NCD003188844_19910625_Carolina Transformer_FRBCERCLA FS_Draft Feasibility Study-OCR

... )-'"·--... _ .. · ..• , .. ~ .,..STAT(,, . o1. /'...," •.. ~,.,,,~-. -.t~.~. •.O' r; f· .J '~\ .
(f :JJ:h~l~ ~i ~~ ~~-\ i ,~--~,.., • ·1'· , V 8,
j) '· .if/ " ...... -.•.. ,.. ,':..."':::.:.~~ ..
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. Mike Townsend
Remedial Project Officer
US EPA Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
RE: Draft Feasibility Study
25 June 1991
· Carolina Transformer Superfund Site
NCD 003188844
Fayetteville, Cumberland County, NC
Dear Mr. Townsend:
William L. Meye:
Director
Enclosed please find comments from the North Carolina Division of Environmental
Management concerning the subject document. These comments arc in addition to the
comments previously submitted by the North Carolina Superfund Section. If you have any
questions, please contact me at [phone].
JB / ds /bypass.10
Enclosure
Sincerely,
~ ~--#~
Jack Butler
Environmental Engineer
Superfund Section
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Marcin, Governor
William W Cobey, Jr., Secretary
June 1 4, 1 9 91 George T Everett, Ph.D.
M E M O R A N D U M
TO:
FROM:
SUBJECT:
Lee Crosby, Chief
Superfund Section
Division of Solid Waste Management
L"' George T. Everett, Director 11,,..L~-
\J Division of Environmental Management
Draft Feasibility Study
Carolina Transformer Superfund Site
Fayetteville, NC
Cumberland County
Project# 91-20
Director
As requested, the subject document has been reviewed by the
Division of Environmental Management. The comments from our Water
Quality, Air Quality and Groundwater Sections are provided below:
Groundwater Section:
The proposed cleanup action appears reasonable contingent on EPA
obtaining proper pretreatment permit from PWC, and evaluating the
lower groundwater aquifer to determine contamination status.
Water Quality Section:
In the subject feasibility study, several alternatives were
examined for the remediation of groundwater including discharge
into waters of the State. For the Carolina Transformer site, the
Water Quality Section will not support a direct discharge of
wastewater to surface water due to the accessibility of Crosscreek
Waste Treatment Plant.
Asheville
704/251-0208
Fayetteville
919/486-1541
Mooresville
704/663-1699
Regional Offices
Raleigh
919/733-2314
Washington
919/946-6481
Pollution Prevention Pays
Wilmington
919/395-3900
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
Winston-Salem
919/896-7007
• •
Air Quality Section
The subject Feasibility Study, as it pertains to the soil remediation alternatives, failed to address potential air quality impacts and compliance with applicable North Carolina Environmental Management commtssion air quality regulations.
Although the Environmental Protection Agency (EPA) has pronounced that no State air permitting is required, all applicable emission control standards including our air toxic regulation must be met. In order for this Agency to determine if the proposed Superfund project will comply with all applicable air quality regulations, EPA must submit for our review and approval detailed information regarding the air quality impacts and compliance status. The level of detailed information should be at least as complete as is currently required to obtain an air quality permit. For your convenience, please find attached an air permit-application form which should assist EPA in determining the level of detail
information required for approval.
If you should have any questions or require additional information, please contact Mr. Larry D. Coble, Winston-Salem Regional Office at [phone].
GE/NT/kz
014A.RGE
Attachments
cc: Perry Nelson, Steve Tedder, Lee Daniel, Larry Coble, Nargis Toma, File
North Caroli.epartment of Environment, Hea.nd Natur,?I Resources ... ' :
Environmental Management Commission
AIR PERMIT APPLICATION
GENERAL INFORMATION
INSTRUCTIONS ON BACK
A
page 1 of 1
To conslruct and opcnte Air.Emission Sources and Control Devices In accordance with N. C. Gener~I Statutes Ch&µL.er 143, Article 21.
·LEASE TYPE OR PRINT. ATTACH APPROPRIATE EMISSION SOURCE AND CONTROL DEVICE FORMS FOR EACH SOURCE
ISTED IN ITEM 6 BELOW '
Facility Name (Company, Establishment, Town, Etc.): Date FOR DEM USE ONLY
DATE RECEIVED:
l Site Location (St./Rd./Hwy.): City Zip Code County ..
Latitude Longitude SIC Code
3. Mailing Address (P. 0. Box/St./Rd./Hwy.):
City State Zip Code Phone with Area Code
L Applicant Technical Contact: Title Phone with Area Code PERMIT NUMBER:
DATE ISSUED:
'1. Description of operation conducted at above facility:
5. List each EMISSION SOURCE and CONTROL DEVICE for which application is made. Assign an ID NUMBER to each emission source
and control device which uniquely identifies that source. Attach appropriate emission source and control device forms for each.
EMISSION SOURCE ID NO. CONTROL DEVICE ID NO.
USE SEPARATE SHEET(S) IF NEEDED
7. Maximum facility operation: _____ Hours/Day _____ Days/Week _____ Weeks/Year
8. Name and address of engineering firm that prepared application or plans:
9. Sign.1wre of responsible person or company official:
Date ----------------------------------------------Signer's Name (TYPE OR PRINT) Title Pho n c with Arca Code
l'ORM AQ-22
• • APPLICATION INSTRUCTIONS
, i'HIS APPLICATION 15 NOT COMPLETE UNLESS ALL REQUIRED INFORMATION IS SUBMITTED
l. P0A0lNT O A TYPE ONLY. FO A ASSISTANCE, Call the Air Quality Section at [phone] or the appropriate field office listed below:
.l..~t;,!vlllc UV.) 2'.il·t.i\ll:I
','J 1,oxxjfln l'hc,,
1.sh<•v l l Jc, IIC 2:1802
\/ltUlon-S.,Jt ... (919) 761-2.351
8025 )kirt.h l'oil'lt Blvd., Sul,~ 100
llin:;lun·5a],,.., )I( T/10(,
919 Worth l'.ilin Slroct 142'1 C&rolir-.e hcnl..W!
tb"irc!;vllJc,, 1/C 1fll!'.i \.14.shirwJton, HC :tfl\89
reyr.Uevllle (919) 'lt16·1~1 Rnll'igh ('.ll'l) 73)-2Jl'I \/iWnglon (91')) 256--1.161
\.uichovh Build.in,;, Suilc 71~
r .. yr.ttr.vi I lr., IIC 2nJ0I
!'u!:l Clfficc l\ox D&B'J
llido:i,111, HC 27f,11
7225 Uright.sviUo henuc
· \/il1dnc:ilon, IIC 2E\403
2. S1.,brnit TWO (2) copies of the application, engineering drawings, specifications, other supporting data and documents to your loc~l field office or to:
N.C. DIVISION OF ENVIRONMENTJ\L MANAGEMENT
J\IR Q!JJ\LITY SECTION
/\JR PERMITS JJRI\NC!l
POST OFFICE BOX 27687
RALEIGH, NORTH C.AROLINJ\ 27611-7687
3. ALL APPLICANTS MUST COMPLETE FORMS "A" ANO "D". Submit ONLY those forms that apply.
11 i\l'l'I.IU\TION IS MAO[ FOK: COMPLETE THE FOLLOWING FORMS:
Gl'nt:r;d Process ..
Uoi!cr .
lncincr,1tor. . . . ........................... .
Woodworking Opcratiom ............ : . · .......... .
P.1incin~. Finishing, Sµray Booths, or Printing Operations ... .
Air Pollulion Control Device . . . .................. .
Concrcle or AsphJlt.13atch Plant. ................... .
"A"
X
X
X
X
X
X
X
"B"
X
X
X
X
X
"C'' "D" "E"
X X
X X
X X
X X
X X X
X X
X X
"F ..
X
"A" GENERAL INFORMATION
"C" AIR POLLUTION CONTROL DEVICE
"8" GENERAL DATA FOR PROCESSES OR FUEL BURNING SOURCES
"O" AREA DIAGRAM
"E" HYDROCARBON EMISSION SOURCES "F" INCINERATOR
4. The app!ication MUST BE SIGNED on Form "A" itom 9 by a RESPONSIBLE INDIVIDUAL of the Company.
5. Because the ;:ipplic.:tion is not ideally suited for every conceivable operation, applicants arc encouraged to .submit additional information when needed to
complete the application and to provide adequate explanation of the operations.
G. Adclress compliance with applicable regulations under NEW SOURCE PERFORMANCE STANDARDS, NATIONAL EMISSION STANDARDS FOR
HAZARDOUS AIR POLLUTANTS, and PREVENTION OF SIGNIFICANT OETERIORATIQN•in the comments section on Form "A" .
.... CHECKLIST••••
DOES YOUR APPLICATION CONTAIN.THE FOLLOWING?
A. Sign;"l\ure by a Company Official.
8. Pollutants ,md Emission flates Before and After Control.
C. Process Flow Oiagram(sl. -
0. Weigh! Hdte Of Materials Entering each Process.
E:.. Cornpletion _of Form "E'. ii Solvents. Paints. Finishing Materials, or any Volatile Organic Compounds aro Used.
F. Oescrip1ion of Emission Sourcc(s) and Air Control Device(s} (Make, Model No., Etticiency, Design Criteria, etc.l
G. Completion of Forms "A" and "O".
•••TABLE OF EMISSION ESTIMATION METHOD CODES .. •
CODE
0 tfot tipplir.;ililc. Erni~sions arc known to he zero.
l Er11i~siom b.Jsetl 01,·source lesting.
2 Emis..siom based on material balance using engineering expertise and knowledge of proces.s.
3 Emissions calculated using emission factors from EPA publication No. AP-42 COMPILATION OF AIR POLLUTION EMISSION FACTORS.
4 J11dgement.
5 Emissions calculated using a special emission factor differing from that in AP-42. Specify reference in comments below.
6 0 lh<!r. Specify in comments below.
COMMENTS:
• • GENERAL DATA FOR PROCESSES Oil FUEL BURNING SOURCES B
page 1 of 3
NOTE: DO NOT USE THIS FORM FOR INCINERATORS, USE FORM "F".
PLEASE TYPE OR PRINT. ATTACH TO THE GENERAL INFORMATION FORM "A". IF APPLICABLE, ATTACH AIR POLLUTION
CONTROL DEVICE FORM "C". USE SEPARATE FORM FOR EACH SOURCE.
1. Emission Source and ID NO. (FROM GENERAL INFORMATION FORM "A", ITEM 6):
2. DescrirHion of Process or Fuel Burning Source Including Air Control Device:
--·---····-··----· -------------------------------------
3. Permit Application is made for (CHECK ONE ONLY):
( ) New Source ( } Existing Source ( } Modification -Last Permit No. _____ _
Commence Construction Date ,19 __ Operation Date---------, 19 __ _
4. Maximum.Source Operation: ___ Hours/Day ___ Days/Week ___ Weeks/Year
5. Air Contaminants Maximum Actual Emissions Emission
Emitted: Before Control After Control Estimate Control
(lb/hr} (lb/hr} Method* Device**
Particulates ...... · ....
Sulfur Dioxide ..... . . .
Nitrogen Dioxide .......
Carbon Monoxide ......
Hydrocarbons (VOC) ....
Lead ... . . . . . . . . . . . .
PM-10 ............
Other ( ) .
*REFER TO BACK OF GENERAL INFORMATION FORM "A" FOR EMISSION ESTIMATION CODE
**ATTACH AIR CONTROL DEVICE FORM "C"
Control
Efficiency%
•
6. Type of Source:
CHECK ONE
( ) A GENERAL PROCESS -Source not covered by Band C below. (Complete items 7, 8, 18 through-22)
I ) B
C
GENERAL PROCESS WITH IN-PROCESS FUEL -Source where products of combustion contact materials heated.
(Complete items 7, 8, 9, 13, 14, 18 through 22) ·
! -•
FUEL BURNING SOURCE (boilers, etc.} -Source where products of combustion are for t~e primary'purpose of pro-
ducing heat or power by indirect heat transfer. {Complete items 9 through 22)
7. Process Operation: ( ) Continuous ( ) Batch -Normal Batch Time ______ No. Batches per Day _____ _
8. Process NJme . Max. Requested
Materials Entering Process*: Input Rates (lb/hr) Permit lnpUt
(Include In-process Solid Fuels) Design Actual Rates (lb/hr)
A. ~~-·---·-.. ·····-
B. ----···
C. ------··
D.
E. --
F. _____
G.
TOTAL WEIGHT ENTERING PROCESS
*DO NOT LIST ANY VOLATILE HYDROCARBONS, USE HYDROCARBON EMISSION SOURCES FORM "E"
• •
DATA FOR PROCESSES OR FUEL IlURNING SOURCES -continued B
page 2 of 3
9. Type of Fuel Burning Source:
( ) Industrial Boiler ( ) Institutional/Residential Boiler ( ) Electric Utility Boiler ( ) Process Burner(s)
( ) Other _____________________ Make and Model No. ___________ _
10. Type of Solid Fuel Burning Equipment Used:
( ) Hand Fired ( ) Overfeed Stoker
( ) Spreader Stoker ( ) Traveling Grate
( ) . Underfeed Stoker ( ) Shaking Grate
( ) Other (specifiy).
( ) Pulverized
( ) Wet Bed
( ) Dry Bed
11. Is collected flyash reinjected? ( ) NO ( ) YES Percent Reinjectcd _______ __,,,
Combustion Air: Percent Excess Air ______ _,,,, Natural ( ) Induced
Specify method and schedule of tube cleaning:
( ) Lancing ( ) Tube Blowing ) Other _________ Schedule __________ _
12. Boiler Horsepower Rating ________ _ Boiler Steam Flow (lb/hr) _________________ _
13. Fuel Burning Source Heat Input: Maximum ______ Million BTU/hr Average ______ Million BTU/hr
14. Fuel Data: Primary Fuel Type(s) (specify) ---------------------------
Standby Fuel Type(s) (specify)---------------------------
FUEL TYPE FUEL USAGE Max.% Max.%
Max. Design Max. Actual Annual Sulfur Ash BTU Value
(gal/hr) (gal/hr) (gal/yr) (OTU/gal)
#6 Fuel Oil -(gal/hr) (gal/hr) (gal/yr) (BTU/gal)
#5 Fuel Oil
(gal/hr) (gal/hr) (gal/yr) (OTU/gal)
#4 Fuel Oil
(lb/hr) (lb/hr) (ton/yr) (BTU/lb)
Coal
(lb/hr dry) (lb/hr dry) (ton/yr dry) (BTU/lb)
Wood R,QQQ __
Other
15. If a combination of fuels is used, specify the ma.xi mum BTU/hr heat input for each:
Fuel Oil ________ Coal ________ Wood ________ Other __________ _
16. Total maximum heat input in million BTU/hr of all indirect fired fuel burning sources within property boundaries excluding that
indicated above:
Fuel Oil _______ _ Coal _______ _ Wood ________ Other __________ _
17. Total No. of indirect fired fuel burning sources within property boundaries:
Fuel Oil ________ Coal ________ Wood ________ Other __________ _
18. Arc there any fugitive emissions (storage piles, product handling, haul roads, etc.)? No ( ) Yes (
comments below, the type, size, estimated emissions and control measures.
19. Describe any liquid or solid wastes generated and method of disposal:
If yes, please describe in
• •
DATA FOR PROCESSES OR FUEL BURNING SOURCES -continued B
page 3 of 3
20. Stack or Emission Point Data:
Height Above Ground (h.) Inside Area (sq. h.) Gas Temperature (Deg. F) Direction of Exit
(up, down or horizontal)
·--·----·-·-·-------------+----------\-----------+---------------
Is rain cap or other obstruction over
stick? ( ) No ( ) Yes, (specify)
Volumetric Flow Rate
(ACFM)
Velocity (ft./scc.)
Is scaffolding available for source testing?
( ) No ( ) Yes
Arc sampling ports available?
( ) No ( ) Yes
Stack ID No. _________ -Sources with a common
stack will have the same stack number.
21. Indicate monitoring and recording instruments installed on stack:
( ) Opacity Monitor ( ) 502 Monitor ( ) NOx Monitor ) Other------------------
22. Attach or sketch a flow diagram of the process or fuel burning source. Include air control device(s). (SEE INSTRUCTIONS ON
BACK OF THIS PAGE):
23. Cornr:ncnts:
---·------------------------------------
·---------------------------------------------
• •
INSTRUCTIONS
FLOW DIAGRAM FOR PROCESSES OR FUEL BURNING SOURCES
INCLUDING AIR CONTROL DEVICES
Draw a complete flow diagram of the process or fuel burning source including air control device(s). Indicate all equipment, mass flow of
material, IOcatio~ of direct heating, inlet and outlet temperatures, and air flow rates. Give flow rates for water used either as cooling or
as scrubbing. Indicate pollutant collected and emissions exhausted to the atmosphere. If a solvent or a mix of solvents, inks, paints or
other volatile liquid mixes are used, complete the Hydrocarbon Emission Sources Form. "E". All materials entering this process should
appear in item 8, page 1.
FOR EXAMPLE:
7
,·-·--·-·----~ _J_Ul_!. l..c"!.!'_r.!l_!£._ 7
UNO ANO
''"HU! 2 II NS
,-----7--
I . ~ i I
I I
I L-r I
I
I
C0lO ACCRfG&I[
IUCUT ll(YJ.IOR
I
I
I
!
I
17
I
I
I __ _j 7
I
5
HOT A.GGR[Gl H
BUCUT El{VltOII
6 VI SRA JI HG
SCRE(NS
VlflGH
MOl'P(II
I
I
I
I
i
~s~~.,,. + I
I
+ D-
Flow diagram of a typical hot-mix asphalt paving batch plant.
1. Rock, gravel, sand, fines, etc. -200,000 lbs/hr or 100 tons/hr.
2. Rock, gravel, sand, fines, etc. -200,000 lbs/hr or 100 tons/hr.
3. Dry aggregate -199,000 lbs/hr or 99.50 tons/hr.
4. 30,000 CFM@ 180° F; 1,000 lbs/hr particulate entering cyclone; 80% cyclone efficiency.
5. BOO lbs/hr returned to dry aggregate.
6. Dry aggregate entering vibrating screens -199,800 lbs/hr.
7. 30,000 CFM@ 180° F; particulates to scrubber -200 lbs/hr.
8. Water 200 GPM; scrubber efficiency -90%.
9. 28,000 CFM@ 140° F; particulate emissions to atmosphere -20 lbs/hr.
10. Asphalt production 219,800 lbs/hr or 109.9 tons/hr.
9
• •
AIR POLLUTION CONTROL DEV,ICE ,,:·, C
page l of 3
PLEA SL TYl'l. OR PRINT. ATTACH TO GENERAL INFORMATION FORM "A". SUPPLY DESIGN DATA, SPECIFICATIONS, AND
AVAILA~LE ENGINEERING DRAWINGS.
l. Air Control Device and ID No. (FROM GENERAL INFORMATION FORM "A", ITEM 6)
2. lf then: JrL' seve1,1I ckvicl'~ in series, list c,1ch unit in series starting at the emission source.
( I) (2) TOTAL UNITS .. ·----·--
3. lndic,11e Emis~ion Source and JD No. that Control Dcvicc(s) is installed on;
4. NJrrativt· Dcscriptio11 of Con!rol Devicc(s):
---------------·
Manufacturer Model Name Model Number
5. Estimated Cost of Control Device
$ ---
Period of Time Control Device is Estimated to be Adequate:
--~----------Years
6. Permit Arplication is made for (CHECK ONE ONLY):
( ) New Source ( ) Existing Source ( ) Modification -Last Permit No. __ _
Commence Construction Date-----------, 19 ___ ~ Operation Date _________ , 19 ____ .
7. Emission Parameters:
Pollutant(s) Controlled
Emission Rate Before Control (lb/hr) ~
Emission Rate After Control (lb/hr} =
Removal Efficiency Percent(%) =
PART.
( )
NOx
( )
co
( )
voe
( )
LEAD
( )
Particle Size Distribution of Particulates Entering Control Device(% Micron):
0-1 ___ l-10
8. Gas Conditions at Control Device:
Flow Rate (ACFM)
Temperature (Deg. F)
Velocity (ft,/sec.)
Pressure Drop (in. H20)
Moisture(%)
___ 10-25
INLET
9. Describe Ultimate Disposal of Collected Materials:
10. Stack or Emission Point Data:
___ 25-50 ___ 50-100
INTERMEDIATE LOCATIONS
OTHER OTHER
_____ Over 100
OUTLET
Height Above
Ground (ft.)
Inside Arca
(sq. ft.)
Arr there obstructions over the stack?
(up, down, or horizontal) ( ) No ) Yes, (specify) l Direction of Exit
--------------~---------------------·--------
Is sc.1ffolding avail;1blc for sources testing?
( ) No ( ) Yes
11. Co111mcnt'i:
Arc sampling ports available?
( ) No ( ) Yes
ll
• •
SUl'PLEMENTAL DATA FOR AIR CONTROL DEVICES
•" "CYCLONE" (MECHANICAL SEPARATORS)*''
C
pagc2of::
Efficiency(%) Volumetric Flow Pressure Drop (in. H20) IJafflcs or Louvers (specify) Position in Series
R,1tc (ACFM) ~ " of _____ ,, ______ Unit~
··--··----·· --. --· ------·--------·--. ·-----.--·----Cyclone Dimensions (inches) Cyclone 8ody Diameter Cyclone Body Height (ft.) Cyclone Cone Height (ft.)
, "'" o""" f "'"":
Wet Spray · 1 No. of Nozzles Liquid Used (sp;cif;)·-· -·-1-··-------------------· Flow Rate (GPM) Makeup Rate (GPM) ___ J% Recirculated
( ) No ( ) Yes
-----·. ---------------------
A process flow diagram must be attached If cyclone is routed to another cyclone or.other equipment, show sketch of entire system.
CYCL0-•1: O!"GPdN UTL T
C~ECK APPROPR !ATE O!JTLET cct:f IGU.~,l. nm~ BELC~ SKETCH OTHE~
COtlF!GURAT!ON
13
Efficiency(%)
Louvers
( ) No ( ) Yes
14
Efficiency (%)
·---
OH O !AGRAJ1 DUCT
Below
INLET
__ J
BOOY
DIMENSION +------1
••• "MUL TICYCLONE" •••
Volumetric Flow No. of Cones Pressure Drop (In. H20) Position in Series
Rate (ACFM) # of
Inlet Dimension of Individual Outlet Dimension of Individual Individual Cyclone
Cyclone (inches) Cyclone (inches) Diameter (inches)
••• "FILTRATION" (BAGHOUSE) •••
Volumetric Flow Filter Surface Air-to-Filter Area Ratio Pressure Drop (in. H20)
Rate (ACFM) Area (sq. ft.) (ft./min.)
leoor
I HEIGHT
ICOHE
I HE !GHT
Units
Inlet Temperature
(Deg. F)
TYPE OF FILTER Fil TER MATERIAL BAG CLEANING I l Fabric Filter (BAGHOUSE) ( ) Fiberglass ( ) Nylon ( ) Mechanical ( ) Sonic ( ) Packed Bed ( ) Mat Filter I ) Nomex ( ) Teflon ( ) Reverse Flow ( ) Air Pulse ( ) Panel Filter ( ) Wool ( ) Dacron ( ) Simple Bag ( ) Ringed Bag ( ) Other ( ) Cotton ( ) Orlon Collapse Collapse
( ) Other ( ) Other
No. of Compartments Time Between Cleaning Inlet Temperature Position in Series
(mins./hr.) (Deg. F) # of Units
15 *** "AFTERBURNER" (FUME INCINERATOR)•••
Type of Afterburner: Efficiency(%) Volumetric Flow Position in Series
( ) Direct Flame Rate (CFM) # of Units ( ) Catalytic
( ) Other
Maximum Burner Rating Combustion Chamber Retention Time Fuel Type (Million BTU/hr) Temp. (Deg. F) (sec.) Usage
--------··-·
Comhustion Chamber Dimensions {ft.): _______ Length _______ Diameter
• •
SUl'PLE~IENTAL DATA FOil AJR CONTROL DEVICES -continued
16. ,....., "SCRUBBER"***
Type uf Suubber: Efficiency(%) Volumetric Flow
( ) Venturi ( ) Orifice Type Rate (ACFM)
( ) lmpingcrncnt Plate ( ) Cyclonic
( I P,1chd Tower ( ) Condenser -·
( I Gr;1vity Tower ( ) Otl1er Pressure Drop I nlct T cmpcraturc
(in. H2D) (Deg. F) ( I 1\lbt Eliminator --------·----: --· . -----r ----Gas Flow Liquid Scrubbing Medium ; Total Liquid Injection (GPM)
( ) Countcrcurrent and Additives (specify) I ( } Concurrent
--·-•-· --·----··----------·---
Vt:nturi
Scrubber
Data:
Inlet Area (sq. in.) ; Throat Area (sq. in.) Throat Velocity (ft./sec.)
I
I
Position in Series
# of
Mist Eliminator Filter Area
(sq. ft.)
Make Up Rate (GPM)
I ( ) Fixed Throat i ( ) Variable Throat
C
page 3 of 3
Units
----
Packed or Surface Area (sq. ft.) Packing Depth (ft.) Type of Packing: No. of Plates Type of Plates
Plate Tower ( ) Rings ( ) Saddles
Data: ( ) Other ____ _
... -·--·--··-· -·-----·-----· --------~---------~-----~---------
17. ... "ELECTROSTATIC PRECIPITATOR" ***
Efficiency(%) Volumetric Flo_w Rate (CFM) Total Collection Plate Pressure Drop Inlet Temperature
Area (sq. ft.) (in H20) (Deg. F)
-------·---------
Resistivity of Gas Viscosity (poise) Charging Field Strength (volts) Collecting Field Strength (volts)
Pollutant (OHM-CM)
---·
CLEANING METHOD
( ) Single Stage
( ) Two Stage
PRECIPITATOR TYPE
( ) Low Voltage
( ) High Voltage
( ) Hot Side
( ) Cold Side
( ) Plate Rapping ( ) Washing
( ) Plate Vibrating ( ) None
( ) Other--·------------
·--·
owcr Corona P
(Watts/JO
Electrical Usage (kw./hr.)
00 cfm)
18.
Type of Adsorption:
( ) One.Pass Regenerative ( ) Recirculating
( ) One-Pass Nonrcgenerative ( ) .Other
Regenerative Method:
( ) Other ___________ _
No. of Compartments No. of Cells/Comp. Position in Series
~ of "
•••"ADSORPTION"***
Efficiency (%) Volumetric Flow Rate (ACFM)
Adsorption Material: Position in Series
Units
( ) Discarded ( ) Thermal (dry heat) ( ) Activated Carbon # of Units ( ) Chemical ( ) Thermal (steam) ( ) Hydrous Silicated
( ) Other __ ( ) Othei
-··.
Pressure Drop I '", .. "'"""""" No. of Compartments How are emissions controlled during
(111 H20I (Deg. F) reg~nera tion?
------.. -. ----.. -----·
S11.e of Adsorbent Bed (ft.)
Length---~------, Width _______ _ Height--------, Diameter ________ _
. ---·· -·-· --·------------------------------------------
Regenerative Schedule: Maximum Time for Desorption __________________________ _
Length of Time to Maximum Saturation _______________________ _
• •
AREA DIAGRAM D
pagclofi
Show .111 ~urroundin,-: buil<link'.S ,ind roads within 1500 feet of the equipment covered by this application. Attach a site diagram identify
ing rJch emission source location(s), propt'rty boundaries and building (structure) dimensions (height, width, and length).
tlORTH
INSTRUCTIONS
1. Indicate location and type of building by the use of small
numbered circles with the decription below.
2. Show roads as lines representing the road edges. Indicate
street names and highway numbers.
3. Show wooded or cleared area by approximate bouridary
lines and thC words "woods", "cleared", "cornfield''. etc.
1500 feet
1000 feet
500 feet
X
CODE
( 1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
( 10)
Example:
DESCRIPTION
(1) Church
(2) Residence
• •
IIYIJl!OCARBON EMISSION SOURCES E
page 1 uf :
NOTE: For emission sources of volatile organic compounds including spray booths, painting, finishing, printing and solvent usage.
PLEASE TYPE OR PRINT. ATTACH TO THE GENERAL INFORMATION FORM "A". IF APPLICABLE, ATTACH AIR POLLUTION
CONTROL DEVICE FORM "C".
1. Emission Source and ID NO. (FROM GENERAL INFORMATION FORM "A", ITEM 6)
2. Process Description (INDICATE NO. OF IDENTICAL PROCESSES -BOOTHS, FINISHING LINES, ETC.):
3. Permit Application is made for (CHECK ONE ONLY):
( ) New Source ( ) Existing Source ( ) Modification -Last Permit No. _________ _
Commence Construction Date----------, 19 __ Operation Date----------, 19 __ _
4. M3ximum Source Operation: ____ Hours/Day ____ Days/Week ____ Weeks/Year
5. List all VOLATILE ORGANIC COMPOUNDS as used: USE NEXT PAGE (PRODUCT ANALYSIS WORKSHEET) TO DETERMINE
IF PRODUCT IS REACTIVE (R) OR NONREACTIVE (NR) AS DEFINED BY 15 NCAC 2D .0518.
TOTAL voe
PRODUCT PRODUCT VOLATILE EMISSION
WEIGHT USAGE BY WEIGHT RATES
PRODUCT NAME R NR (lb/gal) (gal/day) X (lb/gal) = (lb/day) (ton/yr)
·-·-···--··------------X =
-------· --·-------------X =
X =
---------------------X =
-----------------------X =
·· ·· --·---·------------·---------X =
-----------X =
------------------X =
USE SEPARATE SHEET(S) IF NEEDED TOTAL =
6. Describe the storage and handling methods used in employing the organic products listed above. Include the ultimate disposal methods
of the collected waste and wastewater.
7. Surface Coating Operations:
Describe Articles Being Coated: -----------------------------------
Method of Spray:
( ) Airless ( ) Air Atomize ( ) Electrostatic ( ) Other ________ _
Overspray (%) Stack Flow
Rate (CFM)
Exhaust ( ) None
Control: ( ) Waterwash
( ) Dry Filter
( ) Baffles
( ) Adsorption
( ) Incineration
Control Efficiency
( ) Other ______________ _ Particulate ______ %
Hydrocarbon %
No. of Bake Ovens I Method of
Heating:
8. Solvent Degreasing Operations:
Describe Articles Being Degreased:
( ) Steam
( ) Electric
( ) Direct Fired
( ) Other
Fuel Type _________ _
Usage
--·---------·-----------------------------------
Degreaser Type:
( ) Open Top Vapor ( ) Cold Cleaning ( .) Conveyorized ( ) Other _________________ _
Tank Capacity
(gallons)
Makeup Rate
(gallons/day)
Exhaust Control: ( ) None
( ) Adsorption
( ) Surface Condensers
( ) Closed Loop ( ) Other __________ _
• • PRODUCT ANALYSIS WORKSHEET
(SOL VENTS, PAINTS, FINISHING MA TE RIALS, ETC.} E.
page 2 of 2
INSTRUCTIONS: COMPLETE ONE SHEET FOR EACH TYPE OF PRODUCT. GIVE.CHEMICAL NAMES, NOT BRAND NAMES OR
ABBREVIATIONS. FOLLOW THESE PROCEDURES IN DETERMINING WHETHER OR NOT A PRODUCT OF VARIOUS
SOLVENTS IS REACTIVE (R) OR NONREACTIVE (NR).
A) GROUP THE CONSTITUENTS ACCORDING TO WHETHER OR NOT THEY FIT THE DESCRIPTION IN CLASS (1), (2),
(3) OR NONE OF THE ABOVE CLASSES. IF A CONSTITUENT COULD FALL IN TWO GROUPS, IT IS PLACED IN THE
MORE LIMITED GROUP.
B) DETERMINE THE VOLUME PERCENT OF ALL LIQUID CONSTITUENTS OF THE PRODUCT AS APPLIED. (THIS SHOULD
TOTAL 100%.)
C) TOTAL THE VOLUME PERCENT FOR EACH CLASS (1, 2, AND 3). IF THE VOLUME PERCENT FOR ANY CLASS
EXCEEDS THE PERCENT LIMIT FOR THAT CLASS OR IF THE TOTAL FOR CLASSES (1), (2), (3) EXCEEDS 20 PERCENT,
THEN THE PRODUCT IS REACTIVE. IF NONE OF THESE LIMITS ARE EXCEEDED, THE PRODUCT IS NONREACTIVE.
Product Name Product No. This Product is Classified as:
( ) Reactive (R)' ( ) Nonreactive (NR)
PRODUCT COMPOSITION
ORGANIC
CLASS DESCRIPTION OF ORGANIC CLASS NAME OF CONSTITUENTS
A COMBINATION OF HYDROCARBONS, _____________ _
ALCOHOLS, ALDEHYDES, ESTERS, OR
( 1) KETONES HAVING AN OLEFIN IC OR
CYCLOOLEFINIC TYPE OF UNSATURA-____________ _
(2)
(3)
TION EXCEPT PERCHLOROETHYLENE
--5 PERCENT
A COMBINATION OF AROMATIC
HYDROCARBONS WITH EIGHT OR
MORECARBONATOMSTOTHE
MOLECULE EXCEPT ETHYLBENZENE
- 8 PERCENT
. A COMBINATION OF ETHYLBENZENE,
KE TONES HA YING BRANCHED
HYDROCARBON STRUCTURE,
TRICHLOROETHYLENE, OR
TOLUENE
-20 PERCENT
ALL SOLVENTS NOT LISTED ABOVE
SUB-TOTAL=
SUB-TOTAL=
SUB-TOTAL=
Product Usage (gal/hr) _____________ --------------
Product Weight (lb/gal) __________ _ TOTAL=
Weight of volatiles in product (lb/gal)
Total% volatiles by volume in product ______ %
% BY VOLUME OF THE
TOTAL VOLATILES
ACTUAL % LIMIT
5%
8%
20%
100%
IF THE TOTAL REACTIVE PRODUCT EMISSIONS EXCEED 40 POUNDS/DAY FROM YOUR FACILITY, DESCRIBE THE
CONTROL METHODS EMPLOYED FOR MEETING COMPLIANCE WITH DEM REGULATION 15 NCAC 2D .0518:
• •
INCINERATOR F page 1 of 2
PLEASE TYPE OR PRINT. ATTACH TO THE GENERAL INFORMATION FORM "A". IF APPLICABLE, ATTACH AIR POLLUTION
CONTROL DEVICE FORM "C".
1. Emission Source and ID NO. (FROM GENERAL INFORMATION FORM "A", ITEM 6):
2. Incinerator Description:
Manufacturer Model Name Model Number
3. Permit Application is made for (CHECK ONE ONLY):
4.
5.
( ) New Source ( ) Existing Source ( ) Modification -Last Permit No. ________ _
Commence Construction Date-·-----------, 19__ Operation Date----------, 19 __
Maximum Source Operation:
Type of Waste Burned:
(Sec codes on next page)
____ Hours/Day
Maximum Charging Rate (lb/hr)
Design I Actual
____ Days/Week ____ Weeks/Year
Tons/Year Burned Total Waste Generated (lb/day)
6. Combustible __ % Noncombustible __ % Moisture __ % Heat Value _______ (BTU/lb)
7. Primary Chambcf: · Secondary Chamber: Secondary Chamber Type of Feed
Volume cu. ft. Volume cu. ft. Retention Time: ( ) Manual
Seconds ( ) Automatic
Temperature OF Temperature OF
8. Burner Data: BURNER RATING (BTU/HR) AIR FLOW (CFM) Excess Air (%)
Primary
I
Secondary Overtire
I
Underfire
9. Is there a preheat timer? ( ) No ( ) Yes, Preheating Time _________ Min.
10. Auxiliary Fuel Data: Primary Fuel Type(s) _________________________ _
11.
Secondary Fuel Type(s) --------------------------
FUEL TYPE FUEL USAGE Max.% Max.%
Max. Design Max. Actual Annual Sulfur Ash
(SCF) (SCF) (SCF /yr)
Natural Gas ~
(g,1/h,) (g,1/hr) (g,1/yr)
#2 Fuel Oil
Other
Air Contaminants Maximum Actual Emissions Emission
Emitted: Before Control After Control Estimate Control
(lbs/hr) (lbs/hr) Method• Device**
Particulates ........
Sulfur Dioxide ......
Nitrogen Dioxide .....
Carbon Monoxide ....
Hydrocarbons (VOC) ..
Lead .. . . . . . . . . . . .
Other ( ) ..
Other ( ) ..
'REFER TO BACK OF GENERAL INFORMATION FORM "A" FOR EMISSION ESTIMATION CODE
"ATTACH APPROPRIATE AIR CONTROL DEVICE FORM "C"
BTU Value
(BTU/SCF)
(BTU/g•II
Control
Efficiency%
• •
INCINERATOR -continued F
page2of2
12. Ur!itribc any liquid or solid wastes generated and method of disposal:
13. Stack or Emission Point Data:
Height Above Ground (ft.) Inside Area (sq. ft.) Gas Temperature (Deg. F) Direction of Exit
(up, down, or horizontal)
Volumetric Flow Rate
(ACFM)
Velocity (ft./sec.) Arc sampling ports avai_lable?
( ) No ( ) Yes
Is rain cap or other obstruction over
stack? ( ) No ( ) Yes, (specify)
14. Is a RCRA permit required by the N. C. Department of Human Resources? ( ) No ( ) Yes
If yes, has a RCRA permit application been submitted? ______ Date------------, 19 __ _
15. List ALL incinerated HAZARDOUS WASTE specified in the RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
(40 CFR 261) in the comments section below:
16. Comments:
CODE
0
2
3
4
5
6
••• TYPE OF WASTE BURNED CODE TABLE•••
Principal components, usual source, and typical moisture content
Highly combustible waste, paper, wood, cardboard cartons, (including up to 10% treated papers, plastic or rubber scraps);
from commercial and industrial sources; 10% moisture.
Combustible wao;tc, paper, cartons, rags, wood scraps, combustible floor sweepings; from domestic, commercial, and indus-
trial sources; 25% moisture.
Rubbish and garbage; from residential sources; 50% moisture.
Predominantly animal and vegetable waste; from restaurants, hotels, markets, institutional, commercial and club sources;
70% moisture.
'C:.ircasses, organs, solid organic wastes; from hospitals, laboratories, slaughterhouses, animal pounds, and similar sources:
85% moisture.
Gaseous and semi-liquid industrial prOCess waste; variable moisture. Describe in detail under comments.
Solid and semi-solid by-product waste, such as rubber, plastics, wood waste, etc., from industrial operations; variable
moisture. Describe in detail under comments.
• •
AJR TOXICS APPLICATION FORM
ATTACHED ARE THE FOLLOWING:
1. Toxics Data Form (TDF)
2. Air Toxics Regulations 15A NCAC 2D . 1100 and 211 .0610
I. GENERAL INSTRUCTIONS
G
page I of 3
4/17/90
This section must be completed for facilities required to obtain a toxic air
permit by EMC regulation 15A NCAC 2H .0610 and for facilities who emit one or
more of the regulated air toxics listed in 15A NCAC 2H . 0610(h). As specified
-in 15A NCAC 2H .0610, if facility wide emissions for a listed toxic is above
the amounts listed in 15A NCAC 2H .0610(h), then a toxic air permit is
required. Specific exemptions from toxic air permitting are contained in 15A
NCAC 2H .0610.
The attached Toxics Data Form (TDF) must be completed for each air emissions
source that emits a listed air toxic pollutant. Include listed air toxic
emissions from stacks, vents, chimneys, processes, and fugitive sources.
Propose maximum emissions for the listed toxics in 15A NCAC 2H .0610(h) that
are emitted by the source. The source ID NO. must correspond to the source ID
NO. on item 6 of Form A. For assistance in completing this form please contact
the approriate DEM ·field office listed on the back of Form A.
To comply with 15A NCAC 2H .0610(b), for each listed air toxic emitted from the
entire facility in excess of the amounts listed in 15A NCAC 2H .0610(h), air
dispersion modeling is required as part of the toxic air permit application.
Prior to submitting the modeling, the modeling plan must be submitted by the
applicant and approved by this Division.· Section III of this form lists items
needed in a modeling plan. Applicants applying und~r the provisions of 15A NCAC
2H .0610(b)(2) or (c) should contact the Air Quality S~ction to discuss
specific requirements and the information needed for a compliance
determination.
II. COMPLETING THE ATTACHED TOXIC DATA FORM
Complete a separate form for each air emission source emitting a listed air
toxic pollutant. Form data items are described as follows:
ITEM (1) Source ID
Use the same source identification number as assigned on item 6 of Form A
of the AQ-22.
ITEM (2) Source Description
List the source type such as incinerator, spray booth, coal boiler, or
storage tank. Include air cleaning devices if applicable.
ITEM (3) Exhaust Type
Enter the exhaust configuration of the emission source using the codes at
the bottom of the Toxic Data Form. For the purposes of this application
the following definitions apply:
A. Unobstructed Vertical Stack or Chimney -any point in a source designed
to emit solids, liquids or gases into the air, including a pipe or a duct
but not including flares and that is constructed in a vertical direction
and is void of restrictive obstructions, e.g., rain caps.
• • G
page 2 of 3
B. Obstructed or Nonvertical Stack or Chimney -any point in a
source designed to emit solids, liquids or gases into the air, including a
pipe or a duct but not including flares and that is either constructed in
a nonvertical direction or has a restrictive obstruction, e.g., rain caps.
C.· Other Point Source -an identifiable piece of equipment that is used as
a complete unit to accomplish a specific purpose or produce a specific
product which res·ults in an emission ·through a vent or functionally
equivalent opening excluding stacks or chimneys. Describe the particular
point source.
D. Fugitive Emissions -those emissions which could not reasonably pass
through a stack, chimney, vent or other functionally equivalent opening.
This includes ponds or lagoons which are used as reservoirs for cooling
water, wastewater, or other liquid mixtures. Routine leaks entering the
atmosphere from pipes, valves, tanks, condensers or other equipment are
also considered fugitive emissions and must be reported.
E. Other -all other emission types not identified by.A, B, C or D.
Describe the particular exhaust configuration falling within this
category.
ITEM (4) Toxic Emitted To Atmosphere
For the source, list all the toxic pollutants in 2H .0610(h) that are
emitted to the outside atmosphere .. Use additional forms as needed.
ITEM (5) Toxic Pollutant Number
List the number of the toxic pollutant as specified in 2H .0610(h). For
example the number for toluene is (98), the number for ammonia is (5).
ITEM (6) Requested Maximum Emissions
For each toxic pollutant emitted, for the time periods listed in 2H
.0610(f) list the maximum requested emission rate(s) in pounds per year,
pounds per day, pounds per hour, or in pounds per 15 minutes. Emissions
proposed are for annual periods over a calendar year, for 24-hour periods
from midnight to midnight, for one-hour periods beginning on the hour, and
for 15-minute periods beginning on the hour or 15, 30, or 45 minutes after
the hour.
ITEM (7) Calculation Method
Enter the letter(s) of the calculation method using the codes at the
bottom of the Toxic Data Form which best describes the method(s) used to
determine the emission rates in item (6).
ITEM (8) Stack or Vent Diameter
Give the inside exit diameter of the stack or vent in feet to the nearest
tenth of a foot.
• • G
pRge 3 of 3
ITEM (9) Stack or Source Height
Give the actual height in feet above the ground level of the emission
outlet. For a fugitive emission give the height from which the emissions
originate.
ITEM (10) Exit Velocity
Enter the exit velocity in feet per second for the emissions at th~
maximum operating rate. For example:
2 [Exhaust Volume (acfm)] / [Stack or Vent Area (ft)) x [min/60 sec) =
[Exit Velocity(ft/sec)]
ITEM (11) Exit Temperature
Enter the ·exit temperature in degrees Farenheit for the emissions at
the maximum operating rate.
III. MODELING PLAN REQUIREMENTS
Air toxics modeling requirements are contained in 15A NCAC 2D .1106. Applicants
submitting ambient dispersion modeling to comply with 15A NCAC 2H .0610(b) must
first submit a modeling plan to this Division and receive approval of that plan
prior to submitting the toxics modeling demonstration.
The modeling plan should include the following information:
1) A diagram of the plant site, including locations of all
existing and proposed stacks and associated buildings;
2) A list of on-site building dimensions (height, width, and
length);
3) A diagram showing property boundaries, including a scale, key
and a North indicator;
4) The location of the site on a United States Geological Survey
(USGS) map;
5) Calculation of Good Engineering Practice Stack Height for each stack;
6) Discuss all aspects of the project not accounted for in a
simple flat terrain model. These include cavity calculations,
impacts on rolling and complex terrain, building wake effects, and
urban/rural considerations;
7) Discuss reasons for model selections;
8) Discuss meteorological data to be used; and
9).Any other pertinent information.
IUAH., U/\IA ruf\l'l 4/ 1//':,U
(1) Source ID ____ _
Attach to General Information Form "A"
Division of Environmental Management
Toxic Air Permit Application G
(2) Source DescriptioA -Include ______________ _
Any Air Cleaning Equipment
(3) Exhaust Type a --------
(4) (5) (6) (8) (9) (10)
Toxic Emitted Toxic Requested Maximum Emissions Ca lcu-Stack Stack Exit to Atmosphere Pollutant
Number lb/year lb/day
a Exhaust Type:
A. Unobstructed Vertical Stack
B. Obstructed or Nonvertical Stack
Bl. Obstructed Stack
82. Nonvertical Stack
C. Other Point Source (Specify)
D. Fugitive Emissions
E. Other (Specify)
lation Diam. Height Velocity
lb/hour lb/15 min Method (ft) (ft) (ft/sec)
D Calculation Method:
A. AP-42 Emission Factor
B. EPA Document (Give document name)
C. Estimate (Attach related worksheets)
D. Materials Balance (Attach related worksheets)
E. Test Data (Attach related worksheets)
F. Other Emission Factor (Attach description)
(11)
Exit
T5mp.
( F) •
•
• ~-. (ti •
State of North .Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor
William W Cobey, Jr., Secretary
June 1 4, 1 9 91 George T Everett, Ph.D.
M E M O R A N D U M
TO: Lee Crosby, Chief
Superfund Section
Division of Solid Waste Management
Director
FROM: George T. Everett, Director b~
Division of Environmental Management
SUBJECT: Draft Feasibility Study
Carolina Transformer Superfund Site
Fayetteville, NC
Cumberland County
Project# 91-20
As requested, the subject document has been reviewed by the
Division of Environmental Management. The comments from our Water
Quality, Air Quality and Groundwater Sections are provided below:
Groundwater Section:
The proposed cleanup action appears reasonable contingent on EPA
obtaining proper pretreatment permit from PWC, and evaluating the
lower groundwater aquifer to determine contamination status.
Water Quality Section:
In the subject feasibility study, several alternatives were
examined for the remediation of groundwater including discharge
into waters of the State. For the Carolina Transformer site, the
Water Quality Section will not support a direct discharge of
wastewater to surface water due to the accessibility of Crosscreek
Waste Treatment Plant.
Asheville
704/251-6208
Fayetteville
919/486-1541
Mooresville
704/663-1699
Regional Offices
Raleigh
919/733-2314
Washington
919/946-6481
Pollution Prevention Pays
Wilmingron
919/395-3900
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affinnative Action Employer
Winston-Salem
919/761-2351
• •
Air Quality Section
The subject Feasibility Study, as it pertains to the soil
remediation alternatives, failed to address potential air quality
impacts and compliance with applicable North Carolina
Environmental Management commission air quality regulations.
Although the Environmental Protection Agency (EPA) has pronounced
that no State air permitting is required, all applicable emission
control standards including our air toxic regulation must be met.
In order for this Agency to determine if the proposed Superfund
project will comply with all applicable air quality regulations,
EPA must submit for our review and approval detailed information
regarding the air quality impacts and compliance status. The
level of detailed information should be at least as complete as is
currently required to obtain an air quality permit. For your
convenience, please find attached an air permit application form
which should assist EPA in determining the level of detail
information required for approval.
If you should have any questions or require additional
information, please contact Mr. Larry D. Coble, Winston-Salem
Regional Office at [phone].
GE/NT/kz
014A.RGE
Attachments
cc: Perry Nelson, Steve Tedder, Lee Daniel, Larry Coble,
Nargis Toma, File
North Caroli-epartment of Environment, H~a-and Natural Resources
Environmental Management Commission
AIR PERMIT APPLICATION
GENERAL INFORMATION
INSTRUCTIONS ON BACK
•To construct and operate Air. Emission Sources and Control Devices In accordance with N, C. General Statutes Chapter 143, Article 21.
A
page 1 of 1
PLEASE TYPE OR PRINT. ATTACH APPROPRIATE EMISSION SOURCE AND CONTROL DEVICE FORMS FOR EACH SOURCE
LISTED IN ITEM 6 BELOW. . .
1. Facility Name (Company, Establishment, Town, Etc.): Date FOR DEM USE ONLY
DATE RECEIVED:
2. Site Location (St./Rd./Hwy.): City Zip Code County
Latitude Longitude SIC Code
3. Mailing Address (P. 0. Box/St./Rd./Hwy.):
City State Zip Code Phone with Area Code
4. Applicant Technical Contact: Title Phone with Area Code PERMIT NUMBER:
DATE ISSUED:
5. Description of operation conducted at above facility:
6. List each EMISSION SOURCE and CONTROL DEVICE for which application is made. Assign an ID NUMBER to each emission source
and control device which uniquely identifies that source. Attach appropriate emission source and control device forms for each.
EMISSION SOURCE ID NO. CONTROL DEVICE ID NO.
USE SEPARATE SHEET(S) IF NEEDED
7. Maximum facility operation: Hours/Day Days/Week Weeks/Year
8. Name and address of engineering firm that prepared application or plans:
9. Signature of responsible person or company official:
Date --------------------------------------------Phone with Arca Code Signer's Name (TYPE OR PRINT) Title
cORM AQ-22
• APPLICATION INSTRUCTIONS
THIS APPLICATION IS NOT COMPLETE UNLESS ALL REQUIRED INFORMATION IS SUBMITTED
i, PRll'-11 0 R TYPE ONLY. FOR ASSISTANCE, Call the Air Quality Section at 1919) 733-3340 or the appropriate field office listed below:
A::h,:vl\Jc ('/V.) 2'iJ•f,~/j
','J 1,1,"lOd(in l'Jac,,
A..~ho•v i J le, IIC 2:1602
Wltu:lowS.,lca {919) 761·2JSl
802S l'ort.b l''Oint Blvd., Sult I! 100
l.'in!;lun-5,iJ,.,,., IIC T/!0(,
Nooresv1lle ("/01) 6G]-lb':19 W&shlnqtoo ('319) ()\6-£,'i,8\
9J(J North l",ajn Sl.rocl 142'\ Ca.rol1n11 Avenue
>toorn1;vill1:, NC :lflll'., Wo.:;hir,qlon, MC 2'/M9
t'oyi!ltcville (919) 486·1~1 lwhdgh ('.ll'J) "/33-2)1◄ l,liaington (919) 2~-4161
'ol!lcbovle Buil~, Suite 714
i"11yl'llcvilll', Jo'C 7.IIJO\
l'm;t Office llox I1(Jlrl
i!al,d,1h, NC 27f,ll
7225 lolright.svllJo honue
· Wiln.inglon, MC 2!\403
2. Submit TWO (2) copies of the application, engineering drawings, specificatio·ns, other supporting data and documents to your loc~l field office or ta:
N. C. DIVISION OF ENVIRONMEN'l'l\L MANAGEMENT
/\IR QlJALITY SECTION
11.I:R PERMITS HRI\NCII
POST OFFICE BOX 27687
RAI,EIGH, NORTH C'.l\ROLINA 27611-7687
3. ALL APPLICANTS MUST COMPLETE FORMS "A" ANO "0". Submit ONLY those forms that apply.
11· Al'l'l. lli\TION IS MAD[ FOR: COMPLETE THE FOLLOWING FORMS:
Cener;il Process ..
Uoilcr .
lncincr,1tor. . . . ....................... .
Woudworking Operations .............. · .......... .
P,1inting, Finishing, Spray Booths, or Printing Operations ... .
Air Pollution Control Device . . ............... .
Concrete or AsphJlt. 13atch Plant. ................... .
"A"
X
X
X
X
X
X
X
"8"
X
X
X
X
X
"C" "D" "E"
X X
X X
X X
X X
X· X X
X X
X X
"F"
X
"A" GENERAL INFORMATION "B" GENERAL DATA FOR PROCESSES OR FUEL BURNING SOURCES
"C" AIR POLLUTION CONTROL DEVICE "0" AREA DIAGRAM
"E" HYDROCARBON EMISSION SOURCES "F" INCINERATOR
4. The app!ication MUST BE SIGNED on Form "A" item 9 by a RESPONSIBLE INDIVIDUAL of the Company.
5. Because the application is not ideally suited for every conceivable operation, applicants are encouraged to submit additional information when needed to
complete the application and to provide adequate explanation of the operations.
6. Adclress compliance with applicable regulations under NEW SOURCE PERFORMANCE STANDARDS, NATIONAL EMISSION STANDARDS FOR
HAZARDOUS AIR POLLUTANTS, and PREVENTION OF SIGNIFICANT DETERIORATION"in the comments section on Form "A".
*"'**CHECKLIST****
DOES YOUR APPLICATION CONTAIN.THE FOLLOWING?
A. Signoture by a Company Official.
8. Pollutants Jlld Emission Rates Before and After Control.
C. Process Flow Oiagram(s).
0. Weight Hate of Materials Entering each Process.
E.. Cornp!etion of Form "E" if Solvents, Paints, Finishing Materials, or any Volatile Organic Compounds ara Usad.
F. Description of Emission Sourco(s) and Air Control Device(s) (Make, Model No., Efficiency, Design Criteria, etc.)
G. Completion of Forms "A" and "D".
•••TABLE OF EMISSION ESTIMATION METHOD CODES .. •
CODE
0 Not applicalilc. Emissions arc known rn be zero.
l [missions based 011 source testing.
2 Emissions based.on material balance using engineering expertise and knowledge of process.
3 Emissions calculated using emission factors from EPA publication No. AP-42 COMPILATION OF AIR POLLUTION EMISSION FACTORS.
4 J11dgement. ·
5 Emissions calculated using a special emission factor differing from that in AP-42. Specify reference in comments below.
6 Other. Specify in comments below.
COMMENTS:
•
GENERAL DATA FOR PROCESSES OR FUEL BURNING SOURCES B
page 1 of 3
NOTE: DO NOT USE THIS FORM FOR INCINERATORS, USE FORM "F".
PLEASE TYPE OR PRINT. ATTACH TO THE GENERAL INFORMATION FORM "A". IF APPLICABLE, ATTACH AIR POLLUTION
CONTROL DEVICE FORM "C". USE SEPARATE FORM FOR EACH SOURCE.
1. Emission Source and ID NO. (FROM GENERAL INFORMATION FORM "A", ITEM 6):
2. Description of Process or Fuel Burning Source Including Air Control Device:
3. Permit Application is made for (CHECK ONE ONLY):
( ) New Source ( ) Existing Source ( ) Modification -Last Permit No. _____ _
Commence Construction Date __________ , 19 __ ' Operation Date---------, 19 __
4. Maximum.Source Operation: ___ Houri/Day ___ Days/Week
5. Air Contaminants Maximum Actual Emissions ' Emission
Emitted: Before Control After Control Estimate Control
(lb/hr) (lb/hr) Method* Device**
Particulates ..... · ....
Sulfur Dioxide ........
Nitrogen Dioxide .......
Carbon Monoxide ......
Hydrocarbons (VOC) ....
Lead ...............
PM-10 .............
Other ( ) .
*REFER TO BACK OF GENERAL INFORMATION FORM "A" FOR EMISSION ESTIMATION CODE
**ATTACH AIR CONTROL DEVICE FORM "C"
6. Type of Source:
CHECK ONE
( ) A GENERAL PROCESS -Source not covered by Band C below. (Complete items 7, 8, 18 through 22)
___ Weeks/Year
Control
Efficiency %
( ) B GENERAL PROCESS WITH IN-PROCESS FUEL -Source where products of combustion contact materials heated.
(Complete items 7, 8, 9, 13, 14, 18 through 22)
C FUEL BURNING SOURCE (boilers, etc.) -Source where products of combustion are for the primary purpose of pro-
ducing heat or power by indirect heat transfer. (Complete items 9 through 22)
7. Process Operation: ( ) Continuous ( ) Batch -Normal Batch Time ______ No. Batches per Day ____ _
8. Process N,1me Max. Requested
Materials Entering Process*: Input Rates (lb/hr) Permit Input
(Include In-process Solid Fuel;) Design Actual Rates (lb/hr)
A. ·-•--
B.
C.
D.
E.
F.
G.
TOTAL WEIGHT ENTERING PROCESS
*DO NOT LIST ANY VOLATILE HYDROCARBONS, USE HYDROCARBON EMISSION SOURCES FORM "E"
•
DATA FOR PROCESSES OR FUEL BURNING SOURCES -continued B
page 2 of 3
9. Type of Fuel Burning Source:
( ) Industrial Boiler ( ) Institutional/Residential Boiler ) Electric Utility Boiler ( ) Process Burner(s)
( ) Other---------·----------Make and Model No. ___________ _
10. Type of Solid Fuel Burning Equipment Used:
( ) Hand Fired ( ) Overfeed Stoker
( ) Spreader Stoker ( ) Traveling Grate
( ) Underfeed Stoker ( ) Shaking Grate
( ) Other (specifiy L
( ) Pulverized
( ) Wet Bed
( ) Dry Bed
11. Is collected flyash reinjected? ( ) NO ( ) YES Percent Reinjected _______ _,•,,
Combustion Air: Percent Excess Air _____ _,0o ( ) Natural ( ) Induced
Specify method and schedule of tube cleaning:
( ) Lancing ( ) Tube Blowing ) Other _________ Schedule __________ _
12. Boiler Horsepower Rating ________ _ Boiler Steam Flow (lb/hr) ________________ _
I
13. Fuel Burning Source Heat Input: Maximum ______ Million BTU/hr Average ______ Million BTU/hr
14. Ft1el Data: Primary Fuel Typc(s) (specify)---------------------------
Standby Fuel Type(s) (specify) --'--------------------------
FUEL TYPE FUEL USAGE Max.% Max.%
Max. Design Max. Actual Annual Sulfur Ash BTU Value
(gal/hr) (gal/hr) (gal/yr) (BTU/gal)
#6 Fuel Oil
(gal/hr) (gal/hr) (gal/yr) (BTU/gal)
#5 Fuel Oil
(gal/hr) (gal/hr) (gal/yr) (BTU/gal)
#4 Fuel Oil
(lb/hr) (lb/hr) (ton/yr) (BTU/lb)
Coal
(lb/hr dry) (lb/hr dry) (ton/yr dry) (BTU/lb)
Wood RMQ
Other
15. If a combination of fuels is used, specify the maximum BTU/hr heat input for each:
Fuel Oil ________ Coal ________ Wood ________ Other __________ _
16. Total maximum heat input in million BTU/hr of all indirect fired fuel burning sources within property boundaries excluding that
indicated above:
Fuel Oil _______ _ Coal _______ _ Wood ________ Other __________ _
17. Total No. of indirect fired fuel burning sources within property boundaries:
Fuel Oil ________ Coal________ Wood ________ Other __________ _
18. Arc there any fugitive emissions (storage piles, product handling, haul roads, etc.)? No ( ) Yes ( )
comments below, the type, size, estimated emissions and control measures.
19. Descr.ibe any liquid or soli_d wastes generated and method of disposal:
If yes, please describe in
• •
DATA FOR PROCESSES OR FUEL BURNING SOURCES -continued B
20. Stack or Emission Point Data:
Height Above Ground (ft.)
Volumetric Flow Rate
· (ACFM)
Inside Area (sq. ft.)
Velocity (ft./sec.)
Is scaffolding available for source testing?
( ) No ( ) Yes
Gas Temperature ( Deg. F)
Are sampling ports available?
( ) No ( ) Yes
page 3 of 3
Direction of Exit
(up, down or horizontal)
Is rain cap or other obstruction over
stack?. ( ) No ( ) Yes, (specify)
Stack ID No. _________ -Sources with a common
stack will have the same stack number.
21. Indicate monitoring and recording instruments installed on stack:
( ) Opacity Monitor ( ) SO2 Monitor ( ) NOx Monitor ) Other _________________ _
22. Attach_ or sketch a flow diagram of the process or fuel burning source. Include air control device(,). (SEE INSTRUCTIONS ON
BACK OF THIS PAGE):
23. Comr:nents:
• •
INSTRUCTIONS
FLOW DIAG.RAM FOR PROCESSES OR FUEL BURNING SOURCES
INCLUDING AIR CONTROL DEVICES
Draw a complete flow diagram of the process or fuel burning source including air control device{s). Indicate all equipment, niass flow of
material, locatio~ of direct heating, ·inlet and outlet temperatures, and air flow rates. Give flow rates for water used either as cooling or
as scrubbing. Indicate pollutant collected and emissions exhausted to the atmosphere. If a solvent or a mix of solvents, inks, paints or
other volatile liquid mixes are used, complete the Hydrocarbon Emission Sources Form. "E". All materials entering this process should
appear in item 8, page 1.
FOR EXAMPLE:
UNO &NO
AG;t!Ull IIIIS 2
COLD A&CRI CA Tl
IUClll ll!VIIOR
HOT &CGR(GA I(
BUCUT H[UIOR
7.
MIXER
flow diagrilll of a typical hot-mix asphalt paving batch plant.
1. Rock, gravel, sand, fines, etc. -200,000 lbs/hr or 100 tons/hr.
2. Rock, gravel, sand, fines, etc. -200,000 lbs/hr or 100 tons/hr.
3. Dry aggregate -199,000 lbs/hr or 99.50 tons/hr.
4. 30,000 CFM@ 180° F; 1,000 lbs/hr particulate entering cyclone; 80% cyclone efficiency·.
5. 800 lbs/hr returned to dry aggregate.
6. Dry aggregate entering vibrating screens -199,800 lbs/hr.
7. 30,000 CFM@ 180° F; particulates to scrubber -200 \bs/hr.
8. Water 200 GPM; scrubber efficiency -90%.
9. 28,000 CFM @ 140° F; particulate emissions to atmosphere -20 lbs/hr.
10. Asphalt production 219,800 lbs/hr or 109.9 tons/hr.
SIACJ
9
i
~·~~BBL• t I
I I D-
• •
AIR POLLUTION CONTROL DEVICE C
page 1 of 3
PLEAS!: TYPE OR PRINT. ATTACH TO GENERAL INFORMATION FORM "A". SUPPLY DESIGN DATA, SPECIFICATIONS, AND
AVAILAl3LE EN(;INEERING DRAWINGS.
1. Air Control Device and ID No. (FROM GENERAL INFORMATION FORM "A", ITEM 6)
2. If there arc ~('ver,11 ch·viccs in scrit·s, list each unit in series starting at the emission source.
( I) (2) -TOTAL UNITS .. ---·--........... _···----·-
3. lndicc1tr Emission Source and ID No. that Control Devicc(s) is installed on:
4. NJrrativl' Description of Control Devicc(s):
Manufacturer
5. Estimated Cost of Control Device
$.. ...
6. Permit Application is made for (CHECK ONE ONLY):
M.odel Name Model Number
Period of Time Control Device is Estimated to be Adequate:
____ Years
( ) New Source ( ) Existing Source ( ) Modification -Last Permit No. ___________ _
Commence Construction Date----------, 19 __ _ Operation Date---------, 19 ____ __
7. Emission Parameters:
Pollutant(s) Controlled
Emission Rate Before Control (lb/hr) =
Emission Rate After Control (lb/hr) =
Removal Efficiency Percent(%) =
PART.
( )
co
( )
voe
( )
LEAD OTHER
( )
OTHER
Particle Size Distribution of Particulates Entering Control Device(% Micron):
___ ].JO ___ 10·25 ___ 25.50 ___ 50.100 ____ Over 100
8. Gas Conditions at Control Device: INLET INTERMEDIATE LOCATIONS OUTLET
Flow Rate (ACFM) =
Temperature (Deg. F) =
Velocity (ft./sec.) =
Pressure Drop (in. H20) =
Moisture(%) =
9. Describe Ultimate Disposal of Collected Materials:
10. Stack or Emission Point Data:
Direction of Exit Height Above
Ground (ft.)
Inside Area
(sq. ft.) (up, down, or horizontal)
Are there obstructions over the stack?
( ) No ( ) Yes, (specify)
Is !>Clflolding avai1;_1ble for sources testing?
( ) No ( ) Yes
11. Comments:
Are sampling ports available?
( ) No ( ) Yes
12
• •
SUPPLEMENTAL UATA FOR AIR CONTROL DEVICES
'** "CYCLONE" (MECHANICAL SEPARATORS)***
C
page 2 of 3
Efficiency(%) Volumetric Flow Pressure Drop (in. H20) Baffles or Louvers (specify) Position in Series
Rate (ACFM) # of ____ Units
------------------
Cyclone Dimensions (inches) Cyclone Body Diameter Cyclone Body Height (ft.) Cyclone Cone Height (ft.)
Inlet Outlet (inches) . ----------· l ---I % Recirculated Wet Spray No. of Nozzles Liquid Used (specify) Flow Rate (GPM) Makeup Rate (GPM)
( ) No ( ) Yes
A process flow diagram must be attached If cyclone is routed to another cyclone or· other equipment, show sketch of entire system.
CYCLO~lE O!bG~A.11
CHECK APPROPRIATE OUTLET CCt/F IGUR~ TION BE LCW SKETCH OTHER
CONFIGURATION
ON O!AGRA11 DUCT
Below
INLET
DIMENSION -1------...J.
13 ••• "MUL TICYCLONE" •••
Efficiency (%) Volumetric Flow No. of Cones Pressure Drop (In. H20) Position in Series
Rate (ACFM) # of
Louvers Inlet Dimension of Individual Outlet Dimension of Individual Individual Cyclone
( ) No ( ) Yes Cyclone (inches) Cyclone (inches) Diameter (inches)
14 ••• "FILTRATION" (BAGHOUSE) •••
Efficiency (%) Volumetric Flow Filter Surface Air-to-Filter Area Ratio Pressure Drop (in. H20)
Rate (ACFM) Area (sq. ft.) (ft./min.)
.
leOOY
I HEIGHT
IC0NE
I HEIGHT
Units
Inlet Temperature
(Deg. F)
TYPE OF FILTER Fil TER MATERIAL BAG CLEANING
( ) Fabric Filter (BAGHOUSE) ( ) Fiberglass ( ) Nylon ( ) Mechanical ( ) Sonic
( ) Packed Bed ( ) Mat Filter ( ) Nomex ( ) Teflon ( ) Reverse Flow ( ) Air Pulse
( ) Panel Filter ( ) Wool ( ) Dacron ( ) Simple Bag ( ) Ringed Bag
( ) Other ( ) Cotton ( ) Orlon Collapse Collapse
( ) Other ( ) Other
No. of Compartments Position in Series Time Between Cleaning
(mins./hr.)
Inlet Temperature
(Deg. F) # _____ of _____ Units
15 ••• "AFTERBURNER" (FUME INCINERATOR)•••
Type of Afterburner: Efficiency(%) Volumetric Flow Position in Series
( ) Direct Flame Rate (CFM) # of Units ( ) Catalytic
( ) Other
Maximum Burner Rating Combustion Chamber Retention Time Fuel Type
(Million BTU/hr) Temp. (Deg. F) (sec.) Usage
Comhustion Chamber Dimensions (ft.): _______ Length _______ Diameter
• •
SUPPLEMENTAL DATA FOR AIR CONTROL DEVICES -continued C
page 3 of 3
16. •••"SCRUBBER"•••
Type of Scrubber: Efficiency(%) Volumetric Flow Position in Series
( ) Venturi ( ) Orifice Type Rate (ACFM) # of
( ) Impingement Plate ( ) Cyclonic
( ) PJckcd Tower ( ) Condenser
( I Gravity Tower ( ) Other Pressure Drop Inlet Temperature Mist Eliminator Filter Area
( ) Mi~t Eliminator (in. H20) (Deg. F) (sq. ft.) -----------· ------r -I ' Gas Flow Liquid Scrubbing Medium 1 Total Liquid Injection (GPM) Make Up Rate (GPM)
( ) Countercurrent and Additives (specify) I ( ) Concurrent ;
-➔---l Throat Area (sq. in.) Venturi Inlet Arca (sq. in.) Throat Velocity (ft./sec.} ( ) Fixed Throat
Scrubber I ( ) Variable Throat
Data: I --------·------
Packed or Surface Area (sq. ft.) Packing Depth (ft.} Type of Packing: No. of Plates Type of Plates
Plate Tower ( ) Rings ( ) Saddles
Data: ( ) Other
-------_ _. _______ -
17. ••• "ELECTROSTATIC PRECIPITATOR" •••
Efficiency(%) Volumetric Flow Rate (CFM) Total Collection Plate Pressure Drop I nlct Temperature
Area (sq. ft.) (in H20) (Deg. F)
---
Resistivity of Gas Viscosity (poise) Charging Field Strength (volts) Collecting Field Strength (volts)
Pollutant (OHM-CM)
CLEANING METHOD
( ) Single Stage
( ) Two Stage
PRECIPITATOR TYPE
( ) Low Voltage
( ) High Voltage
( ) Hot Side
( ) Cold Side
( } Plate Rapping ( ) Washing
( } Plate Vibrating ( ) None
( ) Other ___________ _
Corona P
(Watts/1
ower Electrical Usage (kw./hr.)
000 cfm)
18.
Type of Adsorption:
( ) One-Pass Regenerative ( ) Recirculating
( ) One-Pass Nonregenerative ( ) .Other
Regenerative Method:
( ) Other ___________ _
No. of Compartments No. of Cells/Comp. Position in Series
# of
•••"ADSORPTION"•••
Efficiency (%) Volumetric Flow Rate (ACFM)
Adsorption Material: Position in Series
Units
---
Units
( ) Discarded ( ) Thermal (dry heat} ( ) Activated Carbon # of Units ( ) ( ) Thermal (steam) ( ) Hydrous Silicated Chemical
( ) Other ( ) Other
Pressure Drop Inlet Temperature No. of Compartments How are emissions controlled·during
(in H20) (Deg. F) reg'.!neration?
-----·-··-·-· -·--·-
Si,e of Adsorbent Bed (ft.)
Length _._....:.. _______ =-=-=-.:._:..'.'.'.''_'.__::=======:_'__.'...'.:~.'..'_:=======:::....~:'.'.."~'.....:========-, Width __ Height , Diameter ________ _
Regenerative Schedule: Maximum Time for Desorption--------'------------------
Length of Time to Maximum Saturation _____________________ _
• •
AREA DIAGRAM D
page 1 of 1
Show dll surrounding buildings ,md roads within 1 S00 feet of the equipment covered by this application. Attach a site diagram identify-
Ing c•ch emission source location(s), property boundaries and building (structure) dimensions (height, width, and length).
1500 feet
1000 feet
500 feet
INSTRUCTIONS
1. Indicate location and type of building by the use of small
numbered circles with the decription below.
2. Show roads as lines representing the road edges. Indicate
_street names and highway numbers.
3. Show wooded or cleared area by approximate bouridary
lines and the words "woods'\ "cleared''. 0 cornfield", etc.
X
CODE
( 1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
Example:
DESCRIPTION
( 1) Church
(2) Residence
• •
HYDROCARBON EMISSION SOURCES E
page 1 of 2
NOTE: For emission sources of volatile organic compounds including spray booths, painting, finishing, printing and solvent usage.
PLEASE TYPE OR PRINT. ATTACH TO THE GENERAL INFORMATION FORM "A". IF APPLICABLE, ATTACH AIR POLLUTION
CONTROL DEVICE FORM "C".
1. Emission Source and ID NO. (FROM GENERAL INFORMATION FORM "A", ITEM 6)
2. Process Description (INDICATE NO. OF IDENTICAL PROCESSES -BOOTHS, FINISHING LINES, ETC.):
3. Permit Application is made for (CHECK ONE ONLY):
( ) New Source ( ) Existing Source ( ) Modification -Last Permit No. ________ _
Commence Construction Date---------, 19 __ Operation Date---------, 19 __ _
4. Maximum Source Operation: ____ Hours/Day ____ Days/Week ____ Weeks/Year
5. List all VOLATILE ORGANIC COMPOUNDS as used: USE NEXT PAGE (PRODUCT ANALYSIS WORKSHEET) TO DETERMINE
IF PRODUCT IS REACTIVE (R) OR NONREACTIVE (NR) AS DEFINED BY 15 NCAC 2D .0518.
TOTAL voe
PRODU_CT PRODUCT VOLATILE EMISSION
WEIGHT USAGE BY WEIGHT RATES
PRODUCT NAME R NR (lb/gal) (gal/day) X (lb/gal) = (lb/day) (ton/yr)
•--------~------X =
-··-------·~·------X =
X = ---------------
----X =
. -------·-------X =
----X =
X = ------·· ----
----X =
USE SEPARATE SHEET(S) IF NEEDED TOTAL =
6. Describe the storage and handling methods used in employing the organic products listed above. Include the ultimate disposal methods
of the collected waste and wastewater. -------------------------------
7. Surface Coating Operations:
Describe Articles Being Coated: ---------------------------------
---------
Method of Spray: Overspray (%) Stack Flow ( ) Airless ( ) Air Atomize ( ) Electrostatic ( ) Other Rate (CFM)
-·-·
Exhaust ( ) None ( ) Dry Filter ( ) Adsorption Control Efficiency
Control: ( ) Waterwash ( ) Baffles ( ) Incineration Particulate % ( ) Other Hydrocarbon % -----
No. of Bake Ovens Method of ( ) Steam ( ) Direct Fired Fuel Type
Heating: ( ) Electric ( ) Other Usage
8. Solvent Degreasing Operations:
Describe Articles Being Degreased: -------------------------------
Degreaser Type:
( ) Open Top Vapor ( ) Cold Cleaning ( .) Conveyorized ( ) Other _________________ _
Tank Capacity
(gallons)
Makeup Rate
(gallons/day)
Exhaust Control: ( ) None ( ) Surface Condensers
( ) Adsorption ( ) Closed Loop ( ) Other _________ _
• •
PRODUCT ANALYSIS WORKSHEET
(SOL VENTS, PAINTS, FINISHING MATERIALS, ETC.) E
page 2 of 2
INSTRUCTIONS: COMPLETE ONE SHEET FOR EACH TYPE OF PRODUCT. GIVE CHEMICAL NAMES, NOT BRAND NAMES OR
ABBREVIATIONS. FOLLOW THESE PROCEDURES IN DETERMINING WHETHER OR NOT A PRODUCT OF VARIOUS
SOLVENTS IS REACTIVE (R) OR NONREACTIVE (NR).
A) GROUP THE CONSTITUENTS ACCORDING TO WHETHER OR NOT THEY FIT THE DESCRIPTION IN CLASS (1). (2).
(3) OR NONE OF THE ABOVE CLASSES. IF A CONSTITUENT COULD FALL IN TWO GROUPS, IT IS PLACED IN THE
MORE LIMITED GROUP.
B) DETERMINE THE VOLUME PERCENT OF ALL LIQUID CONSTITUENTS OF THE PRODUCT AS APPLIED. (THIS SHOULD
TOTAL 100%.)
C) TOTAL THE VOLUME PERCENT FOR EACH CLASS (1, 2, AND 3). IF THE VOLUME PERCENT FOR ANY CLASS
EXCEEDS THE PERCENT LIMIT FOR THAT CLASS OR IF THE TOTAL FOR CLASSES (1). (2). (3) EXCEEDS 20 PERCENT,
THEN THE PRODUCT IS REACTIVE. IF NONE OF THESE LIMITS ARE EXCEEDED, THE PRODUCT IS NONREACTIVE.
Product Name Product No. This Product is Classified as:
( ) Reactive (R) ( ) Nonreactive (NR)
PRODUCT COMPOSITION
ORGANIC
CLASS DESCRIPTION OF ORGANIC CLASS NAME OF CONSTITUENTS
A COMBINATION OF HYDROCARBONS, ____________ _
ALCOHOLS, ALDEHYDES, ESTERS, OR
( 1) KETONES HAVING AN OLEFIN IC OR
CYCLOOLEFINIC TYPE OF UNSATURA-____________ _
(2)
(3)
TION EXCEPT PERCHLOROETHYLENE
·· 5 PERCENT
A COMBINATION OF AROMATIC
HYDROCARBONS WITH EIGHT OR
MORE CARBON ATOMS TO THE
MOLECULE EXCEPT ETHYLBENZENE
-8 PERCENT
. A COMBINATION OF ETHYLBENZENE,
KETONES HAVING BRANCHED
HYDROCARBON STRUCTURE,
TRICHLOROETHYLENE, OR
TOLUENE
-20 PERCENT
ALL SOLVENTS NOT LISTED ABOVE
SUB-TOTAL=
SUB-TOTAL=
SUB-TOTAL=
Product Usage (gal/hr) __________ -------------
Product Weight (lb/gal) _________ _ TOTAL=
Weight of volatiles in product (lb/gal) _____ _
Total% volatiles by volume in product ______ %
% BY VOLUME OF THE
TOTAL VOLATILES
ACTUAL % LIMIT
5%
8%
20%
100%
IF THE TOTAL REACTIVE PRODUCT_ EMISSIONS. EXCEED 40 POUNDS/DAY FROM YOUR FACILITY, DESCRIBE THE
CONTROL·METHODS EMPLOYED FOR MEETING COMPLIANCE WITH DEM REGULATION 15 NCAC 2D .0518:
• •
INCINERATOR F page 1 of 2
PLEASE TYPE OR PRINT. ATTACH TO THE GENERAL INFORMATION FORM "A". IF APPLICABLE, ATTACH AIR POLLUTION
CONTROL DEVICE FORM "C".
1. Emission Source and ID NO. (FROM GENERAL INFORMATION FORM "A", ITEM 6):
2. Incinerator Description:
Manufacturer Model Name Model Number
3. Permit Application is made for (CHECK ONE ONLY):
( ) New Source ( ) Existing Source ( ) Modification -Last Permit No. ________ _
Commence Construction Date------------, 19__ Operation Date---------, 19 __
4. Maximum Source Operation:
5. Type of Waste Burned:
(See codes on next page)
____ Hours/Day
Maximum Charging Rate (lb/hr)
Design I Actual
____ Days/Week ____ Weeks/Year
Tons/Year Burned Total Waste Generated (lb/day)
6. Combustible __ % Noncombustible __ % Moisture __ % Heat Value _______ (BTU/lb)
7. Primary Chamber: Secondary Chamber: Secondary Chamber Type of Feed
Volume cu. ft. Volume cu. ft. Retention Time: ( ) Manual
Seconds ( ) Automatic Temperature OF Temperature OF
8. Burner Data: BURNER RATING (BTU/HR) AIR FLOW (CFM) Excess Air(%)
Primary
I
Secondary Overfire I Underfire
9. Is there a preheat timer? ( ) No ( ) Yes, Preheating Time _________ Min.
10. Auxiliary Fuel Data: Primary Fuel Type(s) _______________________ _
11.
Secondary Fuel Type(s) _______________________ _
FUEL TYPE FUEL USAGE Max.% Max.%
Max. Design Max. Actual Annual Sulfur Ash
(SCF) (SCF) (SCF/yr)
Natural Gas --(gal/lu) (gal/hr) (gal/yr)
#2 Fuel Oil
Other
Air Contaminants Maximum Actual Emissions Emission
Emitted: Before Control After Control Estimate Control
(lbs/hr) (lbs/hr) Method* Device**
Particulates ........
Sulfur Dioxide ......
Nitrogen Dioxide .....
Carbon Monoxide ....
Hydrocarbons (VOC) ..
Lead .. ...... . . . . .
Other ( ) .
Other ( ) ...
*REFER TO BACK OF GENERAL INFORMATION FORM "A" FOR EMISSION ESTIMATION CODE
"ATTACH APPROPRIATE AIR CONTROL DEVICE FORM "C"
BTU Value
(BTU/SCF)
(BTU/gal)
Control
Efficiency%
• • •
INCINERATOR -continued F
page 2 of 2
12. i.>rScribc ,my liquid or solid wastes generated and method of disposal:
13. Stack or Emission Point Data:
Height Above Ground (ft.) Inside Arca (sq. ft.) Gas Temperature (Deg. F) Direction of Exit
(up, down, or horizontal)
Volumetric Flow Rate
(ACFM)
Velocity (ft./sec.) Are sampling ports avai_lable?
( ) No ( ) Yes
ls rain cap or other obstruction over
stack? ( ) No ( ) Yes, (specify)
14. Is a RCRA permit required by the N. C. Department of Human Resources? ( ) No ( ) Yes
If yes, has a RCRA permit application been submitted? ______ Date ____________ , 19 __ _
15. List ALL incinerated HAZARDOUS WASTE specified in the RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
(40 CFR 261) in the commentssection below:
16. Comments:
CODE
0
2
3
4
5
6
••• TYPE OF WASTE BURNED CODE TABLE•••
Principal components, usual source, and typical moisture content
Highly combustible waste, paper, wood, cardboard cartons, (including up to 10% treated paper.;, plastic or rubber scraps);
from commercial and industrial sources; 10% moisture.
Combustible waste, paper, cartons, rags, wood scraps, combustible floor sweepings; from domestic, commerciaJ, and indus-
trial sources; 25% moisture.
Rubbish and garbage; from residential sources; 50% moisture.
Predominantly animal and vegetable waste; from restaurants, hotels, markets, institutional, commercial and club sources;
70% moisture.
·carcasses, organs, solid organic wastes; from hospitals, laboratories, slaughterhouses, animal pounds, and similar sources;
85% moisture.
Gaseous and semi-liquid industrial prOCess waste; variable moisture. Describe in detail under comments.
Solid and semi-solid by-product waste, such as rubber, plastics, wood waste, etc., from industrial operations; variable
moisture. Describe in detail under comments.
·. • •
AIH TOXICS Al'l'LICATJON FORM
AlTACHEIJ ARE THE FOLLOWING:
1. Toxics Data Form (TDF)
2. AJr Toxics Regulations JSA NCAC 21) . 1100 and 211 .0610
!. GENERAL INSTRUCTIONS
page I of 3
1,/17/90
This section must be completed for facilities required to obtain a toxic air permit by EMC regulation 15A NCAC 2H .0610 and for facilities who emit one or more of the regulated air toxics listed in isA NCAC 2H . 0610(h): As specified in 15A NCAC 2H .0610, if facility wide emissions for a listed toxic is above the amounts listed in 15A NCAC 2H .0610(h), then a toxic air permit is required. Specific exemptions from toxic air permitting are contained in 15A NCAC 2H .0610.
The attached Toxics Data Form (TDF) must be completed for each air emissions source that emits a listed air toxic pollutant. Include listed air toxic emissions from stacks, vents, chimneys, processes, and fugitive sources. Propose maximum emissions for the listed toxics in 15A NCAC 2H .0610(h) that are emitted by the source. The source ID NO. must correspond to the source ID NO. on item 6 of Form A. For assistance in completing this form please contact the approriate DEM field office listed on the back of Form A.
To comply with 15A NCAC 2H .0610(b), for each listed air toxic emitted from the entire facility in excess of the amounts listed in 15A NCAC 2H .0610(h), air dispersion modeling is required as part of the toxic air permit application. Prior to submitting the modeling, the modeling plan must be submitted by the applicant and approved by this Division. Section III of this form lists items needed in a modeling plan. Applicants applying under the provisions of 15A NCAC 2H .0610(b)(2) or (c) should contact the Air Quality Section to discuss specific requirements and the information needed for a compliance
determination.
II. COMPLETING THE ATTACHED TOXIC DATA FORM
Complete a separate form for each air emission source emitting a listed air toxic pollutant. Form data items are described as follows:
ITEM (1) Source ID
Use the same source identification number as assigned on item 6 of Form A of the AQ-22.
ITEM (2) Source Description
List the source type such as incinerator, spray booth, coal boiler, or storage tank. Include air cleaning devices if applicable.
ITEM (3) Exhaust Type
Enter the exhaust configuration of the emission source using the codes at the bottom of the Toxic Data Form. For the purposes of this application the following definitions apply:
A. Unobstructed Vertical Stack or Chimney· any point in a source designed to nmit solids, liquids or gases into the air, including a pipe or a duct but ,,ot including flares and that ls constructed in a vertical direction
nn<l is vold of restrictive ohstructi.ons, e.g., rnin caps.
ITEM
• • G
page 2 0 r 3
H. Obstructed or Nonvcrtlcal Stack or Chimney -any poi11t In a source designed to emit solids, liquids or gases into the air, including a pipe or a duct but not including flares and that is either constructed in
a nonvertical direction or has a restrictive obstruction, e.g., rnJn caps.
C. Other Point Source -an identifiable piece of equipment that is used as a complete unit to accomplish a specific purpose or produce _a specific product which results in an emission through a vent or functionally equivalent opening excluding stacks or chimneys. Describe the particular
point source.
D. Fugitive Emissions -those emissions which could not reasonably pass through a stack, chimney, vent or other functionally equivalent opening. This includes ponds or lagoons which are used as reservoirs for cooling water, wastewater, or other liquid mixtures. Routine leaks entering the atmosphere from pipes, valves, tanks, condensers or other equipment are also considered fugitive emissions and must be reported.
E. Other -all other emission types not identified by_A, B, C or D.
Describe the particular exhaust configuration falling within this
category.
(4) Toxic Emitted To Atmosphere
For the source, list all the toxic
emitted to the outside atmosphere.
pollutants in 2H .0610(h) that are
Use additional forms as needed.
ITEM (5) Toxic Pollutant Number
List the number of the toxic pollutant as specified in 2H .0610(h). For example the number for toluene is (98), the number for ammonia is (5).
ITEM (6) Requested Maximum Emissions
For each toxic pollutant emitted, for the time periods listed in 2H .0610(f) list the maximum requested emission rate(s) in pounds per year, pounds per day, pounds per hour, or in pounds per 15 minutes. Emissions proposed are for annual periods over a calendar year, for 24-hour periods from midnight to midnight, for one-hour periods beginning on the hour, and for 15-minute periods beginning on the hour or 15, 30, or 45 minutes after the hour.
ITEM (7) Calculation Method
Enter the letter(s) of the calculation method using the codes at the bottom of the Toxic Data Form which best describes the method(s) used to determine the emission rates in item (6).
ITEM (8) Stack or Vent Diameter
Give the inside exit diameter of the stRck or vent in feet to the nearest tenth of a foot.
• •
pnge 3 or J
ITEM (9) Stack or Source !!eight
Give the actual height in feet above the ground level of the emission outlet. For a fugitive emission give the height from which the emissions
originate.
ITEM (10) Exit Velocity
Enter the exit velocity in feet per second foe the emissions at the maximum operating rate. For example:
2 [Exhaust Volume (acfm)] / [Stack or Vent Area (ft )] x [min/60 sec]=
[Exit Velocity(ft/sec)]
ITEM (11) Exit Temperature
Enter the ·exit temperature in degrees Farenheit for the emissions at the maximum operating rate.
III. MODELING PLAN REQUIREMENTS
Air toxics modeling requirements are contained in 15A NCAC 2D .1106. Applicants submitting ambient dispersion modeling to comply with 15A NCAC 2H .0610(b) must first submit a modeling plan to this Division and receive approval of that plan prior to submitting the toxics modeling demonstration.
The modeling plan should include the following information:
1) A diagram of the plant site, including locations of all
existing and proposed stacks and associated buildings;
2) A list of on-site building dimensions (height, width, and length);
3) A diagram showing property boundaries, including a scale, key and a North indicator;
4) The location of the site on a United States Geological Survey (USGS) map;
5) Calculation of Good Engineering Practice Stack Height for each stack; 6) Discuss all aspects of the project not accounted for in a simple flat terrain model. These include cavity calculations, impacts on rolling and complex terrain, building wake effects, and urban/rural considerations;
7) Discuss reasons for model selections;
8) Discuss meteorological data to be used; and
9).Any other pertinent information.
( 1) Source ID
JUA1l. UAIA 1-UKM
Attach to General Information Form "A"
Division of Environmental Management
Toxic Air Permit Application
4/ l!/~U
G
(2) Source Descriptio~ -Include _______________ _
Any Air Cleaning Equipment
(3) Exhaust Type a ---------
(4) (5) (6) (8) (9) (10)
Toxic Emitted Toxic Requested Maximum Emissions Calcu-Stack Stack Exit to Atmosphere Pollutant
Number 1 b/year lb/day
a Exhaust Type:
A. Unobstructed Vertical Stack
B. Obstructed or Nonvertical Stack
Bl. Obstructed Stack
B2. Nonvertical Stack
C. Other Point Source (Specify)
D. Fugitive Emissions
E. Other (Specify)
lation Diam. Height Velocity
lb/hour lb/15 min Method (ft) (ft) (ft/sec)
bCalculation Method:
A. AP-42 Emission Factor
B. EPA Document (Give document name)
C. Estimate (Attach related worksheets)
D. Materials Balance (Attach related worksheets)
E. Test Data (Attach related worksheets)
F. Other Emission Factor (Attach description)
( 11)
Exit
T®mp.
( F)
' ••
•
•
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor
William W Cobey, Jr., Secretary
June 1 4, 1 9 91 George T Everett, Ph.D.
M E M O R A N D U M
TO:
FROM:
SUBJECT:
Lee Crosby, Chief
Superfund Section
Division of Solid Waste Management
l"" George T. Everett, Director 11,.J..._~
1J Division of Environmental Management
Draft Feasibility Study
Carolina Transformer Superfund Site
Fayetteville, NC
Cumberland County
Project# 91-20
Director
As requested, the subject document has been reviewed by the
Division of Environmental Management. The comments from our Water
.Quality, Air Quality and Groundwater Sections are provided below:
Groundwater Section:
The proposed cleanup action appears reasonable contingent on EPA
obtaining proper pretreatment permit from PWC, and evaluating the
lower groundwater aquifer to determine contamination status.
Water Quality Section:
In _the subject feasibility study, several alternatives were
examined for the remediation of groundwater including discharge
into waters of the State. For the Carolina Transformer site, the
Water Quality Section will not support a direct discharge of
wastewater to surface water due to the accessibility of Crosscreek
Waste Treatment Plant.
Asheville
704/251-6208
Fayetteville
919/486-1541
Mooresville
704/663-1699
Regional Offices
Raleigh
919/733-2314
Washington
919'946-0481
Pollution Prevention Pays
Wilmington
919/395-3900
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
Winston-Salem
919/896-7007
• •
Air Quality Section
The subject Feasibility Study, as it pertains to the soil
remediation alternatives, failed to address potential air quality
impacts and compliance with applicable North Carolina
Environmental Management commission air quality regulations.
Although the Environmental Protection Agency (EPA) has pronounced
that no State air permitting is required, all applicable emission
control standards including our air toxic regulation must be met.
In order for this Agency to determine if the proposed Superfund
project will comply with all applicable air quality regulations,
EPA must submit for our review and approval detailed information
regarding the air quality impacts and compliance status. The
level of detailed information should be at least as complete as is
currently required to obtain an air quality permit. For your
convenience, please find attached an air permit application form
which should assist EPA ii determining the level of detail
information required for approval.
If you should have any questions or require additional
information, please contact Mr. Larry D. Coble, Winston-Salem
Regional Office at [phone].
GE/NT/kz
014A.RGE
Attachments
cc: Perry Nelson, Steve Tedder, Lee Daniel, Larry Coble,
Nargis Toma, File
• .................. #'.•·,_. 51AT( <• ......... . . ·· " .. ., ..• ""°" 1 <f' r-",) ,~A f >1 ,. "-.,., f' ;.;j•-1~•""' ~t 35 .f\l ~' ./· :-. ~~ ,;\ ·11' . . 2, -~~•.:, :.· 'i'J .... ,, ,,.. . '(' ~
State of North Carolina
•
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. Michael Townsend
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
April 5, 1991
Subj: Carolina Transformer NPL Site
Fayetteville, Cumberland County
William L. Meyer
Director
Comments on the March 4, 1991 Draft Feasibility Study
Dear Mr. Townsend:
The NC Super fund Section appreciates this opportunity to
comment on the Draft Feasibility Study. We offer the following
comments:
1. Page 1-3, Section 1. 3. The North Carolina Groundwater
Standards should be included as one of the most important
ARAR' s governing the remediation at this site ..
2. Tables 1-2; 1-3, and 1-4. It would greatly enhance the
usefulness of these tables to include another column titled
"Total Rating" which would contain the sum of the individual
criteria ratings. Also, in Table 1-2, the present worth cost
of Alternative G-3A is presented as $87,500 which appears to
be a misprint since other similar alternatives presented cost
at least 10 times this amount. ·
3. Table 1-4. These alternatives for the structures and debris
are not discussed in Section 1.3. For instance, what is the
difference between the "A" alternative and the 11 B11 alternative
for the structures and debris media. For other media, the "A"
and "B" alternatives are discussed in the text and a footnote
is placed on Tables 1-2 and 1-3 to explain them further. This
approach should also be used for the structures and debris
alternatives.
4. Figure 2-1. A scale is needed on this Figure.
•
Townsend Letter,
3-27-91,
page 2
•
5. Figure 2-2. This Figure should parallel the discussion of the
site on Page 2-2. For clarity and understanding all of the
site features discussed in Section 2.2 should be .labeled on
Figure 2-2. For example, where are the homes and agricultural
field to the north, and where is Lundy Packing Co.? What is
the site boundary? Is the site boundary the fenceline and
what about those sides of the site that are not fenced?
6. Page 2-5. Lead.levels ranging from 18 to 190 ug/liter in the
aquifer surrounding the site are mentioned. However, the
report goes on to state that it is "uncertain whether lead
levels in groundwater are associated with current or previous
conditions at the site." The State would like further
clarification on what this statement means. We note that
that the groundwater extraction wells proposed for the cleanup
are located strictly on the Carolina Transformer property
whereas the 5 permanent monitoring wells which contained lead
are a considerable distance of the Carolina Transformer
property. We can only assume that the lead in the groundwater
in the area of these 5 wells will be left unremediated. Is
this EPA's intent? If so, before the State would approve of
such an action, the State would like evidence that the
Carolina Transformer site is not the source of lead in the
monitoring wells. This same comment goes for the other metals
found in the monitoring wells including chromium, copper,
nickel, mercury, and barium.
7. Page 2-5 and Figure 2-3. It is noted that there are some very
high PCB levels both on the Carolina Transformer property and
along the drainage ditch beyond the property.boundary. The
State of North Carolina would suggest that levels as high as
4,400 mg/Kg in soils or sediments warrants a time-critical
response. The State suggests that the most contaminated soils
(and perhaps the entire site since the buildings also contain
high levels of PCB' s) be fenced through an action by the
Emergency Response and Removal Branch prior to the remediation
of the site. The State is aware that an immediate action was
taken at the Jadco-Hughes NPL site where the highest PCB level
in soils was 1,500 mg/Kg.
8. Table 3-4 and Section 3.1.3.2, Page 3-7. The ARAR's for this
site should include the North Carolina Groundwater Standards
(NCAC Tl5: 02L). A copy of these standards are attached for
your review. These are enforceable standards intended to
maintain and preserve the quality of groundwaters and protect
the public health of the citizens of North Carolina. It is
noted in section .0202 that substances which are not naturally
occurring and for which there is no specific standard (such as
PCB's) shall not be permitted in detectable concentrations.
•
Townsend Letter,
3-27-91,
page 3
•
9. Tables 3-6 and 3-8. It is noted in Table 3-6 th!i,t ~he
drinking water concentration associated with the 10 risk
level is 0.004 ug/liter. However, it is noted in Table 3-8
that the proposed remedial goal for PCB's is 0.5 ug/liter. On
page 2-9 the report states that the EPA risk management policy
ca\ls for ~pe site maximum i~1ividual risk to range between
10 and 10 , but that the 10 risk level should be used as
the starting point for a goal. To be consistent with the
aforementioned EPA policy, the remedial goal for PCB's should
be 0.004 ug/lit_<zr, but in no case should it exceed. 0.4
ug/liter (the 10 risk level). This comment also applies to
1,4-dichlorobenzene and benzene for which the proposed
remedial goal in T_izble 3-8 exceeds the 10·6 risk level
(although not the 10 risk level).
Furthermore the approach taken to develop the cleanup
levels does not take into account the additive effects of the
risks of all the compounds found in the groundwater. This is
one additional reason why the State feels that the remedial
goals should be the NC Groundwater Standards (which are
health-based) and not the MCL's for the individual compounds.
10. Table 3-9. The table's figure of 2,100 mg/Kg for a maximum
soil/sediment concentration appears to be incorrect. Based on
Figure 2-3 in the Feasibility Study and Table 4.1.3 of the
Remedial Investigation, the highest concentration observed in
soil/sediment was 4,400 mg/Kg.
11. Page 3-18. Under the Chemical Precipitation section it states
"all five groundwater contaminants (barium, copper, lead, and
nickel) can be removed using ferrous sulfate precipitation.''
The Superfund Section recommends changing the words
"groundwater contaminants" to "metals". Also, this list of
metals does not mention mercury which was found in 4 of the 5
monitoring wells. Can the ferrous sulfate precipitation
remove mercury sufficiently? If so, it should be added to the
above list as a sixth metal. If not, this potential problem
should be analyzed and included in the discussion of Chemical
Precipitation.
12. Page 3-24. The report states "concrete caps were eliminated
based on their tendency to reduced effectiveness over time."
As an editorial comment, the NC Superfund Section recommends
replacing "reduced effectiveness" with "degrade".
13. Page 3-26. Under the heading Organic Chemical Dechlorination,
the report states "The recovered rinsewater is recovered and
reused. 11 The NC Superfund Section recommends changing the
sentence to read "The rinsewater is recovered and reused.
•
Townsend Letter,
3-27-91,
page 4
•
14. Page 4-2, Section 4.2.1.3 and Appendix B. The NC Superfund
Section feels that the well point extraction system proposed
in the Feasibility Study may not be the best configuration for
groundwater rem·ediation. The proposed configuration forms an
L shape along the property line. This will tend to "pull" and
"smear" contaminants from the center of the site where the
metals levels were the highest and the only notable PCB levels
were found. Also, the goal of the remedial effort should not
be to establish a compliance boundary and stop the
contaminants at the property line, rather it should be to
clean up the groundwater beneath the site. One of the best
ways to do that (in the least amount of time) is to pump from
the area of highest contaminant concentration. The NC
Superfund Section much prefers the alternative depicted in
Figure B-2, Appendix B; an even distribution of well points
over the entire site. If cost is an overriding factor,
instead of using 40 well points, use the same number planned
in Figure 4~3 and space them evenly over the site.
As mentioned previously, there are significant levels of
metals off site in the permanent monitoring wells. Are these
areas going to be remediated? Particularly since these areas
may be closer to off-site private wells.
15. Section 5.1.3.7, Page 5-8. The cost estimates provided for
Alte.rnatives G-3A and G-3B do not take into consideration the
differences between the two alternatives in the area of
permitting and legal costs. The "A" alternative, which calls
for discharge of treated groundwaters to a surface stream,
would require an NPDES permit. This would be more time
consuming and costly than would obtaining a permit from the
local POTW as called for by the "B" alternative. Yet both
alternatives estimate permitting and legal costs at $12,200
(3% of the capital cost). In our opinion the legal and
permitting costs and the added time delay of obtaining an
NPDES permit outweigh the small additional costs of connecting
to the local sewer system. This comment applies equally to
Alternatives G-4A and G-4B; and Alternatives G6-A and G6-B.
Therefore, the NC Superfund Section, although agreeing
that the preferred alternative for groundwater remediation is
G-4, supports the ''G-4A'' alternative for discharging this
water to the local POTW over the G-4B alternative which
'discharges it to surface water.
16. Page 5-8, 5-10, and Table 5-24. Table 5-24 rates the short
term effectiveness of Remedial Alternatives G-3 a "4" and of
G-4 a "5''· Yet both alternative G-3 and G-4 are rated a ''5''
for Protectiveness of Human Health and the Environment. This
is somewhat inconsistent. To be consistent, the State feels
•
Townsend Letter,
3-27-91,
page 5
•
that the short term effectiveness rating for G-3 to should be
changed to a "5" or that G-4 's rating for Protection of Heal th
and the Environment to a 11 4". The logic for this is as
follows:
Under Short-Term Effectiveness for Alternatives G-3 and G-4
the report states that G-3 is slightly less effective in the
short term than G-4 because of any voe emissions that would
escape the carbon adsorber unit on the air stripper. Yet on
Page 5-10 in Section 5.1.4.4 it states that G-3 and G-4
achieve the same reduction in the toxicity, mobility, and
volume of groundwater contaminants. These two statements are
inconsistent. First, G-3 has an air stripper designed to
remove VOC's from the groundwater and G-4 does not.
Therefore, the statement in Section 5.1.4.4 does not appear to
be correct. In theory, G-3 removes VOC's and G-4 does not.
However, the argument can be made that there is not a
significant amount of voe contaminants in the groundwater, and
therefore, the air stripper gives negligible added
environmental benefit. Yet, if this is the case, then it also
must be reasoned that the air emissions from the carbon
adsorber on the air stripper would be even less and would have
negligible impact on local air quality. Therefore, the short
term effectiveness of G-3 would have to be considered the same
as that for G-4. If, however, you assume that the VOC's are
significant, then G-4 should have a lower rating for
Protectiveness of Human Health and the Environment.
17. Page B-2. Under the section entitled Summary of
Groundwater Contamination and Target Area, the report states
"Contamination was not detected in the remaining temporary
monitoring wells located around the perimeter of the site.
The horizontal extent of the contaminant plume must therefore
be assumed to be within the boundaries of the Carolina
Transformer site."
The State does not agree with this statement. First,
there is no plume map presented in the report, but if there
was a plume map for chromium, nickel, and perhaps other metals
you would see significant contamination off the Carolina
Transformer property. The target captive area presented in
Figure B-1 does not include Wells 1 and 25 which are the most
contaminated with metals.
Finally, these comments are not the only comments that will be
provided to you by the State. We have forwarded the Draft
Feasibility Study to the NC Division of Environmental Management
for their review. We will forward their comments to you when we
receive them.
•
Townsend Letter,
3-27-91,
page 6
•
The NC Superfund Section looks forward to continued work with
you on this site. If you have any questions concerning these
comments please contact me at [phone].
BIN/let/ctfscom
attachment
Bruce Nicholson
Chemical Engineer
Superfund Section
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
MAR 6 1991
Mr. Bruce Nicholson
Waste Management Branch
Department of Human Resources
P.O. Box 2091 .
Raleigh, North Carolina 27602
Re: Carolina Transformer NPL Site
Dear Mr. Nicholson:
Enclosed is two copies of the Draft Feasibility Study Report for your
review. I am fast tracking the remainder of the project to meet a
June ROD date, so I ask that you review this document and forward
your comments back to me by March 19, 1991. If you find you have
major problems with the document please give me a call as soon as you
know.
My goal is to get this FS to the public by the end of March, so any
effort you can give to meet this goal is greatly appreciated.
I
Printed on Recycled Paper
~
I
I