NC0063029_Approval_20030711

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
July 11, 2003
Mr. Scott Brewer, P.E.
Environmental Management Division
USMC/Marine Corps Base
Building 1
PSC Box 20004
Camp Lejeune, NC 28542-0004
Subject: Discharge Authorization Letter
USMC Camp Lejeune
TWPS Testing
Onslow County
Dear Mr. Brewer:
In a letter dated June 23, 2003, Camp Lejeune requested NPDES permits for future surface water discharges from
a mobile Tactical Water Purification System (TWPS) unit to be located at two sites. Based on the Division's
understanding of this proposed activity, this letter authorizes you to discharge from the TWPS test sites without an
NPDES permit under the following conditions:
• The objective of the training exercise is to practice operating the mobile water purification unit, rather than
generation of potable drinking water for actual consumption.
• The training exercise will be conducted on an intermittent basis.
• The raw water supply will be run through the mobile TWPS unit, which will result in a treated water stream
and a saline brine stream. No potable water will be consumed. The separated streams will be rejoined prior to
discharge back to the original surface water source.
• Backwash/cleaning water from the reverse osmosis element and the microfiltration filter will be collected for
removal to the local wastewater treatment plant. permitted under NPDES Permit #NC0063029.
• The only chemical that will be added to the water during the TWPS test will be an antiscalant. This chemical
will be added during the cleaning process, and captured in the backwash/cleaning wastestream.
• The chlorine injection system included with each TWPS unit will be exercised by passing water. rather than
liquid calcium hypochlorite, into the TWPS product water.
• Source water locations will be located at Riseley Pier (open ocean) and Mile Hammock Bay. The maximum daily
withdrawal will be 288,000 gallons.
The facility will need to discuss any deviations from the listed conditions with the Division prior to discharge. If any
deviations will result in significant changes in the chemical characteristics of the discharge water, the facility will
then need to obtain NPDES permits for such discharges. If you have any questions about these conditions or
NPDES permitting requirements, please contact Tom Belnick at 919-733-5083, ext 543.
Sincerely,
real W. Klimek, P.
cc: US EPA Region 4, Madolyn Dominy
WiRO Water Quality, Ed Beck
NPDES File
_ETA
'SIC DENR
N. C. Division of Water Quality
1617 Mail Service Center Raleigh, NC 27699-1617
Customer Service 1 800 623-7748
[phone]

Re: USMC.Camp Lejeune- NPDES Request
Vt4
Subject: Re: USMC Camp Lejeune- NPDES Request
Date: Tue, 08 Jul 2003 10:29:20 -0400
From: Ed Beck <[e-mail]>
To: Tom Belnick <[e-mail]>
Tom
Approval without a permit sounds good to me.
Ed
Ed Beck <[e-mail]>
1 of 1 7/8/03 10:31 AM

USMC Caoip Lejeune- NPDES Request
Ned 4/40/4/
Subject: USMC Camp Lejeune- NPDES Request
Date: Tue, 08 Jul 2003 10:10:12 -0400
From: Tom Belnick <[e-mail]>
To: Ed Beck <[e-mail]>
7//o/ o3 - D1sfuJizitt w/ cal(m���1,�
s1
rvlur�hc�l1}. Ccnclk�� -
Hi I need your feedback on this one before going to the EPA. Camp
Lejeune has just applied for 2 NPDES discharge permits for mobile water
teatment plant units. It sounds like they previously requested NPDES
permits, but a decision was made to not require permits and a letter was
signed by Coleen based on national defense issues. Natalie Sierra was
involved in this early effort, and she thought you were the WiRO
contact.
Ed-
Anyways, the USMC has come back again. It sounds like they plan to
continue to conduct training exercises on an infrequent basis (2
weeks/quarter, then maybe no exercises the following year) in which
they practice using portable RO units to treat seawater for drinking
water purposes. They want permits for 2 potential discharge sites-
Risely Pier and Mile Hammock Bay. They do not plan to use the treated
water; rather, it will be rejoined with the saline brine, then pumped
back to the ocean. The maximum daily withdrawal will be 288,000
gallons. Approximately every 100 hours, they will backwash the filters,
and this backwash water will be collected and transported to the WWTP.
The only chemical used will be an antiscalant, which will be collected
in the backwash.
Based on this scenario, Goodrich and I still don't think they need
permits for this activity, since they will recombine the treated water
with brine water prior to discharge, essentially resulting in the
initial source water. Let me know what you think. If you're ok with
this, I'll move on to EPA and see if they concur. If all agree, I would
probably draft a concurrence letter to USMC for the proposed
activity.
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
114 (M44t-6(
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1 of 1
7/8/03 10:31 AM

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UNITED STATES MARINE CORPS
MARINE CORPS BASE
PSC Box 20004
Camp Lejeune, North Carolina 28542-0004
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�Iv�ick
In reply refer to:
6280/19
BEMD
2 3 JUN 2003
Mr. Dave Goodrich
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Suite 942
512 North Salisbury Street
Raleigh, North Carolina 27604 /14/ _ 04
Dear Mr. Goodrich: IA plat, A14 1• Z' 2S
Camp Lejeune is requesting Nation Pollutant Discharge d
Eliminations System (NPDES) permits for future Tactical Water
Purification System (TWPS) tests located at Risley Pier and Mile Z �dc41 Q4)
Hammock Bay. TWPS testing will be conducted on average once per �4 na
quarter for one to two weeks at a time. Enclosures (1) and (2)
forward permit application packages for each location. �,Q5 (',�,f
- -09
If you have any questions or need any clarification of the � t ° /r►r,ie,t
information provided, please contact Mr. ` Brynn Ashton, ' VS F1,4S
Environmental Quality Branch, Environmental Management Division,
Installations and Environment Department, at [phone].
- ocean 11-0111 , p , 044 �:�' rat Sincerely,
-r4,1rAO
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Enclosures:
SCOTT
A. BREWER, PE
Director, Environmental Management
By direction of
the Commanding General
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1. NPDE.S Permit Application with Map for Risley Pier
2. NPDES Permit Application with Map for Mile
Hammock Bay
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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek. PE. Director
May 16, 2003
MEMORANDUM
TO: Dave Goodrich
NPDES Unit Supervisor
FROM: Natalie Sierra 'n4'
Engineer, DWQ — NPDES Unit
A7A
NCDENR
SUBJECT: Camp LeJeune Proposed Reverse Osmosis Unit Test
In December 2002, Brynn Ashton of Camp LeJeune contacted me concerning some proposed training
scheduled to take place in April 2003. This training would entail taking saline water from Mile Hammock Bay and
the waters off Risley Pier, running it through reverse osmosis units, blending the reject and potable waters, and
discharging the blend back into the surface waters. The only chemical addition proposed was an antiscalant.
Membrane backwash would be sent off -site for disposal. The training would be for a limited time — April 14 — May
30, 2003. Mr. Ashton emphasized that since war with Iraq was imminent, it was very important the Marines get
DWQ approval for the training as it concerned a matter of national security (the Marines would be trained prior to
being sent to the Middle East). Furthermore, he stated that similar short-term training had been allowed in other
states, particularly when matters of national security were concerned.
I then phoned Marshall Hyatt and Madolyn Dominy of EPA Region 4 since any DWQ action on the matter
would need to be approved by Region 4. They stated that despite the national security situation, this action required
an NPDES permit. According to them, there is no alternative. I conveyed this information to Mr. Ashton, along
with the potential requirements for a new permit (i.e. source water sampling, an engineering alternatives analysis,
information of the receiving stream, etc.).
Mr. Ashton and I resumed discussions in January 2003, at which time he sent me the specifics of the
operation. He continued to argue that since the discharge water was essentially the same as the source water, it
should not require a permit. Since the EPA had disagreed with this argument previously, we proceeded with the
permitting process. This includes a requirement to sample the source water in question. On February 27, 2003, Mr.
Ashton informed me that he was initiating source water testing and expected to have it as soon as possible. These
data have not yet been received.
On March 196, Mr. Ashton submitted two applications to discharge the testing water — one for a location
off Risley Pier and one at Mile Hammock Bay. These were submitted without proper permit fees. On March 21S`,
the Engineering Alternatives Analysis was submitted. By mid -April, the permit fees and source water data had not
yet been submitted. At this point, the reverse osmosis training at LeJeune had begun. By April22"d, the fees and
data had still not been submitted. Since the next public notice date was May 9th, it became apparent that it would be
nearly impossible (due to the required 30 day public comment period and statutory 45 day waiting period between
public notice and final permit issuance) to issue a permit prior to the termination of the training. After discussions
with Ed Beck of the Wilmington Regional Office, Mr. Ashton and you, it was decided that issuing a retroactive
permit would be of little use. Moreover, since we were then in a time of war, the Marine training would most
definitely be considered a matter of national security, thereby making the discharge permissible. Should Camp
LeJeune wish to establish permanent training on reverse osmosis, Mr. Ashton is aware that a permit would be
required.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

Engineering Alternatives
Subject: Engineering Alternatives
Date: Fri, 21 Mar 2003 14:21:03 -0500
From: Ashton GS12 Brynn T <[e-mail]>
To: "'Natalie Sierra'" <[e-mail]>
Natalie
The attached is the Engineering Alternatives. The Permit Fee will be sent
shortly. Would it be $715 or $1430, since there are two sites?
«Engineering Alternatives Analysis.doc »
Brynn Ashton
Environmental Engineer
Environmental Management Division
Marine Corps Base, Camp Lejeune, NC
Phone: [phone] (DSN 751)
e-mail address: [e-mail]
Engineering Alternatives Analysis.doc
Name: Engineering Alternatives Analysis.doc
Type: Microsoft Word Document
(application/msword)
Encoding: base64
Download Status: Not downloaded with message
5/I/03 2:17 PM

UNITED STATES MARINE CORPS
MARINE CORPS BASE
PSC Box 20004
Camp Lejeune, North Carolina 28542-0004
In reply refer to:
6280/19
BEMD
17 MAR 2003
Mr. Dave Goodrich
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Suite 942
512 North Salisbury Street
Raleigh, North Carolina 27604
Dear Mr. Goodrich:
Camp Lejeune is requesting NPDES permits for future Tactical
Water Purification System tests located at Risley Pier and Mile
Hammock Bay. Enclosures (1) and (2) forward permit application
packages for each location. Source Water Analysis for each
package will be forwarded upon completion.
If you have any questions or need any clarification of the
information provided, please contact Mr. Brynn Ashton,
Environmental Quality Branch, Environmental Management Division,
Installations and Environment Department, at [phone].
Sincerely,
SCOTT A. BREWER, PE
Director, Environmental Management
By direction of
the Commanding General
Enclosures: 1. NPDES Permit Application with Map for Risley Pier
2. NPDES Permit Application with Map for Mile
Hammock Bay

NPDES PERMIT APPLICATION - SHORT FORM C-WTP
For discharges associated with water treatment plants
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number
1. Contact Information:
Facility Name
Owner Name
Street Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
Operator Name
Street Address
City
State / Zip Code
Telephone Number
NCoo
Please print or type
Marine Corps Base, Camp Lejeune
Commanding General Marine Corps Base, Camp Lejeune
PSC Box 20004
Camp Lejeune
North Carolina, 28542-0004
[phone]
[phone]
brewersara lejeune.usmc.mil
Scott A. Brewer, PE
PSC Box 20004
Camp Lejeune
North Carolina, 28542-0004
[phone]
2. Location of facility producing discharge:
Facility Name (If different from above)
Street Address or State Road
City / Zip Code
County
U
3. Standard Industrial Classification (SIC) Codes: 9711
4. Principal process(es): See Attachment 1
5. Ownership Status:
Federal X State Private
Public
6. Check here if discharge is continuous X
If not continuous,
Frequency of discharge during the day:
Frequency of discharge during the month (week):
7. Number of separate discharge points: One

NPDES PERMIT APPLICATION - SHORT FORM C-WTP
For discharges associated with water treatment plants
8. Name of receiving stream(s) (Provide of map of exact location of each outfall, including latitude and
longitude:
Mile Hammock Bay (See Figure 1).
9. List all permits, construction approvals and/or applications (check all that apply):
Type Permit Number Type Permit Number
RCRA NC6170022580-R1 Non -Attainment N/A
UIC N/A Ocean Dumping N/A
NPDES NC0063029 Dredge/Fill Permits Available Upon Request
PSD N/A Other See Attachment 2
NESHAPS N/A
10. Is this facility locatedcon Native American lands? (check one)
YES= NO X
11. Please list all water treatment additives, including cleaning chemicals, that have the
potential to be discharged.
The only chemical that will be added to the water during the Tactical Water Purification
System processing is an antiscalant. The antiscalant is removed from the-s to e
backwash hose. -;
L
12. For NEW water treatment plants, please submit all analyse
See Attachment 3
1 a zoo3
urce water collecte
I certify that I am familiar with the information contained in the application and that to the best
of my knowledge and belief such information is true, complete, and accurate.
Scott A. Brewer, PE
Printed name of Person Signing
Director, Environmental Management Division
Title
1 A,Z 03
Signature of Applicant Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or
certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article. or who falsifies, tampers with, or knowingly renders inaccurate any
recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental
Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by
imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $10,000 or
imprisonment not more than 5 years, or both. for a similar offense.)

Attachment 1. Tactical Water Purification System Test
RECORD OF ENVIRONMENTAL CONSIDERATION
Production Verification Test of the 1500 GPH Tactical Water Purification System
U.S. Army Aberdeen Test Center, Spring 2003 (14 Apr — 30 May 03)
Technical POC: Nancy Castaldo, DSN 298-2510, [phone]
Test Description. A description of the 1500 GPH Tactical Water Purification System
(TWPS) and a brief environmental assessment is provided in an extract from the Scientific and
Technical Report, provided as Enclosure 1. Each of three 1500 GPH TWPS will undergo 525
hours of seawater reliability testing involving the withdrawal and discharge of approximately
4000 gallons per hour per unit of water. Retention of the reverse osmosis (RO) element and
microfiltration filter (MF) membrane cleaning waste water will be accomplished in tanks for
reuse and eventual removal to the local Wastewater Treatment Plant. Water will be withdrawn at
a rate of 12,000 GPH for simultaneous operation of the three units, with a like amount of
discharge consisting of a combination of product water (4600 GPH), brine (6300GPH) and MF
Filter backwash (1000 GPH). The conductivity of the brine is approximately 140-150% the
conductivity of the raw water source. Water samples of the open ocean (Riseley Pier) site were
52.4 uS (34,000 ppm TDS). Samples taken at Mile Hammock Bay were 49.4 uS. The chlorine
injection subsystems included in each TWPS will be exercised by passing water, rather than the
calcium hypochlorite in solution, into the TWPS product water. The only chemical that will be
added to the water during the TWPS processing is an antiscalant. Hypersperse AF150 antiscalant
will be dosed at 1.5 lbs for every 10-hr shift of operation, resulting in a 5 ppm concentration.
The antiscalant is removed from the system via the backwash hose.
Test Operations. Reliability test operations will be accomplished with the three units
operating 24 hrs per day, weekdays. The workweek will start at 0600/0700 hrs on Mondays and
will end at 0600/0700 hrs on Saturday mornings. The maximum daily withdraw will be 288,000
gallons. Every 5`h day of operation, a 1.5 hour road march will be accomplished which will
require a system tear -down, packing and set-up. One system will be operated in a skid
configuration and be transported on an USMC MTVR for its road missions. A 10K forklift will
be used to load/unload the MTVR. Two of the systems will be configured on ISO compatible
pallets and be transported by the Load Handling System (LHS) or Palletized Load System (PLS).
Existing paved roads and trails adjacent to the reliability test sites will be used for the road
marches of the systems.
Test Sites. Two test areas are required. An inland site (Mile Hammock Bay) and an
ocean -side site will be needed. No permanent modifications to the test area(s) will be
accomplished. General-purpose tents will be erected near the test units for rain cover. ISO
containers will be positioned nearby for storage of tools and spare parts. An office trailer will be
positioned on -site for crew administration and computer use. Wooden planks will be used, as
deemed necessary, to offer sufficient bearing strength for the trailer outriggers. Po
will be rented and positioned on site for crew use.
Pli1 SOURCE BRANCH

Attachment 2. Camp Lejeune Permits
Camp Lejeune Permits
• Water Treatment Plants
Hadnot Point 04-67-041
MCAS. NR 04-67-042
Holcomb Blvd 04-67-043
Rifle Range 04-67-046
Courthouse Bay 04-67-047
• Wastewater
Collection System WQCS00015
Application of Class A Biosolids WQ0012346
• Landfills
Closed Landfill 67-10
New Municipal Subtitle D Landfill 67-08
Compost Facility 67-10
Treatment and Processing Facility 67-11
• Air
Title V Air Quality Permit 06591T08

NPDES PERMIT APPLICATION - SHORT FORM C-WTP
For discharges associated with water treatment plants
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number
1. Contact Information:
Facility Name
Owner Name
Street Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
Operator Name
Street Address
City
State / Zip Code
Telephone Number
NCOo
Please print or type
Marine Corps Base, Camp Lejeune
Commanding General Marine Corps Base, Camp Lejeune
PSC Box 20004
Camp Lejeune
North Carolina, 28542-0004
[phone]
[phone]
brewersara lejeune.usmc.mil
Scott A. Brewer, PE
PSC Box 20004
Camp Lejeune
North Carolina, 28542-0004
[phone]
2. Location of facility producing discharge:
Facility Name (If different from above)
Street Address or State Road
City / Zip Code
County
3. Standard Industrial Classification (SIC) Codes: 9711
4. Principal process(es): See Attachment 1
5. Ownership Status:
Federal X State
6. Check here if discharge is continuous X_
If not continuous,
Frequency of discharge during the day:
Private
Public
Frequency of discharge during the month (week):
7. Number of separate discharge points: One
60e/ CI)

NPDES PERMIT APPLICATION - SHORT FORM C-WTP
For discharges associated with water treatment plants
8. Name of receiving stream(s) (Provide of map of exact location of each outfall, including latitude and
longitude:
Riseley Pier (See Figure 1).
9. List all permits, construction approvals and/or applications (check all that apply):
Type Permit Number Type Permit Number
RCRA NC6170022580-R1 Non -Attainment N/A
UIC N/A Ocean Dumping N/A
NPDES NC0063029 Dredge/Fill Permits Available Upon Request
PSD N/A Other See Attachment 2
NESHAPS N/A
10. Is this facility located on Native American lands? (check one)
YEsO NO X
11. Please list all water treatment additives, including cleaning chemicals, that have the
potential to be discharged.
The only chemical that will be added to the water during the Tactical Water Purification
System processing is an antiscalant. The antiscalant is removed from the system via -the'
backwash hose.
12. For NEW water treatment plants, please submit all analyses o
See Attachment 3
water collected.
cha -soo a
eo\N-
I certify that I am familiar with the information contained in the application and that to the best
of my knowledge and belief such information is true, complete, and accurate.
Scott A. Brewer, PE Director, Environmental Management Division
Printed name of Person Signing Title
I-iV\,12. c3
Signature of Applicant
Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or
certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any
recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental
Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by
imprisonment not to exceed six months. or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $10,000 or
imprisonment not more than 5 years, or both, for a similar offense.)

Attachment 1. Tactical Water Purification System Test
RECORD OF ENVIRONMENTAL CONSIDERATION
Production Verification Test of the 1500 GPH Tactical Water Purification System
U.S. Army Aberdeen Test Center, Spring 2003 (14 Apr — 30 May 03)
Technical POC: Nancy Castaldo, DSN 298-2510, [phone]
Test Description. A description of the 1500 GPH Tactical Water Purification System
(TWPS) and a brief environmental assessment is provided in an extract from the Scientific and
Technical Report, provided as Enclosure 1. Each of three 1500 GPH TWPS will undergo 525
hours of seawater reliability testing involving the withdrawal and discharge of approximately
4000 gallons per hour per unit of water. Retention of the reverse osmosis (RO) element and
microfiltration filter (MF) membrane cleaning waste water will be accomplished in tanks for
reuse and eventual removal to the local Wastewater Treatment Plant. Water will be withdrawn at
a rate of 12,000 GPH for simultaneous operation of the three units, with a like amount of
discharge consisting of a combination of product water (4600 GPH), brine (6300GPH) and MF
Filter backwash (1000 GPH). The conductivity of the brine is approximately 140-150% the
conductivity of the raw water source. Water samples of the open ocean (Riseley Pier) site were
52.4 uS (34,000 ppm TDS). Samples taken at Mile Hammock Bay were 49.4 uS. The chlorine
injection subsystems included in each TWPS will be exercised by passing water, rather than the
calcium hypochlorite in solution, into the TWPS product water. The only chemical that will be
added to the water during the TWPS processing is an antiscalant. Hypersperse AF150 antiscalant
will be dosed at 1.5 lbs for every 10-hr shift of operation, resulting in a 5 ppm concentration.
The antiscalant is removed from the system via the backwash hose.
Test Operations. Reliability test operations will be accomplished with the three units
operating 24 hrs per day, weekdays. The workweek will start at 0600/0700 hrs on Mondays and
will end at 0600/0700 hrs on Saturday mornings. The maximum daily withdraw will be 288,000
gallons. Every 5`h day of operation, a 1.5 hour road march will be accomplished which will
require a system tear -down, packing and set-up. One system will be operated in a skid
configuration and be transported on an USMC MTVR for its road missions. A 10K forklift will
be used to load/unload the MTVR. Two of the systems will be configured on ISO compatible
pallets and be transported by the Load Handling System (LHS) or Palletized Load System (PLS).
Existing paved roads and trails adjacent to the reliability test sites will be used for the road
marches of the systems.
Test Sites. Two test areas are required. An inland site (Mile Hammock Bay) and an
ocean -side site will be needed. No permanent modifications to the test area(s) will be
accomplished. General-purpose tents will be erected near the test units for rain cover. ISO
containers will be positioned nearby for storage of tools and spare parts. An office trailer will be
positioned on -site for crew administration and computer use. Wooden planks will be used • .
deemed necessary, to offer sufficient bearing strength for the trailer outri : _ ' • l�a
will be rented and positioned on site for crew use.
��+ SOsa E BAN

Attachment 2. Camp Lejeune Permits
Camp Lejeune Permits
• Water Treatment Plants
Hadnot Point 04-67-041
MCAS, NR 04-67-042
Holcomb Blvd 04-67-043
Rifle Range 04-67-046
Courthouse Bay 04-67-047
• Wastewater
Collection System WQCS00015
Application of Class A Biosolids WQ0012346
• Landfills
Closed Landfill 67-10
New Municipal Subtitle D Landfill 67-08
Compost Facility 67-10
Treatment and Processing Facility 67-11
• Air
Title V Air Quality Permit 06591T08

Figure 1. Risley Plei'Qutlail Location
Water Courses
tallation (Boundary)
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A Guidance Document to Evaluate Wastewater Disposal Alternatives
Engineering Alternatives Analysis (EAA)
to Evaluate Waste Disposal Alternatives
Prior to issuing an NPDES discharge permit, North Carolina's Division of Water Quality requires all
NPDES permit applicants to evaluate and establish their discharge alternatives by performing a
comprehensive Engineering Alternatives Analysis (EAA). It is the Division's mandate that an
applicant document, from all reasonable cost-effective options, the most environmentally sound waste
disposal alternative.
The Division of Water Quality (the Division) implemented the federally -delegated NPDES permit
program in response to the federal Clean Water Act of 1972, conscious of the specific goal "...to
eliminate all surface water point -source discharges by...1985." While the Division has yet to achieve
this goal, it continues to strive toward it by requiring individuals or organizations to complete an EAA
when applying for a new permit or expanding an existing NPDES permit under Title 15A NCAC
2H.0105 (c) (2).
The purpose of this guidance document is to assist the regulated community in its efforts to evaluate
wastewater disposal alternatives. Environmental and economic design -option issues are inter -dependent
and should not be treated as mutually exclusive. While past applicants have inappropriately segregated
environmental feasibility from economic feasibility when evaluating disposal options, the Division
stresses that the applicant should address both when evaluating the alternatives discussed below.
The following outlines should be used to prepare EAAs. Please note that the Division will refuse and
return an EAA as incomplete if it lacks any of the following basic components:
I. GENERAL INFORMATION
A. Provide Basic Identification of the Project
• Facility name: Onslow Beach Tactical Water Purification Facility
• County: Onslow County
• Facility address: Nancy, please provide sponsoring unit's address and phone #
• Facility telephone number Provide sponsoring unit's address and phone #
• EAA preparer's name: Brynn Ashton
• EAA preparer's mailing address and telephone number:
Environmental Management Division (Att: Brynn Ashton)
Marine Corp Base
PSC Box 20004
Camp Lejeune NC 28542-0004
B. Provide a detailed description of the project requiring wastewater disposal. All wastewater flows
should be calculated according to 15A NCAC 2H .0219. Demonstrate and justify the need for
flow volumes, to include any flow reductions realized through flow -restricting devices. For all
Page lof10
Engineering Alternatives Analysis: June 9. 2000

A Guidance Document to Evaluate Wastewater Disposal Alternatives
alternatives, the use of flow -restricting or low -flow devices should be investigated. Report
findings should include flow reduction projections:
Description:
Production Verification Test of the 1500 GPH Tactical Water Purification System
U.S. Army Aberdeen Test Center, Spring 2003 (14 Apr — 30 May 03)
Technical POC: Nancy Castaldo, DSN 298-2510, [phone]
Test Description. A description of the 1500 GPH Tactical Water Purification System (TWPS) is
provided in an extract from the Scientific and Technical Report, provided as Enclosure 1. Each of three
1500 GPH TWPS will undergo 525 hours of seawater reliability testing involving the withdrawal and
discharge of approximately 4000 gallons per hour per unit of water. Retention of the reverse osmosis
(RO) element and microfiltration filter (MF) membrane cleaning waste water will be accomplished in
tanks for reuse and eventual removal to the local Wastewater Treatment Plant. Water will be withdrawn at
a rate of 12,000 GPH for simultaneous operation of the three units, with a like amount of discharge
consisting of a combination of product water (4600 GPH), brine (6300GPH) and MF Filter backwash
(1000 GPH). The conductivity of the brine is approximately 140-150% the conductivity of the raw water
source. Water samples of the open ocean (Riseley Pier) site were 52.4 uS (34,000 ppm TDS). Samples
taken at Mile Hammock Bay were 49.4 uS. The chlorine injection subsystems included in each TWPS
will be exercised by passing water, rather than the calcium hypochlorite in solution, into the TWPS
product water. The only chemical that will be added to the water during the TWPS processing is an
antiscalant. Hypersperse AF150 antiscalant will be dosed at 1.5 Ibs for every 10-hr shift of operation,
resulting in a 5 ppm concentration. The antiscalant is removed from the system via the backwash hose.
Test Operations. Reliability test operations will be accomplished with the three units operating
24 hrs per day, weekdays. The workweek will start at 0600/0700 hrs on Mondays and will end at
0600/0700 hrs on Saturday mornings. The maximum daily withdraw will be 288,000 gallons. Every 5th
day of operation, a 1.5 hour road march will be accomplished which will require a system tear -down,
packing and set-up. One system will be operated in a skid configuration and be transported on an USMC
MTVR for its road missions. A 10K forklift will be used to load/unload the MTVR. Two of the systems
will be configured on ISO compatible pallets and be transported by the Load Handling System (LHS) or
Palletized Load System (PLS). Existing paved roads and trails adjacent to the reliability test sites will be
used for the road marches of the systems.
Test Sites. Two test areas are required. An inland site (Mile Hammock Bay) and an ocean -side
site will be needed (South of Risely Pier off of Onslow Beach.) No permanent modifications to the test
area(s) are proposed. General-purpose tents will be erected near the test units for rain cover. ISO
containers will be positioned nearby for storage of tools and spare parts. An office trailer will be
positioned on -site for crew administration and computer use. Wooden planks will be used, as deemed
necessary, to offer sufficient bearing strength for the trailer outriggers. Portable latrines will be rented
and positioned on site for crew use.
Page 2 of 10
Engineering Altematives Analysis: June 9, 2000

A Guidance Document to Evaluate Wastewater Disposal Alternatives
C. If existing facilities will be used as part of an expansion, discuss those existing units including
present and past performance, unit capacities, and inadequacies of each. Include a schematic with
component sizes: This test will not utilize existing facilities and is not an expansion.
D. Indicate if the project will be constructed in phases. Provide the estimated wasteflow per phase.
Indicate current phase status for existing facilities and provide a schedule for constructing each
additional phase: This test will not be phased. During peak operation, the waste flow will be
12,000GPH.
II. EVALUATE DISPOSAL ALTERNATIVES
The Engineering Alternatives Analysis should evaluate any and all disposal alternatives to
include, at a minimum, the following:
• Connecting to a Publicly Owned Treatment Works (POTW):
The possibility of connecting to the Camp Lejeune Advanced Wastewater Treatment
Plant was investigated at the outset of project planning. It was determined that there
were no proximal wastewater manholes or pump stations which could be utilized to
convey waste to the plant. Further, since the entire effort is merely to train Marines to
use the equipment, and the source water will be returned to the source in a nearly
unaltered state, the need for treatment was minimal. In addition, the saltwater
sourcewater could disrupt treatment at the wastewater treatment plant.
• Connecting to a privately owned treatment works: There are no available privately owned
treatment works.
• Feasibility of individual subsurface systems: Because the wastewater will be saline in
nature, subsurface systems are not feasible.
• Feasibility of community subsurface systems: Because the wastewater will be saline in
nature, subsurface systems are not feasible.
• Drip irrigating - both surface & subsurface: Because the wastewater will be saline in
nature, drip irrigation systems are not feasible.
• Spray irrigating: Because the wastewater will be saline in nature, spray irrigating
systems are not feasible.
• Reuse: Because the wastewater will be saline in nature, water reuse is not feasible.
• Surface water discharge through the NPDES program: This is the preferred alternative.
• Any possible combination of the above options: The only feasible alternative is for
surfacewater discharge through the NPDES program.
A. Connecting to a Sewer -Collection System (served by a municipality or other entity holding a
valid NPDES or Non -Discharge Permit).
1. Existing Sewerage System: Indicate the distance to any existing sewer line within a five -
mile radius (extension of radius should be considered if cost effective for project size).
*NOTE: All connection options should include an evaluation of both a gravity line as well
as a force main with pump station(s):
The closest, and only, wastewater collection system connection point is approximately
4500 linear feet away. The possibility of connecting to the Camp Lejeune Advanced
Wastewater Treatment Plant at this point was investigated at the outset of project
Page 3 of I0
Engineering Alternatives Analysis; June 9, 2000

A Guidance Document to Evaluate Wastewater Disposal Alternatives
planning. It was determined that was not a feasible solution, since the entire effort is
merely to train Marines to use the equipment, and the source water should be returned
to the source in a nearly unaltered state, and the need for treatment was minimal. In
addition, the saltwater source water could disrupt treatment at the wastewater
treatment plant.
(a) Provide a description of sewer facilities and resources necessary to connect to the
receiving wastewater treatment plant: A pump station with a 2 h.p. pump and
4500 linear feet of 2" diameter forcemain. Because this area is prone to
hurricane damage, such an investment does not make sense.
(b) Provide a preliminary indication of flow acceptance from local municipal or
private WWTPs under consideration. If a municipal or private WWTP cannot
accept the wastewater, please explain: The Camp Lejeune WWTP has
sufficient capacity to accept the flows.
(c) Attach a topographic map or a scaled site drawing showing the physical route of
this alternative: N/A.
(d) Perform a Present -Value -of -Costs Analysis for this alternative as outlined in
Appendix A of this document. Investigate cost -sharing options with other
potential users. See Appendix A.
2. Planned Sewerage System: Determine if an area -wide sewerage system, within a five mile
radius, is projected to be available within the next five years that could receive waste from
your project. Determine, from the appropriate authority, an availability date and flow
acceptance projection. Identify your public utility or private management -group contact
person that assisted you with this determination: No known wastewater collection system
expansions are proposed for the area.
B. Land -Based Disposal (Installing nitrification systems, low pressure pipe systems, drip
irrigation, mound systems, and spray irrigation systems).
• Does your organization currently own land that is available and suitable for a subsurface
system? Though land is available on the Base, due to environmental regulations, the
waste would have to be pumped from Onslow Beach to the Mainland. It would be more
feasible to pump the waste to the wastewater collection sytem. Also, because the
wastewater will be saline in nature, subsurface or land -based systems are not feasible.
(a) Provide a description of the necessary facilities and resources including a site plan
indicating the proposed layout: N/A. See above.
(b) Provide soil analyses (see Appendix B of this document): N/A. See above.
(c) Provide calculations used to determine the proposed land disposal capacity. Base
these calculations on design and loading -rate characteristics according to
appropriate regulations: N/A. See above.
(d) If there is insufficient usable land at the site, address why. Describe how you
would modify the plans (reducing the number of units or reduce the design flow,
etc.) to allow for inadequate disposal caused by unusable land. N/A. See above.
Page 4 of I0
Engineering Alternatives Analysis; June 9. 2000

A Guidance Document to Evaluate Wastewater Disposal Alternatives
(e) Perform a Present -Value -of -Costs Analysis for this alternative as outlined in
Appendix A of this document. N/A. See above.
1. If there is insufficient land at the proposed site, determine if any additional land could be
acquired. Document land availability in your area. If adjacent land could be acquired,
evaluate according to item B (1). If adjacent land is unavailable, provide documentation
from the owner stating such. N/A. See above.
2. NOTE: Subsurface disposal systems require a 100% reserve area. Surface disposal systems
must be capable of treating waste to secondary limits including disinfection. N/A. See above.
C. Wastewater Reuse Evaluate reusing all or a portion of the wastewater generated on -site:
Because the wastewater will be saline in nature, water reuse is not feasible.
D. Surface Water Discharge (discharge to a flowing stream - defined as having positive 7Q10
and 30Q2 flows).
1. The U.S Geological Survey (USGS) should be consulted to obtain receiving -stream flow
information. This information should be submitted in conjunction with treatment plant
design. For flow information contact Mr. Curtis Weaver at [phone].
2. Proposed treatment systems should compare discharge both with and without tertiary
filtration, assuming a weekly sampling regime: See enclosure 2, Effluent Analysis.
3. Describe the proposed discharge facilities. Include a schematic diagram of the major
components and a site plan with outfall line(s). All discharge systems must meet design
criteria outlined in the Division's Authorization to Construct process. N/A.
4. Document the availability of required land and/or easement agreements: No known
easements or land acquisitions are required for the preferred alternative.
5. Perform a Present -Value -of -Costs Analysis for this alternative as outlined in Appendix A of
this document: See Appendix A.
E. Disposal Combinations The EAA should evaluate the feasibility of combining several disposal
alternatives in lieu of a surface water discharge: Due to the nature of this discharge,
combining different disposal alternatives is not feasible.
Page 5 of 10
Engineering Alternatives Analysis; June 9, 2000

A Guidance Document to Evaluate Wastewater Disposal Alternatives
Appendix A.
Present -Value -of -Costs Analysis of Connecting
to the Existing WW Collection System
The Present -Value -of -Costs Analysis (PVCA) is meant to evaluate all costs associated with a particular
disposal alternative over the life of the project. Prior to performing a PVCA for any of the alternatives,
all costs must be identified. The PVCA should include all monetary costs associated with construction,
startup and operation of a facility. Costs should include, but not be limited to, the following:
Capital Costs
• Land acquisition costs: N/A
• Equipment, installation and Labor Costs:
Pump Station=$ 10000;
4500' 2" diameter PVC forcemain pipe= $3.2 x4500=$14400
• Design costs: $2500
Total=$26,900
Recurring Costs
• Operation and maintenance costs (with replacement costs): Inspection and routine
maintenance= $2000/yr
• Laboratory costs assuming a weekly monitoring regime for discharge systems
and a monthly regime for non -discharge systems: $1500/ yr
• Operator and support staff costs: Included above.
• Residual disposal costs: N/A
• Connection and subsequent user fees: N/A
• Permit and compliance fees: $ 275/yr
• Utility costs (power, water, etc.): $350/yr
Opportunity Costs
NOTE: The applicant shall reference all cost information. If vender quotes have
been received for treatment units or other components, the applicant shall
include these in the document. All costs have been estimated using past
cost experienced by the Camp Lejeune maintenance staff.
Page 6 of 10
Engineering Alternatives Analysts; June 9. 2000

A Guidance Document to Evaluate Wastewater Disposal Alternatives
Calculating Present Value of Costs
Costs incurred in different time periods must be converted to a common time before they can be
accurately combined or compared. Performing this calculation is known as "computing the present
value," or "discounting" the costs. Present value is also sometimes called "present discounted value" or
"present worth."
The applicant shall compute the present value of all cost estimates prepared under this evaluation
guidance using the following standard formula:
Where:
PV=C +t C`
° (1+r)r
PV = Present value of costs.
Co = Costs incurred in the present year.
Ct = Costs incurred in time t.
t = Time period after the present year (The present year is t = 0)
n = Ending year of the life of the facility.
r = Discount rate. For these calculations, the applicant shall use an interest rate
quoted by the lending institution. The loan interest rate quote shall be
provided with this analysis.
However, if costs are the same in every time period from year one through year n (i.e., Ct = C, a
constant for t = 1,2,..., n), then the formula reduces to:
PV = C + C (1 + r)" —1
° r(1 + r)"
In this case, the present value may also be retrieved from a table containing the present value of
annuities (an annuity is a constant amount payable in each year for a certain number of years). Such
tables are available from financial institutions.
The Present Value of connecting to the existing wastewater collection system, with a discount rate
of 6% and a 10 year test period is= $61465
Page 7 of 10
Engineering Alternatives Analysis; June 9. 2000

A Guidance Document to Evaluate Wastewater Disposal Alternatives
Present -Value -of -Costs Analysis of Discharge to Surface Water
The Present -Value -of -Costs Analysis (PVCA) is meant to evaluate all costs associated with a particular
disposal alternative over the life of the project. Prior to performing a PVCA for any of the alternatives,
all costs must be identified. The PVCA should include all monetary costs associated with construction,
startup and operation of a facility. Costs should include, but not be limited to, the following:
Capital Costs
• Land acquisition costs: N/A
• Equipment costs: $ 5000
• Labor costs : $2500
• Installation costs: N/A
• Design costs: N/A
Recurring Costs
• Operation and maintenance costs (with replacement costs): Inspection and routine
maintenance= $500/yr
• Laboratory costs assuming a weekly monitoring regime for discharge systems
and a monthly regime for non -discharge systems: $1500/ yr
• Operator and support staff costs: Included above.
• Residual disposal costs: N/A
• Connection and subsequent user fees: N/A
• Permit and compliance fees: $ 275/yr
• Utility costs (power, water, etc.): $350/yr
Opportunity Costs
NOTE: The applicant shall reference all cost information. If vender quotes have
been received for treatment units or other components, the applicant shall
include these in the document. N/A.
Page 8 of 10
Engineering Altematives Analysis; June 9, 2000

A Guidance Document to Evaluate Wastewater Disposal Alternatives
Calculating Present Value of Costs
Costs incurred in different time periods must be converted to a common time before they can be
accurately combined or compared. Performing this calculation is known as "computing the present
value," or "discounting" the costs. Present value is also sometimes called "present discounted value" or
"present worth."
The applicant shall compute the present value of all cost estimates prepared under this evaluation
guidance using the following standard formula:
Where:
PV=C +� C
° , (1+r)`
PV = Present value of costs.
Co = Costs incurred in the present year.
Ct = Costs incurred in time t.
t = Time period after the present year (The present year is t = 0)
n = Ending year of the life of the facility.
r = Discount rate. For these calculations, the applicant shall use an interest rate
quoted by the lending institution. The loan interest rate quote shall be
provided with this analysis.
However, if costs are the same in every time period from year one through year n (i.e., Ct = C, a
constant for t = 1,2,..., n), then the formula reduces to:
PV = C° + C (1 + r)" —1
r(1+ r)"
In this case, the present value may also be retrieved from a table containing the present value of
annuities (an annuity is a constant amount payable in each year for a certain number of years). Such
tables are available from financial institutions. The Present Value of connecting to the existing
wastewater collection system, with a discount rate of 6% and a 10 year test period is= $26820
Page 9 of 10
Engineering Alternatives Analysis; June 9. 2000

RE: WTP application
Subject: RE: WTP application
Date: Thu, 27 Feb 2003 07:31:40 -0500
From: Ashton GS12 Brynn T <[e-mail]>
To: "'Natalie Sierra" <[e-mail]>
Thanks, Natalie -
We are initiating analysis of the following constituents in samples from the
two sourcewater points (Atlantic Ocean and Intracoastal Waterway): Dissolved
Oxygen, Ammonia, total metals, fluoride and salinity. Are there any other
constituents required?
Brynn Ashton
Environmental Engineer
Environmental Management Division
Marine Corps Base, Camp Lejeune, NC
Phone: [phone] (DSN 751)
e-mail address: [e-mail]
Original Message
From: Natalie Sierra [mailto:[e-mail]]
Sent: Wednesday, February 26, 2003 5:15 PM
To: Ashton GS12 Brynn T
Subject: WTP application
Brynn-
Attached is the WTP application. If you have the source water data ready,
you may fax the application with
the data to me at [phone]. If you get it to us by Monday morning, we
can put it out to public
notice by Wed.
-Natalie
1 of 1 5/1/03 2:17 PM

informatign for our phone conference on 23rd
Subject: information for our phone conference on 23rd
Date: Fri, 10 Jan 2003 09:10:37 -0500
From: ODonnell Mr John H <[e-mail]>
To: "'[e-mail]"' <[e-mail]>
At Port Hueneme, CA we have operated a Seawater Desalination Test Facility
since the mid 1980's. We have tested numerous reverse osmosis systems such
as the 600 ROWPU's, TWPS, and LWP. The State of California does not require
a permit for this operation since we are returning the combined
brine/product water stream to the source. The re -combination of the brine
and product water results in no change in the feed water Dissolved Solids
concentrations. In addition since the process is not a thermal process, the
water is not heated when returned to the source. I will be glad to fax
anyone a copy of our most recent letter (1999) from the California Regional
Water Quality Control Board, Los Angeles Region that resulted in our ability
to operate without an NPDES permit.
Thanks,
Mark Silbernagel, chemical engineer
US Army TACOM
John O'Donnell
Engineer GTES EPS
Marine Corps Systems Command
United States Marine Corps.
2033 Barnett Ave Suite 315
Quantico Va. 22134-5010
703 784 3310 Ext 2516
1of1 5/1/032:18PM

FW: Information
Subject: FW: Information
Date: Thu, 9 Jan 2003 15:17:37 -0500
From: Ashton GS12 Brynn T <[e-mail]>
To: "'Natalie Sierra" <[e-mail]>
Natalie -
Some information from our Port Hueneme, Ca. office.
Brynn Ashton
Original Message
From: Silbernagel, Mark (NFESC) [mailto:[e-mail]]
Sent: Thursday, January 09, 2003 2:55 PM
To: 'Ashton GS12 Brynn T'; Barbee GS12 Thomas H; Paul, Neal; ODonnell Mr
John H; '[e-mail]'
Cc: Vega GySgt Manuel; Motley Ms Malar W; Silbernagel, Mark (NFESC)
Subject: RE: Information
To all,
At Port Hueneme, CA we have operated a Seawater Desalination Test Facility
since the mid 1980's. We have tested numerous reverse osmosis systems such
as the 600 ROWPU's, TWPS, and LWP. The State of California does not require
a permit for this operation since we are returning the combined
brine/product water stream to the source. The re -combination of the brine
and product water results in no change in the feedwater Dissolved Solids
concentrations. In addition since the process is not a thermal process, the
water is not heated when returned to the source. I will be glad to fax
anyone a copy of our most recent letter (1999) from the California Regional
Water Quality Control Board, Los Angeles Region that resulted in our ability
to operate without an NPDES permit.
Thanks,
Mark Silbernagel, chemical engineer
US Army TACOM
Original Message
From: Ashton GS12 Brynn T [mailto:[e-mail]]
Sent: Tuesday, January 07, 2003 7:51 AM
To: Barbee GS12 Thomas H; Paul GS13 Neal N; ODonnell Mr John H;
'[e-mail]'
Cc: Vega GySgt Manuel; Motley Ms Malar W; Mark Silbernagel (E-mail)
Subject: FW: Information
All -
Please note that the conference call has been postponed. I would like to
give an alternative time/date. How about the 21st at 0915?
BTA
Original Message
From: Natalie Sierra [mailto:[e-mail]]
Sent: Tuesday, January 07, 2003 10:45 AM
To: Ashton GS12 Brynn T
Subject: Re: Information
Brynn-
Dave says that he would like two weeks to review the information that you
sent and discuss it internally
1of2
5/1/03 2:17 PM

FW: Information
before meeting or conference calling. As a result, I'll need to cancel this
Thursday's meeting and ask
that you send me possible dates late in the week of the 20th or the week of
the 27th.
Sorry about that.
-Natalie
Ashton GS12 Brynn T wrote:
> Natalie-
> This is the information I promised to send you. We plan to "reconstitute"
> the water and discharge back at the source. Any backwash or cleaning
streams
> will be captured and discharged into the wastewater treatment plant. Talk
to
> you further on Thursday at 9:15.
> «Record of Environmental Consideration.pdf»
> Brynn Ashton
> Environmental Engineer
> Environmental Management Division
> Marine Corps Base, Camp Lejeune, NC
> Phone: [phone] (DSN 751)
> e-mail address: [e-mail]
Name: Record of
Environmental Consideration.pdf
> Record of Environmental Consideration.pdf Type: Portable
Document Format (application/pdf)
Encoding: base64
Download Status: Not
downloaded with message
2 of 2 5/ 1 /03 2:17 PM

Water Purification Unit Tests
Subject: Water Purification Unit Tests
Date: Thu, 9 Jan 2003 09:21:48 -0500
From: [e-mail]
To: [e-mail]
Natalie,
My name is Nancy Castaldo and I'm the senior test director for the two
technical test programs (TWPS and LWP) that we are trying to accomplish at
Camp Lejeune this year. If you require any additional information than
Brynn Ashton cannot provide prior to our phone conference, please don't
hesitate to contact me directly.
Nancy T. Castaldo
Senior Test Director
U.S. Army Aberdeen Test Center
400 Colleran Rd
Aberdeen Proving Ground, MD 21005-5059
DSN 298-2510, [phone]
Fax [phone]
1 of 1 5/ I /03 2:18 PM

Information
Subject: Information
Date: Tue, 7 Jan 2003 10:24:27 -0500
From: Ashton GS12 Brynn T <[e-mail]>
To: "'[e-mail]"' <[e-mail]>
Natalie -
This is the information I promised to send you. We plan to "reconstitute"
the water and discharge back at the source. Any backwash or cleaning streams
will be captured and discharged into the wastewater treatment plant. Talk to
you further on Thursday at 9:15.
«Record of Environmental Consideration.pdf»
Brynn Ashton
Environmental Engineer
Environmental Management Division
Marine Corps Base, Camp Lejeune, NC
Phone: [phone] (DSN 751)
e-mail address: [e-mail]
[Record of Environmental Consideration.pdf
Name: Record of Environmental
Consideration.pdf
Type: Portable Document Format
(application/pdf)
Encoding: base64
Download Status: Not downloaded with message
1 of 1
5/ 1 /03 2:17 PM

RECORD OF ENVIRONMENTAL CONSIDERATION
Production Verification Test of the 1500 GPH Tactical Water Purification System
U.S. Army Aberdeen Test Center, Spring 2003 (14 Apr — 30 May 03)
Technical POC: Nancy Castaldo, DSN 298-2510, [phone]
Test Description. A description of the 1500 GPH Tactical Water Purification System
(TWPS) and a brief environmental assessment is provided in an extract from the Scientific and
Technical Report, provided as Enclosure 1. Each of three 1500 GPH TWPS will undergo 525
hours of seawater reliability testing involving the withdrawal and discharge of approximately
4000 gallons per hour per unit of water. Retention of the reverse osmosis (RO) element and
microfiltration filter (MF) membrane cleaning waste water will be accomplished in tanks for
reuse and eventual removal to the local Wastewater Treatment Plant. Water will be withdrawn at
a rate of 12,000 GPH for simultaneous operation of the three units, with a like amount of
discharge consisting of a combination of product water (4500 GPH), brine (7500GPH) and
occasional MF Filter backwash. The chlorine injection subsystems included in each TWPS will
be exercised by passing water, rather than the calcium hypochlorite in solution, into the TWPS
product water. The only chemical that will be added to the water during the TWPS processing is
an antiscalant. Hypersperse AF150 antiscalant will be dosed at 1.5 lbs for every 10-hr shift of
operation, resulting in a 5 ppm concentration.
Test Operations. Reliability test operations will be accomplished with the three units
operating 24 hrs per day, weekdays. The workweek will start at 0600/0700 hrs on Mondays and
will end at 0600/0700 hrs on Saturday mornings. The maximum daily withdraw will be 288,000
gallons. Every 5th day of operation, a 1.5 hour road march will be accomplished which will
require a system tear -down, packing and set-up. One system will be operated in a skid
configuration and be transported on an USMC MTVR for its road missions. A 10K forklift will
be used to load/unload the MTVR. Two of the systems will be configured on ISO compatible
pallets and be transported by the Load Handling System (LHS) or Palletized Load System (PLS).
Existing paved roads and trails adjacent to the reliability test sites will be used for the road
marches of the systems.
Test Sites. Two test areas are required. An inland site (Mile Hammock Bay) and an
ocean -side site will be needed. No permanent modifications to the test area(s) will be
accomplished. General-purpose tents will be erected near the test units for rain cover. ISO
containers will be positioned nearby for storage of tools and spare parts. An office trailer will be
positioned on -site for crew administration and computer use. Wooden planks will be used, as
deemed necessary, to offer sufficient bearing strength for the trailer outriggers. Portable latrines
will be rented and positioned on site for crew use.
1

1
NMFREDERICK MANUFACTURING DIVISION
TACTICAL WATER PURIFICATION
SYSTEM (TWPS)
SCIENTIFIC AND TECHNICAL
REPORT
Design Calculations and Logistics
Considerations
Prepared for:
Department of the Army
U.S. Army Tank Automotive and Armaments Command
AMSTA-AQ-SCA-M
Warren Michigan, 48397-5000
Prepared by:
SFA Inc. - Frederick Manufacturing Division
20 South Wisner Street
Frederick, MD 21701
Contract No: DAAE07-98-C-S025
Data Item A003
September 15, 1999
Etik-i 81MAY

TACTICAL WATER PURIFICATION SYSTEM (TWPS)
SCIENTIFIC AND TECHNICAL REPORT
Design Calculations and Logistics Considerations
1.0 Introduction
The 1,500 Gallons Per Hour (GPH) Tactical Water Purification System (TWPS) is the next
generation water purification system that replaces the existing 600 GPH ROWPU. TWPS will
be used to purify a broad range of water sources such as fresh, brackish, sea and nuclear,
biological, and chemical contaminated to meet water support requirements. TWPS is comprised
of a raw water system to automatically deliver source water to the purification system, a water
purification system to produce clean water, and a distribution system to deliver clean water to
assigned holding tanks for use as needed. Several configurations of TWPS are available
depending on transportation requirements including trailer mounted, 5-ton truck mounted, and
ground operated.
TWPS is capable of purifying, storing, and dispensing water meeting Tri-Service Field Water
Quality Standards for long term consumption. TWPS produces at least 1500 gallons of potable
(drinking) water per hour from a fresh water source and 1200 gallons per hour from a sea water
source. TWPS includes a potable water dispensing capability and interfaces with military fixed
storage holding tanks.
TWPS is intended to replace the 600 GPH ROWPU on a 1 for 2 basis thus improving the supply
of potable water to U. S. ground, amphibious, airmobile, and airborne units throughout the
spectrum of conflict in peace and war, and will provide quality water support to civilian agencies
or host nations for emergencies, disaster relief, humanitarian efforts, and peacekeeping missions.
The design of TWPS uses state-of-the-art technology to increase the potable water output
without increasing the size, weight, or deployment features of the 600 GPH ROWPU and
improve water production efficiency and flow rates from sources with high salinity contents.
TWPS has been designed for a 20 year life, with a Mean Time Between Failure of 180 hours.
2.0 General Process Description
The 1500 TWPS is a fully contained mobile water purification system consisting of the
following process systems:
• Raw water system
• Microfiltration (MF) -system
• Reverse osmosis (RO) system
• Air system
• Chemical injection system
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FREDERiCKMANUFAGTURINGDMSlON WATER TECMNOLOGICS DIVISION

• Product distribution system
• NBC final purification system
Power is supplied by a government furnished 60 kW diesel generator set. Control is provided
through a PLC with individual LED displays, switches and push -buttons rather than an operator
interface screen with key pad.
The Process Operating Description can be followed by referring to the Process Operating
Diagrams contained in Appendix A.
The system utilizes micro -filtration (MF) pretreatment to remove suspended solids and bacteria
and high rejection spiral wound reverse osmosis (RO) membranes to produce potable water from
fresh and brackish water sources and from seawater up to 60,000 mg/1 TDS. The nominal water
production is 1500 GPH operating on fresh and brackish water sources and 1200 GPH operating
on seawater. Performance characteristics under various operating conditions are provided in
Appendix B. The MF automatically backwashes on a preset 15 minute operating time interval.
System flow rates and tank capacities are designed to maintain potable water production while
the backwash is in process.
2.1 Raw Water Supply. Raw surface water is supplied by a self priming diesel driven pump
which discharges to a second self priming motor driven pump and then to the TWPS skid raw
water inlet connection. When drawing seawater from a beach location, the second pump
discharges through a hydro -cyclone to remove sand. Within the skid, the raw water flows
through a manual flow control station and then back out through a skid connection and hose to
the micro -filter (MF) Feed Tank. The required flow rate is nominally 65 gpm at the TWPS skid
inlet. The cyclone requires an additional 5 gpm underflow. Therefore, the pumps are designed
for a nominal flow of 70 gpm. When operating on chlorinated municipal water, a sodium
bisulfate chemical injection system is used to eliminate the chlorine. The MF membranes have
almost no tolerance to chlorine.
2.2 MF System. MF feed water is drawn from the tank by the MF Feed Pump which is
deployed on the ground at the tank. The feed discharges through hose media to the TWPS skid
MF feed connection, through dual 600-micron strainers, and then to the MF assembly upper and
lower feed connections. The feed water flows through upper and Iower internal channels to each
of 12 MF modules in parallel.. Each module contains a bundle (lumen) of hollow fibers.
Entering each module, the feed flows around the outside of the fibers and then through the
micro -porous membrane surface of each fiber and into the hollow core. The small, 0.2 micron
nominal, pores filter out almost all of the suspended solids and all of the bacteria. This material
builds up on the fibers while filtering. Filtration is dead ended without a flow to waste. The
filtered feed water (filtrate) flows out both ends of the fiber bundles, into upper and lower filtrate
channels and out to upper and lower connections. These are piped together and discharged
through a flow control valve to the RO Feed Tank. During MF backwash, this tank provides the
reserve capacity to sustain operation of the RO.
2.3 RO System. From the tank the filtered feed flows to the RO feed pump and is discharged to
the High Pressure Pumps. A chemical injection system adds an antiscalant to avoid scale
formation in the RO elements as the water is concentrated. The high pressure pumps are positive
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WATER TECHNOLOGIES D
FREDERICK MANUFACTURING DIVISION rvreIoa
2

displacement direct driven pumps with pistons driven by a hydrodynamic swash plate. The
hydrodynamic water flow is returned from each pump to the RO Feed Tank. The pumps deliver
a combined flow of approximately 59 gpm. This exceeds the 54 gpm needed by the RO;
therefore, approximately 5 gpm of pressurized feed water is returned to the RO Feed Tank
through a valve. Although the RO can accept the full 59 gpm, the lower flow rate results in a
reduced demand on the MF which in turn improves the long term performance of the MF.
The High Pressure Pumps discharge to the pump end of the power recovery Turbocharger where
the pressure is boosted before entering the first of five RO pressure vessels arranged in a series
array. Each vessel contains two 8 x 40 spiral thin film composite polyamide RO elements
installed with a blanking plug between the permeate tubes. The RO permeate is discharged
from each end of each vessel to allow direct measurement of the flow and purity of water
delivered by each of the 10 RO elements. From the last vessel the concentrated feed water, now
reject, discharges to the turbine side of the Turbocharger where the pressure is converted to
energy to run the pump side. The operating pressure is adjusted with a main and an auxiliary
pressure valve which are used to bypass the Turbocharger. The maximum pressure at the High
Pressure Pump discharge is approximately 900 psig. The maximum pressure at the Turbocharger
outlet is 1200 psig. The Waste Out hose directs the RO reject and the MF backwash water back
to the water source away from the raw water intake.
2.4 Product Water. The permeate from each element is collected in a header and piped to the
skid potable water outlet connection. Immediately before the outlet a chemical injection system
adds calcium hypochlorite sufficient to provide a residual of 10 mg/1 free chlorine. A hose
discharges to one of the two 3000 gallon product distribution tanks. The distribution pump
draws water from both tanks and provides up to 125 gpm total through two distribution nozzles.
2.5 NBC System. When operating on an NBC decontamination mission, the product passes
through a bank of 6 NBC filters before the hypochlorite is injected. These filters are arranged in
parallel and each contain a lower Iayer of ion exchange resin and an upper layer of activated
carbon to assure full removal of NBC warfare agents. The filters are rated for 100 hours of
operation and are disposable.
2.6 Air System. An air system is provided to supply the air necessary to backwash the MF and
to operate the automatic valves and control valves. A high pressure compressor supplies air to a
receiver tank to 1300 psig shut-off. Air at 90 psig is supplied for MF backwash and automatic
valve operation. Air at 15 psig is supplied for MF drain and purge steps in the backwash cycle
and other instrument uses.
3.0 Detailed Process Description and Calculations
Refer to P&ID 627 — D —11114 IN Appendix A. This P&ID is simplified to provide process and
control understanding without the complication of presenting fully detailed instrument and
control loops. This section also presents the instrumentation and control logic in a manner which
will provide an understanding of the process, but without full detail. The fully detailed process
logic, including Operator Control Station switches, push -buttons lights and displays, is provided
in Appendix D. The MF valve sequencing charts are also provided in Appendix D.
W` FREDERICK MANUFACTURING DIVISION
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WATER TECHNOLOGIES DIVISION
3

10.0 Environmental Assessment Effort
10.1 Waste Discharge and Reject Water
The waste discharge from the TWPS consists of periodic backwash from the microfiltration
subsystem, reject water from the RO process, reject from the power recovery turbine and, when
required, wash and rinse water from cleaning the RO and MF membranes.
For the latter items, the TWPS system includes three separate collapsible tanks that will store the
RO wash and the MF wash water for reuse if the TWPS is under a long term operational scenario
and a larger tank to store the rinse water. If reuse is unlikely because of a short mission, the
residue from the wash and rinse, which could also be generated during a "stand -down" or de-
commission operation, must be removed and disposed of in an appropriate manner. The
chemicals used in the cleaning are Argo Scientific Bioclean 442 and Argo Scientific IPA 411.
MSD sheets indicate these materials are biodegradable and non -toxic. The MF filters are washed
at 300 hour intervals. The RO membranes are expected to operate for 3000 hours without
washing except for stand -downs.
Periodic MF back wash water is discharged directly to the source. The only chemicals that may
be present in the back wash water are sodium bisulfite and an NSF approved anti-scalana The
contaminants in this process are those present in the source water. Calcium hypochlorite is
added to the product water. During de -commissioning of the TWPS at a process site the product
water may be discharged directly to the ground for disposal. The discharge from the RO system
and the power recovery turbine is also returned to the source. The contaminants in this process
are those present in the source water.
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1500 TWPS Membrane and Permeator Cleaning Summaries
Provided by SFA, Dec 99
MEMBRANE CLEANING — CHEMICALS
1. ARGO SCIENTIFIC BIOCLEAN 442 ORGANIC ACID
• MicroFiltration (MF) CALCIUM, MAGNESIUM AND IRON REMOVAL
• RO CALCIUM CARBONATE AND BIOFILM REMOVAL
• RO PRESERVATIVE
• 2.1% SOLUTION, 26 LBS/CLEANING IN 150 GALLONS, 2.0 pH
• BENEFIT OVER CITRIC ACID: BIOFILM REMOVAL AND PRESERVATION PROPERTIES
FOR RO
• DISADVANTAGE: SOME AQUATIC LIFE TOXICITY AT HIGH CONCENTRATIONS
2. ARGO SCIENTIFIC IPA411 DETERGENT WITH CAUSTIC
• UNUSUAL RO CLEANING TO REMOVE SILT
• STANDARD MF CLEANING, SILT AND BIOFILM REMOVAL
• 2.4% IPA41 I SOLUTION, 30 LBS/CLEANING IN 150 GALLONS
• 2% CAUSTIC (NaOH), 25 LBS/CLEANING IN 150 GALLONS
MEMBRANE CLEANING — ROUTINE
• MF ONLY
• 300 OPERATING HOURS MOST SEVERE FREQUENCY, 1000 HOURS EXPECTED TO BE
TYPICAL
• CLEANING REQUIREMENT INDICATED BY ALARM BASED ON TMP
• BIOCLEAN 442 FOLLOWED BY IPA41 1 WITH CAUSTIC
• 150 GALLONS CLEANING SOLUTION EACH FOR STORAGE AND REUSE
• 15 GALLON LOSS EXPECTED FROM EACH USE, MINIMUM 120 GALLONS REQUIRED TO
CLEAN