DEQ-CFW_00059685

Page 1 of 9
Form DCAR 06-16 — Distribution of Class A Residuals
Attachment H
Operation and Maintenance Plan
This plan describes the residuals management operations at the Chemours Company — Fayetteville
Works facility ("Chemours") as required by North Carolina regulation NCAC 15A 2T .1110.
1.0 Operational Functions
Chemours operates a water treatment process that treats raw water from the Cape Fear River for
industrial uses within the plant. The treatment system consists of a mixing tank, a clarifier, three
gravity filters, a 250,000-gallon water storage tank, a blowdown and backwash collection tank,
and two sediment (residuals") retention basins. The residuals that settle in the bottom of the
clarifier are gravity fed to one of two basins. The backwash from the gravity filters is discharged
to a collection tank then discharged by gravity to the basins. Only one basin actively receives
residuals until it has reached its capacity. When one basin reaches its capacity a valve is switched
_ so that residuals are discharged into the other basin. The residuals accumulated in the full basin
are dried through evaporation. The dried residual residuals are disposed as Class A material in an
on -site land application area.
The Power Area is responsible for the daily operations of the water treatment process. The plant
is operated continuously via two 12-hour shifts, 24 hours a day, 7 days a week. Two technicians
work each shift in the Power Area. Residuals are generated from the clarifier and the gravity
filters. Residuals are accumulated in the filter sludge retention basins. Clarifier blowdown is
remotely controlled from the Distributed Control System (DCS) by setting interval and duration
for the blowdown cycle. The cycle normally occurs twice per hour depending on the suspended
residuals in the raw water and the level of the sludge bed in the clarifier. The three gravity filters
are backwashed on average once per day for each unit based on the backpressure across the filter.
The schedule for the clarifier blowdown and the filter backwash can be adjusted depending on the
level of residuals in the raw water.
The conveyance pipe from the clarifier and gravity filters to the basins has a valve that can be
adjusted to divert the flow to either of the two basins. Under normal operations one basin is in use
at a time. When that basin reaches its working capacity, the valve is manually switched to direct
flow to the other basin. The residuals in the basin are then allowed to dry through evaporation for
a period of 5 to 8 years.
Dry residuals are land applied on undeveloped areas within the facility. Once applied, the area
would be seeded to have a grass cover. Chemours hires a contractor to perform the operation of
removing the residuals from the basin, transporting and spreading of the residuals onto the
application area. The equipment used to transport and spread the residual residuals is owned by
the contractor.
DEQ-CFW 00059685

Page 2 of 9
Form DCAR 06-16 — Distribution of Class A Residuals
Attachment H
Operation and Maintenance Plan
2.0 Maintenance Schedules
Routine maintenance for the water treatment system is performed by the facility's Maintenance
Department. All electrical parts, valves, and meters are checked and serviced. The tanks are
inspected internally on a five year basis by a certified vessel inspector. The north and south basins
are visually inspected daily by the Power Area technicians.
3.0 Safety Measures
The Chemours facility is fenced and access is restricted. The application area is inside of the
fenced area.
All Chemours employees are trained in safety procedures and to identify and respond to potential
hazards. Before beginning work at the Chemours facility all contractors go through a certification
and registration process. Contractors working at the site are under the direct supervision of a
contract administrator and a safety officer oversees all the projects. Chemours and OSHA safety
requirements are part, of the training contractors are required to participate in before working in
the site. This training includes safety procedures, OSHA reporting, and spill procedures.
4.0 Spill Response Plan
Except for sodium hydroxide, chemicals and materials handled and used in the water treatment
process are innocuous. Spill detection and control procedures are in effect at the Chemours site.
Chemours employees are trained in spill response. A release of a small quantity of a chemical is
contained and remediated by area personnel. If the release is a large quantity or is hazardous, then
the facility's Emergency Response Team ("ERT") is summoned to contain and remediate the
release. Spill control equipment is available at the site to contain and recover spilled material. If
a spill were to occur within the water treatment system area or from one of the basins, it would
flow towards the non -contact water conveyance system via storm water ditches. The ditches are
routinely monitored and inspected. Any residuals spill will be contained with spill containing
equipment, removed from the ditch, and returned to the basins.
5.0 Inspection Plan
During normal operation of the water treatment plant, the Power Area technicians inspect the
equipment and the general area at least once each shift.
DEQ-CFW 00059686

Page 3 of 9
Form DCAR 06-16 — Distribution of Class A Residuals
Attachment H
Operation and Maintenance Plan
Prior to each bulk residuals land application event, either Chemours or Chemours' contractor will
inspect the residuals storage, transport, and application facilities to prevent malfunctions, facility
deterioration and operator errors resulting in discharges, which may cause the release of wastes to
the environment, a threat to human health or a public nuisance. During the period when the
sediment is being deposited in the land application area, Chemours will maintain an inspection log
that includes the date and time of inspection, observations made, and any maintenance, repairs, or
corrective actions taken. Chemours will maintain this inspection log for a period of five years
from the date of inspection, and this log shall be made available to the Division upon request.
During the land application of the residuals from one of the sediment basins, the Operator in
Responsible Charge ("ORC") or the back-up ORC would be conducting routine inspections of the
land application area. Inspection of the residuals application will occur at least weekly.
Personnel responsible for conducting inspections:
• Steven Davis — Shamrock Environmental — Operator in Responsible Charge
• Timothy Carroll — Chemours Company — Contract Administrator
• Various — Chemours Company — Power Area Technicians
Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are representative of
the residuals management program:
Biweekly inspection of the land application area's residuals distribution location: The
Operator in Responsible Charge or Chemours Power Area personnel verifies the sediment is
being / has been placed in the area designated for the placement of said material.
2. Biweekly inspection of the land application area's erosion and sediment control features:
The Operator in Responsible Charge or Chemours Power Area personnel visually inspects
the control features for signs of excessive sediment accumulation.
3. Weekly inspection of the condition of heavy equipment used at the Sediment Basin and the
land application area during sediment removal and application: The Contract Administrator
visually inspects the backhoe(s), dump truck(s), and any other heavy equipment for signs of
oil leakage.
DEQ-CFW 00059687

Page 4 of 9
Form DCAR 06-16 — Distribution of Class A Residuals
Attachment H
Operation and Maintenance Plan
4. Weekly inspection of the rye grass at the land application area following sediment removal
and application: The Contract Administrator visually inspects the health and condition of the
rye grass until it is established.
5. Biweekly inspection of the depth of the applied sediment in the land application area during
sediment application: The ORC or Chemours Power Area personnel measures the depth of
the applied sediment to ensure the Cumulative Pollutant Loading Rates (CPLRs) are not
exceeded.
Detailed description of inspection procedures including record keeping and actions to be taken by
the inspector in the event that noncompliance is observed pursuant to the noncompliance
notification requirements under the monitoring and reporting section of the permit.
1. Biweekly inspection of the residuals distribution location: The Operator in Responsible
Charge or Chemours Power Area personnel will visually verify the applied sediment is
contained wholly within the boundary of the land application area. If sediment is found to
be outside the boundary of the land application area, then the inspector will immediately
contact the Contract Administrator who in turn will instruct the heavy equipment contractor
to move said sediment to within the boundary of the land application area. Records of these
biweekly inspections will be maintained in a logbook kept on -site in the Power Area.
2. Biweekly inspection of the land application area's erosion and sediment control features:
The Operator in Responsible Charge or Chemours Power Area personnel will visually inspect
the sediment trap for signs of excessive sediment accumulation. Should the accumulated
quantity of sediment exceed one-half of the height of the sediment trap's gravel filter/berm,
then the inspector will immediately contact the Contract Administrator who in turn will
instruct the site's construction force to remove said sediment from the sediment trap and
return it to the sediment application area in the land application area. Records of these
biweekly inspections will be maintained in a logbook kept on -site in the Power Area.
3. Weekly inspection of the condition of heavy equipment used at the Sediment Basin and the
land application area during sediment removal and application: The Contract Administrator
will visually inspect the backhoe(s), dump truck(s), and any other heavy equipment for signs
of oil leakage, including fuel and hydraulic fluids. If any oil leakage is found, the inspector
will instruct the equipment operator to immediately shutdown the equipment and immediate
deploy oil abatement equipment and materials, and finally will summon the site's Emergency
Response Team to contain and remove any released oil. Records of these weekly inspections
will be maintained in a logbook kept on -site in the Contract Administration Office.
DEQ-CFW 00059688

Page 5 of 9
Form DCAR 06-16 — Distribution of Class A Residuals
Attachment H
Operation and Maintenance Plan
4. Weekly inspection of the rye grass at the land application area following sediment removal
and application: The Contract Administrator will visually inspect the health and condition
of the rye grass ground cover of the sediment application area until the grass is fully
established. If any issues are found during the inspection, the inspector will make the needed
contacts to remedy the problem, such as watering the grass during dry periods, or reseeding
the area if the existing grass fails to become established. Records of these weekly inspections
will be maintained in a logbook kept on -site in the Contract Administration Office.
5. Biweekly inspection of the depth of the applied sediment in the land application area during
sediment application: The ORC or Chemours Power Area personnel will measure the depth
of the applied sediment to ensure the Cumulative Pollutant Loading Rates (CPLRs) are not
exceeded. Prior to the commencement of the sediment application, the Chemours
Environmental Manager will calculate the target depth of the sediment so as to ensure the
Cumulative Pollutant Loading Rates (CPLRs) listed in Section II(4) of the permit are not
exceeded.
6.0 Sampling and Monitoring Plan
Sampling of the residuals would take place after the residuals are allowed to dry in the sediment
basin for the period of 5 to 8 years. Prior to land application, the residuals will be sampled for the
analyses listed in Table 1. The samples shall be analyzed by a laboratory certified by the Division
for the required parameters. The analytes listed in Table 1 will be reviewed every five years at the
time of the permit renewal to ensure that any changes in regulatory requirements are included in
the table. Analytical results shall be retained for a period of five (5) years.
The Chemours Company — Fayetteville Works ("Chemours") will report by telephone to the
Fayetteville Regional Office, telephone number [phone], as soon as possible, but in no case
more than 24 hours or on the next working day following the occurrence or first knowledge of the
occurrence of any of the following:
• Any occurrence with the land application program resulting in the land application of
significant amounts of wastes that is abnormal in quantity or characteristic.
• Any failure of the land application program resulting in a release of material to surface
waters.
• Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
DEQ-CFW 00059689

Page 6 of 9
Form DCAR 06-16 — Distribution of Class A Residuals
Attachment H
Operation and Maintenance Plan
• Any process unit failure, due to known or unknown reasons, rendering the facility incapable
of adequate residuals treatment.
• Any spill or discharge from a vehicle or piping system during residuals transportation.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure
of a storage structure, etc.) outside normal business hours shall be reported to the Division's
Emergency Response personnel at telephone number [phone], [phone], or
[phone]. Following the reporting such occurrences by telephone, Chemours will also file
a written report in letter form within five days following first knowledge of the occurrence. This
report will outline the actions taken or proposed to be taken to ensure that the problem does not
recur.
Additional Sampling and Monitoring Information
1) Before the river sediment ("residuals") are removed from a sediment basin, they are sampled
and analyzed for TCLP constituents, metals, nutrients, bacterial indicators, percent solids, and
perfluorooctanoic acid (PFOA). The analytical results will determine that the residuals satisfy
the requirements for Class A material and can be land applied as such. A detailed list of the
analyses is presented in Table 1.
2) Names and titles of personnel responsible for conducting the residuals application sampling
and monitoring:
• Steven Davis — Shamrock Environmental — Operator in Responsible Charge
• Timothy Carroll — Chemours Company — Contract Administrator
• Various — Chemours Company — Power Area Technicians
3) Detailed description of monitoring procedures including parameters to be monitored;
a) ,Annual sampling of sediment for hazardous characteristics analysis: Approximately
midway through the Sediment Basin's excavation, a random sample will be taken of the
sediment and submitted for TCLP, ignitability, reactivity, and corrosivity analyses. The
needed sample containers and coolers will be obtained through TBL Laboratory or Pace
Laboratory. The samples will be submitted to TBL Laboratory or Pace Laboratory for
analysis. Analytical results will be reported to NC Division of Water Resources via the
annual report.
DEQ-CFW 00059690

Page 7 of 9
Form DCAR 06-16 — Distribution of Class A Residuals
Attachment H
Operation and Maintenance Plan
b) Bimonthly sampling of sediment for metals and nutrients analysis: During the first full
week of the land application of the sediment, and every sixty (60) days thereafter during
the land application of the sediment, a random sample will be taken of the sediment and
submitted for Aluminum, Ammonia -Nitrogen, Arsenic, Cadmium, Calcium, Copper,
Lead, Magnesium, Mercury, Molybdenum, Nickel, Nitrate -Nitrite Nitrogen, Percent
Total Solids, pH, Phosphorus, Plant Available Nitrogen, Potassium, Selenium, Sodium,
Sodium Adsorption Ratio (SAR), TKN, and Zinc analyses. The needed sample
containers and coolers will be obtained through TBL Laboratory or Pace Laboratory. The
samples will be submitted to TBL Laboratory or Pace Laboratory for analysis. Analytical
results will be reported to NC Division of Water Resources via the annual report.
c) Bimonthly sampling of sediment for pathogen reduction analysis: During the first full
week of the land application of the sediment in the land application area, and every sixty
(60) days thereafter during the land application of the sediment, a random sample will be
taken of the sediment and submitted for Fecal Coliform Density analysis. The needed
sample containers and coolers will be obtained through TBL Laboratory or a local
certified commercial laboratory to comply with the short hold time of the sample. The
samples will be submitted to TBL Laboratory or another certified commercial laboratory
for analysis. Analytical results will be reported to NC Division of Water Resources via
the annual report.
4) Sampling frequency and procedures to assure that representative samples are being collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event. The sampling plan shall account for any
foreseen fluctuations in residuals quality and indicate the most limiting times for residuals to
meet pathogen reduction requirements (e.g. facilities that land apply multiple times per year
but have an annual sampling frequency, may need to sample during winter months when
pathogen reduction is most likely to be negatively affected by cold temperatures).
a) Annual sampling of sediment for hazardous characteristics analysis: Approximately
midway through the Sediment Basin's excavation, a random sample will be taken of the
sediment and submitted for TCLP, ignitability, reactivity, and corrosivity analyses. The
entire emptying of the Sediment Basin is expected to take approximately six (6) weeks,
so there should be little to no fluctuations due to weather. Given the uniform areal
sediment deposition in the basin during its twelve year active period, sediment samples
would be expected to be fairly consistent in any one area. Since the truckloads will be
DEQ-CFW 00059691

Page 8 of 9
Form DCAR 06-16 — Distribution of Class A Residuals
Attachment H
Operation and Maintenance Plan
comprised of an excellent vertical sediment composition, the sample will be
representative of the entirety of the sediment.
b) Bimonthly sampling of sediment for metals and nutrients analysis: During the first full
week of the land application of the sediment in the land application area, and every sixty
(60) days thereafter during the land application of the sediment, a random sample will be
taken of the sediment and submitted for Aluminum, Ammonia -Nitrogen, Arsenic,
Cadmium, Calcium, Copper, Lead, Magnesium, Mercury, Molybdenum, Nickel, Nitrate -
Nitrite Nitrogen, Percent Total Solids, pH, Phosphorus, Plant Available Nitrogen,
Potassium, Selenium, Sodium, Sodium Adsorption Ratio (SAR), TKN, and Zinc
analyses. The entire emptying of the Sediment Basin is expected to take approximately
six (6) weeks, so there should be little to no fluctuations due to weather. Given the
uniform areal sediment deposition in the basin during its twelve year active period,
sediment samples would be expected to be fairly consistent in any one area. Since the
truckloads will be comprised of an excellent vertical sediment composition, the sample
will be representative of the entirety of the sediment.
c) Bimonthly sampling of sediment for pathogen reduction analysis: During the first full
week of the land application of the sediment in the land application area, and every sixty
(60) days thereafter during the land application of the sediment, a random sample will be
taken of the sediment and submitted for Fecal Coliform Density analysis. Given the
uniform areal sediment deposition in the basin during its twelve year active period,
sediment samples would be expected to be fairly consistent in any one area. Since the
truckloads will be comprised of an excellent vertical sediment composition, the sample
will be representative of the entirety of the sediment.
5) Pathogen Reduction Requirements
a) The land application will be exclusively of non -biological residuals, therefore the
pathogen reduction requirements of 15A NCAC 02T.1106 do not apply.
6) Vector Attraction Reduction Requirements
a) The land application will be exclusively of non -biological residuals, therefore the
vector attraction reduction requirements of 15A NCAC 02T.1107 do not apply.
DEQ-CFW 00059692

Page 9 of 9
Form DCAR 06-16 — Distribution of Class A Residuals
Attachment H
Operation and Maintenance Plan
Table 1
List of Laboratory Analyses
Toxicity Characteristic Leachate Procedure (TCLP)
Arsenic (As)
m-Cresol Hexachlorobenzene
Pyridine
Barium (Ba)
p-Cresol Hexachlorobutadiene
Selenium (Se)
Benzene
Cresol Hexachloroethane
Silver (Ag)
Cadmium (Cd)
2,4-D Lead (Pb)
Tetrachloroethylene
Carbon Tetrachloride
1,4-Dichlorobenzene Lindane
Toxaphene
Chlordane
1,2-Dichloroethane Mercury (Hg)
Trichloroethylene
Chlorobenzene
1,1-Dichloroethylene Methoxychlor
2,4, 5-Trichlorophenol
Chloroform
2,4-Dinitrotoluene Methyl ethyl ketone
2,4,6-Trichlorophenol
Chromium (Cr)
Endrin Nitrobenzene
2,4,5-TP (Silvex)
o-Cresol
Heptachlor Pentachlorophenol
Vinyl Chloride
Total Metals
Aluminum
Cadmium Molybdenum
Sodium
Arsenic
Copper Nickel
Zinc
Barium
Lead Potassium
Calcium
Magnesium Silver
Chromium
Mercury Selenium
Nutrients
Total Kjeldahl Nitrogen Ammonia Nitrate / Nitrite
Phosphorus
RCRA Characteristics
Corrosivity
Ignitability Reactivity
Bacterial Indicators
Fecal Coliform or Salmonella
Other
Perfluorooetanoic Acid
Percent solids pH
DEQ-CFW 00059693