth) would

be required

. The proposed Alton facility property is not large enough for

such a facility

. Additional farmland offsite would have to be purchased

(at $6,000 to $10,000 per acre) to implement this option

. However, the

construction of a large, lined impoundment would cost at least $20

million, based on preliminary estimates .

Annual operation and

maintenance costs would be approximately $1

.3 million .

Further

drawbacks of this technology are that disposal in monofills will likely limit

32

---

the future use of the land and replacement monofills will be continually

required . Due to these factors, this technology is less preferable and has

been eliminated from further consideration .

5)

Discharge to Alton POTW

This option was investigated because it is commonly used by many

other potential NPDES dischargers ; however, the estimated flow and mass

of solids could not be treated at the relatively small POTW without POTW

expansion. The flexibility of POTW future operations would be severely

curtailed by accepting the water treatment facility residuals

. This option

has been explored on a preliminary basis with the Alton POTW staff who

have indicated that it is not feasible, based on potential hydraulic overload

of the adjacent sewer system, inadequate slope of the inceptor sewer,

elimination of the POTW's reserve capacity, and a quadrupling of the

solids loading (see letter from James Blaine to Kim Gardner in Appendix

A of the SSIS) .

The cost and technical feasibility of expansion of the POTW would

be similar to that of the petitioner constructing an on-site treatment facility

(such as the lagoon or belt press systems described here)

. Based on

consideration of the above factors, the POTW alternative is less preferable

and has been eliminated from further consideration

.

33

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6)

Sludge Dewatering and Subsequent Landfilling

In the screening of this family of technologies, non-mechanical and

mechanical dewatering techniques were reviewed as methods to prepare

the settled solids for offsite landfilling . Analysis of residuals handling

methods was based on industry experiences with alum-based residuals .

The proposed replacement facility will use a Clar'Ion® type alum-organic

polymer coagulant

. However, these methods are expected to be directly

applicable for treatment of Clar'Ion ®-based residuals .

6)A) Non-Mechanical Dewatering Processes

Either non-mechanical dewatering or mechanical dewatering (6B,

below) would be required for sludge dewatering and subsequent landfilling

(alternative 6) . Non-mechanical dewatering relies on drainage, decanting,

evaporation, and freezing processes . It is commonly used for dewatering

residuals, because of its simplicity and low operational costs . However,

non-mechanical processes are often subject to disruptions, due to climatic

fluctuations . Also, non-mechanical processes, perhaps even more so than

mechanical processes, could be plagued by having a low overload capacity

in the event that the rate of solids production were to be higher than

planned . Potential non-mechanical technologies include sand drying beds

and natural freeze-thaw drying beds

. The most efficient way to utilize a

drying bed system is to combine the freeze-thaw operation and

conventional sand drying operations during the course of the year

. This

34

---

option is similar in feasibility and cost to dewatering lagoons . However,

because it requires more area than dewatering lagoons and construction

costs are slightly higher (based on preliminary unit cost estimates), the

drying beds were not considered further .

6)B) Mechanical Dewatering Processes

A variety of mechanical dewatering methods have been screened

.

These processes are typically utilized in the water industry when

insufficient space is available for non-mechanical processes, high solids

concentrations are required for disposal, or when economics dictate their

use. Mechanical processes are less susceptible than non-mechanical

processes to inclement weather conditions

. The mechanical processes

included in this initial screening included vacuum filtration, filter pressing,

and centrifugation .

(i) In the vacuum filtration of residuals, a pre-coated rotating

drum surface is subjected to a vacuum to dewater the solids and to form

a cake . While vacuum filters have been routinely used in the wastewater

treatment industry, they have been reportedly evaluated only on pilot scale

for a sludge application due to problems with the conditioning chemicals

and the poor cake yield

. Therefore, no further consideration will be given

to vacuum filtration .

(ii) The belt filter press utilizes a well known and reliable

technology which has been used in the water industry for 25 years

.

35

---

Conditioning of residuals is required prior to press operations, and

operational data indicate that a solids concentration of 15 to 25 percent is

typically achieved . Despite the higher capital and operating costs

associated with a filter press compared to certain non-mechanical means,

the higher density sludge may translate into cost savings, due to the lower

volume of material to be landfilled

. As a result of the belt filter press

method's reliability and operational characteristics, further analysis was

performed for the filter press dewatering process and subsequent

landfilling of the dried cake .

Land is available at the proposed site to

house the required filter press units and associated tankage .

(iii) Centrifugation is the final mechanical process considered

.

Several different varieties of centrifuges are commercially available

.

However, the solid bowl centrifuge is the most common . These units can

operate in either the co-current or counter-current flow modes

.

Centrifuges have become an acceptable mechanical dewatering technology

and have proven to be capable of dewatering sludges . The centrifugation

and filter press technologies would require similar auxiliary equipment and

the resulting costs would likely be the same

. However, due to the fact

that mechanical belt filter presses are the more common technology, are

in use at other public water supply facilities to which Illinois-American

has direct technical access (i.e., "sister" operations in other locations in

the U .S .) and centrifugation has had a poor success record in dealing with

36

---

Mississippi River silts, the belt filter press technology was selected as the

mechanical dewatering technique for which further analysis would be

performed .

6)C) Landfilline of Dewatered Residuals

Not an alternative in itself, this technology was considered as a

potential component of several technology alternatives, such as temporary

storage and dewatering in lagoons with offsite landfilling (alternative 3),

and the mechanical and non-mechanical dewatering processes (alternatives

6A and 6B) .

The landfilling of dewatered water treatment facility

residuals in Illinois is permissible . Provided that the dewatered solids are

not hazardous waste under Resource Conservation and Recover Act

("RCRA") regulations, the dewatered solids can be landfilled in a

permitted non-hazardous special waste landfill .

Preliminary discussions with the operator of the nearest landfill

(Waste Management Inc

.) which accepts water treatment facility residuals,

located in Granite City, Illinois, indicate that there is sufficient landfill

capacity to receive these residuals for 30 years

. However, as landfill

capacity diminishes and tipping fees escalate, it is likely that it may

become more economical to construct dedicated landfills solely for the

management of the water treatment facility residuals .

As noted in the

discussion of monofills (i.e., Treatment Technology Number 4), the

37

---

diminishment of existing landfill capacity and the high capital cost of

constructing new landfill capacity are major drawbacks to landfill disposal .

54 . Based on their technical feasibility and economic reasonableness, two

candidate technologies were selected for further evaluation along with the direct discharge

option . Application of either of the two candidate technologies would result in the

estimated Alton effluent discharges meeting Illinois water quality standards for TSS . The

two selected technologies are :

•

Construction of four on-site sludge storage lagoons for dewatering of the

solids by non-mechanical means, and subsequent offsite landfilling of the

dewatered residuals ;

•

A belt filter press for dewatering of the solids by mechanical means, at the

facility, and subsequent offsite landfilling of the dewatered residuals .

SSIS at 6-7 .

Temporary Storage and Dewatering in Lagoons was selected for the following reasons

:

•

Reliable operation with minimal maintenance requirements ; and

•

Site is large enough to construct lagoon system

.

Belt Filter Press Dewatering

was selected for the following reasons :

•

Site is large enough for buildings required to house the press dewatering

system; and

•

Reliable operation which produces consistently dense residuals,

55

.

In order for the facility to produce an average of 10 .5 MGD of potable

water (forecasted demand in 15 years), 11

.2 MGD of water must be withdrawn from the

38

---

River .

Under average river sediment conditions (TSS = 180 mg/1) at the flows

described above, the facility will produce approximately 3,400 tons of dry solids per year

from proposed discharges which will require treatment for removal of solids

. Under

these conditions, the average discharge flow rate of this effluent will be 1

.0 MGD. SSIS

at 6-8 .

56 .

It is anticipated that temporary storage and dewatering in lagoons (non-

mechanical dewatering) with subsequent off-site landfilling would require construction

of four on-site lagoons for dewatering the water treatment residuals

. Residuals flow

would be diverted into one of the four dewatering lagoons

. Residuals would be stored

in the lagoons to allow dewatering to approximately four percent (4%) solids

. The

residuals would then be removed and further dewatered by a temporary mechanical

dewatering system

which would dewater the lagoon residuals to approximately twenty

five percent (25%) solids . Following the dewatering the residuals would be transported

to an off-site landfill . SSIS at 6-4 .

57. The second candidate technology involves belt filter press dewatering --

a permanent mechanical dewatering process which would involve conditioning the

residuals prior to press operations

. Operational data indicate that a solids concentration

of 15 to 25 percent is typically achieved through this process. This candidate technology

also requires off-site landfilling of the dewatered residuals

.

58.

Originally each each of the candidate technologies (lagoons alone and belt

filter press dewatering alone) was considered separately

. The original lagoon design

called for two, three-acre lagoons .

Upon consideration of additional site information

39

---

(i.e., required site preparation), the lagoon design was refined to include four, one-acre

lagoons combined with additional mechanical dewatering equipment . The four lagoons

require less subsurface exacavtion and less land area than the previous design . SSIS at

6-8

. Cost estimates were made for the lagoon (non-mechanical) dewatering technology

alone, for the belt filter press (permanent mechanical) dewatering technology alone, and

for the combination of the two . For purposes of comparison, cost estimates for both

non-mechanical and mechanical dewatering technologies, as well as the combination of

the two are presented in Appendix D of the SSIS .

59 . The cost estimate for non-mechanical dewatering as originally designed

(two, three-acre on-site lagoons and off-site landfilling) is detailed in Table D-I of

Appendix D of the SSIS . Major cost items associated with this option are

: (1)

construction of two on-site solids dewatering lagoons ; (2) collection of the supernatant

from the lagoons and discharge of water to the River ; and (3) landfilling dried sludge at

a local landfill . The annualized total cost for this option is approximately

$1,580,000. 11-5f The overall capital cost for this option is approximately $4,580,000,

the annualized capital cost is approximately $450,000, and the annualized operation cost

is approximately $1,130,000 .

60. The cost estimate for the refined (combined) technology of four on-site

lagoons, permanent mechanical dewatering by belt filter presses, and subsequent

landfilling is detailed in Table D-lA of Appendix D of the SSIS .

Major cost items

associated with this option include

: (I) construction of four on-site solids dewatering

-"

All costs are rounded to the nearest $I0 .000

. The annualized costs figure assumes capital costs are amortized over 30 years at a 9%

interest rate .

40

---

lagoons

; (2) collection of the supernatant from the lagoons and discharge of water to the

River ; (3) installation of permanent filter presses to mechanically dewater lagoon

residuals to a solids concentration of 25% ; and (4) landfilling dried sludge at a local

landfill . The annualized total cost for this option is approximately $1,140,000

. The

overall capital cost for this option is approximately $7,380,000, the annualized capital

cost is approximately $720,000 and the annualized operation cost is approximately

$420,000 .

61

. The cost estimate for the belt filter press dewatering and subsequent

landftlling option (without lagoons) is detailed in Table D-2 of Appendix D of the SSIS

.

Major cost items associated with this option

are: (1) installation of one

equalization/storage tank

; (2) construction of on-site residual collection tanks and

ancillary equipment ; (3) installation of one thickener

; (4) installation of large filter

presses and backup units and associated auxiliary facilities sized to handle peak hydraulic

conditions; (5) collection of overflow and discharge to the River

; (6) collection of

filtrate/washwater and return to the treatment facility ; and (7) landfilling sludge at a local

landfill at a solids concentration of 25% in the treated sludge

. The annualized total cost

for this option is approximately $1,630,000

. The overall capital cost is for this option

is approximately $10,800,000, the annualized capital cost is approximately $1,130,000,

and the annualized operation cost is approximately $570,000 .

41

---

Narrative Description of the Proposed Adjusted Standard

62. Section 106.705(f) of the Procedural Rules provides that the petition must

include a narrative description of the proposed adjusted standard as well as proposed

language for a Board order which would impose the standard

.

Efforts necessary to

achieve this proposed standard and the corresponding costs must also be presented . Such

cost information shall include the overall capital cost as well as the annualized capital and

operating costs .

63 .

The Water Company petitions the Board to adopt the following adjusted

standard as Section 304

.223 (or other appropriate designation) under the Board's

regulations governing effluent standards, 35 Ill . Adm . Code Subtitle C, Part 304

:

This section applies to the replacement potable drinking water treatment

facility owned by Illinois-American Water Company ("Company") which

will be located near River mile 204 in Alton . Illinois . and which will

obtain its raw water supply from, and discharge to, the Mississippi River

.

Such discharges from the facility shall not be subject to the effluent

standards for total sus nded solids and total iron of Section 304 .124

. nor

to the regulation of discharge solids or turbidity provided in Sections

304

.106 and 302 .203,

64 .

Efforts and costs necessary to achieve the proposed adiusted standard :

Achieving the proposed adjusted standard at the replacement facility will require the

facility to implement all requirements which may be imposed in its permit, such as BDT

requirements .

As discussed in the next section, the SSIS data and the replacement

facility's use of new, state of the art equipment, such as the Superpulsator

®

, will ensure

that the impact of its discharge is equal to or better than that of the discharge from all

of the similarly situated Mississippi River facilities, all of which the Board has allowed

42

---

to discharge to the River -- i,

e., the existing Alton facility, Rock Island, East Moline and

East St . Louis.

The Quantitative and Qualitative Impact of the Petitioner's Activity on the

Environment Resulting from Compliance with the Regulation of General

Applicability as Compared to Compliance with theProposed Adjusted Standard

65 . Section 106 .705(g) of the Procedural Rules provides that the petition must

compare the qualitative and quantitative nature of emissions, discharges or releases which

would be expected from compliance with the regulation of general applicability as

opposed to that which would he expected from compliance with the proposed adjusted

standard. To the extent applicable, the petitioner must also discuss cross-media impacts

(those which concern subject areas other than those addressed by the regulation of

general applicability and the proposed adjusted standard)

. Finally, Section 28 .l(c)(3) of

the Act, which applies to all adjusted standard petitions, requires the petitioner to submit

adequate proof that "the adjusted standard will not result in environmental or health

effects substantially and significantly more adverse than the effects considered by the

Board in adopting the rule of general applicability ."

66.

As a preliminary matter, the Water Company notes that because of a lack

of significant adverse environmental impact, combined with significant adverse economic

impact and discharge disposal concerns, relief from the generally applicable industrial

effluent standards is the appropriate de facto

rule of general applicability for public water

supply treatment facilities which receive their raw water from the River and do not use

the lime softening process

. This is the category of facilities to which the replacement

facility belongs, as do the facilities currently serving Rock Island, Alton, East Moline

43

---

and East St . Louis

. As a result, the qualitative and quantitative factors pertaining to the

replacement facility should be judged similarly to these facilities for purposes of the

Act's adjusted standard factors (i.e., Sections 28 .1 and 28 .3 of the Act and the BPJ and

BPT factors) .

67 . The potential environmental impacts from the effluent of the replacement

facility on water quality and biota of the River in the vicinity of the potential discharge

are evaluated in the SSIS in significant detail . The SSIS examines impacts to both the

water column and sediments. Also, potential impacts to biota are evaluated .

68 .

Other impacts considered under the site-specific analysis include :

identification of frequency and extent of discharges ; identification of potential for

unnatural bottom deposits, odors, unnatural floating material or color; stream

morphology and results of stream chemical analyses ; evaluation of stream sediment

analyses

; and pollution prevention evaluation . As discussed in this section of the

Petition, the SSIS found that no adverse environmental impacts will result from the

proposed rule.

Modeling Water Quality Effects

69 .

Water quality effects of the replacement facility discharges were evaluated

by analyzing physical and chemical impacts from increases in the dissolved or total

suspended load to the River and the effect of materials settling out and accumulating on

the bottom of the River

. Since it is unlikely that all the discharge TSS will remain

completely in suspension or completely settle out, the results of these types of modeling

44

---

analyses were used as end points to estimate the potential range of environmental effects .

SSIS at 5-2

.

70

. In addition, the SSIS evaluates the effect of chemical coagulant used in the

replacement facility . The primary coagulant proposed to be used at the replacement

facility is Clar'Ion

®, an alum-organic polymer mixture . The SSIS also evaluates the

potential for iron (all of which is from the River) and aluminum from the replacement

facility to pose any adverse ecological effects

. Of these two chemicals, only dissolved

iron has an Illinois Water Quality Standard, which is 0

.5 mg/1. 35 Ill . Adm . Code

302 .208

. Aluminum has an Ambient Water Quality Criteria ("AWQC") value of 0

.87

mg/I (87 ug/1) . See 63 Fed. Reg . 68354 (1998) .

71 .

A series of analyses were made of potential impacts on the receiving

waters (i.e.,

the River near River Mile 204) from the proposed Alton facility effluent

discharges

. The purpose of the modeling was to predict final mixed concentrations of

TSS, iron, and aluminum at the edge of the mixing zone and to provide estimates of

elevated concentrations of TSS downstream of the Alton discharge

. These results were

then compared to ambient receiving water conditions to indicate the relative effect of the

discharges . SSIS at 5-2.

72 . Two types of modeling were conducted

: (1) a simple mass balance

equation to predict the final mixed concentrations of the Mississippi River

; and (2) a

dynamic model using CORMIX to predict concentrations within the mixing plume

. The

former was used to evaluate final concentrations, whereas the latter was used to prove

45

---

a visual estimate (or "footprint") of elevated TSS values below the discharge points .

Details of the CORMIX modeling are provided in Appendix F of the SSIS .

73 .

Several models were developed to determine potential impacts on the River

from the replacement facility's effluent discharges

. Two flow/TSS/coagulant scenarios

were examined

. Test parameters were as follows : application of coagulant was modeled

with two receiving water TSS concentrations (approximate daily minimum and monthly

maximum values for the River near Alton) under two receiving water flows (the seven

day, ten year low flow and the annual average flow, respectively)

. Under the low flow

model scenario (i .e., low ambient river TSS and 7Q10 low flow), the dimensions of the

discharge plume (defined by a limit of a > 1

.0 mg/l increase in TSS above ambient) are

approximately 400 ft, by 25 ft . (0 .28 acre), of which about 175

ft

. by

30 ft . (0 .12 acre)

reaches the River surface at TSS concentrations of 1 .0 - 2 .5 mg/I above ambient levels

.

Design flows and concentrations of the Superpulsator ® and filter backwash for evaluation

of the proposed replacement facility were determined by application of removal rates on

incoming raw water, based on pilot facility results and the design described in Section

3

.0 of the SSIS . The flow amount and effluent TSS concentration of the removal

technologies were sensitive to intake TSS amounts . SSIS at 5-2.

74 . The modeling results indicate that, under worst case, low flow conditions,

incremental increases from the replacement facility's operations will not lead to

significant changes in water quality and will not cause violations of ambient water quality

criteria ("AWQC") . To test the potential magnitude of change for TSS, design low flow

and the daily minimum regime were examined

. The test conditions assumed a 7Q10 low

46

---

flow and a river TSS of 20 mg/1 . Only 25% of the River volume was used for the area

of mixing, as allowed by

35 111 .

Adm

. Code 302

.102 for constituents whose existing

ambient levels in the receiving water do not exceed water quality standards .' The

results indicate that, regardless of the ambient TSS condition, TSS concentrations of the

River increase by less than

0.5%

over a wide range of ambient conditions . The

negligible River TSS increases are well within daily variation and are likely to be

analytically undetectable. SSIS at 5-3 .

75 .

The results of the dynamic mixing zone model are shown graphically in

Figures 5-1 and 5-2 of the SSIS . Figure 5-1 presents an aerial view

of the location of

the predicted TSS plume resulting from the discharge . Figure 5-2 presents a more

detailed aerial view of

the same predicted TSS plume as presented in Figure 5-1 .

Contours (or isopleths) are plotted for various TSS concentrations above ambient

conditions between 1 .0 and 5

.0

mg/I. The figure shows that the River velocity quickly

overcomes the initial discharge momentum (perpendicular to flow away from the

shoreline) .

The edge of the plume, represented by a 1 .0 mg/I contour, reaches

approximately 400 feet downstream and achieves a maximum width

of approximately 30

feet. The distance at which the plume reaches the surface is approximately 225

feet, and

all predicted concentrations are below 2 .5 mg/l ; therefore this model predicts that a River

surface area of approximately 175 ft. by 25 ft . (or 0.12 acre) will be subject to TSS

concentrations 1 .0 to

2 .5 mg/I higher than ambient . This range of TSS concentrations

iw

There is no applicable Illinois Water Quality Standard for TSS, and these test conditions were simply used for

comparative purposes .

47

---

represents values that are 5 to 13% above ambient levels . The SSIS concludes that the

lower end of the range represents a value that will be difficult to visually discern and

very difficult to measure with conventional instrumentation . SSIS at 5-4.

76.

Similarly, the results of projecting the proposed effluent discharges on

ambient dissolved aluminum and iron River concentrations -- representing the annual

mean value and daily maximum under low flow conditions -- indicate that the amount of

coagulant added will not lead to an exceedance of the respective federal AWQCs for

either aluminum or iron, even under low flow conditions

. SSIS at 5-4 . As such, these

incremental increases will not adversely impact water quality .

Id.

In projecting these

impacts, the amount of dissolved aluminum or dissolved iron arising from use of

Clar`Ion ® coagulant was considered . The dissolved fractions were used to address

potential ecotoxicological concerns, because particulate fractions are usually considered

non-bioavailable. Id.

77. To project the impacts of effluent discharges on dissolved aluminum and

iron River concentrations, the amount of metal/metalloid in the Superpulsator

®

effluent

was based on coagulant application rates (function of TSS levels) and stoichiometric

considerations. For Clar*lon ® type coagulants

; the percentage of aluminum is

approximately 4%

. To estimate dissolved iron, the average value of clarifier and filter

backwash effluent discharge concentrations were used

. All of the aluminum or iron was

assumed to be in the dissolved fraction

; as this is unlikely to occur under actual field

conditions, this assumption provides a conservative, worst-case scenario . Mean values

of iron concentrations from a series of analyses from the filter backwash of the existing

48

---

Alton facility were used to estimate metal concentrations in the clarifier backwash . Total

and dissolved fractions of iron were measured in samples of the River and the existing

Alton facility discharges taken in December 1996 and February 1997 . During this

period, Clar*Ion®

was used as the primary coagulant at the existing Alton facility . The

filter backwash had a mean dissolved iron value of 0

.009 mg/1, which is below the water

quality standard of 0.5 mg/I for the receiving water . This value was judged to be

acceptable, because most of the coagulant is added prior to the Superpulsator

®

and is

likely to be mostly discharged with Superpulsator®

effluent ; the basic filter backwash

technology will not be altered in the proposed facility ; and the incoming River silts

remain the same . SSIS at 5-4.

78.

As a further check, the potential for the proposed facility effluent

discharge to cause an exceedance of the Illinois Water Quality Standard for total

dissolved solids ("TDS")

of 1,000 mg/I was also qualitatively evaluated . Review of

available USGS water quality data from the gaging station below Grafton from 1990 to

1997 (over 50 observations) indicates that the average TDS concentration in the River

at this point is 273 mg/1 . There are no TDS data from the existing Alton facility

discharge, but it was assumed for purposes of the SSIS that TDS equals TSS discharge

levels .

This is a highly conservative assumption, because the residual discharge is

comprised primarily of settled particulate material .

Using these assumed values for

discharge and receiving water TDS, the proposed effluent outfall does not lead to an

exceedance of the water quality standard even at effluent TDS concentrations two orders

of magnitude greater than the conservatively assumed levels

; therefore it can be

49

---

concluded that the proposed facility discharge will not lead to an exceedance of TDS

standards in the receiving waters. SSIS at 5-4

.

79 .

Since average flow

conditions are more representative of typical flow

conditions, a series of tests similar to those discussed in paragraphs 69 et seq ., above for

low flow conditions were conducted using average annual

flow of the River as the

underlying hydrologic conditions, while conservatively assuming maximum monthly TSS

discharges from the replacement facility . Under the typical flow model scenario (i .e.,

monthly maximum TSS and mean River flow)

the dimensions of the discharge plume

(defined by a limit of a >2 .5 mg/I increase in TSS above ambient) are approximately

5,250 ft. by 75 ft . (9.04 acre), of which about 650 ft . by 75 ft . (1 .12 acre) reaches the

River surface at TSS concentrations of

2.5

- 5.0

mg/l above ambient . These TSS inputs

represent a 0.4 - 0.8% increase over ambient levels . As expected, test results for

average flow conditions indicate an even lesser impact than under low flow conditions .

SSIS at

5-5

.

The results also indicate that there is no potential that the replacement

facility discharge will raise ambient water quality above acceptable levels

. Id . Water

quality is also not adversely impacted under average flow conditions

. Id

.

80. The potential for "turbidity of unnatural origin" was evaluated based on

the results of the water quality TSS modeling and the likelihood of such turbidity

resulting in an Offensive Condition (35 Ill . Adm . Code

302.203) . Based on the level and

spatial extent of the predicted turbidity increases, the SSIS concludes that the discharge

from the replacement facility will not result in an Offensive Condition . SSIS at

5-22 to

5-23 .

In conjunction with modeling water column effects, the deposition of settleable

50

---

solids in the potential effluent discharges from the Superpulsators ®

and filter backwash

were modeled to determine potential areal distribution in the sediments of the River. The

analysis included performing particle deposition modeling based on several very

conservative assumptions . SSIS at 5-6 to 5-10 . Modeling results demonstrate that the

daily residuals buildup is negligible under both critical low flow and average flow

conditions

.

Id . at 5-10. The impact of the modeled discharges is hardly measurable .

Long-term impact is also negligible, because River velocity and bedload transport also

prevent buildup of deposited materials over time . Id.

81 .

The deposition of settleable solids in the potential effluent discharges from

the Superpulsator® and filter backwash were modeled to determine potential areal

distribution in the sediments of the Mississippi River

. Settling velocities of the

suspended solids in the discharges were analyzed to provide information on their

quiescent settling behavior . Residuals arising from both the Claricone (comparable to

proposed Superpulsator®)

and filter backwash operations were available for analysis . The

cumulative effect of both discharges (Superpulsator ®, filters) were used for estimation

of the potential benthic deposition from the proposed replacement facility

. SSIS at 5-6 .

82.

The objective of particle deposition modeling was to predict rates of

particle deposition on the riverbed as a result of the proposed outfall

. A particle

deposition model, based on the equations and methodologies presented in the U

.S. EPA

Section 301(h) Technical Support Document (U .S

. EPA, 1994), was selected and

applied . See

Attachment J hereto . This model is recommended by U .S

. EPA for

screening level particle deposition evaluations . The particle deposition model results in

51

---

predictions of particle mass per area per time (e.g., g/m2/yr) deposited onto the riverbed

.

For details of the particle deposition model, see Appendix F of the SSIS . SSIS at 5-6.

83 . Particle deposition modeling was focused on predicting long-term rates of

particle deposition and accumulation resulting from the proposed outfall . Also,

predictions of deposition and accumulation resulting from transient events, such as low

river flows and filter backwashing, were required . Thus, a steady-state particle

deposition scenario and two transient particle deposition scenarios were developed to

evaluate particle deposition resulting from the proposed discharge

. The steady-state

scenario applied average values for River flowrate, River TSS concentration, discharge

flowrate, and discharge TSS concentration, because the objective of the steady-state

evaluation was to predict the long-term average rate of deposition

. The transient

scenarios specify extreme conditions (e.g.,

high TSS or low flow) with the goal of

predicting the impacts of worst-case transient events . Particle deposition modeling

scenarios are specified below :

Steady-State Scenario

•

River flowrate at average value of 106,589 cfs

;

•

Average annual discharge flowrate of 1 .6 cfs (0.046

m3/sec) ; and

•

Average daily discharge TSS concentration of 2,092 mg/l

.

Transient Scenario #1 : 7010 River Flowrate

•

River flowrate at the seven-day, 10-year low flow (7Q10) value of 21,500

cfs;

•

Discharge flowrate of 1 .6 cfs (equivalent to 0 .046 m 3/sec)

;

52

---

•

Average daily discharge TSS concentration of 296 mg/I

; and

•

Duration of event : 7 days in every 10 years .

Transient Scenario #2 : Filter Backwash

•

River flowrate at average value of 106,589 cfs ;

•

Discharge flowrate of 2 .5 cfs (0.071 m'/sec)

;

•

Maximum daily discharge TSS concentration of 4,333 mg/I ; and

•

Duration of event

: 15 minutes every 24 hours .

SSIS at 5-7 .

84. The SSIS particle deposition modeling evaluation, however, is based on

several very conservative assumptions, which result in the overprediction of the mass of

particles settling on the riverbed. It is, for example, assumed that all particles settle out

of the water column and onto the riverbed

. The presence of large TSS concentrations

(e.g ., up to 2,000 mg/1) in the ambient Mississippi River clearly indicates that all

suspended solids do not settle out of the water column in this waterway . In addition,

according to US Army Corps of Engineers ("US ACOE") personnel, suspended solids

that are settleable generally settle in harbors or backwater areas, rather than in the main

channel of the River . The proposed outfall is located near the main channel of the River

.

SSIS at 5-7 .

85.

The SSIS particle deposition modeling evaluation also overpredicts long-

term sediment accumulation, because it assumes only average river flows, neglecting

above average flows

. Above average river flows and especially very large river flows

are known to transport particles more effectively than smaller flows

. Also, large river

53

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flows are known to produce scour of the riverbed, picking up deposited materials and

transporting them downstream . The net result of sediment scour is that more particles

are deposited in areas with lower water velocities

(e.g.,

backwater areas) and less

particles are deposited in the main channel

. The particle deposition modeling evaluation

assumes that no sediment scour occurs . SSIS at 5-7 .

86 .

Relevant characteristics of the Mississippi River near the Alton facility

were derived from a river stretch depth profile provided by the US ACOE, St . Louis

office, and the literature . An estimate of velocity during low flow conditions was made

by dividing 7Q10 river flow by the cross-sectional area of the channel near the discharge

point at River Mile 204

. Three channel cross-sections representing transects above, at,

and below River Mile 204 are shown in Figure 4-7 of the SSIS

. The average cross-

sectional area of the three transects is approximately 63,813 square feet. The estimated

velocity is approximately 0.34 ft ./s or 0 . 10 m/s . A similar analysis for flow velocity

during average annual flows provides a velocity of 1 .35 ft .ls or 0 .411 m/s . SSIS at 5-8 .

87

. The exact location and depth of the replacement facility effluent discharge

has not been determined . The discharge was assumed approximately 33 feet (10 m)

offshore at a depth approximately equal to the maximum elevation for preserving the

navigation clearance, or 4 .5 feet

. This corresponds to a height above bottom of 16.4 feet

(5 m) . SSIS at 5-8 .

88. Five water samples were collected from the discharge of the current Alton

facility on five separate dates in December 1996 and another set of four were sampled

in February 1997 . The first set of samples was collected before, during, and after

54

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commencement of the filter backwash discharge . The second set of samples was taken

at the initiation, during, and following clarifier blowdown .

During both periods

Clar'Ion ® was being used as the primary coagulant . The initial TSS were measured, as

was the final turbidity (in NTU) of the supernatant of the settled sample . Settling

behavior of the solids was measured in an Imhoff cone, by monitoring over time the

volume of

settleable solids in the cone, as determined by observing the interface between

the clear supernatant and turbid solids region . The data for these measurements from

both clarifier and filter backwash are presented in Appendix C of the SSIS . SSIS at 5-8 .

89. The settleable solids volume as a function of time is presented in Figure

5-5 (clarifier) and Figure 5-6 (filter backwash)

of the SSIS . The results suggest little

settling during the first 10 minutes (note : the settling interface is often hard to visually

detect initially), but a major portion of the settling takes place within the first 20 minutes,

with hindered settling and compression taking place thereafter

. An average settling curve

was constructed by averaging the results of the 4 or 5 trials for each process type . The

average settling curve was used to estimate settling velocity

. SSIS at 5-8.

90. Settling velocity was estimated by dividing a settling distance by an

average settling time

. The settling distance is the depth of clear supernatant from the top

of the one liter mark of the Imhoff cone to the interface with the cloudy settleable solids

portion .

The settling distance was measured at the time (settling time) at which the

initial linear portion of the settling curve ended and hindered settling and compaction

began

. Dilution of the discharge by River water will likely result in a settling regime

more closely associated with discrete settling than with hindered settling or compaction,

55

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which occurs under relatively quiescent conditions of low velocity and within a confined

area . Therefore, only the initial linear part of the settling curve was used to compute

settling velocities .

The calculated settling velocity for the average settle curve was

analyzed . From these calculations, an average settling velocity for the clarifier and filter

backwash of 2.46

x 10' mlsec was estimated . SSIS at 5-9.

91 . In order to quantify predictions of particle settling behavior resulting from

the discharge of residual-associated TSS, three discrete particle sizes were chosen

. These

three representative particle size groups were then evaluated to determine settling rates,

deposition areas, and accumulation rates for the three scenarios described in paragraph

89-90, above . The following three particle size ranges were assumed to characterize

discharge TSS :

Largeparticle sz : 25%

of discharge TSS, particle size > 0.062 mm in

diameter .

Medium particle size : 50%

of discharge TSS, particle size between 0 .062 nun and

0.039 mm in diameter .

Smallparticle size : 25%

of discharge TSS, particle size between 0 .039 mm and

0.0039 mm in diameter

.

Particle size groups were assigned based on Imhoff cone settling measurements collected

from the present discharge waters as discussed in paragraphs 89-90, above and sieve tests

performed by the USGS on River water in Alton .

Particle size groups selections are

conservative in that all particles are assumed to be settleable

. Also, the particle sizes

listed above were validated using U .S

. EPA guidance documents and were found to be

56

---

typical of fine sand, silty sand, silt, silty clay, and clay that would be expected to be

found in the discharge waters . SSIS at 5-10 .

92 .

Results of modelling for the three scenarios were as follows :

Steady-State Scenario : Results of the steady-state particle deposition modeling

scenario are presented in aerial view in Figure 5-7 of the SSIS . Table 5-6 of the SSIS

contains the areas, deposition rates, accumulation rates predicted in the steady-state

modeling scenario . Particle deposition rates of 4 .38 kg/ft2/yr, 0 .037 kg/ft 2/yr, and 0.012

kg/ft 2/yr

were obtained for the three particle size groups, respectively. The large size

particles were predicted to settle over an area of 4 .1 acres and to accumulate 2

.2 in/yr .

Medium and small size particles were predicted to accumulate very little (less than 0 .01

in/yr) over a larger area (565 acres) . Due to the overlap of settling zones for the two

smaller particle classes, only two zones of deposition are indicated on Figure 5-7 of the

SSIS .

Transient Scenario #1 : 7010 River Flow : Results of the transient scenario #1

particle deposition modeling are in Table 5-6 of the SSIS

. Particle deposition rates of

0.039 kg/ft' and accumulation of 0 .0275 inch per event over an area of 0

.06 acres were

predicted for large size particles . Deposition of medium and small size particles was

predicted to be negligible. SSIS at 5-10 .

Transient Scenario #2 : Filter Backwash :

Results of the transient scenario #2

particle deposition modeling are in Table 5-6 of the SSIS

. Particle deposition rates of

0 .003 kg/ft' and accumulation of 0 .001 inch per event over an area of 1

.04 acres were

57

---

predicted for large size particles

.

Deposition of medium and small size particles was

predicted to be negligible . SSIS at 5-10 .

93

. The SSIS concludes that the amount of daily buildup is negligible for the

residuals either under critical low flow or average flow conditions . The impact of either

of these modeled discharges can hardly be measured in the vertical. The current velocity

and bedload transport will also tend to prevent buildup of deposited materials over time .

SSIS at 5-10.

CharacterizationofPotential Environmental Impacts

94. The SSIS evaluates, in significant detail, the biological communities and

habitats expected to occur in the vicinity of the proposed outfall and evaluates the types

of potential impacts . The SSIS also considers sensitive species and habitats .

95 . Major habitats near River Mile 204, as classified by the Baker system,

include main channel, nearshore bank areas, pools and backwater slough areas

. The

proposed discharge location is within the nearshore bank habitat and adjacent to the

other habitats . SSIS at 5-12. The SSIS also identifies fish and macroinvertebrates likely

to occur in the vicinity of the proposed discharge based on their typical occurrence in the

types of nearby habitats . The habitats are characterized as follows :

Main Channel Habitat :

The main channel forms the major path for water flow

in the river and is characterized by high current speeds, a fairly uniform sand and gravel

substrate, high bottom bedload movement, and high suspended solids levels . In the

vicinity of the proposed discharge, the main channel is actively used for navigation (i

.e.,

river barge traffic) which also leads to disturbance of the bottom and resuspension of

58

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materials . Due to the need to maintain navigation depths, the main channel is

periodically dredged .

Nearshore Bank Habitat : Nearshore bank areas adjoin and merge with the

channel habitat . These areas include both natural and artificially reinforced (i.e.,

rip-

rapped) shorelines

. Current speeds are highly variable along banks, as a function of

several factors including water depth, distance from shoreline, substrate type, and both

natural

(e.g.,

fallen trees) and man-made (e.g., transverse dike dams) obstructions .

Upstream flow eddies may be present . Substrates are variable and may include

consolidated clays and silts, sand and gravels, and muds

. Water quality is similar to that

of the channel habitat, Nearshore hank areas are found on the Illinois side of the River

near the proposed discharge .

Pool Habitat : Pools are relatively deep, slack or slow-moving flow areas within

the main River banks . Pools often form downstream of islands and usually adjoin

sandbar and channel habitat . Pools are characterized by slow currents, relatively greater

depths, and generally fine sediments

. The areas and depths of river pools are usually

dependent on river stage (i.e., elevation).

Pool water quality is usually less turbid,

slightly warmer, and may exhibit higher primary productivity than the channel

.

Slough Habitat : Sloughs are formed from abandoned or secondary river channels,

which may be isolated from the main channel for varying periods of time

. They are

moderate-sized, slackwater habitats which form a continuous connection with the main

channel during average to high river stages .

Current speeds are often insufficient to

scour the bottom so that large amounts of organic debris accumulates at the bottom

. The

59

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enclosed channel, north of Piasa Island ; the former river channels found on the Missouri

side

; and associated vegetated emergent bars provide slough habitat . SSIS at 5-13 .

96

.

Fish and macroinvertebrates likely to occur in the vicinity of the proposed

discharge were identified based on their typical occurrence in the types of habitats

described in paragraph 95, above - namely main channel, nearshore bank areas, pools,

and sloughs . Fish typically found in these subhabitats are identified in Table 5-7 of the

SSIS, which provides both common and scientific names . The fish community in the

main channel is comprised of a diverse mixture of open water species (e .g., shads,

skipjack herring, goldeneye and white and striped bass) and bottom-dwellers (e.g.,

shovelnose sturgeon, carp, blue sucker, buffalofishes, catfishes, and freshwater drum) .

A similar suite of species typically occurs in nearshore bank areas along with American

eel, white and black crappie, sauger, and a variety of smaller fishes (e.g., sunfishes,

minnows, silversides) . Many of the same species listed above occur in pools and slough

habitats, but pools may host paddlefish and sloughs may contain bowfin, pirateperch,

mosquitofish, and largemouth bass.

Macroinvertebrate communities vary among the

habitats described above . Macroinvertebrate communities in the main channel are

generally found to be low in diversity and abundance, dominated by clams, oligochaetes,

chironimids, and nematodes, and concentrated in silt and clay accumulations

. Nearshore

macroinvertebrate communities in the area are often more diverse, due to more moderate

velocity, substrate heterogeneity, and less disturbance, due to decreased bedload

transport . Caddisflies (trichopterans) often dominate in areas of artificial materials,

while mayflies (ephemeropterans)

are found in natural shorelines with clayey substrates .

60

---

Depending on the nature of the substrate clams, oligochaetes, mayflies, caddisflies, or

chironimids may be found in high abundance

. Sloughs may contain similar types as well

as phantom midge larvae (Chaoborus), if isolated from the main channel for extended

periods. SSIS at 5-14

97

. Physical (non-toxic) and toxic potential impacts were considered . Potential

non-toxic impacts of suspended solids on biota include light reduction, abrasion feeding

interference, sedimentation, and destruction of habitat . SSIS at 5-15 to 5-16 . Certain

fish species may tend to avoid waters of high TSS levels (e.g ., >500 mg/l) such that a

small zone of avoidance may exist downstream of the replacement facility discharge .

The CORMIX mixing model indicates that high TSS would be restricted to a small area

immediately downstream of the discharge . This area should not adversely affect fish

movements of migration, due to the small area of elevated TSS, the limited exposure

duration during plume transit, and adaptation of the indigenous fish community to

naturally-occurring TSS levels . Id. at 5-16 .

98.

Based on the ambient suspended solids content of the River and the minor

increase in ambient TSS concentrations, no significant impact to riverine biota is

expected in the area of the discharge plume and potential depositional area

. This

conclusion is based on the magnitude of the incremental increase in TSS (less than I

percent under low flow conditions), the location and areal extent of above-ambient TSS

concentrations, and the nature of the River flora and fauna

. The River biota is routinely

exposed to ambient TSS levels welt above the anticipated incremental level in the vicinity

of the discharge and the areal extent of elevated TSS concentrations is very limited

.

61

---

Inspection of monthly TSS values from 1989-1995 indicates an approximate mean

ambient River TSS of 175 mg/I and an average monthly range of 81 to 362 mg/I .

Maximum suspended solid concentrations in the spring and early summer can run well

above 600

mg/I."

SSIS at 5-16

.

99. The River fish community is composed of warmwater species which are

adapted to the highly turbid conditions which are characteristic of large rivers . Fish

movement and migration of local species should be unaffected by the slight increase in

suspended solids, which is negligible in magnitude to the seasonal patterns of suspended

solids . The incremental increase of less than 1 .0 mg/I predicted is unlikely to be

discernible to these species

. The limited areal distribution of the elevated TSS below the

discharge would be easily avoided under any circumstances

. The impact of the minor

increase in total suspended solids (< 1 percent) on ambient levels under low flow

conditions should have no discernible effect on the underwater light regime . The impact

of the elevated suspended solids on smaller planktonic organisms should likewise be

negligible .

The nature of the released solids (mainly raw River solids) should be

compatible with the use of the water column by zooplankters and other filter-feeders .

Filtration rates may be slightly adjusted in response to higher suspended particle

concentrations, but levels are well below the natural range of suspended solids

encountered by these species . SSIS at 5-16 .

12" Monthly TSS values from 1974-1995 (before and after relocation and construction of

lock and Darn No . 26) indicate

an approximate mean ambient River TSS of 175 mg/I and an average monthly range of 81 to

464 mg/l. Maximum

suspended solid concentrations in the spring and early summer have run above 1,300 mg/I at times from

1974-1995 .

62

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100.

Finally, the minor rates of deposition of silty material on the River bottom

predicted by the SSIS settling analysis are unlikely to bury sessile organisms found there

.

This conclusion is based on the nature of the bottom habitat characterization conducted

by ESI in 1997 indicating unsuitable habitat conditions for unionid colonization and a

relatively depauperate unionid community within a silty bottom environment

. A follow-

up communication from ESI confirmed that silt deposition was uniform with depth from

both shoreline upstream and downstream of the facility

. See letter in Appendix B of

SSIS

. This indicates that no observable silt accumulation has occurred due to the current

facility discharge despite 100 years of operation at the site

. These observations are

consistent with the predictions of the particle deposition model and the dynamic nature

of bottom contours in the River

. These factors tend to further mitigate potential impacts

to the benthos

. SSIS at 5-17 .

101 .

The evaluation of aluminum and iron included considering chemical

characteristics of the receiving water, coagulant content of the effluent discharges,

potential concentrations of coagulant in the mixing zone, other benchmark values (such

as AWQCs), and results from other studies

.

102

. Aluminum is one of the most common elements in natural materials and

is a major component of geologic materials and soils, Aluminum has been shown to be

toxic to many types of aquatic life, but the degree of toxicity is highly dependent upon

water chemistry and relative proportions of various aluminum forms or species

. Studies

indicate that the aluminum that is occluded in minerals, clays, and sand or is strongly

adsorbed to particulate matter is not toxic, nor is likely to be toxic under natural

63

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conditions. Evaluation of toxicity is made more difficult, because of the complex nature

of aluminum geochemistry and its ubiquitous presence in high abundance in the

environment . SSIS at 5-17 .

103 . Despite its abundance in geologic materials and soils, aluminum rarely

occurs in solution in natural waters in concentrations above 1 .0 mg/l, but exceptions are

seen in waters of low pH . Reported concentrations of 1

.0 mg/I in neutral pH waters

containing no unusual concentrations of complexing ions probably consist of largely

particulate material, including aluminum hydroxide and aluminosilicates . Mineral

complexes such as gibbsite are very small (near 0

. 1 µm diameter) and may pass through

conventional filters used to operationally separate "dissolved" fractions in water quality

analyses. The long term average dissolved aluminum concentration in the River near

Alton is 0 .026 mg/1 (SSIS, Table 4-7), with a range of 0 .010 to 0.220 mg/l

. It is not

known what proportion of this aluminum is in a dissolved, monomeric form

. Most

toxicity studies of aluminum have been associated with investigations of the

environmental effects due to acidic deposition, commonly referred to as "acid rain ."

Toxicity from aluminum has been shown to occur in dilute, softwater (poorly buffered)

lakes or streams with low ambient pH conditions (e.g., pH <6.0

standard units) . The

literature also indicates that aluminum has little toxic effect at pH >6.5

. A recent

United States Fish and Wildlife Service (USFW) compendium of the effects of aluminum

on wildlife referred to it as being "innocuous under circumneutral or alkaline conditions ."

Typical pH values in the River near Alton are circumneutral to alkaline, typically

between 7 .5 and 9.0

. SSIS at 5-18

.

64

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104

. Application of the AWQC for aluminum (87 ug/l) was used for comparison

purposes, but has no regulatory standing for the proposed replacement facility . A water

quality criterion for aquatic life has regulatory impact only after it has been adopted in

a State water quality standard

. Illinois Water Quality Standards do not have a standard

for aluminum . Comparison of the results described in Section 5 .1 .1 of the SSIS indicate

that under all flow conditions the contribution of the coagulant-generated aluminum does

not cause an exceedance of the 87 ug/l AWQC

. Inspection of the aluminum AWQC

document indicates the criteria value is due, in large part, to potential toxicity to certain

salmonid species .

Application of the criteria to protect salmonids is inappropriate,

because this portion of the River does not contain preferred salmonid habitat . SSIS at

5-18

. Further, comparison of AWQC toxicity results based on laboratory experiments

in which the aluminum is directly applied as soluble salts (e.g

., aluminum chloride or

aluminum sulfate) under low hardness conditions to predict toxicity of ambient dissolved

aluminum concentrations in the River is probably conservative, due to the potential

biologically unavailable aluminum

. As indicated earlier, the high pH values found in the

River would prevent aluminum toxicity from being a concern

. Id.

105

. A similar analysis was conducted for iron . Modeling of the concentration

impact was conducted using the measured clarifier and filter backwash levels

. The

average filter discharge value of dissolved iron was 0

.009 mg/I. The results of these

models indicate that the discharge does not pose a threat to exceed the value of Illinois

Water Quality Standard for dissolved iron of 1 .0 mg/I in the mixing zone

. 111 . Adm .

Code 302 .208(g) ; SSIS at 5-19

.

65

---

106. Like aluminum, iron is both ubiquitous and found in a variety of mineral

and complexed forms. It is largely biologically unavailable, except for the dissolved

form, which is typically found in significant proportion under conditions of low pH

and/or low oxygen . The pH levels of the River are consistently above 7 .0 and the river

stretch in question is unlikely to suffer from low dissolved oxygen due to its shallowness

and velocity. SSIS at 5-19

.

107 . The SSIS reaches the following conclusions regarding toxic potential

impacts : (1) site specific (i.e., non-salmonid) species are more tolerant and potential

aluminum toxicity is unlikely ; (2) the River normal pH range is 7.5-9.0; (3) the hardness

of the River is greater than 50 mg/I as CaCO 3; (4) impact to the benthic community was

addressed by conducting a mussel survey which indicated no unionid community at the

discharge location

; (5) water velocity at the discharge point is moderate, approximately

1,4 feet per second or higher ; and (6) an environmental assessment was made considering

water use, sediments, water chemistry, hydrology, and receiving water biology

. SSIS

at 5-20.

108 . The only metal of concern generated by the coagulant is aluminum, and

this is only a trace amount of the facility's solids discharge -- about

one third of one

percent (0 .348%) . As such, based on the high levels of natural complexation of

aluminum and the low probability of toxic effects from this very small addition, the

replacement facility's discharge poses no significant potential impact to the River

environment .

66

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109 . The replacement facility's discharge will have no significant impact on the

River biota in the area of the discharge plume and potential depositional area because

:

1) the discharge will result in only a minor increase in the naturally high suspended

solids content of the River

; and 2) the River biota is routinely exposed to ambient TSS

levels well above the anticipated incremental level in the vicinity of the discharge . SSIS

at 5-11 ; 5-17. Similarly, the iron and aluminum content of the effluent discharge was

found to have no significant potential impact on the River environment and its biota

. Id.

at 5-21 .

Justification of the Proposed Adjusted Standard

.110 . Section 106.705(h) of the Procedural Rules provides that the petition must

contain a statement which explains how the petitioner seeks to justify, pursuant to the

applicable level of justification, the proposed adjusted standard

. Section 28 .1(c) of the

Act explains how this requirement must be met for petitions brought pursuant to Section

28.1 .

Ill .

The level of justification required for the adjusted standard sought by the

Water Company is specified at Section 28 .1(c) :

1 .

factors relating to [the Water Company] are substantially and significantly

different from the factors relied upon by the Board in adopting the general

regulation applicable to [the Water Company]

;

2 .

the existence of those factors justifies an adjusted standard

;

3 .

the requested standard will not result in environmental or health effects

substantially and significantly more adverse than the effects considered by

the Board in adopting the rule of general applicability

; and

4.

the adjusted standard is consistent with any applicable federal law

.

67

---

415 Ill . Comp. Stat . 5/28 .1(c) .

112

. Factors exist relating to the Water Company which are substantially and

significantly different from factors relied upon by the Board in adopting the general

regulation applicable to the Water Company . The existence of these factors justifies an

adjusted standard, and the requested standard will not result in environmental or health

effects substantially and significantly more adverse than the effects considered by the

Board in adopting the rule of general applicability

. As well, the adjusted standard is

consistent with applicable federal law

(See paras . 144-163, below) . Specifically :

(i)

The iron and TSS content of the Water Company's proposed

discharge will not affect domestic uses, norr will it result in significant bottom deposits

or excessive turbidity, which are the factors the Board relied upon in adopting these

effluent criteria

. When the Board adopted effluent criteria for iron (dissolved and total),

it relied on the determination that "[w]hile iron's toxicity to man is low, excessive iron

can cause a nuisance for domestic uses or undesirable bottom deposits

." Opinion of the

Board, PCB R 70-8 et al., Jan. 6, 1972, at 16

. The Board based the effluent criterion

for total suspended solids on the determination that "[tihere is a need to keep down other

suspended solids too in order to prevent excessive turbidity and harmful bottom

deposits ." Id . at 19 .

(ii) Site specific impacts of the proposed Alton replacement facility will

not vary significantly from those which would result from application of candidate

control technologies - i.e.,

on-site lagoons with subsequent off-site landfilling ; and on-

site lagoons combined with belt filter press dewatering and subsequent off-site landfilling

.

68

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The feasible candidate control technologies therefore do not provide effluent reduction

benefits with regard to receiving water quality . The application of TSS treatment

technology will not result in perceptible improvements in water quality or sediment

quality, will not enhance habitat quality, and has no effect on local biota .

(iii) Although compliance with the regulation of general applicability

is technically feasible in the sense that compliance can be achieved if the Water Company

is required to implement on-site treatment technologies at considerable expense, direct

discharge is warranted on economic grounds .

(iv) As noted above, the Board has granted relief to all similarly

situated (non-lime softening) water treatment facilities that use the River as their raw

water source .

As a result of a lack of significant adverse environmental impact,

combined with significant adverse economic impact and discharge disposal concerns,

relief from the generally applicable industrial effluent standards is the appropriate

de

facto

rule of general applicability for public water supply treatment facilities which

receive their raw water from the River and do not use the lime softening process

. This

is the category of facilities to which the replacement facility belongs

.

DiscussionofFactors Justifvine Adjusted Standard

113 .

Factors relating to the Water Company that justify the proposed adjusted

standard turn on the absence

of significant site specific environmental and health impacts

of the replacement facility

. Moreover, those impacts are not substantially or significantly

more adverse than compliance with the generally applicable rule by means of one of the

69

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candidate technologies -- i .e., on-site lagoons with subsequent off-site landfilling and on-

site lagoons combined with belt filter press dewatering and subsequent off-site landfilling .

114 . To fully evaluate site specific impacts of the proposed Alton replacement

facility, it is first necessary to examine what is considered BDT, as guided by the factors

identified in 35 Ill . Adm . Code 304 .102 . Each of these factors is considered in detail

below .

1)

Technological Feasibility

115

. A review of candidate control technologies for TSS control is provided in

Section 6 .1 of the SSIS and is discussed in specific detail in the Petition, above . See

paras . 52-61, above . The various technologies assessed included direct discharge

(current practice), land application, monoflls, discharge to POTW, and various sludge

dewatering methods with subsequent landfilling . From this evaluation (see Table 6-1 of

the SSIS) it was noted that :

•

the two options initially identified as most technically feasible (in

addition to direct discharge) are: (1) on-site lagoons with

subsequent off-site landfilling ; and (2) on-site lagoons combined

with belt filter press dewatering and subsequent off-site landfilling,

and

•

control technologies found to be not feasible on a long term basis

include land application, monofills, and direct discharge to the

Alton POTW .

Vacuum filtration and centrifugation, while

70

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feasible, have been shown to be less desirable than filter belt

presses (see Table 6-1 of the SSIS for summary) .

1)

Economic Reasonableness

116. This factor requires the examination of the cost-benefit relationship

between removal of effluent TSS to resulting effluent reduction benefits . Important

factors for site specific relief include

:

•

the unusually high, naturally-occurring level of silt and suspended

solids indigenous to the Mississippi River near Alton

;

•

statements by EPA that natural conditions found in larger highly

turbid rivers may result in unreasonable cost-benefit relationship ;

•

EPA's acknowledgement that returning raw waste sludge to a

highly turbid source can result in an imperceptible increase in TSS

above ambient levels ;

•

the difficulty of handling alum-based residuals and its poor

performance as landfill material

;

•

identification of two candidate technologies which are potentially

capable of treating large volumes of effluent TSS -- i .e.,

on-site

lagoons with subsequent off-site landfilling ; and on-site lagoons

combined with belt filter press dewatering and subsequent off-site

landfilling ;

•

total capital cost estimates for candidate control technologies which

range in the millions of dollars ; and

71

---

•

operation and maintenance costs, which represent a continuing and

potentially escalating cost for future facility operation

. SSIS at 6-

10.

117 . Application of either of the candidate technologies discussed above would

result in the estimated Alton effluent discharges meeting Illinois water quality standards

for TSS . A cost-benefit analysis, however, demonstrates that considerable costs would

be incurred by the proposed replacement facility to meet these effluent limitations without

a clearly-defined improvement to the aquatic environment

. In other words, application

of candidate control technologies does not provide effluent reduction benefits with regard

to receiving water quality . The application of TSS treatment technology will not result

in perceptible improvements in water quality or sediment quality, will not enhance habitat

quality, and has no effect on local biota

. These factors are controlled by the nature of

the receiving water, the River . Further, the TSS treatment: (i) is not needed for control

of sludge or bottom deposits, visible oily odors, or plant or algal growth ; and (ii) has no

effect on stream morphology, and de minimis effect on stream chemistry and sediment

chemistry

. Because the discharge is comprised (> 91 %) of river silts, it will exhibit little

or no differences in color

. Turbidity was evaluated through water quality modeling

(see

Section 5 .1 of the SSIS) . The results of the CORMIX model indicate small areas (<0 .5

acres) where surface receiving water TSS is predicted to be >5% above ambient

conditions (see SSIS Figures 5-2, 5-4)

. As noted earlier, these areas may be interpreted

as representing introduction of turbidity of "unnatural origin" but the level and spatial

72

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extent of these areas does not result in an "Offensive Condition" exceedance

. SSIS at

6-11 .

118 .

The operation and maintenance ("O&M")

costs for residual management

for the proposed candidate technologies (i.e.,

belt presses and lagoons) represent an

increase of approximately 60% to

70%,

respectively, of the current operational costs for

potable water production at the existing Alton facility

. In other words, for the same

volume of potable water produced, the additional O&M costs of residual management

will increase the facility's operational costs 1

.6 to 1 .7

times their current level . SSIS at

6-11 .

119 .

Rate payer and community impacts are factors in considering the economic

reasonableness of the BDT option

. The costs of the control technology will be borne by

Water Company rate payers

. Annualized costs for the candidate technologies range from

$1 .14 to $1

.63 million dollars per year

.

If these costs are divided by the number of

households/businesses served (rounded to

17,500

people), the per unit cost ranges from

$65 to

$93 per year

. In addition, some individual families could be adversely impacted

as a result of construction, operation and transportation activities associated with a nearby

residuals treatment facility .

120

. Socioeconomic costs may be incurred by the potential loss of real estate

value due to the presence of a lagoon in a residential area

.

Neighborhood concerns

regarding lagoons have already been identified in recent public meetings, namely noise,

odor, and traffic problems

. The potential number of truck trips necessary to dispose of

the treated sludge is estimated at approximately

750 trips per year

. Additional truck

73

---

traffic results in potential noise, congestion, and increased traffic hazard . Some

individual families could be particularly adversely impacted (e.g., houses which

potentially abut or overlook lagoons) . Additional community impacts may be incurred

due to the effect of increased traffic to activities associated with the newly-authorized

City of Alton Park located next to the proposed facility entrance road . The park contains

the natural bluff area and features a cliff painting of the "Piasa Bird ." Potential conflicts

exist for trucks entering and exiting the site to park traffic, park visitors, and bike park

traffic. Better delineation of potential conflicts will require

finalization of the park

design. SSIS at 6-12

.

121

.

As part of determining the appropriate discharge requirements, the

Company considered the potential for pollution prevention and waste minimization

. The

following two factors were considered:

•

waste reduction opportunities by process change, improved housekeeping

and recovery of waste components for reuse; and

•

segregation or combining of process wastewater streamsJB'

122 . The type of process employed to make potable water is a critical factor

which helps determine the nature, amount, and treatability of residuals produced . In the

"Draft Development Document For Effluent Limitations Guidelines and Standards of

Performance, Water Supply Industry," sub-categories for the water supply industry were

based on the type of processes or combinations of processes used at a facility (U .S .

EPA,

1975) . See Attachment K hereto

. The proposed replacement facility will rely on

W

These are also required factors in the BDT determination

.

74

---

coagulation of river silt by Clar*Ion® to achieve potable water. This type of process

means that :

•

the percentage of naturally-occurring material in the total solids returned

to the River is typically 91 % or greater ;

•

only a trace amount of the 8 .7 percent discharge solids contributed by the

coagulant is comprised of the metals of concern (i .e., only 0 .348 percent

of the total discharge volume is comprised of aluminum or iron)

;

•

conversely, the residual solids contain a minor amount of process-derived

chemicals ; and

•

use of an alum-organic polymer such as Clar*Ion ® leads to potentially

greater disposal costs due to its poor storage and handling characteristics .

123 .

The possibility of incorporating a number of process changes to reduce the

quantity of and to improve the quality of the effluent was considered for the proposed

replacement facility

. Evaluation of these process changes indicated that :

•

stringent housekeeping measures (in effect at the existing facility) will be

implemented at the proposed replacement facility

;

•

recovery of the small percentage of alum in the Clar*Ion

®

is not

practicable at the proposed replacement facility due to the high silt content

in the residuals ; and

•

segregation of waste streams will not reduce the treatment required nor

improve the effluent quality .

75

---

Thus, no process design changes were identified to significantly reduce the quantity and

improve the quality of the effluent . SSIS at 6-13 .

124 . As

part of the BDT determination, sound engineering judgment was

applied to integrate the various site specific factors and technical elements . A review of

the cost-benefit analysis of the factors considered above indicates that technologically

feasible methods exist for reducing TSS in discharge effluent to Illinois Water Quality

Standards (i.e., 15 mgll daily average) . The capital cost of these options could range

from approximately $7

.38 million to $10 .8 million to implement

. As discussed in

paragraphs 59-61, above, operating costs would be substantial . SSIS at 6-13

.

125.

Important factors in determining the appropriate site specific discharge

standards for the proposed replacement facility include the large amounts of naturally-

derived TSS in the discharge with only minor quantities of process-generated TSS, and

the discharge's lack of discernable environmental impact . The lack of discernable

environmental impact is significant, because the economic reasonableness analysis on

which BDT is based (and thus reasonably also on which site specific relief is based)

presumes the existence of such impacts

. Conventional treatment of process-generated

TSS typically contends with only a small fraction of silt in the process influent water .

In contrast, the River provides large volumes of silt in the intake water

. This volume

of silt translates into large residual volumes which must be disposed .

Little

environmental purpose is served in retaining these residuals and disposing of them on

land at considerable economic cost to the Water Company, and ultimately its rate-paying

customers . SSIS at

6-14 .

76

---

126. Based on a review of modeled physical, chemical, and biological impacts

to the River, the large naturally-occurring volumes of TSS and the lack of discharge

environmental impact make the technically feasible treatment options unwarranted under

BDT

. It appears that little, if any, tangible environmental benefit will be derived from

solids reduction. Water quality and biological communities will not be measurably

enhanced by this solids reduction nor do they appear impacted by the cumulative impact

of current discharges. These findings are similar to those reported from water treatment

facilities on similar large, turbid rivers . Available aluminum and iron data indicates that

dissolved concentrations of either are highly unlikely to impact biological communities

in the River . SSIS at 6-14 .

127. Benefits usually associated with solids reduction are improvement or

enhancement of water quality of receiving waters . Solids reduction in this case will

provide negligible improvement to the water quality parameters in question and no

enhancement of existing biological communities or designated uses of the River

. In

addition, continuation of the return of effluent TSS from residuals does not result in

degradation of the receiving water, as judged by potential impacts . SSIS at 6-14 .

128. Application of the candidate control technologies -- i

.e., on-site lagoons

with subsequent off-site landfilling

; and on-site lagoons combined with belt filter press

dewatering and subsequent off-site landfilling - provides negligible reduction benefits

.

Based on a careful weighing of these factors, a determination of no treatment of TSS in

the discharge is BDT for the proposed replacement facility . SSIS at 6-14

.

129.

Although compliance with the regulation of general applicability is

77

---

technically feasible (in the sense that compliance can be achieved, if the Water Company

is required to implement on-site treatment technologies at considerable expense), direct

discharge is warranted on economic grounds

. As noted above, the Board has granted

relief to all similarly situated (non-lime softening) water treatment facilities that use the

River as their raw water source -- i.e.,

the facilities that currently serve Rock Island,

East Moline, Alton and East St . Louis .

The replacement facility is not significantly

different from these other facilities when analyzed pursuant to the factors relevant to

evaluating adjusted standard relief for these types of public water supply facilities under

the Act -- i.e.,

Sections 28 .1 and 28.3, BPJ, and BPT . Recent U .S

. EPA action for a

similar Missouri River facility also supports granting relief for the replacement facility

on grounds including economic infeasibility . See

Attachments M and N hereto .

facility's direct discharge of residuals to the River will not adversely impact the River's

water quality, or the environment

. Water quality data on the River indicate that TSS and

iron concentrations of the raw River water exceed the general effluent standards

. As

noted in paragraphs 107-109, above, the replacement facility's discharge will cause an

imperceptible increase in the ambient water quality and will pose no significant impact

on the River and the River environment

.

Therefore, the application of treatment

technologies will not result in perceptible improvements in water or sediment quality,

78

3.

Specific reasons for selection of direct discharge option

130 .

(i)

Direct discharge is appropriate, because the effluent

from the replacement facility will

not adversely impact

water quality of the River or the River environment .

As discussed in detail in paragraphs 65 et seq

., above, the replacement

---

will not enhance habitat quality, and will have no effect on local biota

. As such, the

current direct discharge allowed for the existing facility is also appropriate for the

replacement facility .

(ii)

U.S . EPA regulations, guidance documents and its

recent determination for a similar facility recognize that

direct discharge is appropriate .

131 . U.S

. EPA's decision not to promulgate effluent standards for the water

industry and two key U .S. EPA guidance documents also suggest, like the Board's prior

grant of relief to the facilities serving Rock Island, Alton, East Moline and East St

.

Louis, that residuals from raw water in large, highly turbid rivers should not be governed

by general effluent standards . As a result, effluent standards for the water industry must

be determined on a site-specific basis . U .S . EPA regulations and key guidance

documents provide that discharge limitations should be determined on a site-specific basis

and should take into account unique factors of the site

. The guidance documents also

support the proposition that silt removed from raw water may appropriately be returned

to the River . Those documents are the U .S

. EPA Permit Policy Statement #13 issued

September 18, 1974 ("Permit Policy #13") and the Draft Development Document for

Effluent Limitation Guidelines and Standards of Performance

- Water Supply Industry

(1975) ("Draft Development Document")

. Permit Policy #13 and the Draft Development

Document are attached hereto and incorporated by reference as Attachments L and K,

respectively .

132

. Permit Policy #13 concerns "Disposal of Supply Water Treatment Sludges"

79

---

and the following excerpts directly relate to the replacement facility

:

•

It is inappropriate to arbitrarily prohibit silt removed from

public water supply streams from being returned to the

stream. Rather, one must consider the 'supply water silt

burden, nature and quantity of chemical clarification aids

used, availability of land disposal sites, economic impact,

navigational considerations and water quality standards, to

mention a few

." (Page 1)

; and

•

U

.S

. EPA recognized that in some instances the general

effluent standards need not apply to the Mississippi River.

"Because silt is indigenous to certain River waters, notably

the Mississippi and Missouri Rivers, and because our

priority concern is process generated pollutants, and

because unreasonable cost-benefit relationships may result

in some areas of these Rivers and others, it would be

within the intent of best practicable control technology

currently available to authorize, in some instances, either

the partial or total return of silt type sludge to the receiving

waters

." (Page 2) .

133 .

These excerpts emphasize two important points . First, U .S . EPA

distinguishes sludges composed mainly of naturally occurring silts from water treatment

sludges with high concentrations of process generated chemicals . This implies that

discharge of the naturally occurring silt is not the type intended to be restricted and need

not necessarily conform to the general effluent standards . Second, U.S

. EPA

acknowledges that because of the high silt content of the Mississippi River, return of

these silts to the River can constitute the best technology option .

134. The Draft Development Document provides further insight into U.S.

EPA's position on water supply treatment effluents

. The document establishes TSS as

a pollutant parameter for all subcategories of water treatment facilities .

The Draft

Development Document also acknowledges that : 1) return of residuals to a highly turbid

80

---

River will cause an imperceptible increase in turbidity ; 2) treating such discharges is not

cost-effective

; and 3) alum-containing coagulant sludges present unique handling and

disposal problems . Specifically, the Draft Development Document notes that

:

•

Extensive studies made at facilities along one highly turbid

River have shown that returning the raw waste sludge to

the highly turbid source increases the turbidity of the

stream by an insignificant increment . In some instances the

incremental increase in turbidity is less than the precision

of many turbidimeters used for routine monitoring . (Page

46) ;

•

These studies have also shown that the benefit-cost ratio for

dewatering the sludge and hauling to landfills is

very low,

and that the amount of energy used in treating and hauling

it is very high

.

Because of these factors the disposal of

sludge from facilities that must use highly turbid water as

feeds (>200 JTU on an annual average basis) should be

judged on an individual basis

. (Page 46); and

•

Alum sludge is difficult to dewater by lagooning .

However, it will gradually consolidate sufficiently to

provide a 10% to 15% solids content. Water removal is

normally by decantation or by evaporation with some

drainage .

Evaporation may provide a hard crust on the

surface but the sludge below the crust is thixotropic,

capable of turning into a viscous liquid upon agitation with

near zero shear resistance under static load .

Therefore,

lagooned alum sludge cannot be easily handled nor will it

make good landfill material. (Pages 75-76) .

135 . These excerpts demonstrate U .S

. EPA's recognition that the costs of

imposing TSS limitations on water treatment supply facility effluents, especially

coagulant or alum sludges, outweigh the negligible improvement in water quality

resulting from control technology . These U .S

. EPA documents directly apply to the

discharge by the replacement facility, and support direct discharge for the facility's

process residuals

.

81

---

136. The case for direct discharge is further supported by U .S. EPA's own

recent determination that direct discharge is BPJ for Missouri-American Water

Company's public water supply treatment facility located on the Missouri River in St

.

Joseph, Missouri . A copy of U

.S

. EPA's letter stating that direct discharge is BPJ is

attached hereto and incorporated by reference as Attachment M . The Best Professional

Judgment Study Report on which U .S

. EPA's determination was based is attached hereto

and incorporated by reference as Attachment N.

(iii)

The Water Company's discharge will contain only trace

elements of the metals of concern (aluminum and iron),

which is insignificant as compared to the alum and iron

returned by two other water treatment facilities

currently permitted for direct discharge

.

137. The U .S. EPA guidance documents confirm that the process employed to

treat water is a critical factor which helps determine the nature, amount and treatability

of residuals . As noted in paragraph 22, above, the replacement facility intends to rely

on coagulation of river silt by Clar*Ion ® to achieve potable water . This process

generally means that the percentage of naturally-occurring materials in the total solids

returned to the River is typically 91 % or greater

. SSIS at 6-12. The coagulant

contributes approximately 8 .7% of the total solids content of the discharge

. Id. Only

4 % of the 8 .7% coagulant total solids content is comprised of the metals of concern (i.e.,

aluminum and iron), and none of the iron is generated by the coagulant .

Aluminum

contributes approximately only 0 .348% --

approximately one third of one percent, by

weight --

of the total solids content returned to the River . Id . at 6-2

.

82

---

138

. This minute fraction presents a marked contrast to the Board's findings

regarding the Rock Island and East Moline public water supply facilities . The Board

found that "it is undisputed" that 25percent of the solids in East Moline's discharge are

"added in the course of treatment

." Opinion and Order of the Board, R87-35, March 8,

1990, Attachment 0 hereto, at p . 4. The percentage of solids discharged resulting from

treatment additives was even worse in Rock Island . In analyzing Rock Island's proposal

in its Petition to convert from an indirect to a direct discharge to the Mississippi River,

the Board stated that :

We do know that in this case the city's contribution of

solids, as a percentage of the total solid content of its

discharge, would be substantial, onthe order of 50% ; this

is not merely a case of returning solids to the River .

Opinion and Order of the Board, R87-34, March 22, 1990, Attachment P hereto, at p

.

13, emphasis added . Although the final orders granting direct discharge relief to the

Rock Island and East Moline facilities required these facilities to attempt to reduce their

volumes of coagulant based solids, the Water Company's replacement facility is already

designed to implement state of the art best management practices to limit its discharges

as much as possible to the solids it has withdrawn from the River, while still treating the

river water in a manner which results in potable water that meets safety requirements

under the federal Safe Drinking Water Act .

The Water Company's discharge will

unquestionably contain far less metal-based treatment additives than that of Rock Island

and East Moline .

83

---

(iv)

The costs, economic and non-economic, of the two

candidate technologies significantly

outweigh the

negligible benefit of eliminating an imperceptible impact

to the River's water quality .

139 . Little environmental purpose is served in retaining the process residuals

and disposing of them on land at considerable economic cost to the Water Company, and

ultimately its rate paying customers

. The imperceptible improvement to the water quality

and aquatic environment of the River does not justify the considerable costs associated

with the two candidate technologies -- i

.e.,

on-site lagoons with subsequent off-site

landfilling ; and belt filter press dewatering with subsequent off-site landfilling

.

As

demonstrated in the SSIS, the direct discharge of process residuals will have no

significant impact on water quality or sediment quality and will have no effect on local

biota

. As such, the application of the candidate technologies will not result in perceptible

improvements to the water quality or local biota . Therefore, the significant annualized

costs for the candidate technologies

-- approximately $1,140,000 to $1,630,000 -- cannot

be justified .

140.

Furthermore, in considering economic reasonableness, rate payer and

community impacts must be considered

. The costs of residuals handling/treatment will

be passed on to rate payers . Since the annualized costs of the candidate technologies are

approximately $1,140,000 and $1,630,000, the annual cost per household/business served

would be approximately $65 and $93, respectively -- a 22%u to 31%

annual water bill

increase

."' Again, the significant rate payer cost increase is not justified by the

'--"'

This calculation assumes the costs are spread across the approximately 19

.500 ratepayers within she. Company's

Alton District (Le .,

households and businesses to be served from the replacement facility) and that costs are spread

equally among the rate payers .

84

---

negligible improvement to the River water quality (or State or federal regulations) which

would result from residuals treatment/handling .

141

. Finally, the cost-benefit analysis must also consider other intangible factors

including, but not limited to, reduced and/or

more expensive landfill capacity in the

future, potential operational problems with the candidate technologies, and other

socioeconomic costs .

(1)

First, the candidate technologies would require significant landfill

space to dispose of the process residuals, The use of available landfill space to dispose

of what is largely naturally-occurring River silt would be an extremely ineffective use

of landfill capacity .

(ii)

Second, the candidate technologies could potentially experience

operational difficulties .

Operational difficulties should be anticipated, because of the

wide range of TSS concentrations in the raw water and the variable quantity of solids to

be handled .

The likelihood of inclement weather would also lead to operating

difficulties

. These potential operating difficulties also argue against selecting either of

the candidate technologies .

(iii) Finally, other socioeconomic costs and community impacts must

be considered. Neighborhood concerns over potential loss of real estate value, noise,

odor and traffic problems are likely to be associated with lagoons and site-related

operations

. For example, the number of truck trips necessary to dispose of the treated

sludge is estimated at approximately 750 trips per year. This truck traffic could cause

congestion, road degradation, and likely would be an increased traffic hazard

. These

85

---

av

traffic concerns are heightened by the City of Alton's plans to use the road over which

the trucks would travel as the entry and exit road for a tourist attraction which features

a painting of the legendary Piasa Bird ."

142. As noted in paragraphs 66 ; 129-138, above, Rock Island and East Moline

have received Board relief from the generally applicable standards . The Board has also

provided relief from the general effluent standards for water treatment facilities owned

by the Water Company on two previous occasions

. First, the Board promulgated a site-

specific rule for the Water Company's existing water treatment facility in Alton . 35 111 .

Adm, Code 304 .206 . The Board provided that the existing facility's discharge into the

River would not be subject to the effluent standards for TSS and iron of 35 Ill . Adm .

Code 304

.124 . Similarly, the Board granted an adjusted standard for the Water

Company's water treatment facility located in East St. Louis. 35 Ill . Adm . Code

304 .220. There, the Board provided that the facility's discharge into the River would

not be subject to the effluent standards for TSS and iron of 35 Ill . Adm

. Code 304.124,

provided that the Water Company used only biodegradable coagulants approved by U .S .

EPA

. The Water Company currently uses such biodegradable coagulants at the existing

Alton facility and intends to continue to do so at the replacement facility

.

143 . As shown by the Water Company's detailed evaluation of all appropriate

state and federal requirements for the replacement facility, relief from the general

effluent standards is also warranted in this case .

The Piasa Bird is a legendary creature traditionally believed to have inhabited the bluffs .

86

---

Consistency with Federal Law

144.

Section 106

.705(i) of the Procedural Rules provides that the petition must

contain a statement with supporting reasons that the Board may grant the proposed

adjusted standard consistent with federal law . The petitioner must inform the Board of

all procedural requirements imposed by federal law, but not by the Board's adjusted

standard procedural requirements, which are applicable to the Board's decision on the

petition . Citations to relevant regulatory and statutory authorities should also be

included.

145 . As noted in paragraph 14, above, the federal government has not

promulgated any NPDES effluent standards for public water supply treatment facilities .

As discussed below, recent U .S

. EPA action for a similar Missouri River water treatment

facility also supports the consistency of the proposed relief with federal law . The Board

has noted that there are no federal effluent regulations for public water supply treatment

facilities and has concluded that :

In the absence of such regulations, effluent limitations are to be established on a

case by case basis under Section 402(a)(1) of the Clean Water Act . (33 U

.S .C .

1342(a)(1)

.) The Board continues to believe that directives from U .S. EPA give

the Board and the Agency (as permitting authorities) broad discretion in

determining the level of control to apply to discharges from water treatment

plants .

Proposed Opinion and Order of the Board, PCB R85-11, June 16, 1988, at p

. 8 . See

Attachment I hereto .

In addition, U

.S

. EPA has found that direct discharge is

appropriate for the St

. Joseph, Missouri facility .

See

Attachment M hereto

. Therefore,

the proposed adjusted standard is consistent with federal law

. As noted in paragraph 6,

87

---

above, pursuant to this authority the Board has granted relief to all similarly situated non-

lime softening facilities on the River when they have sought such relief .

146.

As noted in paragraph 12, above, the need for an adjusted standard for the

replacement facility is in part based on the need to apply the federal BPJ requirements

in the replacement facility's NPDES permit . U.S. EPA guidance documents, discussed

below, also provide that discharge limitations should be determined on a site-specific

basis and must take into account unique factors, such as the turbid nature of the raw

water . The guidance documents state that, in appropriate instances, residuals from public

water supply systems may be returned to the River .

147 . Pursuant to Section 402(a) of the CWA, developing effluent limitations on

a case-by-case basis requires application of the BPJ factors listed in 40 C .F .R

. § 125 .3(d)

and consideration of: (i) the appropriate technology for the category or class of point

sources of which the applicant is a member, based on available information

; and (ii) any

unique factors relating to the applicant . 40 C

.F.R . § 125.3(c)(2) .W Evaluation of two

specific elements is also required in setting BPJ for the replacement facility

-- best

practicable control technology currently available ("BPT") and best conventional pollutant

control technology ("BCT")

. 40 C .F .R . § 125.3(d) .

148. BPT factors are : (i) the total cost of application of technology in relation

to the effluent reduction benefits to be achieved from such application

; (ii) the age of

21 '

As noted, the BPJ permit factors overlap many of the factors the Board will apply to adjusted standards pursuant

to Section 28 .1 of the Act -- e.g . .

the technical feasibility and economic reasonableness of reducing the particular type

of pollution, and other unique factors such as existing physical conditions

. Along with the Section 28 .3(c) factors and

BDT (35 111 . Adm . Code 304

.102) factors, these are the directly relevant factors for evaluating the merits of a public

water supply facility's request for relief

from the Board's general industrial effluent standards .

88

---

equipment and facilities involved ; (iii) the process employed ; (iv) the engineering aspects

of the application of various types of control techniques

; (v) process changes ; and (vi)

non-water quality environmental impact (including energy requirements)

. 40 C

.F .R . §

125.3(d)(1) . The BCT analysis includes the BPT issues and one additional factor : the

comparison of the cost and level of reduction of such pollutants from the discharge from

publicly owned treatment works to the cost and level of reduction of such pollutants from

a class or category of industrial sources . Id.

149 .

Developing effluent limits on a case-by-case basis pursuant to federal law

requires consideration of

: (i) the appropriate technology for the category or class of point

sources of which the applicant is a member, based on available information ; and (ii) any

unique factors relating to the applicant . 40 C.F.R. § 125 .3(c)(2)

. It is also necessary to

consider the appropriate factors listed in 40 C .F.R

. § 125 .3(d) in developing these

effluent limits

.

Consideration of Appropriate Technology and Unique Factors

150.

Paragraphs 52 through 61 and 18 through 49, above, discuss appropriate

technologies for water treatment facilities and unique factors relating to the Water

Company . The Water Company respectfully refers the Board to those sections for a full

discussion of the Water Company's compliance with these federal requirements

.

Determination of BPT Under Best Professional Jud men

151 . As noted in paragraph 148, above, 40 C .F.R

. § 125 .3(d)(1) provides the

factors necessary for the determination of BPT

. Many of these factors have been

89

---

previously considered in this Petition and the relevant paragraphs will be referenced as

appropriate . The remainder of the factors will be discussed in detail below

.

152 . The first factor to consider for BPT is the total cost of application of

technology in relation to the effluent reduction benefits to he achieved from such

application . 40 C .F.R . § 125.3(d)(1)(i)

. Essentially, this factor examines the cost-benefit

relationship between removal of effluent TSS to resulting effluent reduction benefits and

has been evaluated in paragraphs 139-141, above

; see also, SSIS at 6-15 to 6-20 .

153 .

The second factor to consider under BPT is the age of equipment and

facilities involved . 40 C .F .R. § 125 .3(d)(1)(ii)

. All equipment at the replacement facility

will be new

; therefore, this factor is not a constraint for the facility .

154 . The third factor under BPT is the process employed . 40 C,F.R. §

125 .3(d)(1)(iii) . The type of process employed to treat the raw River water is a critical

factor which helps determine the nature, amount, and treatability of residuals produced

.

As noted in paragraph 22, above, the replacement facility intends to rely on coagulation

of River sediments by Clar*Ion ® to achieve potable water . Under this type of process,

the percentage of naturally-occurring material in the total solids returned to the River is

typically 91% or greater . SSIS at 6-12 . Of the 8

.7% total solids which is contributed

by the coagulant, only a trace amount is comprised of aluminum

-- only about one third

of one percent

(0.348%),

by weight, of the facility's solids discharge

. SSIS at 6-2.

155 .

The fourth factor to consider under BPT is the engineering aspects of the

application of various types of control techniques

. 40 C.F.R. § 125 .3(d)(1)(iv) .

90

---

Consideration of this factor is provided in paragraphs 52-58, above ; see also, SSIS at 6-1

to 6-9 .

156 . The fifth factor under BPT is process changes . 40 C.F .R

. §

125 .3(d)(1)(v)

. As part of the BDT consideration, pollution prevention and/or waste

minimization at the replacement facility was investigated . However, there is little or

nothing the Water Company can do to further minimize waste or prevent pollution for

the following reasons :

•

There is limited potential for treatment process change, as the replacement

facility must treat the River water to a potable level which meets Safe

Drinking Water Act requirements .

•

Process changes, including minimization of the amount or the nature of

chemicals added, have already been implemented by the Water Company

to the extent feasible. In any event, process changes in themselves will

not greatly reduce the amount of residuals, because the quantity of

residuals will always be dictated by the differences between raw water

quality and the drinking water standards .

•

Operational improvements, such as the continuous discharge of residuals

through the use of Superpulsators ®

instead of conventional clarifiers have

already been incorporated .

•

Stringent housekeeping measures (in effect at the existing facility) will be

implemented at the replacement facility .

•

Recovery of the small percentage of aluminum in the Clar`lon

® is not

practicable at the replacement facility, due to the high silt content in the

residuals .

•

Segregation of waste streams will not reduce the treatment required nor

improve the effluent quality.

See SSIS

at 5-23 to 5-24 and 6-12 to 6-13 . Thus, no process design changes exist to

significantly reduce the quantity or improve the quality of the effluent

.

91

---

157. The last factor to consider under BPT is the non-water quality

environmental impact (including energy requirements) . 40 C .F .R. § 125 .3(d)(1)(vi) .

Non-water quality environmental impacts, most of which were discussed above

(e.g.,

paras . 118-121

; 141), include : 1) landfill space requirements for the dewatering lagoon

and mechanical filter press techniques ; 2) land acreage needed for storage lagoons ; 3)

potential energy requirements for handling and pumping sludges

; 4) loss of viable farm

land during the foreseeable future (i.e., next 30 years); 5) approximately 750 truckloads

per year to transport and dispose of treated sludge ; and 6) community stakeholder issues

regarding noise, odor, and aesthetic concerns.

158. Based on consideration of the statutory and unique factors, BPT for the

facility, determined through BPJ, is no treatment of the discharge

.

Determination of BCT Under Best Professional Judnment

159 . 40 C.F.R. § 125.3(d)(1) provides the factors necessary for the

determination of BCT

. All but one of the factors have been previously considered in this

Petition . The remaining factor will be discussed below

.

160. The additional factor under BCT is the comparison of the cost and level

of reduction of such pollutants from the discharge from POTWs to the cost and level of

reduction of such pollutants from a class or category of industrial sources

. 40 C .F .R. §

125.3(d)(2)(ii) .

This factor examines the cost reasonableness of the TSS control

technology (i.e.,

pressure filtration) as it compares to the cost and level of reduction of

TSS from the discharge from POTWs .

92

---

161 . The BCT

methodology is undertaken to determine whether it is cost-

reasonable for industry to control conventional pollutants at levels more stringent than

BPT limitations

. To "pass" the POTW portion of the cost test, the cost per pound of

conventional pollutant removed by industrial dischargers in upgrading from

BPT to the

candidate BCT must be less than the cost per pound of conventional pollutant removed

in upgrading POTWs from secondary treatment to advanced secondary treatment

. 51

Fed. Reg . 24974-25002 (1986)

. In general, the upgrade cost to industry must he less

than EPA's POTW benchmark cost of $0

.25 per pound of

TSS (in 1976 dollars)

. Id .

162.

For the replacement facility, a final unit operation process

of

pressure

filtration will reduce the TSS concentration of the effluent from the generally applicable

regulatory limit of 15 mg/I TSS

22' to essentially

zero.`

SSIS at 6-18, 6-19 . The

annualized costs (in 1976 dollars) per pound

of

TSS removed by the pressure filtration

process amounts to $4 .38 per pound of TSS .24'

Id. at 6-23

. When compared to EPA's

benchmark of $0

.25 per pound of TSS, the pressure filtration candidate technology fails

the cost reasonableness test by orders of magnitude

.

nt

As explained in the SS1S, U .S

. EPA suggested in the St

. Joseph permit proceeding that when the BPI process

indicates that BPT is direct discharge, the cost-reasonableness issue under BCT should nonetheless (for this purpose only)

presume that BPT is conventional treatment

. Thus, the BPT number for this calculation is the generally applicable

effluent standard of 15 mg/l .

3'

The pressure filtration system has been sized based on an estimated hydraulic flaw rate of the total residuals

.

r'

The annualized cost for a pressure filtration system was calculated by amortizing the capital costs over 30 years

at a 9 percent interest rate and adding the yearly operation and maintenance costs

. This cost was then indexed to 1976

dollars .

93

---

163 . Based on the results of the POTW cost test, the candidate BCT technology

is not cost-reasonable . As a result, direct discharge is the appropriate control technology

under both BPT and BCT .

Hearine Request or Waiver

164. Section 106 .705(j) of the Procedural Rules provides that the petition must

state whether the petitioner requests or waives its right to a hearing on the petition .

Hearings are evidentiary in nature and are held before a hearing officer appointed by the

Board and are transcribed before a court reporter . Pursuant to the requirements of

Section 106.713 of the Procedural Rules ; the Water Company requests that the Board

give notice of the petition and schedule a hearing

in accordance with 35 Ill. Adm . Code

Part 103 .

Supporting Documents and Leeal Authorities

165 . Section 106 .705(k) of the Procedural Rules provides that the petition must

cite to supporting documents or legal authorities whenever such are used as

. a basis for

the petitioner's proof

. Relevant portions of such documents and legal authorities other

than Board decisions, state regulations, statutes and reported cases shall be appended to

the petition

. The Water Company has appended to the Petition the following documents :

Attachment A--Photographs of River Flood at the Existing Facility, Summer 1993

Attachment B--Site Specific Analysis for Replacement Facility, March 1999

Attachment C--Final Opinion and Order of the Board, PCB R82-3, March 9, 1994

Attachment D--Opinion and Order of the Board, PCB AS 91-13, Oct

. 19, 1995

Attachment E--Opinion and Order of the Board, PCB AS 91-9, May 19, 1994

Attachment F--Opinion and Order of the Board, PCB AS 91-11, May 20, 1993

Attachment G--Opinion of the Board, PCB R70-8 et al

., January 6, 1972

Attachment H--Illinois Institute for Environmental Quality's Evaluation of Effluent

Regulations of the State of Illinois, June 1976

94

---

Attachment 1--Proposed Opinion and Order of the Board, PCB R85-11, June 16,

1988

Attachment)--U

.S, EPA's Amended Section 301(h) Technical Support Document,

Sept . 1994

Attachment K--U . S

. EPA's Draft Development Document for Effluent Limitations

Guidelines and Standards of Performance, March 1975

Attachment L--U .S . EPA's Permit Policy 13, Sept

. 1974

Attachment M--Memo and letter from John Dunn (U.S

. EPA) to Gale Hutton

(Missouri Department of Natural Resources)

Attachment N--BPJ Evaluation of Existing NPDES Effluent Limitations at

Missouri-American Facility, St . Joseph, MO

Attachment 0--Final Opinion and Order of the Board, PCB R87-35, March 8,

1990

Attachment P--Opinion and Order of the Board, PCB R87-34, March 22, 1990

CONCLUSION

WHEREFORE, for all the reasons stated above, Illinois-American Water

Company respectfully requests that the Board set this Petition for hearing and grant the

adjusted standard specified herein for the Water Company's replacement public water

supply treatment facility in Alton, Madison County, Illinois

.

Respectfully Submitted,

ILLINOIS-AMERICAN

WATER COMPANY

Nancy J

. Rich

James E

. Mitchell

Katten Muchin & Zavis

525 W . Monroe Street

Suite 1600

Chicago, Illinois 60661-3693

(312) 902-5200

By: One g1f:?rneys

95

OF COUNSEL :

Sue A . Schultz

General Counsel

Illinois-American Water Company

300 North Water Works Drive

Belleville, Illinois 62222

(618) 239-2225

---

March 19, 1999

Katten Muchin & Zavis

525 W . Monroe Street

Suite 1600

Chicago, Illinois 60661-3693

312-902-5200

Doc O:CH02 (03879. 0000 5) 924940v1 ;3N W1999Mme:1426

CERTIFICATE OF SERVICE

I, the undersigned, certify that I have served the attached Petition for Adjusted

Standard of Illinois-American Water Company and Appearances of Nancy J

. Rich and James

E. Mitchell, by Messenger upon :

Dorothy M

. Gunn

Illinois Pollution Control Board

James R

. Thompson Center

100 W. Randolph St., Ste

. 11-500

Chicago, Illinois 60601

(with Attachments)

and by Certified Mail upon

:

IEPA Division of Legal Counsel

1021 North Grand Avenue East

Springfield, Illinois 62794

(with Attachments)

Attn: Lisa E. Moreno, Esq .

Assistant Counsel

and

Robert Lawley, Esq

.

Chief Legal Counsel

Illinois Department of Natural Resources

524 S. 2nd Street Room 400

Springfield, Illinois 62701

(without Attachments)

`'_Izso~ld'/`

.

.J.0047-

Oop~

---

ENIb'R.

IIlinois-American Water

Company

Belleville, Illinois

Site-Specific Analysis of

Impacts of Potential

Alternatives for Handling

Public Water Supply Residuals

at Proposed Alton, IL Facility

ENSR

March 1999

Document Number 549307CP

.DFM, 3995-007-500

---

Illinois-American Water

Company

Belleville, Illinois

Site-Specific Analysis of

Impacts of Potential

Alternatives for Handling

Public Water Supply Residuals

at Proposed Alton, IL Facility

ENSR

March 1999

Document Number 549307CP .DFM, 3995-007-500

---

CONTENTS

1 .0

INTRODUCTION

1-1

1 .1 Purpose and Organization of the Site Specific Impact Study 1-1

1 .2 Regulatory Compliance

1-2

1 .2.1

Illinois Environmental Protection Act's Site Specific Regulatory

Requirements

1-3

1 .2 .2 Requirement for Consistency with Federal Law 1-4

1 .3 Current Permit Conditions

1-5

1 .4 Background Information on Effluent Limitations for Public Water Supply

Facilities

1-5

1 .5

Background Information on BPT and BCT Requirements

1-7

EN R

4

.0

ENVIRONMENTAL CHARACTERISTICS OF PROPOSED SITE 4-1

4 .1 Existing Physical Conditions

4-1

4 .1

.1

Historical Significance

4-1

4 .2 Land Use

4-2

4 .3 Characterization of Mississippi River at Afton, Illinois

4-2

4 .3.1

Hydrology

4-3

4 .3 .2 Water Quality in the Mississippi River

4-3

4 .3 .3 Mussel Habitat Near the Proposed Site

4-4

549307DM.ALL, 3995-007.500

i

3 March 1999

2.0

REGULATORY REVIEW AND DEFINITION OF SITE SPECIFIC FACTORS 2-1

2 .1 Preparation of Workplan for Illinois EPA Review 2-1

2 .2 Response to Illinois EPA Comments and Suggestions

2-1

2 .3

Development of Plan for Seeking Stakeholder Input 2-2

2 .4

Additional Meetings with Illinois EPA

2-2

3 .0 DETERMINATION OF PREDICTED EFFLUENT DISCHARGES 3-1

3 .1

Current Plant Configuration

3-1

3 .2 Current Effluent Discharges

3-2

3 .3 Plant History and Replacement Facility

3-3

3 .4 Replacement Plant Design, Capacity, Flows and Discharges

3-4

3 .4 .1

Plant Flows

3-4

3 .4.2

Plant Design

3-4

3 .5 Variability of River Water Quality

3-6

3 .6

Modeling of Anticipated Exceedances

3-7

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54930713M.ALL

3995007-500

CONTENTS

(Cont'd)

4.4 Potential Stakeholder Concerns

4-5

5

.0 POTENTIAL ENVIRONMENTAL IMPACTS OF EFFLUENT 5-1

5.1 Modeling of Water Quality Effects

5-1

5.1 .1

Water Quality

5-2

5.1 .1 .1

Impacts of the Proposed Facility Discharge under Low Flow

Conditions

5-3

5.1

.1

.2 Impacts of the Proposed Facility Discharge under Average

Annual Conditions

5-5

5.1 .2 Impacts of Sediments

5-6

5.1 .2.1 Specification of Model Scenarios

5-6

5.1 .2.2 Assumptions on the Mississippi River 5-8

5.1 .2.3 Settling Behavior of Solids Being Potentially Discharged . . . . 5-8

5.1 .2.4

Estimated Particle Size

5-9

5.1 .2.5 Particle Size Groups

5-9

5.1

.2.6

Particle Deposition Modeling Results 5-10

5.1 .2.7 Uncertainties

5-11

5.1 .3 Summary of Water Quality Impacts 5-11

5.2 Definition of Area of Mixing

5-12

5.3 Characterization of Potential Environmental Impacts

5-12

5.3.1 Biological Communities

5-12

5

.3.1

.1 River Habitats near River Mile 204 5 1?,--~

5.3.1 .2 Fish and Macroinvertebrate Communities 5-14

5 .3.2 Stream Chemical Analyses

5-14

5.3.2.1 Potential Non-Toxic Effects of Suspended Solids on Biota 5-15

5.3.2.2 Effects of Increased Suspended Solids on Biota 5-16

5.3.2.3 Potential Toxic Effects of Replacement Facility Discharge on

Biota

5-17

5.3.2.4 Summary of Impact Analyses 5-21

5.3.3. Sensitive Species and Habitat Evaluation 5-21

5 .4 Identification of Frequency and Extent of Discharges 5-22

5.5 Identification of Potential for Unnatural Bottom Deposits, Odors, Unnatural

Floating Material or Color

5-22

5

.6

Stream Morphology and Results of Stream Chemical Analyses 5-23

5 .7 Evaluations of Stream Sediment Analyses

5-23

ii

3 March 1999

---

5493070M.ALL

. 3995-007-500

CONTENTS

(Cont'd)

5 .8

Pollution Prevention Evaluation

5-23

6.0

BEST DEGREE OF TREATMENT (BDT) ANALYSIS

6-1

6 .1 Identification of Treatment Technologies for Residuals Control 6-1

6.2

Selection of Candidate Technologies

6-7

6.3

Order of Magnitude Cost Estimates for Selected BDT Options

6-7

6 .3.1

Dewatering Lagoons and Subsequent Landfilling Cost Estimate 6-8

6

.3.2

Filter Press Dewatering and Subsequent Landfilling Cost Estimate . . . 6-9

6.4

Development of BDT

6-9

6.4.1

Technological Feasibility

6-9

6.4.2 Economic Reasonableness

6-10

6 .4.2.1

Cost-Benefit Relationship

6-10

6.4.2.2 Community Impacts

6-12

6.4.3 Waste Reduction

6-12

6.4.4 Determination of BDT for Proposed Alton Facility

6-13

6.5 Compliance with Federal BPJ Evaluation

6-15

6

.5.1

Development of BPT Under Best Professional Judgement

6-15

6.5.1

.1

The Total Cost of Application of Technology in Relation to

the Effluent Reduction Benefits to be Achieved from Such

Application

6-15

6.5.1 .2 The Age of Equipment and Facilities Involved 6-15

6.5.1 .3 The Process Employed

6-15

6.5.1 .4

The Engineering Aspects of the Application of Various

Types of Control Techniques 6-15

6.5.1 .5 Process Changes

6-16

6.5.1 .6 Non-Water Quality Environmental Impact (including energy

requirements)

6-16

6.5.1 .7 BPT Determination for the Proposed Alton Facility 6-17

6.5.2

Development of BCT under Best Professional Judgement

6-17

6.5.2.1 The Reasonableness of the Relationship Between the Costs

of Attaining a Reduction in Effluent and the Effluent Benefits

Derived

6-17

6.5.2.2 The Comparison of the Cost and Level of Reduction of

Such Pollutants from the Discharge from Publicly Owned

Treatment Works to the Cost and Level of Reduction of

III

3 March 1999

---

549307DM .ALL, 3995-007-500

CONTENTS

(Cont'd)

Such Pollutants from a Class or Category of Industrial

Sources

6-18

6.5.2

.3

The Age of Equipment and Facilities Involved 6-19

6.5.2.4

The Process Employed

6-19

6.5 .2 .5

The Engineering Aspects of the Application of Various

Types of Control Techniques

6-19

6.5.2.6

Process Changes

6-19

6.5 .2 .7

Non-Water Quality Environmental Impact (including energy

requirements)

6-20

6.5 .2 .8

BCT Determination for Proposed Alton Facility 6-20

7

.0

RESULTING DEFINITION OF SITE SPECIFIC EFFLUENT AND RELATED

LIMITATIONS

7-1

8.0 REFERENCES

8-1

APPENDICES

A OFFICIAL CORRESPONDENCE

B UNIONID SURVEY

C

WATER QUALITY DATA AND IMPACT CALCULATIONS

D

TREATMENT TECHNOLOGY ASSUMPTIONS AND SPREADSHEETS

E

FUTURE WATER DEMAND IN ALTON SERVICE AREA

F DISCHARGE TSS MODELING EVALUATION

IV

EN R

3 March 1999

---

LIST OF TABLES

549307DM .ALL

. 3995-007-500

v

3 March 1999

1-1

Regulatory Components of Site-Specific Impact Study

1-11

3-1 Predicted Effluent Discharges

3-8

4-1 USGS Gaging Stations

4-7

4-2

Mean Monthly Flow (cfs)

4-B

4-3 Mean Monthly Total Suspended Solids

4-10

4-4 Total Suspended Solids

4-11

4-5 Dissolved Iron (ug/I)

4-12

4-6 Dissolved Aluminum (ug/I)

4-13

4-7 Public Comments on Proposed Alton Water Treatment Plant 4-14

5-1 Proposed Alton Facility Test Design Conditions 5-26

5-2 TSS Increases from Proposed Alton Facility Test Discharge

5-27

5-3 Dissolved Aluminum Increases from Proposed Alton Facility Test Discharge . . . . 5-28

5-4 Dissolved Iron Increases from Proposed Alton Facility Test Discharge 5-29

5-5

Estimated Discharge Residuals Settling Velocities

5-30

5-6 Summary of Particle Deposition Results

5-31

5-7

Habitat Distribution of Commonly Occurring Mississippi River Fish Species in

6-1

Selected Habitats in the Vicinity of Alton, Illinois 5-32

Initial Screening of Residuals Management Control Technologies 6-21

6-2 Summary Table of Estimated Order of Magnitude Costs for Selected

6-3

Candidate Technologies

6-22

POTW Cost Reasonableness Comparison Test with Best Conventional

Technology

6-23

---

LIST OF FIGURES

549307DM .ALL 3995-007-500

vi

EN S

3 March 1999

3-1

Existing Treatment Process

3-9

3-2

Proposed Treatment Process

3-10

3-3 Design Basis, Solids Removal (and backwash rate) 3-11

4-1

Topographic Map of Area near Proposed Site

4-16

4-2 Proposed Site Property Boundaries

4-17

4-3 Zoning Map of Proposed Site

4-18

4-4

Aerial View of Proposed Plant Area

4-19

4-5 Mean Monthly Flow 1933-1995

4-20

4-6 Mississippi River Profile (Miles 201-209)

4-21

4-7 Cross Section Areas - Mississippi River near River Mile 207 4-22

4-8 Mean Monthly Total Suspended Solids (mg/I)

4-23

4-9 Sample Points at Intervals on the Mississippi River near Alton, Illinois 4-24

5-1

Location of Plume 1 mg/I Above Background

-

Scenario 1

5-36

5-2 Aerial View of Predicted Effluent TSS Plume (mg/I) - Scenario 1 5-37

5-3

Location of Plume 25 mg/I Above Background - Scenario 2 5-38

5-4

Aerial View of Predicted Effluent TSS Plume (mg/I) - Scenario 2 5-39

5-5

Clarifier Residuals Settling Curves

5-40

5-6 Filter Backwash Residuals Settling Curves

5-41

5-7 Location of Theoretical Maximum Deposition Areas - Steady State Scenario . . .

5-42

6-1

Determination of Best Degree of Treatment for the Proposed Alton Drinking

Water Facility

6-24

---

AWQC

BCT

BDT

BPJ

BPT

cfs

CWA

gpd

IEPA

Illinois EPA

MGD

msl

NPDES

NTU

PACI

PAC

SSIS

SU

TSS

TRC

U .S . ACOE

USFW

549307AC.DFM

. 3995-007-500

LIST OF ACRONYMS

Ambient water quality criteria

Best Conventional Pollutant Control Technology

Best Degree of Treatment

Best professional Judgement

Best Practicable Control Technology Currently Available

cubic feet per second

Clean Water Act

Gallons per day

Illinois Environmental Protection Act

Illinois Environmental Protection Agency

Million gallons per day

mean sea level

National Pollutant Discharge Elimination System

Nephelometric turbidity units

Polyaluminum chloride

Powered activated carbon

Site Specific Impact Study

Standard units (for pH)

Total suspended solids

Total residual chlorine

United States Army Corps of Engineers

United States Fish and Wildlife Service

---

549307DM.ALL, 3995-007-500

1 .0 INTRODUCTION

Illinois-American Water Company ("Water Company") plans to construct a public water supply

treatment plant to replace the existing plant, which is near the end of its useful life and was

inundated by Mississippi River (the "River") flood waters in 1993 and threatened again in 1995

.

The replacement plant will be located on property located at a higher elevation across the Great

River Road (i.e., Illinois Route 100) from the existing plant in order to minimize the potential for

future flooding . The Water Company's existing plant directly returns to the River the residual

natural silts and sediments contained in the raw River water, along with a very small percentage

of water treatment additives used to separate the sediments from the raw water to produce

potable water . The Water Company has conducted a Site Specific Impact Study (SSIS) that

addresses the environmental impact, technical feasibility, and economic reasonableness of

potential alternatives to determine the best degree of treatment for handling the discharge from

the replacement plant

. The discharge effluent from the proposed replacement facility has the

potential to exceed Illinois general industrial standards for total suspended solids (TSS) and iron .

This document reports the findings of the SSIS and provides justification for the recommended

effluent limitations .

1 .1

Purpose and Organization of the Site Specific Impact Study

The purpose of the SSIS is to provide sufficient information to evaluate the reasonableness of

various technologies to treat the residuals arising from the preparation of potable drinking water

including returning the residuals back to the Mississippi River, the original source of the vast

majority of-natural silts comprising the residuals .

This study is structured to satisfy state

requirements under Section 27(a) of the Illinois Environmental Protection Act (the "Act"), satisfy

federal concerns which arise out of the Clean Water Act (CWA), as well as address Illinois

Environmental Protection Agency (Illinois EPA) concerns .

The SSIS report is divided into seven section tasks . Section 1

.0 outlines the general purpose

of the study and the underlying regulatory requirements at both the state and federal levels,

including the Best Professional Judgement (BPJ) process to be met for compliance with CWA

requirements

.

Section 2.0 describes the Water Company's SSIS work plan based on its

meetings with Illinois EPA and its current understanding of Illinois EPA's comments on the draft

work plan . This section also documents Water Company responses to Illinois EPA comments

on the draft workplan and describes the plan used to solicit and incorporate stakeholder input

.

1-1

EN R

3 March 1999

---

549307DMALL 3995-007-500

1-2

Section 3

.0 provides a brief description of the existing Alton waterworks and presents the critical

design elements of the proposed facility . The plant and treatment process design elements are

developed in sufficient detail to predict the nature and magnitude of the effluents to be potentially

discharged into the Mississippi River from, the replacement plant Section 4 .0 describes the

physical and ecological characteristics of the local environment in the vicinity of the proposed

plant, with special focus on the receiving water (Mississippi River), its hydrology, water quality,

and biota, including a mussel habitat survey . This section also identifies potential stakeholder

concerns regarding the structure and operation of the proposed drinking water facility that were

raised during public meetings held to discuss a replacement facility .

Section 5 .0 evaluates the potential changes in river conditions due to the proposed effluent

discharge . The potential impacts of the discharge to river water quality were evaluated under

two flow and water quality scenarios developed in discussion with the Illinois EPA . Potential

impacts to the biological community of the Mississippi River were also evaluated . Impacts

considered included physical and chemical characteristics, habitat changes, possible toxic

effects, and adverse effects to sensitive species and/or habitats .

Section 6 .0 develops the best degree of treatment (BDT) for residuals handling . It identifies

treatment technologies that could be applied to the residuals from the proposed Alton facility .

Candidate technologies were identified from the suite of available technologies, and cost

estimates were prepared. Other community impacts were identified and described . Based on

these factors, BDT was determined for the replacement Alton plant. In addition, the report

establishes the federally required BPT and BCT for the facility through review of the statutory

factors used in a case-by-case determination (including a cost-reasonableness test) that meet

the legal requirements of Best Professional Judgment (BPJ) under the CWA

.

Section 7 .0 reviews and summarizes the findings of the site specific analysis and unique factors

applicable to the proposed drinking water facility

. These factors were considered in arriving at

final recommended permit effluent limitations for the replacement drinking water facility .

1 .2 Regulatory Compliance

Pursuant to the site specific rule codified at 35 IAC 304

.206, the National Pollution Discharge

Elimination System (NPDES) permit of the current Alton drinking water facility does not contain

numerical effluent limitations for TSS or iron

. Historically, the facility has discharged the residuals

arising from the water purification process back to the Mississippi River

. While the replacement

drinking water plant will be at the same location (but at a higher elevation) as the existing plant,

it is appropriate to perform an SSIS to determine whether the replacement plant should be

subject to effluent limitations listed in the general effluent standards (35 IAC 304 Subpart A),

3 March 1999

---

EN3t

particularly those listed in 35 IAC 304 .124(a) including total iron (2 .0 mg/L) and TSS (15 .0 mg/L).

If these limitations are not to be generically applied to the replacement facility, effluent limitations

should be developed through the site specific factors analysis specified in Section 27(a) of the

Act. Similarly, there are no federal categorical effluent limitations for drinking water plants (see

Section 1

.4) and effluent limitations are developed on a site specific basis using BPJ as defined

by the CWA. In addition, the SSIS evaluated whether other constituents in the discharge

(particularly aluminum arising from the use of Clar'lon polymers in plant operations) would have

a potential impact to the environment .

The SSIS addresses the site specific regulatory factors provided in Section 27(a) and Section

28.3 of the Act, and it will also incorporate the federal BPJ factors into this analysis . Both

analyses are required to fulfill regulatory or site specific relief requirements under the Act and

CWA. Table 1-1 identifies the factors considered under both state and federal regulations

.

Additional determination of BDT (as described under 35 IAC 304 .102) for the plant was

recommended by Illinois EPA in comments on the SSIS workplan (see Section 2 .2) and

incorporated into the SSIS.

1 .2.1

Illinois Environmental Protection Act's Site Specific Regulatory

Requirements

The relevant site specific factors under Section 27(a) of the Act include : existing physical

conditions, the character of the area involved, the nature of the receiving body of water, and the

technical feasibility and economic reasonableness of discharge reduction alternatives

. These

factors can be used to establish a best degree of treatment (BDT) for the discharge and should

incorporate waste minimization and pollution prevention practices . Additional Section 27(a)

factors, such as the existing industrial character and the residential development adjacent to the

site, are also considered in the site specific analysis .

Section 28 .3 public water supply factors for direct discharge of waste solids to the Mississippi

or Ohio Rivers from clarifier sludge and filter backwash generated in the River water purification

process are also relevant to the issue of under what circumstances it may be appropriate to

directly discharge residuals from public water supply purification of Mississippi River water

.

Although the legislature imposed a filing deadline for the specific type of adjusted standard relief

provided in Section 28.3, it did not provide that Section 28.3 was repealed after the filing

deadline, and it remains part of the Act

. The Section 28.3 factors are : water quality effects,

actual and potential stream uses, and economic considerations, including those of the discharger

and those affected by the discharge . Justification based on discharge impact shall include, as

a minimum, an evaluation of receiving stream ratios ; known stream uses ; accessibility to stream

and side land use activities (residential, commercial, agricultural, industrial, recreational)

;

549307DM.ALL

3995.007-500

1-3

3 March 1999

---

frequency and extent of discharges ; inspections of unnatural bottom deposits, odors, unnatural

floating material or color

; stream morphology and results of stream chemical analyses . Where

minimal impact cannot be established, justification shall also include evaluations of stream

sediment analyses, biological surveys (including habitat assessment), and stream chemical

analyses that may include, but are not limited to, analyses of parameters regulated in 35 IAC

302. A description of the proposed alternative control strategy and the discharge limitations

associated with the strategy is also required .

1 .2.2 Requirement for Consistency with Federal Law

In addition to the state factors described above, the federal BPJ factors are relevant because the

Water Company must demonstrate that the discharge proposal it develops in the study is

consistentwith federal law, including the NPDES permit requirements . The federal CWA requires

the Illinois EPA to impose technology-based treatment requirements in the NPDES permit it will

issue for the replacement facility . As noted by the Illinois Pollution Control Board (Board) in an

opinion and order pertaining to a site specific relief petition filed in the 1980s for the Water

Company's East St . Louis public water supply facility, Illinois EPA sets effluent limits for public

water supplies on a case-by-case basis under CWA Section 402(a) . Because of the huge

variability in raw water sources, U .S. EPA never established industry-wide limits for public water

supplies (see Section 1

.4 for discussion) .

The federal regulations provide at 40 CFR 125 .3(c) (2) that the permit writer shall develop case-by-

case limits under CWA Section 402(a) by applying the appropriate factors listed in 125 .3(d) and

shall consider: (i) the appropriate technology for the category or class of point sources of which

the applicant is a member, based on available information ; and (ii) any unique factors relating

to the applicant.

The 40 CFR 125 .3(d) factors are divided into factors which the permit writer must consider for

the two elements of BPJ relevant to non-toxic pollutants--best practicable control technology

currently available ("BPT") and best conventional pollutant control technology ("BCT")

. These

factors are listed in Table 1-1 . For purposes of evaluating the proposed replacement facility,

both BPT and BCT must be considered . For BPT, the factors are : (i) the total cost of application

of technology in relation to the effluent reduction benefits to be achieved from such reduction

;

(ii) the age of equipment and facilities involved ; (iii) the process employed

; (N) the engineering

aspects of the application of various types of control techniques ; (v) process changes

; and (vi)

non-water quality environmental impact (including energy requirements) . For BCT requirements,

the permit writer must consider : (i) the reasonableness of the relationship between the costs of

attaining a reduction in effluent and the effluent reduction benefits derived ; (ii) the comparison

of the cost and level of reduction of such pollutants from the discharge from publicly owned

EN M

549307DM.ALL, 3995-007.500

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treatment works to the cost and level of reduction of such pollutants from a class or category

of industrial sources ; (iii) the age of equipment and facilities involved ; (iv) the process employed

;

(v) the engineering aspects

of

the application of various types of control techniques ; (vi) process

changes ; and (vii) non-water quality environmental impact (including energy requirements)

. The

relationships between BPT and BCT are discussed further in Section 1 .5 of this report .

1

.3

Current Permit Conditions

The NPDES permit for the current Alton facility water treatment supply plant is IL #0000299 and

covers one discharge (001-0) . This permit requires daily monitoring of flow, while pH, TSS, total

iron, and TRC are monitored on a monthly basis . An effluent limitation range exists for pH

between 6 .0 to 9.0 standard units (SU) . As a result of the site specific rule applicable to the

existing plant, no treatment is required for the discharge effluent other than dechlorination which

will be required as of November 1998

.

1

.4

Background Information on Effluent Limitations for Public Water Supply Facilities

In part, the need for site specific effluent limitations for the Alton water supply plant is based on

the lack of national effluent limitations guidelines for the water supply Industry

. Under these

circumstances, a permit writer drafting a NPDES permit must develop effluent limitations on a

case-by-case basis using Best Professional Judgement (previously known as Best Engineering

Judgement) following consideration of the factors listed in 40 CFR 125

.3 (see Section 3 for

statutory factors) . However, the permit writer also needs to consider "any unique factors relating

to the applicant" (40 CFR 125 .3(c)) .

In developing the case-by-case considerations, a permit writer may consider proposed national

effluent limitation guidelines, draft development documents, available technical data from similar

facilities, or other regulatory guidance. Therefore, it is important to review information contained

in the draft development document and related U .S

. EPA communiques as part of the case-by-

case development of effluent limitations for the Alton facility under BPJ .

In this regard, two key U .S. EPA documents are the U .S. EPA Permit Policy Statement #13

issued September 18, 1974 (U.S. EPA, 1974) and the Draft Development Document for Effluent

Limitation Guidelines and Standards of Performance - Water Supply Industry (U .S. EPA, 1975)

hereafter referred to as the "Draft Development Document" . Both of these U .S. EPA documents

contain information which is directly relevant to development of effluent limitations for the Alton

facility.

EIR

5493070M.ALL 3995-007-500

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EN R

Permit Policy Statement #13 concerns "Disposal of Supply Water Treatment Sludges" and

contains language which directly relates to the Alton facility, including :

•

its suggestion of possible subcategories of sludges such as

: 1) silt removed from raw

water; and 2) chemical water treatment sludges such as lime ;

• its statement that it is not appropriate to arbitrarily prohibit silt removed from public

water supply streams from being returned to the stream, due to considerations of

". . .supply water silt burden, nature and quantity of chemical clarification aids used,

availability of land disposal

sites,

economic impact, navigational considerations and

water quality standards, to mention a few" [U.S . EPA, 1974; pg . 1 ] and

• specific identification of the Mississippi River as a special case . "Because silt is

indigenous to certain river waters, notably the Mississippi and Missouri Rivers, and

because our priority concern is process generated pollutants, and because

unreasonable cost-benefit relationships may result in some areas of these rivers and

others, it would be within the intent of best practicable control technology currently

available to authorize, in some instances, either the partial or total return of silt type

sludges to the

receiving

waters." [U .S. EPA, 1974 ; pg. 2] .

As these sections underscore, the Permit Policy Statement recognizes two important points . The

first is the distinction U .S. EPA makes between sludges composed mainly of naturally-occurring

silts as opposed to water treatment sludges with a high concentrations of process generated

chemicals . The second point is the acknowledgement that due to the high silt content of the

Mississippi River, return of these silts to the river can constitute BPT

.

Additional insight Into U .S. EPA concerns toward water supply treatment effluents is provided in

the Draft Development Document (U .S. EPA, 1975) . The document established total suspended

solids as a pollutant parameter for all subcategories of water treatment plants

. The Draft

Development Document also contains key passages which acknowledge that

: (1) return of

residuals to a highly turbid river will cause an imperceptible increase in turbidity

; (2) treating such

discharges is not cost-effective ; and, in addition, (3) coagulant sludges present unique handling

and disposal problems. Specifically, the Draft Development Document notes that

:

• "... extensive studies made at plants along one highly turbid river have shown

that

returning the raw waste sludge to the highly turbid source increases the turbidity of the

stream by an insignificant increment . In some instances the incremental increase in

turbidity is less than the precision of many turbidimeters used for routine monitoring

."

[U .S. EPA, 1975; pg. 46] ;

549307DM.ALL, 3995-007-500

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3 Merch 1999

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ERa

• 'These studies have also shown that the benefit-cost ratio for dewatering the sludge and

hauling to landfills is very low, and that the amount of energy used in treating and

hauling it is very high. Because of these factors the disposal of sludge from plants that

must use highly turbid water as feeds ... should be judged on an individual basis." [U . S .

EPA, 1975 ; pg. 46] ; and -

• "Sludge is difficult to dewater by lagooning. However, it will gradually consolidate

sufficiently to provide a 10% to 15% solids content . Water removal is normally by

decantation or by evaporation with some drainage . Evaporation may provide a hard

crust on the surface but the sludge below the crust is thixotropic, capable of turning into

a viscous liquid upon agitation with near zero shear resistance under static load .

Therefore, lagooned sludge cannot be easily handled nor will it make good landfill

material." [U .S . EPA, 1975 ; pg . 75-76] .

These passages

indicate the recognition by the U .S. EPA that imposition of TSS effluent

limitations for water treatment supply plant effluents, especially coagulant sludges would provide

an inadequate cost-benefit ratio, particularly when dealing with return to raw water sources where

negligible improvements in water quality would result from control technology.

U .S

. EPA decided in 1977 not to promulgate national effluent guidelines for the public water

supply industry . Since that time, U.S. EPA's comments on regional guidance documents

indicate

that the nature and magnitude of water quality impacts should be considered in

determining the appropriate treatment, and that regional differences in environmental conditions

are relevant (U

.S.

EPA,

1991b) .

1 .5 Background

Information on BPT and BCT Requirements

To apply BPJ to the proposed Alton replacement

facility as a case-by-case determination, a

number of factors were considered, including those specified at 40 CFR 125(d)(1) and (d)(2),

those identified by U .S. EPA Permit Policy Statement #13 (U .S. EPA, 1974), as well as unique

factors as provided at 40 CFR 125 .3 (c) including economic achievability . Addressing these

factors provides a comprehensive approach to deriving effluent limitations and satisfied

the

required analysis and fact-finding process which a

permit writer is directed to employ under BPJ .

Discharge permits developed under the NPDES process may contain effluent limitations

or

permit conditions such as monitoring and reporting

requirements. The CWA requires that

NPDES permit effluent

limitations be developed either as a technology-based treatment or a

water quality-based

limit (whichever is more stringent) . In cases where technology-based

5493070M .ALL, 3995-007-500

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3 March 1999

---

Ems

promulgated effluent guidelines are absent, CWA Section 402(a)(1) requires that the NPDES

permit issuing authority develop case-by-case effluent limitations reflecting BPJ

.

Since national effluent limitations, have not been issued for the water supply industry, technology-

based treatment is developed on a case-by-case basis through BPJ. The permit writer will

determine the appropriate limitations without the use of national industry-specific effluent

limitation guidelines

. Rather the permit writer will apply a series of statutory factors listed in 40

CFR 125.3(d)

and consider (1) the appropriate technology for the category or class of point

sources of which the applicant is a member, based upon all available information ; and (2) any

unique factors relating to the applicant

.

On the basis on his/her consideration of these factors, the permit writer is required to develop

the analysis of the application of the statutory factors which lead to the proposed effluent

limitations . This analysis is usually put on a fact sheet which accompanies the proposed permit

.

In considering the statutory factors contained in 125 .3(d), it is necessary to consider the nature

of the water quality effluent parameters . Since the effluent parameters in question include TSS

and iron, "conventional" water quality pollutants, the appropriate control technology is based on

best conventional pollution control treatment or BCT . However, in order to establish the BPJ

basis for the current effluent limitation of the Alton facility, it may be applicable to consider best

practicable control treatment currently available or BPT, as well as BCT

. This is because BCT

must be at least as stringent as the effluent limitations developed under BPT .

In essence, to evaluate the specific-case effluent limits for the post-clarifier residuals developed

under BPJ for the Alton facility, a two-step technical analysis was required .

First, it was

necessary to examine whether the proposed replacement facility residuals handling methods are

BPT (based on current practices or adaption of treatment technologies) . Second, the possible

limitations developed as BCT will be compared to BPT limits

.

Factors which are to be considered by the permit writer for the setting of BPT effluent limitations

are listed in 40 CFR 125 .3(d)(1), and are presented below :

(i) The total cost of application of technology in relation to the application of technology

in relation to the effluent reduction benefits to be achieved from such application

;

(ii) The age of the equipment and facilities involved ;

(W) The process employed ;

54930713M.ALL

3995007-500

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(i)

549307DM.ALL 3995-007-500

1-9

EI~.9t

(iv) The engineering aspects of the application of various types of control techniques

;

(v) Process changes ; and

(vi) Non-water quality environmental impact (including energy requirements) .

Factors which are to be considered by the permit writer for the setting of BCT effluent limitations

are listed in 40 CFR 125.3(d)(2) and are presented below :

The reasonableness of the relationship between the costs of attaining a reduction

in effluent and the effluent reduction benefits derived ;

(ii)

The comparison of the cost and level of reduction of such pollutants from the

discharge from publicly owned treatment works to the cost and level of reduction

of such pollutants from a class or category of industrial sources ;

(iii)

The age of the equipment and facilities involved ;

(iv)

The process employed ;

(v)

The engineering aspects of the application of various types of control techniques

;

(vi)

Process changes

; and

(vii)

Non-water quality environmental impact (including energy requirements) .

While an effluent limitation established by BPJ must consider these factors, the permit writer also

must consider additional available information and site specific or unique factors (see 40 CFR

125 .3(c) (2)) . In particular, BPJ takes into account any site specific factors which make the Alton

facility unrepresentative of the water supply industry in general, such as those identified by the

U.S

. EPA 1974 Permit Policy Statement (water supply silt burden, nature and quantity of

clarification aids, etc.) . This "unique factors" consideration is an important component of the

case-by-case determination

.

For the purposes of the analysis of the Alton discharge effluent limitations, Best Professional

Judgement was based on :

3 March 1999

---

EH

• Establishment of effluent limitations as BPT through consideration of the factors listed

in 125.3(d)(1), as well as additional available information including U .S . EPA policy

documents and applicable state regulations ;

•

Establishment of effluent limitations as BCT through consideration of the factors listed

in 125.3(d)(2), as well as comparison of effluent limitations established by BPT ;

•

Consideration of relevant "unique" factors (125.3(c)(2))

including but not limited to :

the hydrology and water quality of the Mississippi River at Alton

;

potential impacts of TSS in the effluent discharges on the water quality and biota

of the Mississippi River ;

-

potential environmental impacts caused by land disposal of effluent residuals ;

additional information from water treatment plants located along large, turbid rivers ;

and

economic achievability.

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TABLE 1-1

Regulatory Components of Site-Specific Impact Study

E*R

54930778

.

1

-1, 3995-007

.500

5 February 1999

Best

be

~ree

of

Treatment

9

Best Pr

ti

ac cable

Control

7pehnohsgy

.

.

.

Best

Conventional Pollutant Cantrol

.7at

httologti

;

Sections 27(a) and 28

.3 of the Act

40 CFR 125

.3(d)1

40 CFR 125

.3(d)2

35 1AC 304

.102

Section 27(a)

i)

The total cost of application of technology

)

The reasonableness of the relationship between the

i)

Existing physical conditions

in relation to the effluent reduction benefits

costs of attaining a reduction in effluent and effluent

ii)

The character of the land involved

to be achieved from such application

reduction benefit derived

iii)

The nature of the receiving body of

water

ii)

The age of the equipment and facilities

ii)

The comparison of the cost and level of reduction of

iv)

Technical feasibility and economic

employed

such pollutants from the discharge

. from publicly

reasonableness of discharge reduction

owned treatment works to the cost and level of

alternatives

ii)

The process employed

reduction of such pollutants from a class or category

iv)

The engineering aspect of the application

of various types of control techniques

iii)

of industrial sources

The age of the equipment and facilities involved

Section 28

.3

i)

Water quality effects

ii)

III)

Actual and potential stream uses

Economic considerations, including

v)

Process changes

iv)

The process employed

those of the discharger and those

affected by the discharge

vi)

Non-water quality environmental impact

(including energy requirements)

v)

The engineering aspect of the application of various

types of control techniques

35 IAC 304

.102

I)

Technological feasibility

v)

Process changes

ii)

ii)

Economic reasonableness

Sound engineering judgement

vi)

Non-water quality environmental impact (including

iv)

What degree of waste reduction can

energy requirements)

v)

be achieved by process change,

improved housekeeping and recovery

of Individual waste components for

reuse?

Whether individual process wastewater

streams should be segregated or

combined

---

2.0 REGULATORY REVIEW AND DEFINITION OF SITE SPECIFIC FACTORS

The SSIS was designed to address relevant factors provided in Section 27(a) and 28 .3 of the Act

as well as potential Illinois EPA or other regulatory agency concerns not explicitly addressed by

those sections . A preliminary scoping meeting was held with Illinois EPA to discuss the

necessary elements of the SSIS

.

As a result of that meeting a draft SSIS Workplan was

developed and sent to Illinois EPA for review and comment (Section 2.1) . The resulting

comments were incorporated into the final SSIS Workplan (Section 2

.2) which defines the site

specific factors to be addressed . As part of the Workplan, the Water Company developed a

program to identify potential stakeholder concerns about the project (Section

2.3). A second

meeting with Illinois EPA was held to discuss project status and revisit the SSIS Workplan and

was followed by several meetings with Illinois EPA to discuss portions of the SSIS Report or

additional information requested by them (Section 2.4) .

2.1

Preparation of Workplan for Illinois EPA Review

A September 12, 1996 meeting was held between the Water Company and Illinois EPA to review

the overall project, determine relevant regulatory requirements, identify additional Illinois EPA

concerns, and discuss the proposed timetable of the SSIS in the context of the planning and

construction of the Alton replacement plant . As a result of that meeting, the Water Company

prepared a draft SSIS workplan . That document served as the draft work plan of the site specific

factors analysis, including BPJ factors, and was submitted to Illinois EPA for review and

comment. The workplan was intended to provide sufficient detail to clearly outline the proposed

approach and intended analyses .

2.2 Response to Illinois EPA Comments and Suggestions

The draft SSIS Workplan was submitted to Illinois EPA for review in early October 1996 . Illinois

EPA provided comments on the draft SSIS workplan in a letter from Thomas G

. McSwiggin

(Manager, Permits Section) to the Water Company dated December 16,1996 (Illinois EPA, 1996) .

Illinois EPA concerns identified in that letter included the potential plant construction impacts on

terrestrial endangered species ; evaluation of any site historical significance ; more complete

evaluation of effluent standards under 35 IAC 304

; and consideration of all expected pollutants

in the area of mixing . A copy of the comment letter is included in Appendix A.

549307DM.ALL . 3995-007-500

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3 March 1999

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2.3 Development of Plan for Seeking Stakeholder Input

An important part of the SSIS is the identification and incorporation of stakeholder concerns into

the overall site specific evaluation

. Relevant stakeholders for the proposed Alton replacement

facility include abutters, local residents, community groups, local government leaders, and other

.interested parties. The Water Company had identified and met with several stakeholders for the

former proposed site on an informal basis

. However, a more comprehensive plan to seek

stakeholder input was developed to formalize and document this input.

As part of this plan, the Water Company conducted a series of presentations to the stakeholders

and interested local community . These meetings were scheduled to provide an opportunity for

Illinois EPA to participate

. The first of these stakeholder meetings was held on December 18,

1996 and included a presentation by Mr . McSwiggin (Manager, Permits Section) regarding the

regulatory requirements . The December meeting and emergent identified issues are further

described in Section 4 .4. A second stakeholder meeting was held on February 26, 1997 but no

new additional environmental issues were identified . Subsequent to the meeting in February

1996, Illinois-American decided to develop the property at the former Mississippi Lime site rather

than the Godfrey site . A third public meeting was held on July 21, 1998 to discuss the proposed

Alton facility. Comments and issues raised by the stakeholders for both the Godfrey and Alton

sites were similar and are addressed by the SSIS, if applicable, or otherwise considered in the

planning and development of the final plant design and/or operations .

2.4

Additional Meetings with Illinois EPA

Due to a change in project location, specifically the decision to construct the replacement plant

on property adjacent (including property across Route 100) to the current Alton plant rather than

a proposed site in Godfrey, IL to capture a greater than six million dollar savings in construction

costs, a second meeting with Illinois EPA was held on August 21, 1997 . The purpose of this

second meeting was to inform Illinois EPA of the project status and to revisit the SSIS Workplan

to identify any additional site specific factors which needed to be considered for the Alton

replacement facility

. Based on this meeting, a mussel habitat characterization and protected

species survey was added to the Workplan prior to its implementation .

Subsequent meetings between the Water Company and Illinois EPA were held in May 1997,

October 1998, and December 1998 to discuss portions of the SSIS Report and outstanding

issues . As a consequence of these meetings, the Water Company supplied additional

information and/or analyses to Illinois EPA to provide sufficient information for the agency to

evaluate the proposed facility, and all outstanding issues were addressed .

Ems

549307DM.ALL, 3995-007-500

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3.0 DETERMINATION OF PREDICTED EFFLUENT DISCHARGES

3.1

Current Plant Configuration

Illinois-American Water Company, Alton District owns and operates the water treatment facility

located along the Mississippi River at approximately River Mile 204 (latitude 38°, 53", 56' north ;

longitude 90° 12" 11' west) in Alton, Illinois . The Mississippi River is the sole source of water

supply for the facility and the District . As of 1998, there were approximately 265 miles of water

main in the distribution system and the District served a population base of 76,429 customers

and 17,479 households/businesses .

The Alton facility has been supplying water to the City of Alton and nearby residents since the

1890s. The original 13 .3 million gallons per day (MGD) Main Service Plant was constructed in

the 1930s . An additional 5 MGD High Service Plant was constructed in 1981 at the same site .

The Main Service Plant consists of two mixing tanks, one circular clarifier, two rectangular

sedimentation basins, sand filters, 650,000 gallons of filtered water storage and raw and filtered

water pumping stations . The High Service Plant consists of one mixing tank, two clarifiers, four

filters, raw, transfer, and filtered water pump stations, and one million gallons of filtered water

storage . The two plants share a common side channel intake structure at the River . The

existing treatment process is summarized in Figure 3-1 .

At the existing facility, water is taken from the Mississippi River through a side channel intake into

two wet wells in the facility Gate House . Two traveling screens are located at these wet wells to

strain out debris . The screens are regularly cleaned with finished water, and the expelled

material and screen wash water are returned directly to the Mississippi River. Three pumping

units transmit raw water to the two flocculation tanks in the Main Service plant . Three pumping

units convey raw water to the mixing tank in the High Service Plant

At the Main Service plant, open rectangular steel channels convey the raw water from the mixing

tanks to the circular clarifier where sand and heavy sediment are removed . From the clarifier,

the water is split into approximately equal proportions

. The clarified water enters the lower

chamber of each of the two parallel rectangular sedimentation basins. From the lower chamber,

the water rises to the upper chamber. From the sedimentation basins the treated water enters

the former recarbonation tank where additional treatment chemicals are added . From the

recarbonation tank, the treated water flows to nine sand fitters

.

549307DM.ALL, 3995-007-500

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3 March 1999

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EIa

At the High Service plant, flocculation occurs in the mixing tank in which one side wall mixer is

mounted . From the mixing tank, water flows by gravity to two Claricone . sludge blanket type

clarifiers

. From the clarifiers, water flows by gravity to four sand/anthracite filters .

Treatment to aid in sedimentation begins as water leaves the intake, where the primary coagulant

(Clark

[on) is added to coagulate the sediment in the water

. Powdered activated carbon (PAC)

may be added at the intake in order to control odor and taste

. Lime or caustic may added at

this point as well when alkalinity is low . Based on historical records, alkalinity is low during high

flows or high turbidities . In the mixing tanks, the retention time and gentle mixing promote

coagulation . The coagulated sediment will then settle in the clarifier and sedimentation basins

in the Main Service plant or in the Claricone clarifiers at the High Service plant.

Disinfection is provided by chlorine addition immediately after flocculation and again after

clarification in the sedimentation basins . Ammonia is added before clarification to promote

chloramine formation .

3.2 Current Effluent Discharges

There are two types of effluent discharges from the Alton treatment system

-

operational and

maintenance discharges . Operational discharges are those flows which occur regularly, on a

daily or weekly basis, during periods when the plant is producing potable water . Operational

discharges include return of intake screen wash, return of pre-sedimentation silts from the

clarifier, blowdown from sedimentation basins and filter backwash . The second category of

discharge (maintenance) is the annual cleaning of accumulated solids in the clari ier, the

sedimentation basins, and the mixing tanks .

Residuals from the existing Alton plant are stored in a dedicated wet well at the Gate House .

They can be discharged by gravity or can be discharged using a dedicated transfer pump during

high river levels

. All plant residuals are discharged from this location

.

The two Main Service plant operational discharges consist of intermittent clarifier blowdown and

filter backwash . Blowdowns occur based on the turbidity of the clarifier influent and effluent

.

Plant operators manually open the drain valve for approximately one hour to blow down the

residuals . On the average, approximately 30,000 gallons per day (gpd) of blowdown are

discharged two days a week from the clarifier . However, the frequency and duration of

blowdowns are very variable since they are dictated by raw water turbidity

. The sand filters used

at the Main Service plant are backwashed daily for approximately 15 minutes . Each filter runs

approximately 24 to 30 hours between backwashings

. On the average, approximately 630,000

gpd of backwash is discharged from these filters .

549307DM .ALL

. 3995.007-500

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3 March 1999

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The Main Service plant maintenance discharges are produced during cleaning of the clarifier,

sedimentation basins, and mixing tanks . The two sedimentation basins do not include sludge

removal equipment so the basins are dewatered prior to manual sludge removal . The

sedimentation basins, mixing tanks and clarifier are cleaned three times per year . Approximately

72,000 gpd of water (carrier water with residuals) are discharged during this five day-long

maintenance activity (i.e., total annual discharge is 1,080,000 gallons) .

The High Service plant operational discharges include Claricone clarifier blowdown, filter

backwash, and cleaning of the Claricone clarifier . Plant operators release clarifier residuals

based on the condition and thickness of the sludge blanket . On the average, 12,000 gpd of

blowdown residuals are discharged from the clarifier on a regular basis . Two of the four

sand/anthracite filters at the High Service plant are backwashed daily for approximately 15

minutes . Each filter runs approximately 48 hours between backwashings . On the average,

approximately 210,000 gpd of backwash is discharged from these filters . The Claricone clarifiers

are cleaned once a year . Approximately 24,000 gpd of water (carrier water with residuals) is

discharged during the two days of maintenance activity.

3

.3

Plant History and Replacement Facility

As noted earlier, portions of the existing Illinois-American Alton facility are over 100 years old .

The Alton facility has been supplying water to the City of Alton since the 1890s . In the 1930s the

13.3 MGD Main Service Plant was constructed . In 1981, an additional 5 MGD High Service Plant

was constructed at the same site .

The entire facility is located within a physically-restricted parcel of level land approximately 20 feet

above the normal river summer level . The facility is bounded directly to the northeast by the

Norfolk Southern Railroad and Illinois Route 100 and bounded to the southwest by the

Mississippi River. Across the railroad and highway corridor, the land slopes steeply up to the

bluffs overlooking the River .

Due to its proximity to the Mississippi River, the site is subject to an increasing frequency of

flooding . Sandbagging to protect the facility from flooding was required in 1973, 1986, 1993,

1994, and 1995 . In August of 1993, the entire site was flooded . Both the Main Service and High

Service plants were out of service for four days . Limited service was provided initially by the

High Service plant

. Full service was reinstated soon thereafter . Consumers in the Alton service

area were required to boil tap water over a 10 day period .

EN M

549307DM.AL1, 3995-007-500

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3 March 1999

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In order to replace the aging facility and avoid future flooding, a replacement water treatment

plant will be constructed approximately 60 feet higher than the existing facility on property

located directly across the Illinois Route 100 in the City of Alton, IL

. The Water Company

evaluated nine alternatives for a water supply replacement facility site before choosing the

proposed site

. This site is

preferred due to its industrial zoning, proximity to the existing plant

and infrastructure, favorable site topography for construction, size, and proximity to the existing

raw water intake location

. Other alternative supplies/locations had significant drawbacks .

3.4

Replacement Plant Design, Capacity, Flows and Discharges

At this stage, the key design elements and process treatments have been selected

. This

provides sufficient detail to allow evaluation of the discharges of the proposed plant

.

3.4.1

Plant Flows

The proposed replacement plant has been designed to produce, on average, up to 10

.5 MGD

of potable water for the Alton area

. The hydraulic design capacity of the plant will be 16 MGD

.

The value of 10

.5 MGD was selected as the average daily potable water demand, based on

projections of future water demand conducted as part of Illinois-American's Comprehensive

Planning Study (Illinois-American, 1996)

. [Note:

relevant sections of the Comprehensive

Planning Study are included in Appendix E

.] Water demand was estimated using predicted

demographic trends through the year 2010, which predict a modest growth in population in

Madison County

. Population growth is likely to be influenced by the newly constructed multi-lane

highway bridge across the Mississippi River at Alton, highway improvements, continued

downtown development in Alton, and increased tourist attractions .

Based on an internal plant demand

(i.e.,

not going into Illinois-American's distribution system)

of 1 MGD for Superpulsatore blowdowns, filter backwashes,

etc. at

a peak potable water flow

of 15 MGD, a proportional internal plant demand of 0

.7 MGD was estimated for the average

potable water flow of 10.5 MGD

. The combined flow, 10.5 + 0.7 = 11.2

MGD, was used to

evaluate potential discharge impacts in Section 5

.0 .

3.4.2

Plant Design

The new plant will consist of a new raw water intake and pumping station, clarification and

filtration units, filtered water storage and chemical feed facilities

. The proposed treatment

process is summarized in Figure 3-2 .

549307DM

.ALL, 3995-007-500

3-4

EP R

3 March 1999

---

EM M

Clarification of raw water at the new plant will be provided by four Superpulsator® units (high rate

blanket-sludge type clarifiers manufactured by Infilco Degremont Inc)

. An initial presettler unit,

such as the lamella inclined plate clarifier, may be considered during final design

.

Filtration will be provided by six gravity dual media (sand/granular activated carbon) units

. Each

filter will be equipped with a rate of flow controller, filter to waste piping, an air surface wash

system and automatic monitors for flow rate, head loss and water level .

Residual discharges from the proposed Alton replacement plant will be composed of

Superpulsator® blowdown, filter backwash, and Superpulsator® cleaning water as summarized

in Figure 3-3 for average river turbidity and Clar'lon® addition . Note that the amount of residuals

produced (measured as dry solids) balances with the suspended solids introduced in the influent

river water (measured as dry solids) and added as coagulant aids (measured as dry solids) . The

amount of residuals produced by coagulants is minor in comparison to that introduced naturally

as sediments in the raw water .

One additional maintenance discharge will arise from the replacement plant . This discharge is

from periodic wet well cleaning (once every 5 years) . Since this discharge is minor in amount

and duration, uses raw water for cleaning, and does not contain process-generated chemicals

(i.e., coagulant) it has been eliminated from further consideration .

Chlorine will be used at a variety of points within the proposed Alton replacement drinking water

facility. Chlorine may be added on a seasonal basis prior to the Superpulsator® or filter

backwash treatments . Ammonia and chlorine are applied at rates necessary to achieve a total

chlorine residual sufficient for disinfection in the treatment process and to provide a final TRC for

disinfection in the potable water distribution system

. Figure 3-2 indicates the process locations

of all chemical additions, including ammonia and chlorine addition .

The Water Company will use the process of chloramination at the proposed Alton facility

.

Ammonia is applied just after chlorine treatment in order to form chloramines rather than free

chlorine residual

. Chloroamines may be added to the raw water prior to the Superpulsator® .

If treatment is similar to other plants, a TRC of 3 to 4 mg/L could be expected in the

Superpulsator® unit

. A trace of free chlorine would also be expected at this point . Alternatively,

if chlorine is added, the Superpulsator® TRC would be expected to range from 1

.0 to 1 .5 mg/L.

The settled solids are continuously removed from the Superpulsator® and routed to the effluent

discharge

.

Water from the Superpulsator® will flow to six carbon/sand dual media filter units . Due to this

filtration through the carbon, some minimal reduction in free chlorine residual and TAO would

549307DMALL . 3995-007-500

3-5

3 March 1999

---

be expected. TRC would be expected in the filter backwash water, which constitutes nearly half

of the total effluent discharge .

Chlorine and ammonia will be applied to the filtrate (i .e., at the clearwells) to maintain a

disinfectant residual in the potable water distribution system

. However, these application points

do not effect the discharge, since the discharge stream is split away prior to this part of the

process .

The proposed replacement facility will prevent unacceptable TRC concentrations in the effluent

discharge through dechlorination .

To dechlorinate the effluent discharge from the Anon

replacement facility, two dechlorination systems will be used to treat the Superpulsators® and

filter backwash discharges, respectively. Separation of the filter backwash water from the other

effluent volumes will allow the Water Company to treat only the water which contains the residual

chlorine and reduce the volume of water requiring treatment . This will provide flexibility and

redundancy for the plant .

Operation of the treatment facility is assumed to be highly automated

. The required equipment

includes an analyzer, controller, flow proportioning system, automatic switchover gage, diffuser,

scale for cylinders, and a SO 2 detector. In addition, storage and restocking of chemicals and

seasonal maintenance are required .

3.5

Variability of River Water Quality

The raw water quality of the Mississippi River at the river intake is highly variable . Based on data

from the existing Alton facility (January 1990 through December 1995), the turbidity of the influent

varies dramatically on a daily basis . For example, in May 1990 the influent turbidity changed

from 39 nephelometric turbidity units (NTU) to 964 NTU (the maximum value over the six year

period of record) over the month. The minimum daily turbidity value was B NTU in January 1994 .

Similarly, the mean of annual averages and the monthly averages differ substantially . The mean

of annual averages for the six year period is 90 NTU whereas the maximum of monthly averages

is 430 NTU .

To account for this natural variability, three River turbidity conditions were evaluated for

conceptual design purposes and to support the potential impact evaluation conducted in Section

5.1 . The turbidity values (NTU) were correlated to suspended solids concentrations (mg/L TSS)

using a ratio of 1 :2 NTU/TSS . The ratio of turbidity to suspended solids in rivers similar to the

Mississippi River ranges from 1 :1 .8 to 1 :2

. In order to consider maximum solids production, the

ratio of 1 :2 was selected . [Note: Due to the importance of this value for determining potential

residual loads, this value was peer-reviewed by two engineering firms : Hazen & Sawyer, and

EM

549307DMALL 3995-007-500

3-6

3 March 1999

---

EN, R

Burns and McDonnell] . The long term river water quality is represented by the mean of the

annual turbidity averages, or 90 NTU (180 mg/L TSS) . Discharges calculated based on this

condition were used to design long term treatment units such as lagoons . The medium term

river water quality is represented by the maximum of the monthly turbidity values or 430 NTU

(860 mg/L TSS)

. Discharges calculated-based on this condition were used to design all the

residual handling equipment such as belt filter presses . The short term river water quality is

represented by the maximum daily value or 964 NTU (1928 mg/L TSS) . Residual discharges

calculated based on this condition were used to design the initial equalization basins so that

storage volume would be provided to handle this worst case condition . The residual discharge

volumes and solids content are summarized in Table 3-1 for the three river water quality

conditions .

3.6 Modeling of Anticipated Exceedances

Modeling of anticipated exceedances of water quality standards was conducted using the

discharge values derived in Section 3 .4. These values include discharge flows and

concentrations under variable flow TSS and flow conditions selected in consultation with Illinois

EPA

. These values were used to model potential worst-case and average flow scenarios to

evaluate the potential for the discharged effluent to exceed Illinois Water Quality or Effluent

Standards. Details of the characteristics of the receiving water are given in Section 4

.0, while the

modeling of water quality effects is presented in Section 5 .1 .

549307DM .ALL- 3995-007.500

3-7

3 March 1999

---

TABLE 3-1

Predicted Effluent Discharges

Illinois-American Water Company

New Alton Water Treatment Plant

11.2 MGD

Unit Discharge

Frequency

(under variable influent turbidity)

Assumed Clarion A41 0-P Coagulant

REV112.wk402/08/9910

:37 AM

549307DM.ALL. 3995-007-500

3-8

Estimated Predicted

Flow (gpd) TSS (mg/!) Solids Load

EN R

8 February 1999

Average Annual Turbidity

(TSS = 180 mg/I)

Superpulsator

Continuous 433,099

5,000

(tons/year)

3296.9

Filter Backwash

Intermittent 620,400

65 .0

61 .4

Total

1,053,499

3,358

Max Monthly Turbidity

(TSS = 860 mg/I)

Superpulsator

Continuous 1,002,018

10,000

(tons/month)

1233.6

Filter Backwash

Intermittent 930,600

207.0

24.4

Total

1,932,618

1258.0

Max Daily Turbidity

(TSS = 1928 mg/I)

Superpulsator

Continuous 2,194,206

10,000

(tons/day)

89.9

Filter Backwash

Intermittent 930,600

464.1

1 .8

Total

3,124,806

91

.7

---

399503A

--INTAKE

w

io

CARBON

Clar

+

Ion

®

CHLORINE

CHLORINE FLUORIDE

I

I

'

AMMONIA

POLYMER

pH

ADJUSTMENT

-+ INTAKE

BLANKET

CARBON POLYMER

AI

1

(POLYMER)

MIXING

MIXING

CLARIFIER

CLARIFICATION

-

FILTRATION

(BASINS)

I

Clar

+

Ion

®

AMMONIA FILTER AI

(POLYMER)

MAIN

SERVICE

PLANT

CHLORINE

CHLORINE FLUORIDE

AMMONIA

CLARIFICATION

FILTRATION

pH ADJUSTMENT

AMMONIA

FILTER AID

CHLORINE

Clar

*

lone

HIGH

SERVICE PLANT

FIGURE 3-1

EXISTING TREATMENT PROCESS

ILLINOIS

-

AMERICAN WATER COMPANY

ALTON DISTRICT

STORAGE

STORAGE

TO DISTRIBUTION

SYSTEM

TO DISTRIBUTION

SYSTEM

---

399501A

w

0

POTASSIUM

PERMANGANATE

FOR

ZEBRA

MUSSEL

POLYMER

CONTROL

COAGULANT

1

1

INTAKE

PAC

pH ADJUSTMENT

Oar

s

Ions

MIXING

TANK

CHLORINE AMMONIA

PRESETTLER

BLANKET

(OPTIONAL)

POLYMER

SUP ERPULSATOR

AT 4 gpm/sq

.ft

.

FIGURE 3-2

PROPOSED TREATMENT PROCESS

IWNOIS

-

AMERICAN WATER COMPANY

CHLORINE FILTER AID

AMMONIA

'

FILTR TION

:

GAC SAND

5 gpm/sq

.ft

.

CHLORINE

pH

ADJUSTMENT AMMONIA

AMMONIA

STORAGE

~ POTENTIAL/SEASONAL APPLICATION

---

FIGURE 3-3 NEW ALTON WTP - ILLINOIS AMERICAN WATER COMPANY

Design Basis, Solids Removal (and backwash rate)

Primary Coagulant = Clarion

Average Turbidity

RIVER WATER

TSS (mg/I) =

180

Flow (MGD)

11 .2

Dry solids weight

(tons/day) =

8.4

DISCHARGES

TSS Removal (%) =

TSS (tons/day) _

TSS (mg/I) =

Solids Content

Wet weight (ton/day) =

Residual Spec .Grav. =

Residual flow (gpd) =

TSS (tons/day) _

TSS (mg/I) =

Solids Content

Wet weight (ton/day) =

Residual Spec .Grav. =

Residuals flow (gpd) =

1

38,070

filters

Washwater flow (gpd)= 620,400

TSS Removal (%) =

2

0.2

65

0.01

2588

1

620,400

TSS (tons/day) _

TSS (mg/I) =

Solids Content

Wet weight (ton/day) _

Residuals Spec .Grav. _

Flow (gpd)

549307DM.ALL, 3995-007-500

superpulsator

98

8.2

5000

0.5

1648

-.4-

1

395,030

chemical residuals

0.8

5000

0 .5

159 _ __

3-11

4

Blanket

SuperpulsatorsSludge

Clarifier

Loading Rate = 4 gpm/sf

V

Chemical Sludge

V

V

6 Gravity GAC/Sand Filters

Surface Area = 470 sf/filter

Loading Rate = 3 gpm/sf

V

FINISHED WATER

TSS (mg/I) =

0

Flow (MGD)

10.2

ENR

8 February 1999

---

4.0

ENVIRONMENTAL CHARACTERISTICS OF PROPOSED SITE

The environmental characteristics of the proposed Alton replacement facility and vicinity were

identified . This included the existing physical conditions (Section

4.1) ; land use (Section 4 .2) ;

characterization of the receiving waters (Section 4.3)

; and stakeholder concerns (Section 4 .4) .

A series of photographs depicting the current facility, the proposed replacement facility site, and

the Mississippi River near River Mile 204 are provided in Plates #1 - #10.

4.1

Existing Physical Conditions

The proposed site consists of approximately 18 acres located within the bounds of the City of

Alton, Illinois in Madison County (Figure

4-1) . Alton is located in southwestern Illinois on a bend

in the Mississippi River north of St. Louis, Missouri (Plates #1 and #2)

. Other local population

centers near Alton include the towns of East Alton, Elsah, Grafton, and Bethalto

. Highways that

pass near the vicinity of the site include Illinois Routes 3, 67, 100, 111, 140, 143, and 267. The

proposed site is located on Illinois Route 100 (Great River Road), a four-lane highway along the

Mississippi River, at the site of a former quarry (Figure 4-2)

. Access to the site is from Illinois

Route 100

. The site can also be accessed from Grand Avenue, an unimproved street

.

4.1 .1

Historical Significance

The proposed replacement facility will be located in Alton, IL

. Alton is a small city located in the

northwestern corner of Madison County

. The region of the proposed replacement facility has

a rich historical heritage

. Alton was founded in 1818 and was named after the eldest son of the

town's founder, Colonel Rufus Easton

. Colonel Easton valued the location as an important ferry

position on a major route to the western frontier

. In 1673, Marquette and Joliet recorded sighting

the "Piasa Bird" painted on the bluff upriver of Alton

. In the winter of 1803-1804, Lewis and Clark

made Wood River, just downstream, as their starting point for the historic exploration of the

northwestern United States

. The final debate between Stephen Douglas and Abraham Lincoln

took place in Alton in 1858

. During the Civil War, Alton served as a stop on the underground

railway

; housed a Confederate prison, hospital, and cemetery

; and functioned as a main supply

depot for the Union Army

.

To meet the requirements of the Illinois State Agency Historic Resources Preservation Act, the

Illinois Historic Preservation Agency was requested to review potential historic, architectural, and

archaeological impacts resulting from the proposed replacement plant

. Due to the site's history

(quarry) and heavily disturbed nature, the Preservation Agency stated that no significant

EK2

549307DMALL. 3995-007-500

4-1

3 March 1999

---

historical, architectural, or archaeological resources are expected to exist on the site .

The

request and response letters are contained in Appendix A .

4.2 Land Use

The 22-acre property is located on a former quarry site . Residential subdivisions are located

above the western and northeastern corners of the property (Figure 4-2)

. The triangular-shaped

property is bounded by Illinois Route 100 to the south, by Grand Avenue and residential areas

accessed by Jefferson Avenue, Upper Hawthorne Road, and Woodcliff Drive

. The site is

composed of both hilly and flat areas

.

The central flat portion of the site, the old quarry floor,

is largely bedrock with sparsely vegetated open areas (Plates #3-#5) . The flat area is

constricted by the bluffs to the west and an elevated area to the east which may be composed

of old quarry debris (Figure 4-2) . Portions of the site are covered with trees and woody

vegetation overlying quarry debris . The eastern portion of the site is accessible via Grand

Avenue, which is bordered by thick vegetation (Plates #6-#7) . The northern half of the site is

less constricted by bordering slopes (Plates #8, #9) . The quarry site is elevated about 50 feet

above the current plant, but is easily accessible to the current intake location (Plate #10) .

Approximately 10 acres of the property are suitable for construction .

The majority of the site (18 acres) is zoned as M-2, Heavy Industrial District with four acres zoned

residential (Figure 4-3) .

In the immediate vicinity of the site, other zoned uses include mostly

residential areas (Alton Zoning Office, 1997)

. The immediate area is nearly fully developed with

minimum vacant land available . The general character of the land use in the area can be seen

in an aerial photograph of the area (Figure

4-4) .

The site is abutted by both single and multi-family residences . Land uses near the proposed site

include higher and moderate income single family residences, apartments, and industrial sites .

Barges tie up along the river banks just downstream of this area prior to passage through the

Melvin Price Locks and Dam .

4.3

Characterization of Mississippi River at

Alton, Illinois

The prominent natural feature of the area and the central environmental resource, due to its role

as both raw water source and potential receiving water, is the Mississippi River . The Mississippi

River near Alton was characterized as to hydrology (Section 4 .3) and water quality (Section

4 .3 .2) .

549307DM

.ALL, 3995-007-500

4-2

EN1t

18 March 1999

---

4

.3.1

Hydrology

Hydrologic and water quality data are available for the Mississippi River near Alton from three

local United States Geological Survey (USGS) gaging stations listed in Table 4-1

. It should be

noted that the Alton stations (i .e ., #05587500, and #05587550) were discontinued after 1989

following relocation and construction of Lock and Dam No

. 26 and that hydrologic and water

quality measurements were resumed at the identified Grafton stations (i.e., #05587450, and

#05587455)

. The stations measure flow emanating from a 171,300-171,500 square mile drainage

basin. Based on 60 years of USGS data, the average mean monthly flow of the Mississippi River

is 106,859 cubic feet per second (cfs) (Table

4-2).

Data were collected at USGS gaging station

#05587500 (Mississippi River at Alton) from April, 1933 through September, 1988 and at USGS

gaging station #05587450 (Mississippi River at Grafton) from October, 1990 through September,

1995. Recorded mean monthly flows ranged from 20,200 to 469,300 cfs (July, 1947 and July,

1993, respectively) . The minimum seven day 10 year flow (7010) is 21,500 cfs (Skelton, 1976) .

The mean monthly flows represented in Figure 4-5 show that March through June are the typical

peak flow months and August to January are the lower flow months .

Cross sectional profiles of the Mississippi river have been determined by the Army Corps of

Engineers who are responsible for maintaining depth in the navigation channels . River depths

in the vicinity of the proposed plant range from 0 to 30 feet deep (U .S. ACOE, 1994). The

normal high water level for this section of the river is 419 feet above mean sea level (MSL) with

a low water level at 413 feet MSL (Orlins and Voigt, 1996) . A map indicating water depth in the

vicinity of the proposed Intake (about River Mile 204) are shown in Figure 4-6

. Three cross-

sections of transects slightly above, at, and slightly downstream of River Mile 204 are shown in

Figure 4-7 (location of transects are given in Figure 4-6) .

4.3.2 Water Quality in the Mississippi River

Water quality data were obtained from the USGS District office in Rolla, Missouri

. Data for total

suspended solids (TSS) were collected at the three USGS gaging stations listed in Table 4-1,

using different methodologies for different time periods . Table 4-3 contains data that were

collected at USGS gaging station #05587455 (Mississippi River below Grafton) from October,

1993 through September, 1995 and at USGS gaging station #05587450 (Mississippi River at

Grafton) from October, 1989 through September, 1993. The average mean monthly TSS value

ranged from 29 to 605 mg/L with an average monthly value of 171 mg/L . The data represented

in Table 4-3 are based on daily monitoring events by an automated gaging station and are

thought to be more representative than the data in Table 4-4 since the monthly averages are

based on averaged daily sampling rather than once-per-month sampling

.

EN R

549307DMALL 3995007-500

4-3

3 March 1999

---

TSS concentrations listed in Table 4-4 are based on individual sampling events collected by the

Water Quality group at the USGS district office in Rolla, Missouri . Data were collected at USGS

station #05587455 (Mississippi River below Grafton) from March, 1989 through September, 1994

.

Individual readings ranged from 17 to 506 mg/L (January 1990 and April 1994, respectively) .

Despite the greater range of TSS concentration resulting from single grab samples, the mean

value of TSS from these data is 156 mg/L which is consistent with the average value of 171

mg/L found in the more intensive sample collection (Table 4-3) . The raw intake TSS for the

current Alton facility (as estimated by turbidity) is 180 mg/L . Thus, the three estimates of annual

average TSS at Alton are fairly consistent

(i.e., 156, 171, 180 mg/L) and considered

representative .

Seasonal fluctuations in TSS can be seen (Figure 4-8) using the more reliable data in Table 4-3 .

The peak months for TSS are the same as the peak flow months (i.e., March through June) .

March has the highest TSS due to spring thawing action and subsequent mobilization of eroded

clays and silts in the watershed . Representative TSS values for characterizing daily minimum

(20 mg/L) and monthly maximum (600 mg/L) were selected following discussion with Illinois

EPA (pers . comm

. Robert Mosher) .

Dissolved iron concentrations in the Mississippi River near Alton were available from USGS data

records . The daily values ranged from 3 to 710 µg/L (May 1993 and November 1992,

respectively) with an average value of 36 Vg/L

. Data were collected on individual days in a

scheduled month from March 1989 through September 1994 at USGS station #05587455

(Mississippi River below Grafton) . The dissolved iron values are shown in Table 4-5 .

Dissolved aluminum data were also collected by USGS and are shown in Table 4-6

. The daily

values ranged from 10 to 220 µg/L ( 10 µg/L on several occasions, 220 µg/L in November,

1993) with an average value of 26 lsg/L . Data were collected from March, 1989 through

September, 1994 at USGS station #05587455 (Mississippi River below Grafton) .

4.3.3 Mussel Habitat Near the Proposed Site

Discussions with Illinois EPA at the August 21, 1997 meeting identified the need for a

characterization of the potential mussel habitat near River Mile 204 in the vicinity of the proposed

intake and discharge pipes. To meet this request, Illinois-American (through its consultant

ENSR) selected Ecological Specialists, Inc

. (ESI) to conduct a unionid (mussel) survey of the

Mississippi River at the proposed site . The goal of this survey was to characterize the potential

mussel habitat found offshore of the proposed site and to determine the potential presence of

protected (i .e.,

threatened and endangered) mussel species . ESI conducted the survey on

October 27-28, 1997 using a protocol reviewed and approved by Illinois EPA (see letter from

549307DM.ALL 3995-007-500

4-4

3 March 1999

---

Heidi Dunn to Robert Mosher in Appendix A)

. Sampling was conducted at 6 transacts

bracketing the present Alton facility . The upstream limit was 100 meters (m) upstream of the

present intake location and the downstream limit was 400 m below the proposed discharge

location . Diver surveys were conducted along these 6 transacts with sampling at the points

indicated in Figure 4-9 .

The proposed replacement plant discharge location is located

approximately between Transects No . 3 and No. 4.

The survey results show that the area currently does not support a unionid community

. No living

animals were found in the study area and only the shells of eight species were collected . None

of the collected species were federal or Illinois protected mussel species

. Only the shells of

Leptodea fragills

was represented by freshly dead shells

; the remaining shells were weathered

or sub-fossil.

ESI reported that substrate composition apparently limited unionid distribution in the study area

.

Substrate throughout the study area consisted of deep silt (0 .75 m) from the bank to

approximately 50-60 m riverward, and then gradually changed to unstable sand farther into the

navigation channel . The report noted that the study area is upstream of Melvin Price Locks and

Dam and that similar depositional substrate commonly results from low flow conditions typically

found upstream of navigational dams . The study concluded "Given that habitat conditions within

the study area are unsuitable for unionid colonization, and no unionids were found, construction

and operation of the water intake and treatment discharge should not impact unionids ." The full

ESI report is contained in Appendix B .

4.4 Potential Stakeholder Concerns

The Water Company hosted a public meeting on December 18, 1996 at the Ramada Inn in Alton .

Ron Skrabacz (then Alton District Superintendent) opened the meeting with a welcome and a

brief description of the need to build a new facility to serve the Alton area

. [Note

: At that time,

the proposed facility location was in Godfrey . However, most of the stakeholder concerns are

of a general nature and would apply to the proposed site.]

Kim Gardner (Director of

Engineering) described the new plant project to the attendees . Karen Tsikteris (then Director of

Water Quality) gave an overview of the methods for disposing of residuals . Thomas McSwiggin,

the Illinois EPA permits manager, gave a regulatory perspective on the project

. After the

speakers, the floor was open to questions from the public .

Major concerns included the aesthetic impacts of the new plant, particularly that of noise

.

Concerns were raised over the potential impact on land values from the building of a new,

industrial structure. These issues were addressed by the panel, who explained that Illinois-

American planned to build a plant which would blend with the surroundings, described the type

ENN

549307DM .ALL 3995-007-500

4-5

4 March 1999

---

of motors and pumps used in a modern plant, and noted that they do not produce an excessive

amount of noise. Traffic issues were addressed, including the potential for increased traffic on

access roads and number of potential truck trips . Other concerns raised in the meeting included

the impact on resident wildlife at the site, the threat of spills in the river contaminating the

drinking water, the safety and aesthetics of the intake pipes, and the fate of the old plant and

associated land .

A second public meeting was convened at February 26, 1996 at the Ramada Inn in Alton

. Karen

Tsikteris presented the elements of the SSIS and approach used to evaluate environmental

impacts . No additional environmental issues regarding water quality or ecological impacts were

identified at this second meeting, although comments were raised on proposed facility building

and infrastructure (e.g., lighting, signage, Iroquois Trailtraffic, vandalism, setbacks, the Piasa Bird

monument) . A summary table listing the concerns and public comments arising from these two

meetings is provided in Table 4-7 .

Subsequent to the meeting in February 1966, Illinois-American decided to develop the property

adjacent to the current plant, rather than the proposed Godfrey site . A third public meeting was

held on July 21, 1998 to discuss the proposed Alton facility . Illinois-American staff (Tsikteris (now

Cooper), Gregory, Gardner, Lawhon, Schultz) presented information and responded to

stakeholder questions . Thomas McSwiggen and Roger Selbert from Illinois EPA were in

attendance . Alton Mayor Don Sondich and other city officials (Aldermen Loy, Brake, and Hakes)

were present and indicated the City of Afton's support of the proposed plant .

Stakeholder questions included discussion of the development of the former Mississippi Lime

Site, the nature of possible lagoons, the fate of the old plant, noise associated with superpulsator

operation, the amount of site lighting, the exterior design of the proposed main building, visual

issues, site enclosure (fencing), lagoon dewatering, placement of facility buildings, the bike path

easement, and access through Grand Avenue .

549307DM .ALL 3995-007-500

4-6

EH R

3 March 1999

---

TABLE 4-1

USGS Gaging Stations

on Mississippi River in . Vicinity of

Proposed Replacement Facility

Erm

Station ID

nescrlptio. .

Location'

54saorra4-1, 3995-007-500

4-7

February s

. 1999

05587450

Mississippi River At

38'58'05"/90°25'-

218 .6 miles upstream

Hydrologic

Grafton

42"

from the mouth of the

1989-present

Ohio River

Water Quality

1989-1993

05587455

Mississippi River

38°57'04"/90°22"-

214 .6 miles upstream

Water Quality

Below Grafton

16"

from the mouth of the

1993-1995

Ohio River

05587500

Mississippi River At

38°53'06'/90'10'

202 .7 miles upstream

Hydrologic

Anon

51"

from the mouth of the

1933-1989

Ohio River

(discontinuous)

---

Table 4-2

. Mississippi River Near Alton

:

Mean Monthly Flow (cfs)

1e '

t7 u

:

F

bru9ry

March,

.

.

Ap

II'

May

JUpe

July

69860

AUgust

.-,-

41160

September

30380

Octobar,

34280

Novem

er

31320

December

27610

Annual -_

Mea

n

;

._

.

Value

•'

-

82779

Mlii Value

27610

Mak

:valbe

.

195300

1933

189900

195300

125200

31720

38260

30150

77600

35940

48310

48100

38360

57670

65900

88640

45280

45632

102704

29830

38360

88640

182800

1934

29830

32350

38370

69870

46680

1935

68540

79360

148400

158700

182800

130100

162300

68400

156900

30280

22340

53670

59830

53970

33830

72513

22340

173900

1936

1937

40070

76920

48670

92800

173900

173000

155100

125900

158500

117000

70900

42810

32180

31520

34010

29380

82077

29380

173000

1938

42500

42500

42500

42500

1939

27830

30370

33380

30527

27630

33380

1940

23960

25740

51470

86310

65210

75630

49370

59910

55730

29040

42000

100100

31140

186200

41210

177600

51990

92410

49980

100602

23960

29040

86310

186200

1941

54160

54920

75580

156700

158100

103700

132100

116900

192200

140000

175500

88760

109300

93670

60870

94520

44370

102800

52760

88550

45860

119008

130013

63700

44370

192200

263400

1942

63700

140100

135600

1943

1944

1945

103400

42840

37700

121300

52500

59600

135300

147400

152500

186600

224300

256300

263400

271500

204000

261500

236600

244700

140200

148300

111500

118400

60050

74190

62250

49870

71480

57500

46090

73880

61290

45840

61700

121100

39040

59360

59820

113694

117243

112383

39040

37700

57500

271500

256300

197700

1946