HomeMy WebLinkAboutNCD991278953_19990218_National Starch & Chemical Corp._FRBCERCLA RD_Response to Comments on the Revised Final Design Document OU-3-OCR1EL
BlASI.AND. BOCC;< & LEE, INC.
engineers & scientists
Transmitted Via Certified Mail/Return Receipt Requested
February 18, 1999
Mr. Jon K. Bornholm
Remedial Project Manager
United States Environmental Protection Agency
Region 4
Atlanta Federal Center
61 Forsyth Street, S.W.
Atlanta, GA 30303-3104
Re: Response to Comments on the Revised
Final Design Document for Operable Unit 3
National Starch & Chemical Company
Cedar Springs Road Plant Site
Salisbury, North Carolina
Project#: 050.55 #2
Dear Mr. Bornholm:
fTB 2 3 1999
RECEIVED
FEB 26 1999
SUPERFUND SECTION
On behalf of National Starch & Chemical Company (NSCC), Blas land, Bouck & Lee, Inc. (BBL) has
prepared this response to regulatory comments provided in correspondence dated January 25, 1999 by the
United States Environmental Protection Agency (USEPA) and the North Carolina Department of
Environment and Natural Resources (NCDENR) on the Revised Final Design Document for Operable Unit
3.
We appreciate the effort put forth in preparing the comments on the above-referenced document. For your
convenience, regulatory comments are listed below in bold type followed by NSCC's response on a point-
by-point basis.
USEPA COMMENTS
I. First page of December 3, 1998 Response to Comments on the Draft Final Design report, first
bullet, second sentence: The intent of this sentence is not clear. This sentence states, " ... trench
contains less mass than the ground water ... ". The question is less mass of what?
This sentence should have read " ... trench contains less mass of constituents than the ground water ... ". The
concentrations of the constituents of concern measured in the ground-water emanating from the trench are
less than the ground-water emanating from NS-47.
2. Page 2-2, Section 2.3 Ground-Water Impacts, third paragraph, first sentence: The OU #4
Record of Decision identified a second source of contamination in Area 2 which was a solvent
recovery system (distillation unit).
8 South River Road • Cranbury. NJ 08512-9502 ·• . ' rel (609) 860-0590 • Voice Mail (609) 860-8072 • Fax (609) 860-049 I • Offices Nationwide
•
Mr. Jon K. Bomholm
February 18, 1999
Page 2 of9
BBL concurs, the solvent recovery system was also a potential source of ground-water impacts.
3. Page 4-2, Section 4.3, second sentence: This sentence lists the sources of groundwater that
require treatment in the Pretreatment System. Where is the groundwater being extracted from
the plume periphery wells going? A short sentence should be included in this section stating
where the plume periphery groundwater is being treated.
The ground water extracted from the plume periphery wells is currently discharged directly to the wastewater
treatment lagoons. There are no plans to re-direct the plume periphery ground water to the proposed Ground-
Water Pre-Treatment System.
4. Page 4-4, Section 4.5.1: Refer to comment #3.
Please refer to the response to Comment# 3.
5. Page 4-4, Section 4.5.2, first paragraph: The description of the location of the trench needs to
he expanded to include a distance between the eastern end of the trench and the Northeast
Tributary, especially since the trench is not incorporated into either Figure 1-2 or Figure 2-1.
The eastern end of the trench is approximately 25 feet from the Northeast Tributary.
6. Page 4-4, Section 4.5.2, first paragraph, fourth sentence: What is the rationale for placing the
perforated pipe 1 foot above the base of the trench? Why not on the base of the trench or an
inch or two above?
The intent of the pipe placement is to provide protection from possible silting of the trench bottom.
7. Page 4-5, Section 4.5.3, first paragraph, last sentence: Is there a reason that the two extraction
wells don't require a hand/off/auto switch incorporated in the control panel?
The extraction well control panels include a hand/off/auto switch. Please refer to Drawing 13 of Appendix
D which presents electrical diagrams for the extraction wells control panel. ·
8. Page 4-8, Section 4.7, fourth paragraph: This paragraph refers to using micro-purging
techniques. To help prevent any misunderstanding on expectations, I enclo_sed Section 7.2.2.
Purging Techniques (Wells Without Plumbing or In-Place Pumps) from the USEPA, Region 4,
Science and Ecosystem Support Division, Environmental Investigations Standard Operating
Procedures and Quality Assurance Manual, May 1996 (EISOPQAM), which last revised on
August 19, 1998. This section describes two low now purging approaches: low-now, low-stress
and low-now, low-volume. The easiest resolution will be for BBL to include the actual micro-
purging procedures (step by step) in this document.
BBL concurs. Attached please find a copy of the step-by-step proced,;res to be implemented for the
sampling program .
BLASLAND. BOUCK & LEE. INC.
engineers & scienrisis
Mr. Jon K. Bornholm
February 18, I 999
Page 3 of9
9. Page 4-9, Section 4.7: An additional bullet needs to be incorporated into this sequence for
retrofitting these monitoring wells. After enclosing the screened interval with sand, a bentonite
seal needs to be placed on top of the sand layer. This bentonite seal must be at least 2 feet in
thickness and the bentonite pellets should have at least 8 hours to hydrate prior to grouting the
remainder of th·e annular space with the cement-bentonite mixture.
BBL concurs. Attached please find a revised Page 4-9.
10. Page 3 of 3, Design Influent Sampling, second paragraph, last sentence: What is the basis of this
statement?
The results of the second sampling event from the existing influent stream indicated higher concentrations
of organic constituents. The first sampling results were not consistent with the historical data. Thus the
results of the second sampling event were used.
The Agency has no comments on Appendices C, D, and E. The following comment is on Appendix F.
11. Section 2. Project Organization: It may be advantageous not to identify people by name as done
in Section 2.1.1 but refer the reader to Figure 1 for the actual individ.ual who has a particular
role. If there are future changes in personnel, it is easier to revise Figure 1 than the revise the
text of the Construction Management.Plan.
BBL concurs. Attached please find a revised Section 2 and Figure I. Future changes to the Construction
Management personnel will be performed through revision.of Figure I.
The following comment is on Appendix G.
12. Page 2-4, Table 2-1: This table needs to be revised.
BBL concurs. Attached please find a revised Table 2-1.
The following comment is on Appendix H.
13. Figure 1 needs to be revised.
BBL concurs. Attached please find a revised Figure I.
The following comments are on Appendix I.
14. Page 3-1, Section 3.2.3: Shouldn't the Caustic Day Tank be added to this list?
BBL concurs. The Caustic Day Tank will be monitored daily for signs of leaks or deterioration. In addition,
the associated metering pumps and piping will be monitored for leaks and proper operation.
IS. Page 3-3, Section 3.3.2: What will be done with the residue from cleaning out the air stripper?
BLASLAND. BOUCK & LEE. INC.
engineers & scientists
Mr. Jon K. Bornholm
February 18, 1999
Page 4 of9
The routine cleaning of the air stripper should not result in the creation of residue. The pressure washing
operation should result in a very dilute aqueous solution which will be pumped from air stripper sump
through the system. The solution will be treated in the waste water treatment lagoons prior to discharge to
the Publicly Owned Treatment Works.
The following comments are on Appendix J.
16. Page 2-5, Section 2.2.4.1, Purging Technique: Refer to comment #8 above. As specified in the
Attachment for Well Purging, under low flow/low volume method, the well is to sit 24 to 48
hours after the pump or tubing (i.e., pump intake) is introduced into the well before purging is
to commence. Also the pump intake is to he placed in the zone of the well that has the highest
flow rate. Have these zones been identified in all wells to he sampled/monitored?
BBL requests additional clarification on the protocol described above. The EISOPQAM indicates that
"purging is conducted after hydraulic conditions within the well have re-stabilized, usually within 24 to 48
hours." Based on BBL's experience in performing low-flow/low-volume sampling, aquifer re-stabilization
due to the introduction of a bladder pump will occur well within 24 hours. Please note that the pumps in
question are typically approximately less than 2 inches in diameter, 2 feet in length, and 30 percent solid.
Therefore, the head rise within the well is very small, much smaller than a slug test, and the aquifer
disturbance is minimal.
The known zones of highest flow rate for the wells in the OU3 program are as follows:
NOTES: I.
Well Zone of Highest Flow Rate'
(ft below top of casing)
NS-46 143.93 -163.73
NS-48 151.03 -170.83
NS-50 130.34 -150.21
NS-52 119.35 -139.0
NS-54 174.86 -203.33
Zone of highest flow rate determined by packer tests pcrfonncd by NSCC during the RD/RA Field
Investigation and reported in the FISR (NSCC, 1997).
The screened intervals for the retrofit of the open borehole bedrock wells correspond to the zones of highest
flow rate for the wells in the OU3 program. The pump will be lowered to the middle of the screened interval
of the well during purging and sampling.
17. Page 3-1, Section 3.1, first paragraph, first sentence: This sentence refers to Figure 2-.1 for
showing the two locations where stream elevations will be measured. However, Figure 2-1 shows
four locations.
Figure 2-1 should reflect two stream gauges installed in the Northeast Tributary. One of the stream gauges
is located approximately adjacent to S WISE-IO and one is located approximately adjacent to SW /SE-13.
BLASLAND. BOUCK & LEE. INC.
enginee:; 3. scientisrs
The Agency has no comments on Appendices Kand L.
NCDENR COMMENTS
Responses to Specific Comments from the USEPA
Mr. Jon K. Bomholm
February I 8, 1999
Page 5 of9
1. The response to USEPA specific comment #2 states that the term "collection trench and
pumping manhole" shall be replaced by the term "collection trench and pumping well"
throughout this document. However, the "collection trench and pumping manhole" terminology
still remains in the last sentence of Section 4.5.2. Please correct this oversight.
BBL concurs. Attached please find a revised Page 4-4.
2. The response to USEP A specific comment #8 states that the text of Section 4.5.2 shall be revised
to incorporate a detailed description of the flow meter for the pumping well. However, this
detailed description was inadvertently omitted. Please correct this oversight.
BBL concurs. The flow meter is specified as a Brooks Model 7400 WaferMag with 3520 smart local operator
interface as shown in Drawing 18, Appendix D.
3. The response to USEPA specific comment #12 states that Se~tion 4.6.5 has been revised to
describe the revised caustic storage tank design, including the caustic material usage rate.
However, this revised text was inadvertently omitted. Please correct this oversight.
BBL concurs. Attached please find a revised Page 4-7.
4. The response to USEPA specific comment #13 indicates that the Section 4.8 text has been revised
to state that the cement-bentonite mixture will be allowed to sit overnight before commencing
with the next portion of the work. Please amend Section 4.8 to further state that all monitoring
well retrofit activities shall be conducted in accordance with the USEPA Region IV
Environmental Investigations Standard Operating Procedures and Quality Assurance Manual.
BBL concurs. Attached please find Page 4-8, which has been revised with the recommended changes.
Responses to Specific Comments from the NCDENR
5. The response to NCDENR specific comment #12 indicates that groundwater elevation
measurements were not collected from groundwater monitoring well NS-01 due to the well's
historically dry nature. Please delete the reference to NS-01 groundwater elevation
measurement collection in the second paragraph of the section entitled,,Hydraulic Evaluation -
Measurement of Aquifer Response, of the Memorandum included in Appendix B.
BBL concurs. Attached please find a revised Page 2 for the Dynamic Ground-Water Quality Test in
Appendix 8.
6. The response to NCDENR specific comment #16 indicates that a revised Figure 9 presents the
results for observation well NS-50 assuming a saturated thickness of 158 feet (ft). However, this
BL,\SLAND, BOUCK e. LEE. INC.
engineers & scieniisrs
•
Mr. Jon K. Bomholm
February 18, 1999
Page 6 of9
revision increases the transmissivity for NS-50 to 597.4 square feet per day (ft'/d). This increase
in transmissivity in turn increases the geometric mean of the individual estimates of
transmissivity for the transition zone/fractured bedrock to 416.5 ft'/d. The sixth sentence, third
paragraph of the section entitled, Hydraulic Evaluation -Estimation of Aquifer Parameters,
states that the geometric mean of the individual estimates of transmissivity for the transition
zone/fractured bedrock is 390 ft2/d. Please clarify this discrepancy. Additionally, the former
Figure 12 was inadvertently submitted as Figure 13. Please ·delete Figure 13 from future
submittals.
BBL's response to the subject question stated that "the geometric mean calculated assuming this revised
value is 390 ft2/d, which assumes that the computed values contain 3 significant figures". The response
should have stated "the geometric mean calculated assuming this revised value is 395 ft2/d, which assumed
that the computed values contain 3 significant figures". Assuming 4 significant figures for the computed
values, the geometric mean is 416.5 ft'/d as discussed by NCDENR. Figure 13 will be deleted from future
submittals.
7. The response to NCDENR specific comment #17 indicates that the estimated transmissivity for
the saprolite (32 ft2/d) cited in the text was computed assuming the data arc fit to a type curve
generated using the Cooper-Jacob analytical solution. The response further stated that the
estimated transmissivity presented in Figure 7 (11.04 ft2/d) is based on the Neuman analytical
solution for unconfined aquifers. Please submit the data, type curve and output generated
during the Cooper-Jacob analysis of saprolite observation well NS-47. Additionally, please
briefly describe the two methods, including their limitations, in an analysis and justification for
the use of the Cooper-Jacob analytical solution over the Neuman analytical solution.
The attached figure presents the data, type curve, and output for well NS-4 7 based on the Cooper-Jacob
analysis. The Cooper-Jacob method involves a modified version of the Theis equation, which is based on
an equation derived from the truncation of the infinite series expression for the Theis well function. The
Cooper-Jacob method is valid only after a sufficiently long time has expired so that only the first two terms
of the expression for w(u) in the Theis equation are significant. For unconfined aquifers, the Cooper-Jacob
uses a correction for water level displacement based on a relationship between the observed displacement
and the saturated thickness of the aquifer. The Neuman method is based on an analytical solution for
unsteady flow within an unconfined aquifer with accommodation for delayed yield. The approach involves
matching two different type curves to the early and later portions of the displacement versus time plot of an
aquifer test and enables estimates of specific yield and horizontal to vertical anisotropy in addition to
transmissivity and storativity. The Cooper-Jacob result may be considered more appropriate in estimating
transmissivity of the aquifer since aquifer tests involving unconfined aquifers are often not conducted long
enough to allow for complete drainage of the upper portions of the aquifer due to delayed yield. Application
of the higher transmissivity estimated using the Cooper-Jacob method for well NS-47 is appropriate since
a higher transmissivity represents a more conservative approach to evaluating potential contaminant transport
at the site. It should also be emphasized that the differences in T estimated using either approach may not
be considered significant. A majority of practicing hydrogeologists are often satisfied with an order-of-
magnitude estimate ofT, especially when considering that T can vary in hydrogeologic environments by
more than 13 orders of magnitude.
8. The response to NCDENR specific comment #18 states that Table 2 has been submitted.
Although Table 2 has been submitted, Table 2 docs not include the sample collec_tion dates for
BLASLAND. BOUCK & LEE. lflC.
engineers & scientists
Mr. Jon K. Bomholm
February 18, 1999
Page 7 of9
the groundwater sample results shown on page 3 and page 4 of Table 2. Please correct this
oversight.
BBL concurs. Attached please find a revised Table B-2.
9. The response to NCDENR specific comment #28 states that 2-inch diameter schedule 40
galvanized steel pipe is to be used to transport the groundwater to the pretreatment building.
Please revise Sheet l of the Final Design Specifications to reflect the correct schedule of pipe to
be used.
Drawings I and 18 of Appendix D reflect the use of Schedule 40 galvanized steel pipe.
10. The response to NCDENR specific comment #30 states that Figure 1 has been included in the
FDR. However, Table 8 -Flow Capacity and Friction Loss for Schedule 80 Thermoplastic Pipe
and Table 9-Equivalent Length of Pipe were submitted but are illegible. Additionally, a flow
capacity and friction loss table for Schedule 40 galvanized piping should be submitted. Please
submit legible copies of the appropriate pipe tables.
BBL concurs. Attached please find a copy of the requested tables.
11. The response to NCDENR specific comment #35 states that the Final Construction Health and
Safety Plan will be signed in accordance with BBL's internal policy. Please note that this
document must be signed and dated by the appropriate personnel prior to initiating work
activities.
BBL concurs.
12. NCDENR specific comment #41 was only partially addressed. The table given in Section 2.2.2
of Appendix I is inconsistent in applying elevations expressed in feet above mean sea level (i.e.,
screen interval, casing interval). Please correct tliis oversight.
BBL concurs. Attached please find a revised Page 2-3 for Appendix I.
13. NCDENR specific comment #42 was not addressed. The sixth sentence, first paragraph of
Section 2.3.l of Appendix I states that "a new pH element and indicating transmitter will be
located on a 2-inch recirculation line at the equalization tank." However, the third and fourth
items given under the section entitled, Equipment, in this section indicates that the existing pH
transmitter is to be re-used. Please clarify this discrepancy. Furthermore, the appropriate
specifications should be given to demonstrate the adequacy of the new and/or existing pH
transmitters and level transmitters.
The existing pH element and transmitter will be used. A new pH indicating controller will be provided.
1-1. NCDENR specific comment #43 was not addressed. Section 6.1 of Appendix I is too general.
Please detail how NSCC proposes to demonstrate compliance with air and wastewater discharge
requirements.
BLASLAND. BOUCK & LEE. INC.
enyineers & scientists
•
•
Mr. Jon K. Bornholm
February 18, 1999
Page 8 of9
At the time of the submittal of the FDR, the Air Permit was not issued. Subsequent to the issuance of the
FDR, the Air Permit was issued. Attached please find a copy of the Air Permit. In accordance with the
permit requirements, hours of operation of the catalytic oxidizer unit will be recorded on a quarterly basis.
Compliance with wastewater discharge requirements is demonstrated on at least a monthly basis. NSCC
collects samples of the effluent and samples for applicable discharge parameters. On a semi-annual basis,
Salisbury Water Resources samples the effluent. All analyses are performed by an outside laboratory or by
Salisbury Water Resources.
15. NCDENR specific comment #44 was not addressed. The Performance Verification Plan does
not address air sampling. Please detail how NSCC proposes to demonstrate compliance with
the air pollutant discharge permit.
The Air Permit does not require sampling to demonstrate compliance. It is unlikely that air sampling will
be performed.
16. NCDENR specific comment #45 was not addressed. The Performance verification Plan does not
address wastewater effluent sampling. Please detail how NSCC proposes to demonstrate
compliance with the wastewater discharge permit.
NSCC collects wastewater effluent samples monthly, except for the months of June and December when
Salisbury Water Resources collects samples. Random sampling of the wastewater effluent is performed by
Salisbury Water Resources. OCPSF chemical sampling is performed twice a year, once by NSCC and once
by Salisbury Water Resources. All samples collected by NSCC are analyzed by an independent laboratory.
Samples collected by Salisbury Water Resources are sampled either in-house or by an independent
laboratory.
Appendix D -Final Design Plans and Specifications
17. Delete the phrase "to be demolished back to PLC cabinet" in demolition note #6 in Drawing No.·
6.
BBL concurs.
Appendix G -Cons/ruction Heallh and Safely Plan
18. Table 3-1 was inadvertently omitted. Please correct this oversight.
BBL concurs. Attached please find Table 3-1 for inclusion in Appendix G.
Appendix [ -Operation and Maintenance Plan
19. The second item given for Fuel Train maintenance in Section 3.3.3 should state "Check high and
low gas pressure switches ... ". Please correct this oversight.
BBL concurs. Attached please find a revised Page 3-3 for Appendix I.
BLASLAND. BOUC, & LEE. INC.
engineers & scientists
Appendix H -Construction Quality Assurance Plan
Mr. Jon K. Bornholni
February 18, 1999
Page 9 of9
20. The third sentence of the first paragraph of this section should state that " ... the OUl
pretreatment building will be retrofitted ... ". Please correct this oversight.
BBL concurs. Attached please find a revised Page 3-1 for Appendix H.
Appendix J -Performance Verification Plan
21. The second paragraph of Section 1 should state that "This PVP is an appendix to the Final
Design report (FDR) for OU3, submitted to the United States Environmental Protection Agency
(USEPA) in December 1998. The FDR and its associated appendices are hereby incorporated
by referenced into this document." Please correct these oversights.
BBL concurs. Attached please find a revised Page 1-1 for Appendix J.
If you should have any questions or comments regarding these responses, please feel free to contact me at
(609) 860-0590.
Sincerely,
BLASLAND, BOUCK & LEE, INC.
,,-I"'
-. Michael P. Fleischner
Senior Project Engineer
MPF/plb
04890562.WPD
cc: Mr. Douglas E. Cregar, National Starch & Chemical Company
Mr. Alex Samson, National Starch & Chemical Company
Ms. Angela Doh!, National Starch & Chemical Company
Mr. Richard D. Franklin, National Starch & Chemical Company .
Mr. Raymond E. Paradowski, National Starch & Chemical Company
Mr. Joseph J. Hochreiter, Jr., CGWP, Blasland, Bouck & Lee, Inc.
8LASLAND. BOUCK & LEE. INC
engineers 3 scientists
Low-Flow Ground-Water Purging and Sampling
All of the ground-water sampling will be conducted by the low-flow ground-water purging and
sampling method. "Low-flow" refers to the velocity with which water enters the pump intake, and
does not refer to the flow rate of water discharged at the surface. This method causes less
disturbance to the aquifer materials and the water column within the well compared to commonly
employed ground-water sampling procedures. The low-flow purging and sampling technique
decreases turbidity in the well and the sample volume, and minimizes aeration during sample
collection, resulting in samples that are more representative of the ground-water quality in the
aquifer. An additional benefit of the low-flow purging and sampling method is that only a relatively
small quantity of purge water is generated.
WELL PURGING and SAMPLING
The objective of low-flow ground-water purging and sampling is to pump in a manner that
minimizes stress ( drawdown) on the aquifer. This method requires purging until specific field
parameters have stabilized as an indication that the sample is representative of formation ground
water, and not standing well water. The procedures for this activity are outlined below.
• Well water will be evacuated through PTFE (Teflon®)-lined polyethylene
tubing employing a bladder pump. All in-line fittings and valves must be
constructed of stainless steel or Teflon®.
• During the initial round of ground-water sampling, the pump will be
positioned at the middle of the well screen. During any subsequent rounds
of sample collection, other information will be evaluated to determine if the
pump should be positioned at any other depth for purging and sampling. This
information will include the presence of intervals with relatively high
hydraulic conductivities (as indicated on the well logs), the type of
contaminants suspected, and the potential presence of non-aqueous phase
liquids.
• The purging rate will be controlled at a rate of approximately I liter per
minute so that the water level in the well is not lowered more than 0.1 meters,
or approximately 0.33 feet. This is accomplished by using the pump's
variable speed flow controller and/or a valve in the discharge line. As a
result, the pumping rate may be less than I liter per minute, depending on
well recharge rates and aquifer formation characteristics.
• Water level measurements will be collected frequently during purging to
ensure that the water level has not dropped beyond the recommended
drawdown limit and to facilitate a modification of the pumping rate if
excessive drawdown occurs.
• During the purge cycle, field parameters consisting of specific conductance,
pH, dissolved oxygen (DO), turbidity, temperature, and oxidation-reduction
potential (ORP) will be measured continuously using a flow-through cell
assembly. Field parameters and water level measurements will be made
every two to three minutes, and will be recorded in the field notebook or on
sampling logs. Once stabilization trends develop in the readings, the
measurement frequency should be increased to five minutes to verify
stabilization.
• Monitoring wells will be purged until three consecutive field measurements
made at five minute intervals of specific conductance, pH, and one of either
DO or turbidity have stabilized to within the ranges presented below. lfthese
parameters fail to stabilize, sampling should commence after a minimum of
three well volumes are removed .
. .. =<:-:::. .. r·ie_fo·:t~/3,nie_~ei)?t< = -,-· ·=·-==·=.==-="·'~t~_bi:~i~~'.ti~'.0\¢~-it;·~:io~ \/'''' .. :-· -·
Specific Conductance 3 Percent Full Scale Range
pH 0. 10 pH Unit
Dissolved Oxygen 10 Percent
Turbidity IO Percent
GROUND-WATER SAMPLE COLLECTION
When purging is complete, sample aliquots will be collected in the order listed below.
• Volatile Organic Compounds;
• Semi-Volatile Organic Compounds;
• Methane, Ethane, and Ethylene; Nitrogen Gas; and Carbon Dioxide;
• Phospholipid Fatty Acids;
• Total Organic Carbon;
• Chemical Oxygen Demand;
• Total Metals;
• Dissolved Metals;
• Sulfide. Sulfate, and Chloride;
• Phosphorus;
• Nitrogen Parameters;
• Alkalinity Parameters; and
• Total Dissolved Solids.
The above list is comprehensive for wells being sampled for Natural Attenuation parameters. Wells
sampled only for select parameters should follow the above order, omitting the aliquots not being
2
collected from that well.
Samples will be collected directly through a sampling port, which will be located on the discharge
line from the sampling pump prior to the in-line flow-through cell assembly. Prior to sampling, the flow rate will be reduced to I 00 milliliters per minute (ml/min). To minimize volatilization,
collection of aliquots for VOC analysis will be accomplished by directing the flow toward the inside wall of the sample container. Aliquots for other parameters will be collected by fully inserting the discharge tube to the bottom of the sample container, and filling the container until overflowing
while maintaining the submergence of the end of the discharge tube below the surface of the sample
to prevent aeration. For filtered metals aliquots, the discharge will be filtered with an in-line 0.45 micron filter following the preceding technique. Non-aerating pumping and filling procedures must
be maintained at all times. All samples will be preserved according to the appropriate laboratory
protocols.
3
•
•
•
A screen and casing will be installed in the borehole;
The annular space around the screened interval will be filled with a sand pack;
A bentonite seal, at least 2 feet in thickness, will be placed on top·ofthe sand pack. The bentonite seal will
be allowed to sit for at least 8 hours to hydrate the bentonite pellets; and
A cement-bentonite grout will be used in the annular space from the top of the bentonite seal to land surface.
4.8 Construction Cost Estimate and Preliminary Construction Schedule
An engineer's estimate of probable construction cost and a preliminary construction schedule are included in
Appendix Kand L, respectively, ' ·
BLASLAND, BOUCK & LEE, INC.
F.\PROJECTS\NSCa672B0842.P..PT .• 2/l5fi9 engineers & scientists 4-9
2. Project Organization
The implementation of the RA for OU3 will be accomplished by a combined effort ofNSCC, BBL, and BBL's
affiliated construction management company BBL Environmental Services, Inc. (BBLES). The use of BBL and
BB LES ensures continuity between the design and construction phases to efficiently resolve issues which m'ay arise
during the construction phase. The roles of key personnel are described in the following sections. Key personnel
are shown in the Project Organization Chart, presented as Figure 1.
2.1 National Starch & Chemical Company
NSCC will provide assurance through the use of BBL and BBLES that the project is completed in accordance with
the requirements of the FDR and in accordance with the schedule in the Supplemental Remedial Design/Remedial
Action Work Plan. NSCC will accomplish this goal through the combined efforts of the RA Coordinator, the RA
Site Coordinator, and the Site Health and Safety Coordinator.
2.1.1 RA Coordinator
The RA Coordinator will coordinate with the RA Site Coordinator and the Project Manager to resolve project issues
and to ensure that the construction is completed according to the approved plans and specifications and according
to the schedule included in the FDR.
2.1.2 Site RA Coordinator
NSCC personnel will serve in the role of Site RA Coordinator through the implementation of the RA. In this role,
the Site RA Coordinator will act as liaison with the Construction Manager to address issues which arise in the field
during the construction phase.
2.1.3 Site Health & Safety Coordinator
The Site Health and Safety Coordinator will be responsible for ensuring that the construction manager is
implementing the Construction Health and Safety Plan (CHASP) and that the sitewide health and safety procedures
are being followed.
2.2 BBL Environmental Services, Inc.
,\
' BBLES will act as General Contractor responsible for implementing the plans and specifications through the
coordination of necessary disciplines. BB LES will also be responsible for implementing the Construction Quality
Assurance Project Plan (CQAPP) and for observing the implementation of the work. BB LES will accomplish these
goals through the combined efforts for the Project Officer, Project Manager, Construction Manager, Quality
Assurance/Quality Control (QA/QC) Manager, Health and Safety Coordinator, and Site Inspector.
2.2.1 Project Officer
The Project Officer is ultimately responsible for the construction of the RA in accordance with the approved plans
and specifications. The Project Officer is also ultimately responsible for ensuring that the project is completed
accordi11g to schedule.
BLASLAND, BOUCK & LEE, INC
engineers & scientists 2-1
2.2.2 Construction Manager-QA/QC Manager
BBLES personnel will serve as both the Construction Manager and QNQC Manager. The Construction Manager is responsible for working with the Site RA Coordinator, Project Officer, Project Manager, Project Engineer, and Site Inspector to the following:
Direct the procurement of equipment and subcontractors;
• Ensure that the project is completed accordi_ng to the plans and specifications;
• Ensure that the project is completed according to the approved schedule;
• Resolve issues which may arise during the implementation of the RA;
• Document changes to the approved plans and specifications; and
Direct the implementation of the CQAPP.
2.2.3 Health & Safety Manager
The Health and Safety Manager is responsible for coordination with the Health and Safety Coordinator, Project Manager, Construction Manager, and Site Inspector to Implement the Construction Health and Safety/Contingency Plan. The Health and Safety Manager may periodically visit the site to perform audits.
2.2.4 Site Inspector
A Site Inspector will be responsible for working with the Construction Manager, Health and Safety Manager, and subcontractors to:
Ensure that the construction is completed according to the plans and specifications;
Implement the CQAPP;
• Implement the CHASP; and
Perform the necessary documentation to prepare the Remedial Action Report.
2.3 Blasland, Bouck & Lee, Inc.
BBL will continue in the role of design engineer and provide support to BBLES and NSCC in ensuring that the project in completed in accordance with the plans and specifications. BBL will use the documentation provided by BB LES to prepare the Remedial Action Report and certify that the construction was completed in accordance with the plans and specifications. BBL will also participate in the construction change process as described in Sectinn 4.
BLASLAND. BOUCK & LEE, INC.
engineers & scientists 2-2
•
2.3.1 Project Officer
The Project Officer will assume ultimate responsibility for the direction of the Design Engineers and the preparation
of the Remedial Action Report. The Project Officer will also provide continuity from the design to construction
phase.
2.3.2 Project Certifying Officer
The Project Certifying Officer will provide the Professional Certification for the completion of the construction
according to the plans and specifications.
2.3.3 Project Manager
The Project Manager will be responsible for coordinating with the RA Coordinator, Project Engineer, and
Construction Manager to:
Implement the construction change protocol described in Section 4;
• Ensure that the construction is completed according to the plans and specifications;
• Ensure that the project is completed according to the approved schedule; and
Prepare the Remedial Action Report .
2.3.4 Project Engineer
The Project Engineer will be responsible for answering design questions during the implementation phase and
interpretation of the results of the initial testing program.
BLASLAND. BOUCK & LEE. INC.
engineers & scientists 2-3
BBL
7/'l8/98 08581538, COR
Environmental Services, Inc.
Syracuse, New York
Contractor
Richard P. DiFiore
Project Officer
To Be Determined
Construction Manager
Field Services Staff
NCDENR
I Angela Dohl
Remedial Action Coordinator
National Starch and Chemical Company USEPA
Blasland, Bouck & Lee, Inc.
Syracuse, New York
Engineer
'--
Joseph J. Hochreiter, CGWP Edward R. Lynch, P.E.
Project Officer Project Certifying Officer
Michael P. Fleischner
Project Manager
Office Services Staff
NATIONAL STARCH ANO CHEMICAL COMPANY
CEDAR SPRINGS ROAD PLANT -SALISBURY, NORTH CAROLINA
COMBINED OU1 AND OU3 PRETREATMENT SYSTEM
CONSTRUCTION QUALITY
ASSURANCE PLAN
ORGANIZATION CHART BBL BLASLAND BOUCK • LEE INC
AGURE
•n;ln••r• & 1c:;J•nll1/1 1
•
\TABLE 2-1
KEY PERSONNEL
I .·.··.{·:·-,: .... :.-•.,-: .. , .. :· : :--·1.-::::···:··:-' .,..,.:•,:,, "::::•:,•:::.:·-__ _.:,;. '··:f)'fational'Star_ch and:(:1~C~_i_~-~1_._<;()mpa_ny _ K~y _Personnel
Remedial Action Coordinator
Site Health and Safety Coordinator
Project Manager
Construction Manager
Site Supervisor/Health and Safety
Specialist
Project Officer
Corporate Health and Safety Associate
To be determined
Niime
Jon Bornholm
Dave Mattison
i,ll66()l;l4].ll.Pf ·• 1/11/)')
Richard b. Franklin
I
To be N.Jed Later ' I To be Named Later
I
I Richard P.1iFiore
I Jay D. KcTgh, CIH
NCDENR
BLASLAND, BO CK & LEE. INC.
engineers & scientists
l O Findeme A venue
Bridgewater, NJ 08807
(908) 685-7085
Cedar Springs Road Plant
Salisbury. NC
(704) 642-6223
Add ;:~;;_rr.;J¥'P:;'.~'.-~_;:·N_o. -}:){()
8 South River Road
Cranbury, NJ 085 I 2
(609) 860-0590
6723 Towpath Road, P.O. Box 66
Syracuse, NY 132 I 4-0066
(315) 446-9 I 20
8 South River Road
Cranbury. NJ 08512
(609) 860-0590
JOO Alabama Street S. W.
Atlanta. GA 30303-3104
(404) 562-8820
40 I Oberlin Road
Suite 150
Raleigh. NC 27605
(919) 733-2801, ext. 349
2-4
Richard D. Franklin
Site Health and Safety
Coordinator, NSCC
Herrick L. Teeter, CIH
Health and Safety Manager
BB[E-S
To Be Determined
Site Remedial Action
Coordinator, NSCC
11M 8YR-OM-t.lUI
0!!o0~1:Ml50Mf01 CDR
NCDENR , --. .
Remedial Action Coordinator·I---
An ela Dohl
· . USEPA . ., . .
BBL Envlrorimeiital Servi~~s, lnC. ·
Contractor
Richard P. Difiore
Project Officer
BBLES
To Be Determined
Construction Manager
BBLES
Site Inspector and
Field Services Staff
BBLES
Engineer
Joseph J. Hochreiter, CGWP __ --Edward-R~Lynch,P,E-. -a-----1
Project Officer
BBL
Michael P. Fleischner
Project Manager
BBL
Project Engineer
And Office Services Staff
BBL
Project Certifying Officer
BBL
NATIONAL STARCH AND CHEMICAL COMPANY
CEDAR SPRINGS ROAD PLANT • SALISBURY,
NORTH CAROLINA
COMBINED OU1 AND OU3 PRETREATMENT
SYSTEM
CONSTRUCTION MANAGEMENT PLAN
PROJECT ORGANIZATION CHART
RRL FIGURE
1
•
4.5 Ground-Water Collection System
4.5.1 · General
The Pretreatment System will collect and treat grounp water extracted from both OU I and OU3. Six existing OU I extraction wells, one existing OU3 collection trench and pumping well, and two new OU3 extraction wells will collect area ground water. The new collection trench land pumping well and the two new extraction wells have been designed to promote efficient removal of ground wat~r from area OU3 and operational flexibility. No changes to the pumping from the Trench Area extraction wells), (OU I), will be made. Final Design drawings 8 and 9 detail the design of the ground-water collection trench and pumping well, and new extraction wells NS-49 and NS-51. I 4.5.2 Ground-Water Collection Trench and Pumping Well
The ground-water collection trench is located in the\ ~ortheastern portion of the Site parallel to the Site fencing approximately 25 feet north of existing well NS-45, ~s shown on Final Design drawing I. The collection trench is approximately 200-feet long by a minimum 3-fe~t wide by approximately 14-feet deep. The depth of the collection trench is such that the trench penetrated lhe transition zone which is the most important feature for ground-water flow in the Piedmont. The trench inclLdes an 8-inch-diameter high density polyethylene (HOPE) perforated pipe installed approximately I foot above tHe base of the trench. The pipe is sloped to discharge directly into a I 4-inch-diameter PVC, HOPE pumping weld The perforated pipe is embedded in thoroughly washed crushed gravel, which was used to backfill the trench tb a depth of 3 feet below grade. The crushed gravel within the collection trench is surrounded by a non-woven ge9textile fabric to mitigate the influx of fine sediment into the trench. Backfill above the crushed gravel consists of approximately 3 feet of native soil to grade. Collection ' trench details are presented on Final Design drawing 8.
The pumping well is located at the eastern end of the lllection trench. The pumping well consists of a 14-inch-diameter, by approximately 15-foot-deep HOPE pipb containing one submersible pump and associated level controls. The pump will be connected to a 2-inch-diam~ter PVC discharge pipe. This pipe exits the top of the pump well and transitions to a 2-inch-diameter schedule 40 galvanized steel pipe, which transports the ground water to the pretreatment building. , I
The ground-water discharge flow rate from the pumping well will be measured by a flow meter located in the pretreatment building. Total operating time of the subbersible pump will be recorded on an elapsed time meter located in the pumping well control panel. The pumping well control panel also contains a main panel breaker ' switch, hand/off/auto switch, ready/run light, and a high-level alarm light.
Operation of the pump within the pumping well will mai\ntain a constant drawdown on the water level in the trench ' and thereby create an inward gradient from the surrounding formation. As ground water enters the pumping well, the pump will turn on. The pump will operate until th~ water level is lowered to the pump "off' elevation. As discussed in the basis of design (Section 4.2), the antici~ated flow rate from the pumping well is 3 to 6 gpm.
4.5.3 Extraction Wells NS-49 and NS-51
Existing wells NS-49 and NS-51 are located on the eastern portion of the Site near Lagoon 2 as shown on Final Design drawing I. The construction of these existing wblls is described in the table below .
,~-,. =l, '" ,~ r\P0.0iECIS\NSCC\67]30!l42.R?T --1./1 l,',9
4-4
discharges from the scrubber sump will occur b4ed on elevated levels of salts in the scrubber water. This
wastewater discharge will be routed to Lagoon I. <t:austic addition to the scrubber will be accomplished using a
metering pump to pump caustic solution from thd caustic day tank directly into scrubber sump. The caustic
addition rate will be controlled via a 4-20 mA sig1al sent from a pH transmitter located in the scrubber sump.
Clean vapors exiting the scrubber will be discharge□ through a FRP stack through the building roof.
4.6.5 Caustic Day Tank
In order to provide caustic for pH adjustment in the equalization tank and the vapor phase scrubber, a caustic day
tank will be provided in the pretreatment building by\retrofitting the existing lime mix tank. The caustic day tank
is 5 feet in diameter, with a 6-foot-high sidewall and has a 900 gallon capacity. The tank is manufactured of carbon
steel. The tank will be equipped with a tank level huge and high level alarm. Caustic feed to the day tank is
provided via connection to the existing plant-wide\caustic feed system. Approximately 8,100 pounds of 50%
caustic will be used in the caustic day _tank on a monthly basis.
4.6.6 Instrumentation and Control
The Pretreatment System will be adequately equipped with instrumentation necessary for continuous operation with
minimal operator attention. The Pretreatment System design utilizes the existing NSCC PLC for monitoring and
control. The submersible pump operation at extractio~ wells NS-49 and NS-51 will be controlled via a three-probe
type new level controller corresponding to pump "off, pump "on", and high level alarm. The submersible pump
operation at the collection trench pumping well will be controlled via a four-probe type level controller
corresponding to low level alarm, pump "off', pump 1(on", and high level alarm. Submersible pumps and probes
will be controlled through the local control panels. Alarm conditions will be relayed to the existing PLC.
I
The equalization tank will be equipped with a level indicating transmitter. The discharge flow rate from the
equalization tank will be controlled by a· control valve\ The control valve will receive a 4-20 mA signal from the
level transmitter through the PLC based upon a pro~rammed set point level. Three alarm conditions will be
programmed into the PLC based upon equalization tank level. A low-low level alarm will signal the equalization
tank transfer pump and the influent caustic metering pJmp to tum "off'. A low level alarm will signal the control
valve to close. A high level alarm will signal all well knd sump pumps feeding the equalization tank to tum "off'.
The equalization tank will also be equipped with a \pH indicating transmitter. The ground-water pH will be
maintained via caustic addition from a metering pump. The metering pump will receive a 4-20 mA signal from
the pH transmitter through the PLC based upon a progr~mmed set point of7.0 s.u. Three alarm conditions will be
programmed into the PLC based upon ground-water pH. A low-low pH alarm will signify a transmitter failure and
will signal the caustic metering pump to turn "off' and\a diaphragm valve to close. A low pH alarm will signal a
diaphragm valve to close. A high pH alarm will signal the caustic metering pump to turn "off' and a diaphragm
valve to close.
The low-profile air stripper system will be a prepackaged system with level switches, pressure switches, and alarms
primarily controlled by a local control panel. Three prirliary alarm conditions will be tied back to the PLC. A high
level alarm. low pressure alarm. and high pressure alan~ at the air stripper will all signal the equalization transfer
pump to turn "oft'" through the PLC.
The catalytic oxidizer and scrubbing system will be a prepackaged system with a pH controller, level switch and
alarms. conductivity switch and alarms. temperature controllers, motorized valves, and pressure switches all
controlled through a local PLC. A catalytic oxidizer and scrubbing system "shutdown" will be linked from the local
BLASLAND. B UCK & LEE. INC
engineers & scientists 4-7
•
PLC to the existing main PLC. In the event that theJ is a catalytic oxidizer and scrubbing system "shutdown", the
equalization tank transfer pump and air stripper bloter will turn "off'.
The caustic day tank will be equipped with a level transmitter and a high-high level alarm float. Two alarm
conditions will be programmed into the PLC via output from the level transmitter. A low level alarm will signal
the caustic feed line solenoid valves to open. A higH level alarm will signal the caustic feed line solenoid valves
to close. The high-high level alarm will be linked thr1 ugh the PLC from a float switch. The high-high alarm will
signal an alarm light to indicate that the tank is full.
4.7 Ground-Water Monitoring System
Ground-water monitoring will be performed at the Site to meet the following objectives:
I Expand the database of ground-water quality information at the site;
Compare the ground-water quality to the Perfolance Standards set forth in the ROD;
Evaluate the effectiveness of the ground-water Ltraction system in exercising hydraulic control; and
• Address vertical delineation.
The existing ground-water monitoring network at the Site is capable of meeting all of the objectives listed above
except addressing vertical delineation. As was discu sed and agreed upon in a meeting between representatives
of USEPA, NCDENR, NSCC, and BBL on June\ 15, 1998 in Raleigh, North Carolina and confirmed in
correspondence from USEPA dated July 7, 1998, to aadress vertical delineation, existing open borehole bedrock
extraction wells will be retrofitted with well casings ~nd well screens.
The well screens will span 20-foot-long intervals coLesponding to water-producing zones in the bedrock. The
selection of screened intervals is based on the water-prbducing zones observed during the packer testing performed
I
in the RD/RA Field Investigation and reported in the FISR (NSCC, 1997).
The evaluation of vertical delineation will include the !collection of data on the ground-water quality and ground-
water elevation from the wells. This data will be used in conjunction with the conceptual model to understand the I vertical delineation. The bedrock monitoring wells will be sampled using micro-purge techniques described in the
USEPA Region IV Environmental Investigation Stan~ard Operating Procedures and Quality Assurance Manual
(EISOPQAM)(USEPA, 1996). These techniques will help to ensure that the aquifer is not over-stressed during the
sampling and that the sample obtained is more represeritative of the ground-water quality in the adjacent formation.
I Table 4-2 presents the proposed monitoring well retrofit information. All monitoring well retrofit activities shall
I
be conducted in accordance with the USEPA Region V EISOPQAM (USEPA, 1996). Appendix J presents the
proposed PVP for OU3.
The monitoring well retrofit will be accomplished thr ugh the following activities:
• Tremie grouting with a cement-bentonite mixture ver the open borehole from the bottom of the hole to 2 feet
below the desired screened interval (the cemcnt-bI1·ntonite mixture will be allowed to cure for a minimum of
12 hours);
BLASLP,'-JD, B UCK & LEE INC
~.\f'RG)ECT~\,°\ISCa67280/J4].RPT -t/1 V!9 engineers & scientists 4-8
•
Mike Ford
June 15, 1998
simulation of the aquifer response with he ground-water flow model created for the site.
Hydraulic Evaluation
i\,feasurement of Aquifer Response
On April 27, 1998, BBL installed pressure trans9ucers in wells NS-28 (background), NS-36, NS-40, NS-42, NS-45, NS-46, NS-47, NS-48, NS-50, NS-51 and 1J'1S-52. The pressure transducers were programmed to obtain a measurement of depth-to-water once every 15 seconds for the duration of the test. Pumps were set in well NS-47 at 42 feet (ft) below ground surface (bgs) knd in well NS-51 at I I 5 ft bgs.
On the morning of April 28, 1998 BBL collected J initial round of ground-water elevation measurements from I wells NS-0 IA, NS-02, NS-03, NS-12, NS-I 3, NS1-l 4, NS-I 5, NS-24, NS-28, NS-33, NS-34, NS-36, NS-37, NS-38, NS-39, NS-40, NS-41, NS-42, NS-43, NS-44, NS-45, NS-46, NS-47, NS-48, NS-49, NS-50, NS-5 I, NS-52, NS-53 and NS-54. Additional initial meaJurements were taken for the surface water elevation in the Northeast tributary at NE-0 I and NE-02. \
At approximately 11 AM on April 28, 1998, thel pumps were activated in NS-47 and NS-51. The initial pumping rate for NS-47 was I gpm and the initial pumping rate for NS-51 was IO gpm. At approximately 1 PM on April 28, 1998, the pumping rate in NS-47 fas reduced to 0.75 gpm. This was done to avoid drawing the ground-water level below the intake of the pump.
Hourly measurements of ground-water elevation wle obtained from wells NS-I 3, NS-14, NS-33, NS-34, NS-' 39, NS-41, NS-43, NS-44, NS-47, NS-49, NS-51, NS-53 and NS-54. These measurements were performed for the first four hours of the test. The measurements Jere then obtained every four hours thereafter. Additional manual measurements were obtained from the remdinder of the wells listed above approximately once every four hours. Table I presents a summary of the mariual measurements.
Estimation of Aquifer Parameters
Water level response readings from each pressure transducer were downloaded for subsequent data I reduction/correction and estimation of aquifer hydraulic properties using AQTESOLVE. Corrections to observed drawdown were applied for each well ducl to influences from atmospheric pressure variations and differential recharge, based on water level results Iheasured in monitoring well NS-28. NS-28 is located beyond the inferred area of influence of the pumping 1
1wells, approximately 1900 feet and 2200 feet away from pumping wells NS-47 and NS-51, respectively. Figure I presents the water level response for NS-28 prior to and during the test, and Figure 2 presents a comprrison between NS-28 results and barometric pressure readings performed at the site during the same timerterval.
The corrected drawdown versus time data were evaluated using AQTESOLVE to estimate transmissivity, storativity, and if applicable depending on the part!icular analytical solution, coefficients associated with leakage from adjacent hydrogeologic units. It is assurried that drawdown associated with pumping well NS-47 reflects unconfined hydraulic conditions within the saJrolite. Pumping well NS-51 and observations wells NS-36, NS-40, NS-42, NS-45, NS-48, NS-50, and NSi52, are assumed to reflect confined to semi-confined conditions within the transition zone and fractured bedrock. These associations are based on: I) the site hydrogeologic setting; ii) the well screen/open-hole i~tervals of the pumping and observation wells; and iii) the observed drawdown versus time responses in each well.
I '""~' ~, .. "'" .,,~ ~ ,~, ' '1' Transmitted Via Facsimile
9. '""'I ' " "I ' " "'I 1 "I" I '"'I '' '"! "'I ' till
NS-47
7.2 -Data Set: C:\CJY\NSCC\4 7-CJAQT _,t9 --~-----
ii= Date: 02/11/99 Time: 14:14:12
c • j\o
Q)
E 5.4 -Q) -0 u
C1l
Cl. (/)
0
-0 3.6 -Q) t,
Q)
~ I ~ 0 SOLUTION u --·----------
1.8 Aquifer Model: Unconfined
¥ Solution Method: Cooper-Jacob
ff
T = 32.39J2tday .ifi o:f S = 0.0006342 0. I • I II,!,~ I " ",,I I 101111 ,, .. 1
0.01 0.1 1. 10. 100. 1000. 1.E+041.E+051.E+06
Adjusted Time (min)
AQUIFER DATA
Saturated Thickness: 20. ft Anisotropy Ratio (Kz/Kr): 1.
WELL DATA
AQTESOLV for Windows
Data Set: C:\CJY\NSCC\47-CJ.AQT
At1e: NS-47
Wate: 02/18/99
Time: 10:57:18
AQUIFER DATA
Saturated Thickness: 20. ft
Anisotropy Ratio (Kz/Kr): 1.
PUMPING WELL DATA
Number of pumping wells: 1
Pumping Well No. 1: NS-47
X Location: 4217. ft
Y Location: 8083. ft
No. of pumping periods: 1
Pumping Period Data
Time (min) Rate (gal/min)
0. 1.
BSERVATION WELL DATA
Number of observation wells: 1
Observation Well No. 1: NS-47
X Location: 4217. ft
Y Location: 8083. ft
No. of observations: 102
Observation Data
Time (min) Displacement (ft) Time (min) Displacement (ft) Time (min) Displacement (ft)
1. 0.03 18. 2.032 300.5 6.371
1.5 0.023 18.5 2.081 420.5 6.881
2. 0.275 19. 2.116 540.5 7.123
2.5 0.427 19.5 2.157 661. 7.303
3. 0.416 20. 2.187 780.5 7.405
3.5 0.418 20.5 2.219 900.5 7.457
4. 0.545 21. 2.254 1020.5 7.536
4.5 0.614 21.5 2.284 1140.5 7.582
5. 0.695 22. 2.316 1260.5 7.649
5.5 0.778 22.5 2.351 1380.5 7.73
6. 0.84 23. 2.381 1500.5 7.734
NS-47
AQTESOLV for Windows NS-47
Time (min) Displacement (ft) Time (min) DisplaceTent (ft) Time (min) Displacement (fl) ,a 6.5 0.905 23.5 2.415 1620.5 7.561 '9 7. 0.971 24. 2.445 1740.5 7.884
7.5 1.041 24.5 2.4711 1860.5 7.97
8. 1.101 25. 2.49,8 1980.5 8.061
8.5 1.161 25.5 2.528 2100.5 8.066 I 9. 1.218 26. 2.5611 2220.5 7.82
9.5 1.276 26.5 2.58p 2340.5 8.184
1 o. 1.329 27_ 2 61 r 2460.5 8.198
10.5 1.38 27.5 2.64! 2580.5 8.148
11. 1.428 28. 2.671 2700.5 8.195
11.5 1.474 28.5 2.69t 2820.5 8.2
12. 1.52 29. 2.729 2940.5 8.283
12.5 1.567 29.5 2.775 3060.5 8.309 ' 13. 1.619 30. 2.821, 3180. 8.27
13.5 1.663 30.5 2.87~ 3300. 8.29
14. 1.71 31. 2.92/il 3420. 8.258 14.5 1.76 31.5 2.971 3540. 8.396
15. 1.804 32. 3.019 3660. 8.427
15.5 1.846 32.5 3.061 3780. 8.357
16. 1.887 33. 3.107 3900. 8.387
16.5 1.929 33.5 3.149 4020. 8.374
17. 1.963 60.5 4.623 4140. 8.442
17.5 2.005 161. 6.217 4260. 8.614
LUTION
Aquifer Model: Unconfined
Solution Method: Cooper-Jacob
VISUAL ESTIMATION RESULTS
Estimated Parameters
Parameter
T
s
e
Estimate
32.39 ft2/day
0.0006342
-----------·------------1-------------------02/18/99 2 10:57:18
:;ample ID N:;-00DUP NS'00 DUPDL
Sample Date 05/05/98 05/05/98
Lab ID 10628626 10628626DL
Parameter voes
Dilution Factor 1 20
Chloromethane 10 U 200 U
Vinyl Chloride 11 200 U
Bromomethane 10 U 200 U
Chloroethane 10 U 200 U
1, 1-Dichloroethene 10 U 200 U
Methylene Chloride 6 J 200 U
1, 1-Dichloroethane 10 U 200 U
Chloroform 10 U 200 U
1, 1, 1-Trichloroethane 10 U 200 U
Carbon Tetrachloride 10 U 200 U
Benzene 10 U 200 U
1,2-Dichloroethane 1100 E 2300 D
Trichloroethene 10 U 200 U
1,2-Dichloropropane 5 J 200 U
E!Iomodichlorometha,,e 10-tt---2007J
Toluene 10 U 200 U
1, 1,2-Trichloroethane 10 U 200 U
T etrachloroethene 10 U 200 U
Dibromochloromethane 10 U 200 U
Chlorobenzene 10 U 200 U Ethylbenzene 10 U 200 U
Styrene 10 U 200 U
Bromoform 10 U 200 U
1, 1,2,2-Tetrachloroethane 10 U 200 U
trans-1,3-Dichloropropene 10 U 200 U
cis-1,3-Dichloropropene 10 U 200 U
Xylene (total) 10 U 200 U
Acetone 4 J 200 U
2-Butanone 10 U 200 U
Carbon Disulfide 10 U 200 U
4-Methyl-2-Pentanone 2 J 200 U
2-Hexanone 10 U 200 U
1,2-Dichloroethene (total) 10 U 200 U
Units in ug/1
U -Not Detected
J -Estimated concentration less than the detection limit
E -Concentration exceeds calibration curve
D -Concentration in diluted run sample
Duplicate sample collected from NS-39
-B-2 Ground Water Quality Sampling Results
April/May 1998 Sampling Event
National Starch and Chemical Company
Salisbury, North Carolina
N:;-13 NS-13DL N<:>-14 NS-33
05/06/98 05/06/98 05/05/98 05/05/98
10628675 10628675DL 10628543 10628550
100 200 1 1
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
27000 E 39000 D 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000_U_ __ w•· 10-l:/
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
1000 U 2000 U 10 U 10 U
N<:>-34 N:,-35 NS-36 N:;-~OLJL
05/05/98 05/06/98 05/05/98 05/05/98
10628568 10628683 10628667 10628667DL
1 250 50 100
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 50000 9800 E 7900 D
10 U 2500 U 500 U 1000-U-,o-o--2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
10 U 2500 U 500 U 1000 U
e
::>ample ID NS-37 NS-38
Sample Date 05/05/98 05/05/98
Lab ID 10628584 10628576
Parameter
voes
Dilution Factor 1 1 Chloromethane 10 U 10 U Vinyl Chloride 10 U 10 U
Bromomethane 10 U 10 U Chloroethane 10 U 15 1, 1-Dichloroethene 10 U 10 U Methylene Chloride 10 U 10 U 1, 1-Dichloroethane 10 U 10 U Chloroform 42 10 U
1, 1, 1-Trichloroethane 10 U 10 U Carbon Tetrachloride 10 U 10 U Benzene 10 U 10 U 1,2-Dichloroethane 10 U 10 U
T richloroethene 10 U 10 U
1,2-Dichloropropane 10 U 10 U Bromodicllloromethane ,_ --u-10 U
Toluene 3 J 37 1, 1,2-Trichloroethane 10 U 10 U
Tetrachloroethene 10 U 10 U
Dibromochloromethane 10 U 10 U Chlorobenzene 10 U 10 U Ethylbenzene 10 U 10 U
Styrene 10 U 10 U
Bromoform 10 U 10 U
1, 1,2,2-Tetrachloroethane 10 U 10 U trans-1,3-Dichloropropene 10 U 10 U cis-1,3-Dichloropropene 10 U 10 U
Xylene (total) 10 U 10 U Acetone 10 49
2-Butanone 10 U 10 U Carbon Disulfide 10 U 10 U 4-Methyl-2-Pentanone 10 U 10 U
2-Hexanone 10 U 10 U 1,2-Dichloroethene (total) 10 U 10 U
Units in ug/1
U -Not Detected
J -Estimated concentration less than the detection limit
E -Concentration exceeds calibration curve
D -Concentration in diluted run sample
Table B.ntinued)
Ground Water Quality Sampling Results
April/May 1998 Sampling Event
National Starch and Chemical Company
Salisbury, North Carolina
NS-39 N::>-40 ,.,,-40DL ,.,,-41
05/05/98 05/05/98 05/05/98 05/05/98
10628634 10628642 10628642DL 10628659
25 200 2500 500
250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U
2100 120000 D 110000 D 71000
250 U 2000 U 25000 U 5000 U
250 U 2000-U->-25000-8 5000-t1-
250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U
250 U 2000 U 15000 DJ 5000 U
250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U
250 U 2000 U 25000 U 5000 U 250 U 2000 U 25000 U 5000 U
•
NS-42 N::>-42DL NS-43 N::i-44 05/05/98 05/05/98 05/05/98 05/05/98
10628618 10628618DL 10628592 10628600
250 1000 1 1
2500 U 10000 U 10 U 10 U 2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U 2500 U 10000 U 10 U 10 U 2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U 2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U 2500 U 10000 U 10 U 10 U 2500 U 10000 U 10 U 10 U
130000 E 170000 D 10 U 10 U
2500 U 10000 U <o_u 1-0-V e---2500 U 10000 U 10 U 10 U 2500 U 10000 U 10 U 10 U
400 J 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U 2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U
2500 U 2100 DJ 10 U 10 U
1200 J 6500 DJ 4 J 10 U 2500 U 10000 U 10 U 10 U 2500 U 10000 U 10 U 10 U
2500 U 2400 DJ 10 U 10 U
2500 U 10000 U 10 U 10 U
2500 U 10000 U 10 U 10 U
::;ample ID NS-45 NS-45DL
Sample Date 04/20/98
Lab ID 10606770 10606770DL
Parameter
voes
Dilution Factor 10 · 20
Chloromethane 100 U 200 U Vinyl Chloride 100 U 200 U
Bromomethane 100 U 200 U Chloroethane 100 U 200 U
1, 1-Dichloroethene 100 U 200 U
Methylene Chloride 100 U 200 U 1, 1-Dichloroethane 100 U 200 U Chloroform 100 U 200 U 1, 1, 1-Trichloroethane 100 U 200 U
Carbon Tetrachloride 100 U 200 U
Benzene 100 U 200 U
1,2-Dichloroethane 3100 E 3000 D Trichloroethene 100 U 200 U 1,2-Dichloropropane 100 U 2QQ_II
Brom-ootchlorometnane 100 U 200 U
Toluene 100 U 200 U 1, 1,2-Trichloroethane 100 U 200 U
Tetrachloroethene 100 U 200 U Dibromochloromethane 100 U 200 U
Chlorobenzene 100 U 200 U Ethylbenzene 100 U 200 U Styrene 100 U 200 U
Bromoform 100 U 200 U 1, 1,2,2-T etrachloroethane 100 U 200 U
trans-1,3-Dichloropropene 100 U 200 U cis-1,3-Dichloropropene 100 U 200 U
Xylene (total) 100 U 200 U
Acetone 140 200 U
2-Butanone 100 U 200 U Carbon Disulfide 100 U 200 U
4-Methyl-2-Pentanone 100 U 200 U
2-Hexanone 100 U 200 U 1,2-Dichloroethene (total) 100 U 200 U
Units in ug/1
U -Not Detected
J -Estimated concentration less than the detection limit
E -Concentration exceeds calibration curve
0 -Concentration in diluted run sample
Table siintinued)
Ground Water Quality Sampling Results
April/May 1998 Sampling Event
National Starch and Chemical Company
Salisbury, North Carolina
NS-46 NS-47 N::;-47UL N::;-48
04/20/98 04/20/98 04/22/98
10606762 10606754 10606754DL 10606853
1 1000 10000 25
10 U 10000 U 100000 U 250 U 10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U 10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U 10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U 10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U 10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U
29 630000 E 470000 D 6700 E
10 U 10000 U 100000 U 250 U •Q_JJ_ -10000-ll--1-1 __ V LVV
10 U 10000 U 100000 U 250 U 10 U 10000 U 100000 U 270
10 U 10000 U 100000 U 250 U 10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U 10 U 10000 U 100000 U 250 U 10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U 10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U 10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 180 J 10 U 10000 U · 100000 U 250 U
10 U 10000 U 100000 U 250 U 10 U · 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U
10 U 10000 U 100000 U 250 U
•
""-48UL N::;-49 l\ffi-50 N::;-ouuL
04/20/98 04/21/98
10606853DL 10606788 10606796 10606796DL
50 250 250 500 500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 1800 DJ
500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U
5900 D 36000 96000 E 94000 D 500 U 2500 U 2500__\J_ _5000-U
500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U
230 DJ 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U
500 U 2900 2500 5900 D 500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U
500 U 2500 U 2500 U 5000 U 500 U 2500 U 2500 U 5000 U
;:,ample lu NS-51
Sample Date 04/21/98
Lab ID 10606804
Parameter
voes
Dilution Factor 1000
Chloromethane 10000 U
Vinyl Chloride 10000 U
Bromomethane 10000 U
Chloroethane 10000 U
1, 1-Dichloroethene 10000 U
Methylene Chloride 10000 U
1, 1-Dichloroethane 10000 U
Chloroform 10000 U
1, 1, 1-Trichloroethane 10000 U
Carbon Tetrachloride 10000 U
Benzene 10000 U
1,2-Dichloroethane 230000 E
Trichloroethene 10000 U
1,2-Dichloropropane 10000 U
Bromodicilloremeth .... , ,..., ,oooo--t:J-
Toluene 10000 U
1, 1,2-Trichloroethane 10000 U
T etrachloroethene 10000 U
Dibromochloromethane 10000 U
Chlorobenzene 10000 U
Ethylbenzene 10000 U
Styrene 10000 U
Bromoform 10000 U
1, 1,2,2-Tetrachloroethane 10000 U
trans-1,3-Dichloropropene 10000 U
cis-1,3-Dichloropropene 10000 U
Xylene (total) 10000 U
Acetone 10000 U
2-Butanone 10000 U
Carbon Disulfide 10000 U
4-Methyl-2-Pentanone 10000 U
2·Hexanone 10000 U
1,2-Dichloroethene (total) 10000 U
Units in ug/1
U -Not Detected
Table B-2 (Continued)
Ground Water Quality Sampling Results
April/May 1998 Sampling Event
National Starch and Chemical Company
Salisbury, North Carolina
N<:>-51DL N<:>-52 N<:,-5,j
04/21/98 04/22/98
10606804DL 10606812 10606838
2000 250 250
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 1300 J 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
240000 D 35000 110000 E
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U e--20000-0---:zsoou 2500 U
20000 U 2500 U 1100 J
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
26000 D 2500 U 2200 J
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
20000 U 2500 U 2500 U
J -Estimated concentration less than the detection limit
E -Concentration exceeds calibration curve
D -Concentration in diluted run sample
0
N<:>-53DL N::i-54 N:S-54DL
04/22/98
10606838DL 10606846 10606846DL
1000 50 500
10000 U 500 U 5000 U
10000 U 78 J 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
110000 D 79000 E 82000 D
10000 U 500 U 5000 U
10000 U 5oo_u_ -5000-U-
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
10000 U 500 U 5000 U
Flow Capacity a11dl Friction loss
for Schedlule 80
Thermoplastic Pipe
"1 r,~.48
2 °2,95
5 7.39
7 .1~3J 10
½ in.
4.02 a.be
45.23
83,07
'.1.74
3.48
':19.59
35.97
¾ In."'---
0.71 . 0.86 0.37 •: a •• _
1,57 ·1.12"" 0.74 o.94 · B:aa 0.38
.3.'92 9.6,7 4.19 2.3'1 2.75 ·1.19 s . .;9 17.76 1 69' ,; 3.2a· s:04. · ·. 2:19,
7.84 33.84 14;65., 4.68 9.61 ,. -1.16
15 4 in. 0 ,, 0 11.-76 71.70•-31'.0~ 7.01 , 20.36 <>tt.82
20 0 0.57. 0.04 0.017 " " " .t 9.35 ~ 34.68 . ? 15.Q2.
2S'<, ·o.i2 , 0.06 0;026 '" '5 in. "' 11 ' ·"' 11.69 ' 52.4:i 22:70
ao o:ss a.as ·0.035 .o.54~ "0.03, 0.0-13 .. 1-to3 i'3.4B ., -,~1 .. ai
35 1:00 9 0.11 0.0413 · 0;63 ,0.04. 0.017 •0·~
0.52
1.30
1.B?
2,60
3.90 ·
5.2'o
6:50
7.80·"
'gj()
e
0.21 0.09
,9.66 0.29
1'.21 • 0 0,53
2.30 1'.00
4.87 2.11
0 8.30 3;59·
12.ss 5J13
17,59 ° 7.62 0
23.40 10."fa.
•
0.38 0.10
0.94. ~ 0.30
1.32 'I-; -0,55
.1.86 1.04
' 0.041 0.126 ,o.24~·
0.45
0.56
",0.78
... , 1.12-·
Q < w ",_ Zw ow ~~
" ~
. 0.10, o.15
0.29
0.040
0.065
0.13<>.
0.39
0.54
0,78
0.05'
. 0.07
0,12
0.022
0,032 o:os·2~
0,25
0.35
0.50
•
3_in.
0.02
0.028
0.04
0.009
0.012
.b.017
2.81 2.20 0;95 1.68 · ({P.62·· 0.27 1.17 0.26 0.11 0,75 0.09 0,039
3.75 ° 3.75 1.6.?~.' i2.23., "1~06 0.45 -1-.56', ¥ 0.44 0.19. 1.00,. 0 o.fs o,665
4,69 -, 5.67" 2.46 ., 2.?<J' ·1.60 0.69 1.95 0 00.67, 0.29 o 1.25 0.22 °•0,095
5.63 ;,.7.95 3.44 :.' .3.3!{° .. 2.2s o.97. 2.34 ,o.94 o.~1 1.49' o.31 0.13 ·,
6,57 10,58 4.58 C ~ J,91•'~ 2,99 1.29 2.73 1.25 0.54 1.74, 0.42 0.18
40
~., 45 1.15 0.14 0.061 · u.12 otot ,:, 9.011/ ~
1.29'."' 0'.17 o.of4~ 0.81 0.06 °_ 011~6" _ , ,~··.6:i_f!~ ,, -~ ". ~ .10..49 29_.~7o_, 12.98 Y " -_1 1-t':TO -, _ 31.21 10.1"4 .
, 1.so '13.55 ,-_ s-:87 4 47 _ , 1 83~..66.....-'3.1-22-t-aG0-0:£9 1:W-0:sr--u:~;.-i
8.44 16.85, 7.30 -'5.03 1' 4.76' 0 2.07 .. 3.51 i.99, 0 0.86 2.24" 0.67 ~ 0.29
, AJ I o.2t· 0.091 _ 0.90 0.07 . o,o:,o ·_ .. i0.63 .\ ,~ 0,03
so 1. 12 o.30 ·o:·i3 tO,f· 0,10. o.043 °. 'b:1s -d.04
10 2.01 o.39° o. 11 ° -f.26 0.13.' o.os6 o.88 .: 6.os
.;::~-z~~ 013:po~.0 15.30_0 , 19.61-
;:-. o:022· ,;. ,.0
75 2:JS ,Q,45 0:19 1:35 'Q,14• 0061 0.94 ~o0.06 0,026
, .. BO 2.29 0.50 0.22 1!44 0. 16. 0,069 . Hi'b 0:07. : 0.030
"',90 ·2..sa0 0,5:f' 0.21, ·1~s2 0.20 0.001 ·1.13, o:oa ./0.035
~· 1,008 ~2.87 "·_ 0.76 0.33 ~ 1.B(J'" 0.24~ . 0.1!c) ,,,__,.';· ·!,'25 , 0~1_9 t.:0,013•
125 C 3:59 ... L16 0.50 2,25 Q,37 0,16 ~ q 1.57 0,16 .:0.06{l' 0,90
<150, 4.30 UH 0.-70 • . 2.70' · O.S2 0.23 ·L88 .,., &0;22 -0;095·' '1.07 •
175 s.02 2.1.s0 o.93 03.15 0.69. o.3o 2.26 o.29 oe g.1?~. 1.25
200 °5:73. ~.75 1.19,. 3.ao ~ o.aa' · ~o:3s 2.s1 ""0.37 ·11·0~1'6 1.43
"• 25001 7.16 4.16 1.61 4.50 1.'34 0.58 3.14 ·.., o.5aa· ·o·.24·~ 1.79
~300 8.60 5,83 2.52 -5.40 1.87 • 0.81 3.76 0.78 0.34. 2.14
350 10.03 7.76 3.36 6.30 2.49 · 1.08 4.39 1.04 0,45 2.50
400 11.47 ° ~.93 ·4'.!m 7.'19 '3.18 1.38 5.02 ·. 1,33 °0 0.58. 2.86?
450 8.09 '3.97 1.72 5.64 ·· 1.65 e ~0.71' 3.21
soo O a.99: 4.a2 °2.09 ~;?7 \-2.00 a.a/ --3.57
"'"'1so -., ., ~ 9.40 °,;,,.·,i.2s. .·1.84 '5.36
~~~g ~<> "a
O
C .12.54
0
~~-' ].2}
1500
;Z.14
il.93
~-10.71
o'.045 0.019
U.05 o 0.022
0,075 0.033
o:09 ., o:039
0.14 0.6l.
0.20 • 0.087
0:21
0.34
0.42
0:51
1;08
0.12
0.15
0.18
0.22 0
0.47 ° .
9.~6 20;4'3, P ,;;a.ai'' ,Jsa ,,;;;. '5:79 ; 2.~1 ~ a-,, 3.9(),' 2.42 1:os ~ 2.'49 ·..:o.a, 0.35,
11.26 -?a:10, -1~.43·_~_ 670 a.12 3.'52 4.68" 3.39 1.47 2.99 1.14 o.49~
~' i0 in. c
o.so,'a "'o.036
1.14 J}.045
1,36 · 0.07
1 ,59 ~ _. 0.085
1.81 , 0.11
2.0;4 -· 0 .. 14·
2.27 0.17
3..40 0.36
4.54 0.61
Q5.67 , 0.92
6.80 . 1.29
"'1.i2 s"'10 so"g 4.G-8 5,46 -,4.51 1,95 3.49 1.s1 o.ss,
a3a 11, 12.21 • 5.311 .,. 5.as 5.12 2.22 $~93 ~ 13:83 5.99 t3.E4 -'5.77 2.50
1o~o_s-·_i {1.20 7.45 .... ' 1.02 1.,,rn 3.11
.. 11.-1·1 ~· 20]0 .,.9~0Sc "' 1.80 a.12 3;1a
'0 '! 9.'/5, 13.21 5.72
-0.037 0
0.048'
0.061
0:074 o,m·.,
0.26
..
1.12
1:28
.1Ai1
1.60
2.40
. --11.70 ° 18.48 8.00
,1 F'i~l. . -· .o:q;,-,7
. 0:0'5 °
0.06
"'0.07 ,, b,1s
0.016 it
.,0.022
,!).026,
0,030
0.065
0,26.,,c 0,11 ~
0.40 0.17~
3.74
3.99
~ 4.48"
C 4.9a:"'
6.23
' ' 0
7.47
. 8.72
9.97
12.46
.q, 0.74
1.94 0.84
2.41 1,04, )
, 2;,93, .. L27 ·
4.43. t.9:t
6.20 ~ 2.68
I).26 3.58 ·
10.57 4.58.
16.00 ·6.93
2000
2500"
1.84
"2.1a
3'.89
~0.80
1.20-
0 (68
• 0
,,',9_.3047 '2.19 . -3.33
0_.0.40
0.56
0.95
1.44 °
0.55 0.24_
3.20
.4.0f ·~:,
4.81
6.41
8.01
0.94 " 0.41,
'.,_ 1:42 0.62i ..
3000
3500
;400Q, 0 ' 0 ... :fl ·..,.., •
9.61
11.2~
12:82
-; 1.99 0.86.0 ••
2,ps -1.1s
3.41. _ 1;4a
• • •
Talble 9
Equivalent length of Pipe, Feet
¼" 1" 1¼" 1¼" 2" 2¼" 3" 4" 8" 10" 12"
. . ----. --... .. . .,--' ,O . . Wilh no otSuucUOn J11 flal, . , 'c . . IJeve!, ~f p!U(l _type St;i!! .,. . Fully Open , "10.3 ~11.s-" . 23 3 . '29.7 39.1" ''4fi.6 • · 58.§ 69,95 130.!:l 114.1 171.8 226.1 283.9, ,338,2 •. , .,. ' GonventiOnal . . •
Wilh wing or pin 9uided disc Fo)IY Open 13.7 ,23.3 30.9 39.] ;11.8 , 60.4 77.5 92.6 115,1 151'.0 227.4 299.3 375.8: 447.7 ·, H ' . . . GLOBE ' (No obs1ruc\fon in ilaf, . • VALVES Uevd or µluy l1,•pe seal) .. . -· 0
-Wi!h stem 60 degree:; ·,
F1_1IIY Open ' Y-Paliern ,''· !rum'.run ol 11iµc.li1ic 0
_. . ., 5.3 9,1•. . 12.0 15.3 20.1 '23.5 30,1 36.0 44.7 ° 58.7 '88.4 116.4 146.1 174,1 . .
' -:-·With tiem 45 de~mes ' , .
' 0 0 from rua -of pipe· lina ;, ., Ft1Jly,Open . 4.4 7 ~5 IO.0 12.7 16 7, 19:5 25.0 . 29.8 3(,1 ;~a.s • ?3.3 f -· 96.4 121.1 14-1.~ ' .. · . • . ~ . . .. . . ' . ·" . . With no obstruction-indlal; .. • .. . 0 . .
b~vel, P}ll!l tyj)e t"ea.1 o. ;4.4 ANGLE 0 Fully Open 7,5 10.0 12.7 16.7 19.5 25:0 29;8 37.1 48.6 73.3 96.4 121.t 144.3
' CDrlVf:!lliOn<l[ .. . VAI.VES . 0 111f'UT7)i1rguidim .. t-ully upen 0.1 ·•10.4 . 13.7 17,5 23.0 26.8 34:5 •\ 1~2 51.1 '67.1 101.1 133.0 167.0 199.0 . .
, . . ~ .. . ;,o ' o.s' . '.Ii'' 'fl!,JIY open 0.4 07 , 1.1 1.5' 1.7 2.2 2.70 3.3 4.4 0.6 8.6 10.9 12.9
Conventional • Th'rc!·Ouar~Crs Open 1.8 2.4 4:0 _<.7 .. 7.i '.l4.6 GATE Wedge Db;c!> . .. .. 0 .1.1 3;1 6.0 8.9• 1\.7 17.7 ~ 23.3 29.2"'
0 . . VALVES dlbl Disc, 01 . One-Hall Open • 4.9 8.3 11.9 14.0 18-4 21.5 27.6 32.9 40.9 53.7 80.9 106.4 133.6 159.2 Plug Dis'E . . .. One-Quarter Open 27.3 45.7 61.8. 78.7 103.5" 120.8 155.0 185,2· 231l.1 302,0 ·454.9 598.6 751.5 895.4 . . •
BAU.,, . "•"',
Chcmlrol fulHod Ot•sign Fully Open Same as an CQuivalcnt of Sch. 60 Pipe VALVES .. . . so• Sianllard Elbow . . 0.9 1.6. 2.1 2.6 3'.5 4.0 5.5 6.2 7.7 10.1 15.2 20.0 25.1 29.8 .. .
45• Standard ElbOw 0 . ,. ' 0.5 0.8 1.1 1.4 1:a 2.1 2.8 '3.3' ~.1' 5.4 8.1 10.6 13.4 15.9 .. • .. .
sp• Long Radius Elbow . 0:6 1.rr 1.4 1.7 2.3 2.7 4.3 05.1 6.3 08.3 12.5 16.5 20.7 24.7 . . . . • . ..
FITTIUGS 90" :5treet ~!!low . 1.5 2.6 3.4 4.4 5.8 6.7 8.6 10.3 12.8 16.8 25.3 0 33.3 41.8 49.7 . ' •
45" Street Eioow . . ' . 0 o.a 1.3 1.8 2.3 3.0 3.5 4,5 5.4 6.6 8.7 13.1 17.3 21.7 25.9 . 0 . 3_0-', Squaw C0mer Elbow ' ' 1.7 3.S 5:0 6.5 7.6 ... 9.8 11.7 14.6 19.1 28.8 0 37.9 47.6 '56.7
,, . .. . 0 . With Frow ihrnugh run ' 0.6 1.0 ... ~. ,,
5.11 16.s
0 S1a-nda1d 1.4 1;7 2,3 2.7 •1.3 '6.3 8.3 12.5 ~ 20.7 24.7
lee . With_ Flo1·1 Unouyh bf,mcif • 6:9 0
" . 1.8 4 0 , 5.1 6.0 ~ '· l 12 14:3 16.3 22.1 32.2 39.9 50.-1 59,? ' • . • ., .. .... ; "I,, . , l ' ' . . f,: . . '
Lldld
FLOW OF WATER THROUGH SCHEDULE 40 STEEL PIPE
Pressure Drop per 100 !eel and Velocity In Schedule 40 Pipe for Waler al 60° F Discharge Veloc• Preu. Veloc-Preu. Veloc-Prttl. Veloc• Ptns. Vtloe--· ,_ Preu. Vtloc· Pus,. , .... -"' D<op '" Diop '" "" "' D<op "' D<op '" D<op "' O,op "' "" ..... """" Fe,, "" F~I '°' Fw "' Fool u,, F"' u,, Fool u,, Feel lbs Fool u,,
.e:i. ..: .. "'' "' "' pe, "' "' "' ,.
,. 0~ ,. ..,
~~n. "" ,. """" ~. ~-Second c:,, In -~-Second "~. In Second Sa.In Secord .In.
118" 114" 318" 1/2" ., -~ ,.13 <N 0616 o= o, 0~ "' '" O~• o= 0~ D 1~9 0317 o~• 314" o• o-• ,,. ON '" ' .. oon o~• om 0-o• 000\11 m "' ·~ ,,, 0-o= o"' 0167 ooo, o= .. 0001)4 ,,, ", <M ,~ '" 07~1 o= "~ o~, 0.041 .. 000178 . " ,so ,~ '" ·~ ',, 0-·-o"' 0.102 1" 1 114" ' "'"" -~ "' ,~ . " <N ,M ·~ , .. ,-"" 0371 ,_ 1 112" ' ,_ "~ '"' "' "' ,~ ,,. 2.1\ 2.10 ·~ '"' O.74l "" "~ ,_
' ,..,. "' .. , -~ "' "' ·~ 1.81 ,m 1.114 o= ,-OM om '~ • ,_,
2" "~ 1112 "' "' w ,., ,., ... , 1_4g '"' o= 0.1!SO "" 0,071 ' 001114 ... ~· ,,. '" '" ,,, , .. •o= 1.073 •= "" O<N • 001lJ7 0~74 0-2 112" "~ "' on ". '" ON '" 1.17 ,,, ,-0-0.1"5 • 001782 OOM oon "" '" ... 27,7 '" -~ a, '" ,.n 0.511 ,,. ~ .. " """ ·-.. ~ "" ,_ 3" ". .,, -~ ... .,, '" "' om '" ., .. " ·-'" -~· ' " .... 3112" ,m ". rn ·~ "' •-~ ,,, "" " 0-"' "" "' "" .... o= ,om '" , " "' .~ ,,. '" .,, " o=• ,,, 0.561 <Y o= 00 , .. 0812 0.0u 4" ,,. '" ,,, "' OM ,.a ,. ,_ "' ""' '" ,~, <M 0114 0974 ,_ 11,14 n, '" -~ ,n on " 00119t '" '"' '" o,» '" O 1)1 1.14 001' ,.., 0.041 "" ~, , " ,oo '" , .. .. 005!2 '"' '" '"' "" 1.14 0192 '" ·-' " o= ""' ", rn 1024 '" . ., ., "= rn 1.67 "' o= '"' •= '" 0.117 1.13 '"" '" ""' '"' >M " 0.1114 "' ,m "' o= rn ·~ '" "" ,,. 0.071 5" 1074 ,OM '"' 7.15 " 01337 , " 2.81 ·~ 1.18 ,.oo "" '"' "" 1.51 0.107 " .. m '" 10.21 " "= ' " , .. ... ·~ ,~ o= "' oo,, '·" ..., 1.12 0,047 ""' 13.71 " 01782 ,~ .,, >» '" w ow ·~ ,.= "' ""' "' •= "" 17.59 ,. ,~ -~ ,,. ,m '" '" '"'' ,~ 0.411 = o~• '" 0074 6" .. ~ "' ,,. '"" .~ "' . " '"' ·~ '"' ,~ ,,. '" o,n ,.oo ,_ UI o= "" ,., "' 0270$ II 91 11 76 '" "' '" ' " ·~ o ... "' 0415 2.01 0.1~ '" '"' "" ... "' "'" 14'.16 16 10 10 05 ... '" ,,. "' •-~ ,n '"' ,., "" U1 oon "' ""' lb/~ m "" .., ,oo ,oo ON '" ... 0.774 "' "" ,.M 0.ID:f 8" "' .... . 044!,t 1\114 ,., IH2 "" ON '" ... '"' ·~ .... ,,, "'' '" 0.1JO "' ., '! 0!.013 ""' .. " '" ,., , " ,~ ,., "' 3.11 0.401 ,~ 0.1112 '" ··~ !~•-:,., 0.!>570 <OM ,,, . " , .. '" , .. , 4.01 •,O.~ rn •0.111:5_ 1 '°· '. 0.0111; • 0&127 "" 1.14 rn , .. ,,. '·" , 4.41 ""' 3.05°\ 0ZM 1.l'8.:,0.0ll1 ,.. o .... "00 '" "' ·~ '" "' UI •--3.33 :~0215 !::!~):.: lSO:' ~ :; . 0.71'911 !1,l!; "' '"' , .. '" 0.,1, u, I 0.3$7 • 400 ·•-:,: -0.1512 12.98 •m "~ , .. ,.,_ • 1.11 4.'4•,, 0.471 ~=·,:;-~:~ ,so ,-,moo 10''. 14 61 ... 11.:14 •oo '" '" ·,-;::t::-·.::c.-' ) .. ,, ~--:~:i:-~::-: ,oo'{'._ ~ I 114 ,m .... 12" "00 , .. -~ 1.BI l.21 -'0..lln &00' ·" _. ___ 1.337 '" ... 15 12 -~ '" "' B.511 • I.D:f "3M .' 0.258 ~):. :::.., 1.560 2.es · 0..112 2.01 ·~· 14" "" "' ,.,. -,~ ... . ,.,., (: i-= = • 0.1'3 ,,. '"' ""' .., ... '·" 5..13 • ·~ "' ·. , .. • 0.171 '" 0,01$ rn 0.047 16" "" '" -~ l.18 ,.n "" 1000 , .· •. 2.221 .. , 0.218 "' 0.0511 "' o.~1 .. ~ OM 11.10 ·~ ... .. ,, '"' . . 2.174 ... -'" .. ~ OM '"' 2.11 '·"' 13.33 "' ,,. ,_
"" 3.119 ,_,. ·-4.01 0.111 "' 0.107 ,~ ,.,,
18" <SM $.1J ·~ ·~ ·-'· ,,,, '" •= ... 0.219 ,n 0.138 ,,. .~. ,1.n .. , "" , .. "" 4.010 ,~ ,.., "' .,,. .,, o.,n "' ·-'" 0000 "" "' 11.Sol ,~ zooo·' .... ... ... ,n •= 4.74 •= ,~ O..J01 "' o"' "" 10.J "~ OM
□ an 7~ 1 ~ 2 (Jj 3~ 48 58 68-
Valve & Fitting Losses In Expressed In Equivalent Feet of Pipe
Pipe fitting NomlntJ Pipe or T11bl Sue (lnehn) orvu.r, ,. '" .. 11/4 "" 2 "" 3 "" to• Sland•1d (Ibo• " " " " .. " ,o ,., .. " " " ,.
4,• S1anda1d (Ibo• . ,, .. " " " '' " " " ., " " " " Flo••fhrough lranch Tu " " .. " " " " " " " " ~ ~ ~
Slrolghl ThlOugh Flo• Tu · Ho Roduc1lon " " " " " " .. '' " ,, " " " 51rolghl n,ough Flo• T••• Reduud 11' " " " " " ,., " '' " .. " " " • 51r•lght Through Flo•, .. · A•ducod 111 " " " " " .. " .. ,, .. " " " ro
' Globe Vol .. · fully oponod " " ll ~ ~ ., M .. M ,oo ,ro ·~ ,oo = • Ool• Vol .. • Fully oponod " " " " " .. " " " .. " " " "
~ '~ h i:
I
Lonvers1011s & tqu!u
Flowrate Nozzle Exp;itw,
Serles
0= K(PSh1 " ,~
cw "' ~=+ft.. ,~
PS/•(~)11' " ,~
" -~ ------Vess11I with internal pressure: -~
GPM=K (PSI.-.-PS/v...,u,)·1 "" -~ o, ( PSI,)' •• ' .. 0, PSI, -~ ·-------·-" "' Oropslze System Design
!!,_ a("')-OJ PS/Pump = PSINaulB -t PSIP,p,,L<J.SSBs
Di Pi
Conversion Data ·-· ___ !0 OB!_~IN MULTIPLY BY -------
atmospheres 1 013 "" almosph8feS ~~· l<l<lto1 water
atmosphefes ·= ],.g/cml
atmospheres 101 J klloPascals (kP~) -
atmospheres 1•6911 "" ----·· ---. ..., ,oo "' .. -----___ ,. __
""' ,., "' -----· ·-·-------· ---
barrols (011) ., -g,dlcu,s -· -------·-·
cen!lme!l!fS o=• inches
cenhSlokes ...... cenhPois&
=' o~• •' =' 0~ ''"""' =' 0.IXl1 """ ,,, •= •' ,,, ·-m' ,,, 'q ,_, ,,, n~ 11\ers
tt3(wa1er) "" pounds (wale,)
•' .. ~ =' •'
,_
gallons
•' 0.16-! li18fS
m' "" ,,,
m' 61.016 •' m' ~· , ....
m' ·= ~!e,S
degr1111 (angle) 00 minutas
clegr&e (Celsius) ('"C•lBf,32 degr1111 (fahrenheil)
degree (Fahrenheit) rF-32)•056 oagr1111 (Celsius)
100, ·---100.,.., »d cenume\el'Slsec
Trrms .ind Conditions.
l'n,.~'1"'-"-'l•,..IUH.~.MA.T...,....el,._/10....,.lO.S..y,1«•~"'·
<ounb..M-........i.,,-•'2!1.IXI--A ...-~cho<tft<>I 1~-.. ,.111.pplyl«ota...S.nl pnJu<1 o«wp<,d h ......,,.. up tu...,. yu, f""" 11>, J,to <>I l"'"-i..., ~El~ l'l)C NI lill l ~<i,,righ< ~,.i..,~ -""r,otl-d.,.Kn>Un•~ "-"~•'"'• IN1 l.-<Yt>onW w"h-...,, ~ •ut.........,bun N""'S<,u,,,urJ"""'•r.-...t>"'1~•orluln
'" 00
"" . ., .el>_ "' "' t 144 HCSQ "' " ,~
Conversion Data
MUl.111'1..Y BY ___ ------·-
_ looVSOC _____ UN
1w1olwatur ·--------
loot or wa!11r 0-
1001 or water ow
gJHons JIIS:, -----
ualloo~ 0 !lJ1 -· •-I
l)Jllou~ ,,~ --------
gallom;tmm 0-
imperial gallons " hofsepowe, 1014
horaopowm ~= -~ oq -,~
'9'=' "" kiloWal!s ·-~l11rs •=
~tars ,~
•m• -~ .... ~-metarl ,n,
mic;rOns (µm) ,_
"'""" "'
mileSJhr 'q' -... ... ,_
"'
,_
-----··-
"' ·-"' '"' ----·-
"' "~
"' ·-BH~ RlG NU/.Zl.1....,.., 11w "&"' ... .,..~,,._ ..... ,, Hnww>llluut......._w lllu>l••->ho.•wnlloW.c,i.~o1, Wan .. ty-.U~....J,.,.w,.,o-.Jt.,,.,....._k.,.,..1
,i.n.J..o,J ,...t w,U f""lunn •n ..,..,.J • ..,.w.wlth 11w fon.lU• ll•ll-,io.-, ti.~illty -BHt', l"l•h')" ..... u b.lom,k,l' '""""'"""•r,,ni.....,.-....
I> ••·. /.·.· .· i it~iri >··•···. Ii .··.••·i<N'sL,9_ \ <I .• NS-51 i\• I
Diameter (inches) 6.0 6.0
Top of Casing Elevation 767.0 765.0
Well Depth (feet below top of casing) 115.5 117.6
Screen Interval Elevations 722.5 to 653 .4 72 I .5 to 652.5
Casing Interval Elevations 767.0 to 722.5 765.0 to 721.5
Pump Intake Elevation 650.0 647.4
Pump Off Elevation 655.0 655.0
Pump On Elevation 740.0 740.0
High Level Alarm Elevation 758.0 758.0
Note: Elevations listed as feet above mean sea level.
As ground water enters the wells, the pump will start at the elevation shown above. The pump will run until the
water level is lowered to the pump "off' elevation. If for some reason water level within the well reaches the high
level alarm elevation, the corresponding alarm will be activated.
The following is a summary of equipment, associated with pump operations within extraction wells NS-49 and NS-
51.
Equipment (per we/I)
1. Pumps
Number:
Pump Sizing:
Manufacturer:
Model:
Type:
Electrical:
2. Probes
20 gpm at 225 feet of TOH
Goulds
18EI0.434
Submersible pump
I hp, 460 Volt, three phase
Number: 3
2.3 Ground-Water Treatment
Impacted ground water pumped from the ground-water collection system described in Section 4.5 and the existing
OU I ground-water collection system will be combined and treated in the existing pre-treatment building. As
described in the l'inal Design Report basis of design (Section 4.2), the Pretreatment System will consist of
integrated, pre-engineered packaged treatment equipment designed for treatment of both the liquids and vapors.
Major Pretreatment System equipment includes: the existing equalization tank, a low-profile air stripper, and a
vapor phase catalytic oxidation and scrubbing system. The Pretreatment System is designed to run continuously
BLASLAND. BOUCK & LEE. INC.
'19/81369.RPT --UI 1n'J engineers & scientists 2-3
•
Odor
Substance IP' Threshold
[CASI (eV) (ppm) ROuteb
Acetone 9.7 13-100 lnh
Ing
167-64-1 I Con
Bromodichloromethane NA NA lnh
Ing
Con
Carbon disulfide 10.08 500 lnh
Abs
Ing
[75-15-0[ Con
Chloroform 11.42 133-276 lnh
(trich1oromethane) Ing
Con
[67-66-3[
Chloroethane 10.97 NA lnh
Abs
[75-00-31 Ing
Con
1,2-Dichloroethane 11.05 lnh
(ethylene dichloride) Abs
Ing
I 1 07-06-021 Con
Refer to footnotes at emf of table.
Table 3-1 Chemical Hazard Information
Symptoms of Exposure Treatment
Irritated eyes, nose, and Eye: Irrigate immediately
throat; headache, dizzi-Skin: Soap wash immediately
ness; dermatitis. Breath: Respiratory support
Swallow:
Immediate medical attention
Irritation of eyes, nose, Eye: Irrigate immediately
and throat; drowsiness, Skin: Water flush immediately
lightheadedness. Breath: Respiratory support
Headache, dizziness, Eye: Flush immediately
restlessness, low Skin: Wash area immediately
weight, psychosis, -Breath: Respiratory support
Parkinson-like
symptoms, heart, liver,
kidney damage, skin
burns, reporductive
effects.
Dizziness, mental Eye: Irrigate immediately
dullness, nausea, Skin: Soap wash immediately
disorientation; Breath: Respiratory support
headache, fatigue; Swallow:
anesthesia; liver Immediate medical attention
enlargement; irritated
eyes, skin.
Carcinogenic.
Incoherence, inebriation, Eye: Irrigate immediately
abdominal cramps, Skin: Soap wash immediately
cardiac arrest, liver, Breath: Respiratory support
kidney damage. Swallow:
Immediate medical attention
Depressed central Eye: Irrigate immediately
nervous system, Skin: Soap wash promptly
nausea, vomiting, Breath: Respiratory support
dermatitis, irritated Swallow:
eyes, corneal opacity. Immediate medical attention
Carcino enic.
1
TWAC STELd
30ppm
10 ppm
•
• • •
Chemical Exposure Information
Odor
Substance IP' Threshold IDLH
[CASI (eVJ (ppm) Routeb Symptoms of Exposure Treatment TWAC STELd Source• iNIOSHI'
1,2-Dichloroethylene 9.65 17 lnh Irritated eyes and respi-Eye: Irrigate immediately .... :200 ppm PEL
Ing ratory system; Skin: Soap wash promptly :· 200 ppm TLV
[540-59-0) Con depressed central Breath: Respiratory support 200 ppm./. REL
nervous system. Swallow;
Immediate medical attention
Dichloropropane 10.87 lnh Irritation of eyes, skin, Eye: Irrigate immediately 75 ppm PEL
Abs and respiratory system. Skin: Water flush immediately
[78-87-51 Ing Drowsiness, light-Breath: Respiratory support
Con headedness, liver, Swallow:
kidney damage. Immediate medical attention
Ethyl benzene 8.76 0.09-0.6 lnh Irritates eyes, mucous Eye: Irrigate immediately 125 ppm PEL
Ing membranes; headache; Skin: Water flush promptly 125 ppm TLV
[100-41-4) Con dermatitis; narcosis, Breath: Respiratory support 125 ppm REL
coma. Swallow:
Immediate medical
attention
Methylene chloride 11.32 lnh Fatigue, weakness, Eye: Irrigate immediately Cl,000 ppm; PEL
(dichlornrnethane) Ing sleepiness, lightheaded-Skin: Soap wash promptly C2,000 TLV
Con ness; numbness and Breath: Respiratory support ... mg/m3
(75-09-2( tingling in limbs; Swallow: '' .. (5 min in REL
nausea; irritated eyes Immediate medical attention 2 hrs)
and skin.
Methyl ethyl ketone 9.54 2-85 lnh Irritated eyes and nose; Eye: Irrigate immediately 300 ppm PEL
Ing headache, dizziness; Skin: Water flush promptly 300 ppm TLV
178-93-3] Con vomiting. Breath: Fresh air 300 ppm REL
Swallow:
Immediate medical attention
Refer lo footnotes al end of tabk.
2
-Substance (CASI Toluene 1108-88-31 1, 1,2-Trichloroethane (methyl chloroform) (71-55-61 T etrachloroethene 1127-18-41 Trichloroethylene (TCE, trichloroethene) 179-01-6) IP-leV) 8.82 11.0 9.32 9.45 Refer to footnotes a1 end of table. Odor Threshold (ppm) 0. 1 6-37 390 NA 21.4 Routeb lnh Abs Ing Con lnh Ing Con lnh Abs Ing Con lnh Ing Con e Chemical Exposure Information Symptoms of Exposure Fatigue, weakness; con-fusion, euphoria, dizzi-ness, headache; dilated pupils, lacrimation; ner-vousness, muscular fatigue, insomnia; .e_araly_sis; dermatitis. Headache, lassitude; central nervous system depression, poor equilibrium; irritated eyes; dermatitis; cardiac arrhythmia. Irritation of eyes, nose, throat, nausea, flushed face, vertigo, dizziness, headache, liver damage Headache, vertigo; visual disturbance, tremors, somnolence, nausea, vomiting; irritated eyes; derma-titis; cardiac arrhythmia, paresthesia. Carcino-enic. Treatment Eye: Irrigate immediately Skin: Soap wash promptly Breath: Respiratory support Swallow: Immediate medical attention Eye: Irrigate immediately Skin: Soap wash promptly Breath: Respiratory support Swallow: Immediate medical attention Eye: Irrigate immediately Skin: Soap wash promptly Breath: Respiratory support Swallow: Immediate medical attention Eye: Irrigate immediately Skin: Soap wash promptly Breath: Respiratory support Swallow: Immediate medical attention 3 TWAC .. __ 1 oo ppm .. · 5·0 ppmJskiri):=· 1oo·ppm · · STEL0 150':ppm · 150 p;.;, -Source• IDLH (NIOSH)'
•
Odor
Substance IP" Threshold
[CASI (eV) {ppm)
Xylenes 8.56/ 1.1-20
(o-, m-, and p-isomers) 8.56/
8.44
I 1330-20-7;95-4 7-6;
108-38-3; 106-42-3]
Vinyl chloride 9.9 25 ppm
~Ip = Ionization potential (electron volts).
Routeb
lnh
Abs
Ing
Con
lnh
Con
e
Chemical Exposure Information
Symptoms of Exposure
Dizziness, excitement,
drowsiness, incoordin-
ation, staggering gait;
irritated eyes, nose,
throat; corneal vacuo-
lization; anorexia,
nausea, vomiting,
abdominal pain; derma-
titis.
Drunkeness, dizziness,
weakness, abdominal
pain, GI bleeding,
nl ,
Treatment
Eye: Irrigate immediately
Skin: Soap wash promptly
Breath: Respiratory support
Swallow:
Immediate medical attention
Eye: Frostbite
Skin: Frostbite
Breath: Respiratory support
~Route = lnh, Inhalation; Abs, Skin absorption; Ing, Ingestion; Con, Skin and/or eye contact.
•
Source•
PEL
. TLV
REL
PEL
IDLH
{NIDSHI'
cTWA = Time-weighted average. The TWA concentration for a normal work day (usually 8 or 10 hours) and a 40-hour work week, to which nearly all workers may be repeatedly exposed, day after
day without adverse effect.
0STEL = Short-term exposure limit. A 15-minute TWA exposure that should not be exceeded at any time during a workday, even if the TWA is not exceeded.
•PEL = Occupational Safety and Health Administration (OSHA) permissible exposure limit (29 CFR 1910.1000, Table Z).
TLV = American Conference of Governmental Industrial Hygiene (ACGIH) threshold limit value-TWA.
REL = National Institute for Occupational Safety and Health (NIOSH) recommended exposure limit.
1IDLH (NJOSH)-lmmediately dangerous to life or health (NIOSH). Represents the maximum concentration from which, in the event of respirator failure, one could escape within 30 minutes without
a respirator and without experiencing any escape-impairing or irreversible health effects.
NE = No evidence could be found for the existence of an IDLH (NIOSH Pocket Guide to Chemical Hazards, Pub. No. 90-117, 1990).
C = Ceiling limit value which should not be exceeded at any time.
Ca = Carcinogen.
NA = Not applicable.
? = Unknown.
LEL = Lower explosive limits.
LC50 = Lethal concentration for 50 percent of population tested.
LDr,0 = lethal dose for 50 percent of population tested.
NIC = Notice of intended change (ACGIH).
References:
Refer to footnotes al end of iable.
4
Chemical Exposure Information
American Conference of Governmental Industrial Hygienists Guide to Occupational Exposure Values, 1991, compiled by the American Conference of Governmental Industrial Hygienists.
Amoore, J. E. Hautula, "Odor as an Aid to Chemical Safety," Journal of Applied Toxicology, 1983.
Clayton, George 0., Clayton, F. E., Patty's Industrial Hygiene and Toxicology, 3rd ed., John Wiley & Sons, New York.
Documentation of Tl Vs and BEls, American Conference of Governmental Industrial Hygienists, 5th ed., 1986.
Fazzuluri, F. A., Compilation of Odor and Taste Threshold Values Data, American Society for Testing and Materials, 1978.
Gemet, L. J. Van, Compilation of Odor Threshold Values in Air and Water, CIVO, Netherlands, 1977.
Gemet, L. J. Van, Compilation of Odor Threshold Values in Air and Water, Supplement IV, CIVO, Netherlands, 1977.
Lewis, Richard J., Sr., 1992, Sax's Dangerous Properties of Industrial Materials, 8th ed., Van Nostrand Reinhold, New York.
Micromed'ex Tomes Plus (R) System, 1 992, Micromedex, Inc.
National Institute for Occupational Safety and Health Pocket Guide to Chemicals, Pub. 1 990, No. 90-11 7, National Institute for Occupational Safety and Health.
Odor Threshold for Chemicals with Established Occupational Health Standards, American Industrial Hygiene Association, 1989.
Respirator Selection Guide, 3M Occupational Health and Safety Division, 1993.
Verschuseren, K., Handbook of Environmental Data on Organic Chemicals, Van Nostrand and Reinhold, 1977.
Warning Properties of Industrial Chemicals-Occupational Health Resource Center, Oregon Lung Association.
Workplace Environmental Exposure Levels, American Industrial Hygiene Association, 1992.
Refer to foomotes at end of table.
5
•
•
•
3.3.2 Air Stripper Cleaning
During operation, dissolved minerals (namely calcium carbonate and iron) may precipitate out of the water onto the air stripper trays. These minerals form insoluble deposits that can "foul" the aeration openings in each tray. "Fouling" may cause higher than normal operating air pressure within the air stripper unit. In order to prevent fouling of the aeration trays, the trays should be periodically pressure washed. Pressure washing of the air stripper aeration trays and sump with a dilute acid solution should be conducted as necessary to maintain normal operating air pressures within the air stripper. Access to the air stripper trays is made through clean out ports located on each end of the air stripper trays. Normal cleaning operations can be accomplished via the access ports therefore removal of the air stripper trays is not necessary.
3.3.3 Catalytic Oxidizer and Scrubbing System
. The catalytic oxidizer and scrubbing system is designed to operate with a minimal amount of maintenance. The following general maintenance should be performed as noted.
I. Fan
• Check and clean fan wheel quarterly. If worn out or out of balance, contact manufacturer. • Check air proving switch for proper operation by increasing set point until switch trips.
• Check inlet filter every 1,000 hours of operation. Clean or replace, if required.
• Inspect belt for proper tension monthly or 2 to 3 days after any belt replacement.
2. Controllers
• Check and adjust controllers quarterly. Calibrate transmitters, as necessary.
3. Burner
• Inspect flame rod and spark ignitor quarterly. Clean if necessary.
• Inspect burner air distribution plates yearly for excessive warping or breakage.
4. Fuel Train
• Check main shut off valve for leakage semi-annually.
• Check high and low gas pressure switches. Verify proper operation by adjusting set point up or down until
the switch opens.
5.
• Verify that all gas pressures arc within previously recorded parameters.
• Check operation of firing rate valve and actuator. Use controller manual mode to run it through its full stroke. Check linkage for binding, slippage, wear, and corrosion. Replace, if necessary.
Catalyst
• Inspect catalyst semi-annually. clean if necessary with high pressure air or a vacuum.
• Inspect catalyst gaskets for proper seating.
• Remove catalyst plug yearly and send it in to the catalyst supplier for testing .
• I nspcct catalyst access door gasket for proper seating.
• Check catalyst modules yearly for fouling or discoloration.
BLASI.AND. BOUCK & LEE. INC. 'J'l7Rl]69.l<Pf ·-l/1{,')'.I engineers & scientists 3-3
I
•
3. CQA Requirements
3.1 Site Preparation
The co111bined OUI and OU3 Pretreatment System will be located in the existing OUI pretreatment building. Currently located in the pretreat111ent building are process equip111ent, electrical, controls, and piping not related to the re111edial design. Therefore, the OUI pretreatment building will be retrofitted to enclose the new Pretreat111ent System by removing all unrelated equipment, electrical, controls, and piping, and installing a I 0-foot by 16-foot roll-up door.
Site preparation activities also include the modification of existing extraction wells NS-49 and NS-51 and piping. Well pu111ps will be installed into each of the two extraction wells and will be controlled by intrinsically safe contact probes and local control panels. The wells will discharge to a 2-inch schedule 40 galvanized steel pipe. The discharge pipe will run aboveground on a new pipe rack system to the pretreatment building.
A collection trench was installed at the northeastern portion (Area 2) of the site in October 1998. The collection trench is approximately 200-feet long by 3-feet wide by 14-feet deep, and includes an 8-inch-diameter high density polyethylene (HDPE) perforated pipe installed approximately I-foot above the base of the trench. The pipe shall discharge directly into a 14-inch-diameter HDPE pumping well. The perforated pipe is embedded in thoroughly washed crushed gravel, which was used to backfill the trench to a depth of3-feet below grade. The crushed gravel is durable, sharp angled fragments free fro111 coatings and a minimum of 85 percent by weight of the crushed particles have at least two fractured faces. The crushed gravel within the trench is surrounded by non-woven geotextile fabric to mitigate the influx of fine sediment into the trench. The remainder of the trench is backfilled with native soil to grade.
The pumping well is located at the eastern end of the ground-water collection trench. The pumping well consists ofa 14-inch-diameter, by approximately 15-foot-deep HDPE pipe containing one submersible pump and associated level controls. The pu111p is connected to a 2-inch-diameter PVC discharge pipe; this pipe exits the top of the well and transitions to a 2-inch-diameter schedule 40 galvanized steel pipe, which transports the ground water to the trench pretreatment area.
All site preparation activities shall be performed by the Contractor in accordance with the Final Design Plans and Specifications. CQA testing will consist of observation and documentation of all site preparation activities by the Construction Manager during construction. The Contractor shall sub111it manufacturer's details including materials of construction and detailed shop drawings showing all pertinent information necessary for the site preparation activities. Any changes to the Final Design Plans and Specifications must be shown and highlighted on the shop and n.:cord drawings.
3.2 Treatment Building Modifications
As shown on the Construction Drawings, the existing pretreatment building at the site will be used to house the new l'rctrcatn1ent System. Therefore, no new enclosures will be erected as part of the construction phase. However, modit'ications to the existing pretreatment building (discussed above in Section 3.1) will be necessary for install;ition of the new Pretreatment System. All modifications to the existing pretreatment building will be made in acco,·d;incc with the Final Design Plans and Specifications. CQA testing will consist of observation and doc11111L·11tatio11 ol'all modifications by the Construction Manager during construction .
BLASLAND. BOUCK & LEE. INC ~--1·.1·',/''•
engineers & scientists 3-1
•
1. Introduction
This Performance Verification Plan (PVP) was prepared for Operable Unit 3 (OU3) at the National Starch and Chemical Company (NSCC) facility in Salisbury, North Carolina (Figure 1-1 ). OU3 contains ground water beneath the Production Area and surface water and sediment in the Northeast Tributary. The remedial action for OU3 will consist of ground-water collection and treatment to provide hydraulic control for the aqueous phase impacts of a potential dense non-aqueous phase liquid (DNAPL) zone.
This PVP is an appendix to the Final Design Report (FDR) for OU3, submitted to the United States Environmental Protection Agency (USEPA) in February 1999. The FDR and its associated appendices are hereby incorporated by reference into this document.
1.1 Purpose and Objectives
The purpose of this PVP is to outline methods to be used for ground-water, surface water, and sediment monitoring conducted as part of the ongoing Remedial Design/Remedial Action (RD/RA) program. The objectives of the ground-water, surface water, and sediment sampling are to:
• Evaluate operation of the ground-water extraction system for providing hydraulic control over the inferred source area;
• Monitor ground-water quality within the zone of hydraulic control, and surface water and sediment quality;
• Address vertical delineation concerns per the OU3 ROD; and
• Collect additional data to expand the current site ground-water, surface water, and sediment quality database; and
• Evaluate the effectiveness and thoroughness of the existing monitoring system and determine if additional monitoring wells are needed to adequately monitor the extraction system or if monitoring points can be eliminated from the existing monitoring system; and
• Determine if the present list of chemical analyses performed on the ground-water samples is sufficient, or should be expanded or reduced.
Methods outlined in this PVP were obtained from the USEPA Region IV Environmental Investigation Standard Operating Procedures and Quality Assurance Manual (EISOPQAM) (USEPA, 1996). The EISOPQAM is hereby incorporated into this document by reference.
1.2 Report Organization
This report is organized into the following sections:
• Section 2 -Ground-Water Monitoring;
• Section 3 -Surface Water Monitoring;
• Section 4 -Sediment Monitoring; and
• Section 5 -Performance Monitoring Deliverables and Submission Schedule .
BLASLAND. BOUCK & LEE. INC F,\PRCJ:CCiS\NSCQ6B5c8084].RPT --1/11/)9 engineers & scientists 1-1
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Air Permit Number 5279R28 _
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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Mr. Richard D. Franklin, Coordinator
Safety & Environmental Affairs
National Starch and Chemical Company
485 Cedar Springs Road
Salisbury, _North Carolina 28147
SUBJECT: Air Permit No. 05279R28
National Starch and Chemical Company
Salisbury, North Carolina
Rowan County
Fee Class: Title V
Site Number: 03/80/00055
Dear Mr. Franklin:
DIVISION OF AIR QUALITY
December 14, 1998
In accordance with your completed application received September 21, 1998,
we are forwarding herewith Permit No. 05279R28 to National Starch and Chemical
Company, Salisbury, Rowan County, North Carolina for the construction and operation
of air emission sources or air cleaning devices and appurtenances. Additionally, any
emissions activities determined from your air permit application as meeting the
exemption requirements contained in 15A NCAC 2Q .0102 have been listed for
informational purposes as an "ATTACHMENT" to the enclosed air permit.
If ,any parts, requirements, or limitations contained in this Permit are
unacceptable to you, you have the right to request a formal adjudicatory hearing within
thirty (30) days following receipt of this Permit, identifying the specific issues to be
contested. This hearing request must be in the form of a written petition, conforming
to the G.S. IS0B-23 of the North Carolina General Statutes, and filed with the Office
of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina
27611-7447. The form for requesting a formal adjudicatory hearing may be obtained
upon request from the Director of the Division of Air Quality. Unless a request for a
hearing is made pursuant to G .S. l S0B-23, this Air Permit shall be final and binding.
You may request modification of your Air Permit through informal means
pursuant to G.S. IS0B-22. This request must be submitted in writing to the Director
and must identify the specific provisions or issues for which the modification is
sought. Please note that the permit will become final and binding regardless of a
request for informal modification unless a request for a hearing is also made under
G.S. IS0B-23.
PERM ITS SECTION
P.O. Box 21i1'!580, RALl!.IOH NC 27620-0580 / 2728 CAPITAL BLvo., RALl!IGH NC 27804
PHONI! gt g.7115·823!5 FAX 919•733-5317 www.ehnr.atate.nc.USIEHNR
A~ EQUAL OP'l"ORTUNITY / Al"l"IRMATIVI! ACTION EMPLOYER· 150% Ptl!:CYCLIID/10%, P09T•CON■UMll:R l"AP'llR
•
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Mr. Richard D. Franklin, Coordinator
Safety & Environmental Affairs
December 14, 1998
Page2
Unless exempted by a condition of this Permit or the regulations, construction of new air pollution sources or air cleaning devices, or modifications to the sources or air cleaning devices described in this Permit must be covered under a Permit issued by this Division prior to construction. Failure to do so is a violation of G. S. 143-215.108 and may subject the Permittee to civil or criminal penalties contained in G. S. 143-215.114A and 143-215.114B.
This Permit shall be effective from December 14, 1998 until July 31, 2001, is nontransferable to future owners and operators, and shall be subject to the conditions and limitations as specified therein.
For PSD increment tracking purposes the total particulate emissions (including PM-10) have increased by 10.8 pounds per hour since the baseline date was triggered. The total sulfur dioxide emissions have not been affected since the baseline date was triggered.
Should you have any questions concerning this matter, please contact Ms. Wanda Hinnant, E.I. T. at (919)715-6256 .
Enclosure
c: Mike Landis, Mooresville Regional Office
Central Files
Title V file w/review
.... -.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DMSION OF AIR QUALITY
Issue Date: December 14, 1998
Expiration Date: July 31, 2001
AIR PERMIT NO. 05279R28
Effective Date: December 14, 1998
Replaces Permit: 05279R27
To construct and operate air emission source(s) and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere. In accordance with the provisions
of Article 21 B of Chapter 143, General Statutes of North Carolina as amended, and other applicable
Laws, Rules and Regulations,
National Starch and Chemical Company .
Cedar Springs Plant
485 Cedar Springs Road
Salisbury, Rowan County, North Carolina
Fee Class: Title V
Site Number: 03/80/00055
is hereby authorized to construct and operate air emission sources and/or air cleaning devices and
appurtenances consisting of:
1. two tray dryers (ID Nos. EP-PP-TRA YI and EP-PP-TRAY2),
2. one packed-tower scrubber (7 gallons per minute liquid injection rate of caustic
solution, ID No. CD-A2-2-T20PS) installed on two reactors (ID Nos. T20 and
MV4),
3. a Littleford drying system (ID No. ES-Al-2) consisting of:
(a) one iniemal fabric filter (43 square feet of filter area, ID No. CD-Al-LDF-
BFI) and two condensors (75 and 25 square feet of surface area,
respectively, ID No. CD-Al-LDF-Cla and CD-Al~LDF-_Clb) installed in
series on Littleford No. I, · · · ·
(b) one internal fabric filter (24 square feet of filter area, ID No. CD-Al-LDF-
BF2) and one condensor (220 square feet of surface area, ID No. CD-A 1-
LDF-C2) installed in series on Littleford No. 2, and
(c) a fabric filter (33 square feet of filter area, ID No. CD-Al-LDF-BF3)
installed on the Littleford packout system.
Air Permit No. 05279R28
December 14, 1998
Page No. 2
4. one surface condenser (250 square feet of surface area, JJ) No. CD-A3-l-R04C) installed on an organic synthesis reactor (ID No. R04),
5. one counter-current packed tower acid scrubber (15 gallons per minute injection
rate of sulfuric acid, ID No. EP-ST52-S03-SC) installed on a sulfur trioxide storage tank (ID No. ST-52),
6. two surface condensers (125 and 100 square feet of surface area, respectively, ID No. S-13-VCI and S-13-VC2) installed on a chemical reactor (ID No. Reactor S-13-V),
7. one surface condenser (282 square feet of surface area, ID No. R-02-C) installed on a chemical reactor (ID No. Reactor R-02),
8. one refrigerated vapor recovery unit (ID No. V-VRUI) installed on:
(a) three lacquer tanks (ID Nos. S4V, S7V, and SIOV),
(b) two neutralizer stripper vents (ID Nos. S9V and SI I V/S 12V),
' (c) six storage tanks (ID Nos. ST18, ST20, ST46, ST49, Tl6, and T30),
(d) DCE still wet receiver tank (ID No. DCE-1)
(e) DCE still dry receiver tank (ID No. DCE-2)
(f) one distillate tank (ID No. S 12),
(g)* two sulfonated polystyrene (SPS) stripper vessels (ID Nos. MV2 and
T20V),
(h)* one lacquer process vessel (ID No. MVI),
(i) seven slow add tanks (ID Nos. SAT-I-I, SAT-1-2, SAT-1-3, SAT-2-1,
SAT-2-2, SAT-2-3, and D14),
(j) two storage tanks (ID Nos. TIS and T27),
(k) one distillate receiver tank (ID No. RCV-1),
(I) one batch distillation vessel (ID No. S20V),
(m) one water storage vessel (ID No. S22V),
(n) one neutralizer vessel (ID No. S25V), and
Air Permit No. 05279R28
' December 14, 1998
Page No. 3
(o) one flashing unit (ID No. Tl3). • *connected to vapor recovery unit only when in ethylene dichloride service,
otherwise these vessels exhaust through manifold vents Nos. I, 2, and 3 on the
common exhaust manifold system,
9. Seventeen chemical reactor vessels and processes identified as:
!:Qt::!IlEl::!SERS REACTQRS !:QNTRQI, PRIMARY SECONDARY EXIT SIZE ID EFF. YR. Er: IIl..l::!ll. m IIl..l::!ll. IIl..l::!ll. ~ I::!!!. .22 !mt.
360 TI0VC-1 360 TI0VC-2 *V-VRUI 4000 TI0V 98·•· 1977
250 MVIC-1 150 MVIC-2 **AREA II 4000 MVI 98 1974
504 CD-A2-l-l 30 S5VC-2 **AREA II 4000 S5V 99.5 1989
S5V-C
125 S9VC 5500 S-9-V 98 1981
125 RI2C-l 104 RI2C-2 2000 Rl2 98 1984
125 RIC 5500 RI 95 1970
125 R2C 5500 R2 95 1970
104 RSC-I 104 R5C-2 2000 R5 · 96 1971
80 R6C-l 80 R6C-2 1500 R6 94.3 1971
250 MV2C-l 250 MV2C-2 **AREA II 4000 MV2 98 1976
125 MV3C-l 250 MV3C-2 250 CD-A2-2-4000 MV3 98 1978
MV3C3
250 MV4C-l 250 MV4C-2 80CD-A2-2-4000 MV4 98 1978
MV4C3
175 TI3VC-l 250 Tl3VC-2 4000 T-13V 98 1975
41 C-400 ------------------------400 DR-I 98 1988
5.4 LUWAC WI LUWA 95 1983
FEVAP
6000 7R 1978
300 8RC-l 125 8RC-2 4000 8R 96 1970
*Refrigerated Scrubber, ••common Vent Manifold, ••• Main 7 Secondary Efficiency
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Air Pennit No. 05279R28
'December 14, 1998
Page No. 4
IO . one packed-tower type wet scrubber (30 gallons per minute caustic solution
injection, ID No. EP-ST60-SC) installed on a storage tank (ID No. STG-60),
11. one packed-tower type wet scrubber (5 gallons per minute liquid injection rate, ID
No. lOOGLSS-PPS-1) installed on both the condenser (ID No. A) installed on the
100-gallon glass lined reactor (ID No. lO0GL) and the condenser (ID No. B)
installed on the 100-gallon stainless steel vessel (ID No. IOOSS),
12. a pilot plant operation consisting of:
(a) one packed-tower wet scrubber system (5 gallons per minute aqueous acid
(phosphoric), aqueous base (caustic solution), or water injection rate, ID
No. CD-PPS-I) installed on the common exhaust manifold of:
(i) two condensers ( one water-cooled or propylene glycol/water
mixture-cooled with 25.5 square feet of surface area, ID No. CD-
PP-50GLC I and one propylene glycol/water mixture-cooled with
4.9 square feet of surface area, ID No. CD-PP-50GLC2) installed
in series on one glass-lined chemical reactor vessel (50 gallons
capacity, ID No. 50GL),
(ii) two condensers (one water-cooled or propylene glycol/water
mixture-cooled with 22 square feet of surface area, ID No. CD-PP-
60SSC l and one propylene glycol/water mixture-cooled with 4.7
square feet of surface area, ID No. CD-PP-60SSC2) installed in
series on one stainless steel chemical reactor vessel (60 gallons
capacity, ID No. 60SS),
(iii) two condensers ( one water-cooled or propylene glycol/water
mixture-cooled with 65 square feet of surface area, ID No.
250SSC! and one propylene glycol/water mixture-cooled with 19
square feet of surface area, ID No. 250SSC2) installed in series on
one stainless steel chemical reactor vessel (250 gallons capacity, ID
No. 250SS),
(iv) two condensers (one water-cooled or propylene glycol/water
mixture-cooled with 80.5 square feet of surface area, ID No.
300GLC 1 and one propylene glycol/water mixture-cooled with
20.6 square feet of surface area, ID No. 300 GLC2) installed in
series on one glass-lined chemical reactor vessel (300 gallons
capacity, ID No. 300GL),
(v) two condensers ( one water-cooled or propylene glycol/water
mixture-cooled with 86 square feet of surface area, ID No. CD-
SOOSSC I and one propylene glycol/water mixture-cooled with 17
square feet of surface area ID No. CD-500SSC2) installed in series
on a stainless steel chemical reactor vessel (500 gallons capacity,
ID No. SOOSS),
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Air Permit No. 05279R28 0
December 14, 1998
Page No. 5
(vi) two condensers (one water-cooled or propylene glycol/water
mixture-cooled with 190 square feet of surface area, ID No. CD-
lOOOSSCl and one propylene glycol/water mixture-cooled with 29
square feet of surface area ID No. CD-IOOOSSC2) installed in
series on a stainless steel chemical reactor vessel (I 000 gallons
capacity, ID No. lOOOSS),
(vii) two condensers (one water-cooled or propylene glycol/water
mixture-cooled with 240square feet of surface area and one
propylene glycol/water mixture -cooled with 30 square feet of
surface area, ID Nos. CD-PP-2000SSCI and CD-PP-2000SSC2)
installed in series on one stainless steel chemical reactor vessel
(2000 gallons capacity, ID No. 2000SS),
(viii) two condensers (one water-cooled with 22 square feet of surface
area, ID No. CD-PD300Cl and one propylene glycol/water
mixture-cooled with 4.7 square feet of surface area ID No. CD-
PD100C2) installed in series on a pan-dryer (300 liters capacity, ID
No. ES-PD300),
(ix) one condenser (propylene glycol/water mixture-cooled with 90
square feet of surface area, ID No. CD-TD 17 /25C I) installed on a
pan-dryer ( 1700 liters capacity, ID No. ES-TD l 7 /25),
(x) one glass-lined slow add tank (20 gallons capacity, ID No.
20GLSA), .
(xi) one stainless steel slow add tank (20 gallons capacity, ID No.
20SSSA),
(xii) one stainless steel mix tank (300 gallons capacity, ID No.
300SSMIX),
(xiii) one stainless steel slow add tank (I 00 gallons capacity, ID No.
IOOSSSA),
(xiv) one stainless steel slow add tank (200 gallons capacity, ID No.
200SSSA),
(xv) one stainless steel slow add tank (500 gallons capacity, ID No. 500
SSSA),
(xvi) one condenser (propylene glycol/water mixture-cooled with 30
square feet of surface area, ID No. CD-VPICI) installed on a
vacuum pump (ID No. ES-VP!), and ·
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Air Permit No. 05279R28
' December 14, 1998
Page No. 6
(xvii) one condenser (propylene glycol/water mixture-cooled with 30
square feet of surface area, ID No. CD-VP2Cl) installed on a
vacuum pump (ID No. ES-VP2),
13. * two sulfonation vessels (ID Nos. SIR and S6V),
14. * three aerated effluent lagoons (ID Nos. I, 2, and 3) located in the facility wastewater treatment plant,
15. * three common exhaust manifold vents (ID Nos. MAN No. 1, MAN No. 2, and MAN No. 3),
16. * pilot plant operations, including process vents Nos. PPlOOG/L, PP400SS,
PP275MT, and Area ill ventilation fan,
I 7. * quality control laboratory exhaust hood,
I 8. * process development laboratory exhaust hood,
19. * one catalytic oxidizer (900 cubic feet per minute gas flow rate, ID No. CD-
CERCLA-la) and one packed-column scrubber (22 gallons per minute of 50% NaOH scrubbing medium, ID No. CD-CERCLA-lb) installed on a CERCLA cleanup project air stripper (ID No. CERCLA-1),
20. * one sludge stripper (ID No. STRIP-I)
21. * the Area II building ventilation system, and
22. a Cosmetics Process consisting of:
(a) one condenser (ID No. CD-A3-2-X2-CP-l) installed on reaction process
(ID No. CP-1),
(b) two condensers (ID Nos.CD-A3-2-X2-CP-4 and CD-A3-2-X2-CP-6)
installed on pearlization process (ID Nos. CP-4 and CP-6),
(c) one condenser (ID No. CD-A3-2-X2-C-l) installed on centrifuge process
(ID No. C-1),
(d) two condensers (ID Nos. CD-A3-2-X3-DC5001 and CD-A3-2-X3-
DC5003) installed on solvent recovery system,
(e) two monomer SIA tanks (ID Nos. CP-2 and CP-13),
(f) two catalyst SIA tanks (ID Nos. CP-3 and CP-14),
(g) five process vessels (ID No. CP-9, CP-10, CP-11, CP-12, and HOPPER),
and
Air Permit No. 05279R28
'December 14, 1998
Page No. 7
NSPS 23.
(h) seventeen storage tanks:
i) (10,000 gallon storage capacity, ID No. CP-!02: 10,000 gallon
storage capacity, ID No. CP-103: 6,000 gallon storage capacity, ID
No. CP-104: 6,000 gallon storage capacity, ID No. CP-)05; 10,000
gallon storage capacity, ID No. CP-)) ) ; 10,000 gallon storage
capacity, ID No. CP-1 )2: 10,000 gallon storage capacity, ID No.
CP-113: 500 gallon storage capacity, ID No. CP-1 )5; and 500
gallon storage capacity, ID No. CP-) ) 6:),
NSPS ii) (5,000 gallon storage capacity, ID No. CP-)0); 30,000 gallon
storage capacity, ID No. CP-)06: 30,000 gallon storage capacity,
ID No. CP-)07: 20,000 gallon storage capacity, ID No. CP-) 08:
20,000 gallon storage capacity, ID No. CP-) 09; 20,000 gallon
storage capacity, ID No. CP-1 )O; 20,000 gallon storage capacity,
ID No. CP-) ) 4: and 25,000 gallon storage capacity, ID No. Cf=
120).
One (I) Natural gas/No. 2 oil-fired boiler (10.04 million Btu per hour maximum
heat input, ID No. ES-A3-2-B7).
* Items permitted as part of a North Carolina Air toxics modeling demonstration.
in accordance with the completed application (APP8000055.98B) received September 21, 1998,
including all plans, specifications, previous applications, and other supporting data, all of which
are filed with the Department of Environment and Natural Resources, Division of Air Quality
(DAQ) and are incorporated as part of this Permit.
This Permit is subject to the following specified conditions and limitations including any
TESTING, REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
I. Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title ISA North Carolina Administrative Code (NCAC), Subchapter
2D .0503, .0515, .0518, .0521, .0522, .0524 (NSPS Subpart De & Kb), .0535, .llOO., and
Subchapter 2Q.0507 and .0711.
2. PARTICULATE CONTROL REQUIREMENT -As required by ISA NCAC 2D .0503
"Particulates from Fuel Burning Indirect Heat Exchangers," particulate matter emissions
from the fuel burning indirect heat exchangers shall not exceed allowable emission rates
listed below:
SOURCE
boiler (ID No. ES-A3-2-B7)
EMISSION LIMITCSl
3.57 lb/hr
Air Permit No. 05279R28
December 14, 1998
Page No. 8
3. As required by ISA NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes,"
particulate emissions from the air emission sources shall not exceed allowable emission
rates. The allowable emission rates are, as defined in 2D .0515, a function of the process
weight rate and shall be determined by the following equation(s), where Pis the process rate
in tons per hour (tons/hr) and E is allowable emission rate in pounds per hour (lbs/hr).
(a) P ,;; 30 tons/hr: E = 4.1 (P)°-67
4. As required by ISA NCAC 2D .0518(d) "Miscellaneous Volatile Organic Compound
Emissions," volatile organic compound emissions that are photochemically reactive as
defined in ISA NCAC 2D .0518(d) shall not exceed 40 pounds per calendar day from the
entire plant site or facility, unless the discharge has been reduced by a minimum of 85
percent by weight.
a.
b.
RECORD,KEEPING REQUIREMENT -Daily records must demonstrate that the photochemically reactive VOC emissions from the solvents as applied, have been
reduced by a minimum of 85 percent by weight. Calculations of photochemically
reactive VOC emissions per day must be made at the end of each workday.
Photochemically reactive VOC emissions shall be determined by multiplying the
daily consumptiori of material containing photochemically reactive VOCs by the
photochemically reactive VOC content of each material. This calculation and the
total amount of photochemically reactive VOC emissions must be recorded in a daily
emissions log.
REPORTING REO]JIREMENT -Within 30 days after each calendar year quarter,
the Permittee must submit in writing to the Regional Supervisor, Division of Air
Quality (DAQ):
(i) A statement indicating whether the photochemically reactive VOC emissions
have been reduced by a minimum of 85 percent by 'weight per calendar day,
during the quarter.
(ii) A summary page of the photochemically reactive VOC daily emissions log
showing the daily photochemically reactive VOC emissions, before and after
the 85 percent by weight reduction, for the quarter.
The Permittee shall make available to the Department upon request, copies of the daily
photo-chemically reactive VOC emissions log or summary page of the photochemically
reactive VOC emissions log. The Permittee must keep each entry in the daily
photochemically reactive VOC work log and each monthly record on file for a minimum of
three years.
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Air Permit No. 05279R28
'December 14, 1998
Page No. 9
5.
6.
7.
As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from
all the emission sources, established after July I, 1971, shall not be more than 20 percent
opacity when ave~aged over a six-minute period, except that six-minute periods averaging
not more than 87 percent opacity may occur not more than once in any hour nor more than
four times in any 24-hour period. However, sources_ which must comply with ISA NCAC
2D .0524 "New Source Performance Standards" or .11 IO "National Emission Standards for
Hazardous Air Pollutants" must comply y;ith applicable visible emissions requirements
contained therein.
As required by ISA NCAC 2D .0522, "Control and Prohibition of Odorous Emissions," the
permittee shall not cause, allow, or permit any source to be operated without employing
suitable measures for the control of nuisance odors.
LIMITATION TO AVOID ISA NCAC 2P .0530 "PREVENTION OF SIGNIFICANT DETERIORATION" -To comply with this Permit and to avoid applicability of ISA NCAC
2D .0530, "Prevention of Significant Deterioration," as requested by the permittee, the
volatile organic compound (VOC) emissions from the tray dryers (ID Nos. EE-PP-TRA YI
and EE-PP-TRA Y2) must be less than 40 tons per consecutive twelve ( 12) month period.
(a) To ensure enforceability of this limit, calculation of VOC emissions in tons per
month shall be made at the end of each month. VOC emissions shall be determined
by mass balance calculations comparing the masses entering and leaving the tray
dryers (ID Nos. EE-PP-TRA YI and EE-PP-TRA Y2). These calculations and the total
amount of VOC emissions must be recorded in a monthly emissions log. In addition,
the Permittee must make available to officials of the Division of Air Quality, upon
request, copies of the monthly emissions log. The Permittee must keep each entry
in the monthly emissions log and all required records on file for a minimum of three
years.
(b) For compliance purposes, within 30 days after each calendar year quarter, the
following shall be reported to the Regional Supervisor, Division of Air Quality:
(i) the monthly VOC emissions for the previous 14 rribnths. The emissions must
be calculated for each of the three 12-month periods (tons per year) over the
previous 14 months.
(ii) the total hours of operation and total monthly volatile organic compound
emissions of the tray dryers (ID Nos. EP-PP-TRA YI and EP-PP-TRA Y2),
8. LIMITATION TO AVOID I SA NCAC 2D .0530 "PREVENTION OF SIGNIFICANT DETERIORATION" -To comply with this Permit and to avoid applicability of ISA NCAC
2D .0530, "Prevention of Significant Deterioration," as requested by the permittee, the
combined volatile organic compound (VOC) emissions from the Littleford No. 2 dryer (ID
No. LFD-2) must be less than 40 tons per consecutive 12 month period.
(a) To ensure enforceability of this limit, calculation of VOC emissions in tons per
month shall be made at the end of each month. VOC emissions shall be determined
by mass balance calculations comparing the masses entering and leaving the
Littleford No. 2 dryer (ID No. LFD-2). These calculations and the total amount of
•
•
Air Permit No. 05279R28
December 14, 1998
Page No. 10
8 .
9.
Cont'd.
(b)
VOC emissions shall be recorded in a monthly emissions log. In addition, the
Permittee must make available to officials of the Division of Air Quality, upon
request, copies of the monthly emissions log. The Permittee must keep each entry
in the monthly emissions log and all required records on file for a minimum of three
years.
For compliance purposes, within 30 days after each calendar year quarter, the ' following shall be reported to the Regional Supervisor, Division of Air Quality:
(i) the monthly VOC emissions for the previous 14 months. The emissions must
be calculated for each of the three 12-month periods (tons per year) over the
previous 14 months.
(ii) the total hours of operation and total monthly volatile organic compound
emissions of the Littleford No. 2 dryer (ID No. LFD-2), and
(iii) the control efficiency for volatile organic compound emissions of the
Littleford No. 2 dryer (ID No. LFD-2).
LIMITATION TO AVOID I SA NCAC 2D ,0530 "PREVENTION OF SIGNIFICANT DETERIORATION" -To comply with this Permit and to avoid applicability of 15A NCAC
2D .0530, "Prevention of Significant Deterioration," as requested by the permittee, volatile
organic compound (VOC) emissions from the reactor (ID No. S-9-V) must be less than 40
tons per consecutive 12 month period.
(a) To ensure enforceability of this limit, calculation of VOC emissions in tons per
month shall be made at the end of each month. VOC emissions shall be determined
using volumetric displacement calculations bases on EPA recommended
methodology. These calculations and the total amount of VOC emissions must be
recorded in a monthly emissions log. In addition, the Permittee must make available
to officials of the Division of Air Quality, upon request, copies of the monthly
emissions log. The Permittee must keep each entry in the monthly emissions log and
all required records on file for a minimum of three years. To assure that emissions
are less than the 40.00 tons per year limit, the following permit limits must not be
exceeded:
(b) the operation of the reactor (ID No. S-9-V) shall not exceed 5,333 hours per any
twelve month rolling period. Volatile organic compound emissions must not exceed
fifteen pounds per hour.
8
•
Air Permit No. 05279R28
, December 14., 1998
Page No. 11
9. Cont'd.
11.
(c) For compliance purposes, within 30 days after each calendar year quarter, the
following shall be reported to the Regional Supervisor, Division of Air Quality:
(i) the monthly VOC emissions for the previous 14. mpnths. The emissions must
be calculated for each of the three 12-month periods over the previous 14.
months.
(ii) the total hours of operation of the reactor (ID No. S-9-V) and annual volatile .
organic compound emissions based on the 15 pounds per hour maximum
permitted emission rate.
LIMITATION TO AVOID ISA NCAC 2D ,0530 "PREVENTION OF SIGNIFICANT
DETERIORATION" -To comply with this Permit and to avoid applicability of 15A NCAC
2D .0530 "Prevention of Significant Deterioration," as requested by the Permittee volatile
organic compound emissions from the reactor (ID No. Rl2) must be less than 4.0.00 tons per
year, calculated each month for the previous twelve months. To assure that emissions are
less than the tons per year limit, the following permit limits must not be exceeded:
(a) the operation of the reactor (ID No. Rl2) shall not exceed 3,999 hours per any 12-
month rolling period. Volatile organic compound emissions must not exceed 20
pounds per hour,
(b) For compliance purposes, within 30 days after each calendar year quarter, the
following shall be reported to the Regional Supervisor, Division of Air Quality:
(i) the monthly VOC emissions for the previous 14. months. The emissions must
be calculated for each of the three 12-month periods over the previous 14.
months.
(ii) the actual hours of operation of the reactor (ID No. Rl2) and the annual
volatile organic compound emissions based on the 20 pounds per hour
maximum permitted emission rate,
The Permittee must keep each monthly record on file for a minimum of three years.
(a)
(b)
When the pilot plant packed tower-type wet scrubber No. IOOGLSS-PPS-1
(Permitted Item No. 11) is operated to reduce hydrogen chloride emissions, the
scrubbing liquid shall consist of dilute sodium hydroxide.
When the pilot plant packed tower-type wet scrubber No. lOOGLSS-PPS-1
(Permitted Item No. 11) is operated to reduce dimethylamine emissions, the
scrubbing liquid shall consist of dilute phosphoric acid .
Air Permit No. 05279R28
December 14, 1998
Page No. 12
12. TOXIC AIR POWJTANT EMISSIONS LIMITATION AND REPORTING
REQUIREMENT-Pursuant to 15A NCAC 2D .1100 and in accordance with the approved
application for an air toxic compliance demonstration, the following permit limits shall not
be exceeded:
(a) Emissions of the following listed toxic air pollutants shall be limited to the following
emission rates:
Pollutant
Ethylene dichloride
Benzene
Methylene chloride
Formaldehyde
Facility Emission Rate
40,141.5 pounds per year
'
76.7007 pounds per year
10.5 pounds per hour
16,000 pounds per year
6.976 lb/hour
(b) To assure compliance with the toxic air pollutant emission limits specified above, the
following conditions and limitations shall apply:
(i) Ethylene dichloride emissions from the sources listed below shall not exceed:
Source ID No,
S5V
SIR
S6V
EP-A2-MANI
EP-A2-MAN2
EP-A2-MAN3
Pounds Per Year
3034
1933
1932
0
0
0
The total monthly and annual ethylene dichloride.emissions from each source shall
be recorded in a toxic air pollutant emissions log book.
(ii) Hours of operation per calendar year quarter of the CERCLA project air
stripper (ID No. CERCLA -1) and sludge stripper (ID No. STRIP-I) shall be
rec.orded in the toxic air pollutant emissions log book.
(iii) A mass balance of ethylene dichloride emissions from the facility per
calendar year quarter shall be conducted using inventory purchase and storage
records and the results recorded in the toxic air pollutant emission log book.
(iv) Keeping of these records shall begin upon initial completion of the SPS
production expansion modifications.
(v) Chemical Reactors ID Nos 3R and 4R will be removed from the facility.
•
•
Air Permit No. 0S279R28
December 14, 1998
Page No. 13
12. Cont'd .
(vi) Formaldehyde emissions from the AREA I, exhaust manifolds (Nos. Al-
man-1 and A l-man-2) will be no greater than 1.276 lb/hr for each manifold.
(c) For compliance purposes, the Permittee shall record hourly emissions from the
AREA I, exhaust manifolds (Nos. Al-man-1 and Al-man-2). The hourly emissions
from each source shall be recorded in a toxic air pollutant emissions logbook. These
emissions can be recorded at the end of each workday.
(d) The total monthly and annual benzene emissions from each source shall be recorded
in a toxic air pollutant emissions log book.
(e) The total monthly and annual methylene chloride emissions from each source shall
be recorded in a toxic air pollutant emissions log book.
(f) The toxic air pollutant emissions log book shall be made available for inspection by
personnel of the Division of Air Quality.
(g) Within 30 days of each calendar year quarter, the following shall be reported to the
Regional Supervisor, Division of Air Quality:
(i)
(ii)
(iii)
(iv)
The facility wide ethylene dichloride emissions. ·
The facility wide benzene emissions.
The facility wide methylene chloride emissions.
All exceedances of the hourly emissions limits of formaldehyde or a
statement that emission limits were not exceeded during the quarter.
13. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT -Pursuant to
ISA NCAC 2Q .0711, for each of the below listed toxic air pollutants (TAPs), the Permittee
has made a demonstration that facility-wide actual emissions do not exceed the Toxic Permit
Emission Rates (TPERS) listed in ISA NCAC 2Q .0711. The facility shall be operated and
maintained in such a manner that emissions of any listed toxic air pollutant(s) from the
facility, including fugitive emissions, will not exceed the toxic permit emission rate(s)
(TPERs) specified in ISA NCAC 2Q .071 I.
(a) A permit to emit any of the below listed T APs shall be required for this facility if
actual emissions from all sources will become greater than the corresponding TPER.
(b) PRIOR to exceeding any of these listed TPERs, the Permittee shall be responsible for
obtaining a permit to emit TAPS and for demonstrating compliance with the
requirements of ISA NCAC 2D. l IOO.
( c) In accordance with the approved application, the Permittee shall maintain records of
operational information demonstrating that the toxic air pollutant emissions do not
exceed the TPER(s) as listed below:
•
•
•
Air Permit No. 05279R28
December 14, 1998
Page No. 14
13. Cont'd .
Pollutant
(CAS Number)
acetic acid
(64-19-7)
acrylonitrile
(107-13-1)
chlorobenzene
(l08-90-7)
epichlorohydrin
(106-89-8)
ethyl acetate
(141-78-6)
hexane
(l l0-54-3)
hydrogen
chloride
(7647-01-0)
methyl ethyl
ketone (78-93-3)
methyl isobutyl
ketone
(l08-10-1)
toluene
(l08-88-3)
xylene
(1330-20-7)
Carcinogens
Ob/yr)
l0.0
5600.0
TPERs Limitations
Chronic
Toxicants Acute Systemic Acute Irritants
(lb/day) Toxicants (lb/hr) Ob/hr)
6.8
46.0
36.0
23.0
0.18
78.0 22.4
52.0 7.6
98.0 14.4
57.0 16.4
14. J SA NCAC 2D 0524 "NEW SOURCE PERFORMANCE STANDARDS" -For the boiler (ID No. ES-A3-2-B7), the Permittee shall comply with all applicable provisions, including
the notification, testing, reporting, record keeping, and monitoring requirements contained
in Environmental Management Commission Standard ISA NCAC 2D .0524, "New Source
Performance Standards" (NSPS) as promulgated in 40 CFR 60, Subpart De, including
Subpart A "General Provisions".
(a) NSPS REPORTING REQUIREMENTS -In addition to any other notification
requirements to the Environmental Protection Agency (EPA), the Permittee is
required to NOTIFY the Regional Supervisor, Division of Air Quality, in WRITING.
of the following:
(i) the date construction (40 CFR 60.7) or reconstruction (40 CFR 60.15) of an
affected facility is commenced, postmarked no later than 30 days after such
date;
•
•
Air Permit No. 05279R28
December 14, 1998
Page No. 15
14. Cont'd .
(b)
(c)
(ii) the anticipated date of initial start-up of an affected facility, postmarked not
more than 60 days nor less than 30 days prior to such date; and
(iii) the actual date of initial start-up of an affected facility, postmarked within 15
days after such date. If the affected facility is permitted to burn multiple
fuels, then the actual date of start-up, for each fuel, must be submitted and
postmarked within 15 days after such date.
(iv) the sulfur content of the distillate oil combusted in an affected facility shall
not exceed 0.5 percent by weight. Within 30 days after each calendar year
quarter, the Permittee must submit in writing to the Regional Supervisor,
Division of Air Quality, the sulfur content of the distillate oil combusted in
an affected facility. If fuel supplier certification is used to demonstrate
compliance, fuel supplier certification shall include the following
information:
(A) the name of the oil supplier;
(B)
(C)
a statement from the oil supplier that the oil complies with the
specification under the definition of distillate oil in 40 CFR 60.41(c);
and
a certified statement signed by the owner or operator of an affected
facility that the records of fuel supplier certification submitted
represents all of the fuel combusted, during the quarter;
NSPS RECORD KEEPING REQUIREMENTS -In addition to any other record
keeping requirements of the Environmental Protection Agency (EPA), the Permittee
is required to maintain records as follows:
(i) the owner or operator of an affected facility shall record and maintain records
of the amounts of each fuel combusted during each day; and
(ii) all records required under this section shall be maintained by the owner or
operator of an affected facility for a period of two years following the date of
suoh record.
NSPS EMISSIONS LIMITATIONS -As required by ISA NCAC 2D .0524, the
following Permit limits shall not be exceeded:
AFFECTED FACil,ITY POLLUTANT EMISSION LIMIT
boiler so, 0.5 lb SO/million BTU
•
•
Air Permit No. 05279R28
• December 14, 1998
Page No. 16
15 .
16.
ISA NCAC 2D 0524 "NEW SOURCE PERFORMANCE STANDARDS" -For the eight
storage tanks in the Cosmetics Process (ID Nos. CP-101, CP-106, CP-107, CP-108, CP-109,
CP-110, CP-114 and CP-120), the Permittee shall comply with all applicable provisions,
including record keeping, contained in Environmental Management Commission Standard
15A NCAC 2D .0524, "New Source Performance Standards" (NSPS) as promulgated in 40
CFR 60, Subpart Kb.
FABRIC FILTER REQUIREMENTS -Particulate emissions from the Littleford drying
system (ID No. ES-Al-2) shall be controlled by the three fabric filters (43, 24, and 33 square
feet of filter area, ID No(s). CD-Al-LDF-BFI, CD-Al-LDF-BF2, and CD-Al-LDF-BF3,
respectively).
( a) Inspection and Maintenance Requirements
(b)
To comply with the provisions of this Permit and ensure that maximum control
efficiency is maintained, the Permittee shall perform periodic inspections and
maintenance as recommended by the manufacturer. The recording and record
keeping schedule is given below.
An annual internal inspection shall be conducted on the fabric filter by the Permittee
to ensure structural integrity such that optimum control efficiency is achieved. The
results of this inspection, and any maintenance performed on the fabric filter, shall
be recorded in a logbook which will be kept on site and made available to the
Division of Air Quality upon request.
Recordkeeping and Reporting Requirements
A fabric filter logbook shall be kept on site and made available to Division of Air
Quality personnel upon request. Any variance from manufacturer's recommendations
or from those given in the permit (when different) shall be investigated with
corrections made and date of actions recorded in the logbook.
( c) The inspection, maintenance, and recordkeeping requirements shall become effective
January 15, 1999.
17. CONDENSER REQUIREMENTS-.
(a) Inspection and Maintenance Requirements
To comply with the provisions of this Permit and ensure that maximum control
efficiency is maintained, for all permitted condensers the Permittee shall perform
periodic inspections and maintenance as recommended by the manufacturer including
those given below.
(i) inspect and maintain the structural integrity of the condenser, including
inspection for leakage of coolant and, if the system is under positive gauge
pressure, leakage of the contaminated gas stream. In order to indicate leakage
of the coolant, the condensate shall be inspected fur the presence of coolant,
•
Air Permit No. 05279R28
December 14, 1998
Page No. 17
(ii) inspect and maintain the structural integrity of duct work and piping leading
to and coming from the condenser, and
(iii) maintain records of inspections and any measures taken to repair leaks or
other possible sites of fugitive emissions.
The Permittee shall report the results of such inspections according to the
recordkeeping and reporting requirements given below.
(b) Record Keeping and Reporting Requirements
A condenser logbook shall be kept on site and made available to Division of Air
Quality personnel upon request. Any variance from manufacturer's recommendations
shall be investigated with corrections made and date of actions recorded in the log
book.
(c) The inspection, maintenance, and recordkeeping requirements shall become effective
January 15, 1999.
18. PM-SCRUBBER {PACKED TOWER }REQUIREMENTS -
(a) Inspection and Maintenance Requirements
To comply with the provisions of this Permit and ensure that maximum control
efficiency is maintained, for all permitted scrubbers the Permittee shall perform
periodic inspections and maintenance as recommended by the manufacturer. As a
minimum, the inspection and maintenance program will include inspection of spray
nozzles, packing material, chemical feed system (if so equipped), and the
cleaning/calibration of all associated instrumentation. 1 Additionally, two weeks
following start-up of the scrubber, the Permittee shall shut down the. system and
inspect for nozzle plugging and settling of the packing.
The Permittee shall record the results of inspections according to the schedule of
record keeping and reporting given below.
(b) Record Keeping and Reporting Requirements
A scrubber log book shall be kept on site and made available to. Division of Air
Quality personnel upon request. Any variance from manufacturer's recommendations
shall be investigated with corrections made and date of actions recorded in the log
book.
(c) The inspection, maintenance, and recordkeeping requirements shall become effective
January 15, 1999 .
•
Air Permit No. 05279R28
' December 14, 1998
Page No. 18
I
19. NOTIFICATION REQUIREMENT -As required by 15A NCAC 2D .0535, when
emissions exceed Environmental Management·Regulations for more than four hours, the
Regional Supervisor, Division of Air Quality, shall be notified as promptly as possible, but
in no case later than 24 hours or on the next working day of becoming aware of the
occurrence. Such notice shall specify the facility name and location, the nature and cause of
the excess emission, the time when first observed, the expected duration, and the estimated
rate of emissions. This reporting requirement does not allow the operation of the facility in
excess of Environmental Management Commission Regulations.
20. NOTIFICATION REQUIREMENT -This permit may be revoked unless the Cosmetics
Process and appurtenances are constructed in accordance with the approved plans,
specifications, and other supporting data. Within fifteen (15) days after start-up of the new
or modified facilities, the Permittee shall provide written notice of the start-up to the
Regional Supervisor, Division of Air Quality. If the proposed'operational date of January
31, 1999, is riot met, a revised permit is not needed. However, within fifteen (15) days after
the proposed operational date is not met, the Permittee shall notify, in writing, the Regional
Supervisor of the new proposed operational date. Any existing equipment being replaced
is permitted to operate in compliance until the replacement equipment is operational.
21. NOTIFICATION REOJJIREMENT -Within fifteen (15) days after start-up of each of the
following: the CERCLA project air stripper (ID No. CERCLA-la), the chemical reactor
vessel (ID No. 2000SS), the pan-dryer (ID No. ES-TD17/25), and all corresponding
appurtenances, the Permittee shall provide written notice of the start-up to the Regional
Supervisor, Division of Air Quality.
22. Pursuant to 2Q. 0507, the Permittee, upon becoming aware that any relevant facts were
omitted or incorrect information was submitted in the Title V application, shall promptly
submit such supplementary facts or corrected information to:
I.
2.
Division of Air Quality
Post Office Box 29580
Raleigh, North Carolina 27626-0580.
B. GENERAL CONDITIONS AND LIMITATIONS
REPORTS, TEST DATA, MONITORING DATA, NOTIFICATIONS AND REQUESTS
FOR RENEWAL shall be submitted to the:
Regional Supervisor
North Carolina Division of Air Quality
9 I 9 North Main Street
Mooresville, North Carolina 28115
(704) 663-1699
PERMIT RENEWAL REQUIREMENT -The Permittee, at least 90 days prior to the
expiration date of this Permit, shall request permit renewal by letter in accordance with ISA
NCAC 2Q .0304 (d) and (t). Pursuant to ISA NCAC 2Q .0203 (i), no permit application fee
is required for renewal of an existing air permit. The renewal request should be submitted
to the Regional Supervisor. Division of Air Quality.
•
•
Air Permit No. 05279R28
• December 14, 1998
Page No. 19
3 .
4.
5.
ANNUAL FEE PAYMENT -Pursuant to 15A NCAC 2Q .0203 (a), the Permittee shall pay
the Annual Permit Fee within 30 days of being billed by the Division. Failure to pay the fee
in a timely manner will cause the Division to initiate action to revoke the permit.
(
EQUIPMENT RELOCATION -A new air permit shall be obtained by the Permittee prior
to establishing, building, erecting, using, or operating the emission sources or air cleaning
equipment at a site or location not specified in this permit.
REPORTING REQUIREMENT -Any of the following that would result in previously
unpermitted, new; or increased emissions must be reported to the Regional Supervisor,
Division of Air Quality:
a. Changes in the information submitted in the application regarding facility emissions;
b. Changes that modify equipment or processes of existing permitted facilities; or
c. Changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the Division of Air Quality
to reflect any necessary changes in the permit conditions. In no case are any new or
increased emissions allowed that will cause a violation of the emission limitations specified
herein.
6. This permit is subject to revocation or modification by this Division upon a determination
that information contained in the application or presented in the support thereof is incorrect,
conditions under which this permit was granted have changed, or violations of conditions
contained in this permit have occurred. The facility shall be properly operated and
maintained at all times in a manner that will effect an overall reduction in air pollution.
Unless otherwise specified by this permit, no emission source may be operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. This permit is nontransferable by the Permittee. Future owners and operators must obtain
a new air permit from the Di vision of Air Quality.
8. This issuance of this permit in no way absolves the Permittee of liability for any potential
civil penalties which may be assessed for violations of State law which have occurred prior
to the effective date of this permit.
9. This permit does not relieve the Permittee of the responsibility of complying with all
applicable requirements of any Federal, State, or Local water quality or land quality control
authority.
10. Reports on the operation and maintenance of the facility shall be submitted by the Permittee
to the Regional Supervisor, Division of Air Quality, at such intervals and in such of form and
detail as may be required in such by the Division. Information required in such reports may
include, but is not limited to, process weight rates, firing rates, hours of operation, and
preventive maintenance schedules.
•
•
Air Permit No. 05279R28
December 14, 1998
Page No. 20
11. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G. S. 143-215. l 14A, 143-215. l 14B, and 143-215.114C, including assessment
of civil and/or criminal penalties.
12. Pursuant to North Carolina General Statute 143-215.3 (a) (2), no person shall refuse entry
or access to any authorized representative of the Division of Air Quality who requests entry
or access for purposes of inspection, and who presents appropriate credentials, nor shall any
person obstruct, hamper, or interfere with any such representative while in the process of
carrying out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment of civil penalties.
13. The Permittee must comply with any applicable Federal, State, or Local requirements
governing the handling, disposal, or incineration of hazardous, solid, or medical wastes,
including the Resource Conservation and Recovery Act (RCRA) administered by the
Division of Waste Management.
14. PERMIT RETENTION REQUIREMENT -The Permittee shall retain a current copy of the
Air Permit at the site. The Permittee must make available to personnel of the Division of Air
Quality, upon request, the current copy of the Air Permit for the site.
Permit issued this the 14th day of December, 1998.
NORTH CAROLINA ENVIRONMENT AL MANAGEMENT COMMISSION
Air Permits Section
By Authority of the Environmental Management Commission
Air Permit No. 05279R28
t
A TI ACHMENT to Air Permit No. 05279R28, December 14, 1998
Activities Exempted from Permitting Under ISA NCAC 2Q .0102(b)(2)
Date of Exemption Source of Source of Title V
Source Application Regulation TAPs? Pollutants?
One (I) natural gas-fired March 22, 1996 2Q .0102(b)(2)(B)(i) Yes Yes
hot oil heater ( 1.9 million
Btu per hour maximum heat
input, ID No. H-1)
One (I) surface condenser March 22, 1996 2Q .0102(b)(2)(E)(i) No Yes
(50 square feet of surface
area) installed on a water-
based materials tumble
dryer, ID No. TIJM-1.
One 5,300 gallons waste August 20, 1996 2Q .0!02(b)(2)(E)(i) Yes Yes
storage tank in pilot plant
area
Five (5) Natural gas/No. 2 March 22, 1996 2Q.0 I 02(b )(2)(B )(ii) Yes Yes
oil-fired boilers, (12.5
million Btu heat input each, .
ID Nos. BI, B2, B3, B4,
and B5, built in 1970, 1970,
1978, 1978 and 1978
respectively)
..
l. Because an activity is exempted from being required to have a permit or permit modification
does not mean that the activity is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
2. When applicable, emissions from stationary source activities identified above shall be
included in determining compliance with the permit requirements for toxic air pollutants
under 15A NCAC2D .1100 or 2H .0711.