August 29, 2002

Ms. Huxhold-Fliss:

I read the May and June 2002 reports on the performance of the Illinois Central Treatment Facility and have some questions and comments.

1) As noted many times previously, the reference to "clarified" water dumped from the storage tanks as "treated" is a misnomer verging on falsification. The treatment facility collects spring water and treats it to remove PCBs by filtering out sediments and passing the water through carbon absorption units before release. Any water that does not pass through this process cannot be called "treated". Temporary storage in the tanks has not been shown to remove PCBs. The residence time is too short for precipitation of PCB-laden sediments.

And further, one might question if the "overflow" is water that actually overflows the storage tanks. Since engineers usually design to add or remove water from the bottom of a tank, the water sent to overflow is not from the top of a sediment-free, clarified water column. If any sediment does fall to the bottom, any water released is probably not really "clarified". It more likely contains a larger component of PCB-laden sediments than originally present in the water. If any PCBs are removed during residence, it is probably due to volatilization to the atmosphere from the open tanks. If you want to include atmospheric release and partial settling as a component of the treatment process, then you should verify that the water released meets effluent release standards of 0.3 ppb, and that atmospheric release is an acceptable technique. Otherwise it appears to be worse than simply releasing untreated water. Further, if volatilization is acceptable, why was this filtration and carbon absorption process used? Why not just aeration?

2) The June report mentions four false fire alarms occurred. The May report indicates that the fire alarm system was serviced that month. What was done to disable the fire alarm system? If errors were made, then the disabler should pay for the repairs.

3) The data logger malfunctioned for eight days in May. Doesn't a full-time operator monitor the facility? What caused this malfunction and the lapse in attention? What data was lost? Is that information important in the performance of the system? What other important monitoring points going unwatched? Wouldn't an alarm to warn of system failure be appropriate?

4) The monitoring of PCB content appears to be done on an inconsistent basis. Doesn't the operating manual require that effluent levels are to be done weekly? Why are effluent tests done during rainfall events? No influent measurements are presented, and those might be done during rainfall events. Also the rainfall events (dates and levels) reported in the daily reports do not match those of the PCB monitoring reports. Why are all the other parameters (DO, pH, TSS, Conductivity, Temperature, and Turbidity) done on effluent?

5) What is the response time for the PCB analyses? Considering that the plant capacity is 1,000 gpm, almost 1.5 million gallons could pass through the system in a day. The period between samplings that the June 6 level of 0.32 ppb represents was 11 days. This allowed 6.95 million gallons to go through that may not have been properly treated. And during a period of high rainfall, as much as 15.8 million gallons of inadequately treated water could have been released. The delay in getting performance results is too long and too much damage can be done if it is not done in real time. And further, the facility should be using the congenor method of PCB analysis.

6) The reports mention that the PCB levels in the sump area are so high that personnel are in danger when working in the area. Apparently administrative and engineering controls are being considered. Hopefully the solution to the problem does not involve atmospheric venting of PCBs. The whole treatment system already leaks too much PCB into the atmosphere. The solution to the high levels in the sump should not increase the air-released levels.

7) The reports mention an improvement of the control of the SRS Tank Drain Valve that limits the flow to 1,000 gpm. Since the plant capacity is 1,000 gpm, where does the excess go? If the drain valve accepts only 1,000 gpm for the plant and the storage tanks, this suggests that the whole system is bypassed by spring flows that are greater than 1,000 gpm leading to direct release to the surface stream. Please clarify what the transfer capacities for the plant and storage tanks are and what spring flows cause direct bypass.

8) In the June report, a tank "calibration" check was underway that caused bypassing of untreated water to the stream when the system had adequate capacity for treating the water. Only about 10% of maximum flow was treated. Unfortunately a rainfall event on June 5 caught the system by surprise and both the plant and storage capacity were exceeded and bypass of untreated water occurred. Why can't normal operations during rainfalls be used to calibrate? There are so many times when the tanks are used to capture excess water that it seems inappropriate and unnecessary to actually cause a bypass event for a routine maintenance action. And, the report doesn't indicate that the calibration was successful.

9) The plant capacity is approximately 44 million gallons per month and the May report shows about 23 million gallons or 52% of available capacity were treated. Why were 11.9 million gallons of untreated water allowed to bypass the system as "clarified"? What is it in the design or operation of the facility that makes it so inefficient?

Any help that you can provide in understanding these questions would be appreciated.

Sincerely,
Joseph G. Hailer