NC0035173_Corrective Action Plan_20191029

Wieland
October 29, 2019 Wieland Copper Products, LLC
3990 US 311 Hwy N
Pine Hall, NC 27042
NCDENR Phone: [phone]
2918
Water QualityPermittingSection-NPDES Fax: wiel 427 om
[e-mail]
1617 Mail Service Center www.wielandcopper.com
Raleigh, NC 27699-1617
Attention:Joe Corporon
Subject:Wieland Copper Products, LLC RECEIVED
Corrective Action Plan for Copper Removal NOV 1�79
NPDES Permit No: NC0035173
NCDEQIDWR/NPDES
Dear Mr. Corporon:
Enclosed is one signed original and 1 copy of Wieland Copper Products, LLC Current Status and
Corrective Action Plan for Copper Removal from the discharges of Outfall's 001 and 003.
If you have any questions please feel free to call me at(336)445-4526.
r
Sincereljr1VL
,/'
"(
'Tony Rin
Environmental Supervisor

Wieland Copper Products, LLC
Corrective Action Plan Status Report
Permit Number NC0035173
ENVIRONMENTAL
P R66A C ESS
SOLUTIONS, PLLC
RECEIVED
NOV 0 5 2019
I4CDEQIDWRINPDES
Environmental Process Solutions, PLLC
7000 Stinson Hartis Rd Ste F
Indian Trail, NC 28079
980-202-2377 I Firm P-0882

Corrective Action Plan
Wieland Copper Products,LLC
Copper Reduction
Table of Contents
Report Submission Authorization 3
Introduction 4
Purpose 4
Existing Treatment Facilities 4
Status of Alternatives evaluated Outfall 001 4
Status of Alternatives evaluated Outfall 003 5
Updated Schedule of Compliance 7
Selected Alternative Implementation Plan 8
2

Report Submission Authorization
This Corrective Action Plan is submitted by Wieland Copper Products, LLC and Environmental Process
Solutions, PLLC to meet the requirements for NPDES permit NC0035173, Part 1, Condition A(6), Item 1.
This section includes the schedule of compliance for achievement of the Total Copper limits for
discharge of the effluent through Outfalls 001 and 003 by November 1, 2021.
The following people have developed the content and approve submission of this report:
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Glenn Maxwell, President
MA, /4 29 /9-
Jar-d 'anken, Director of Environmental, Health and Safety
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Tony Spr'nkle, Environmental Supervisor
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Kellie Hedrick, PE,Consultant with Environmental Process Solutions, PLLC
3

Introduction
Wieland Copper Products, LLC is located at 3990 US Hwy 311 N, Pine Hall, NC. Wieland Copper
Products, LLC had been operating wastewater treatment facilities under NC discharge permit
NC0035173 and received a renewal on September 27, 2017. This renewed permit added limits for Total
Copper to the permit including a compliance schedule for achievement. As part of the compliance
schedule, a Corrective Action Plan summarizing the actions to be taken in order to achieve compliance
by November 1, 2021 was submitted last year (2018) and this report is the annual status update.
Purpose
In 2018, Wieland Copper Products submitted a Corrective Action Plan that summarized the plans
intended to achieve compliance with the total copper limits at Outfalls 001 and 003. This report
summarizes the activities to date along with the plans for the next year.
Existing Treatment Facilities
Wieland Copper has two outfalls located on unnamed tributaries that flow into the Dan River. Outfall
001 receives wastewater generated through the sanitary sewer. This wastewater is treated by a
package activated sludge plant and typically processes about 5000 gal/day. Wastewater flows through a
bar screen into the aeration basin, solids settle in the clarifier, and the clarified effluent is further
treated by a tablet chlorinator followed by a tablet de-chlorinator prior to final discharge. The treated
effluent is then discharged though Outfall 001. There is no manufacturing wastewater processed
through this system. The sanitary treatment system has an approximate copper concentration of 240
ug/L compared to the new limit of 40.7 ug/L. This system has been prioritized highest for need to add
an additional treatment unit in order to reliably meet the limits that will be fully implemented
November 1, 2021.
The process wastewater generated through boiler blowdown, cooling tower blowdown, and non-
contact cooling water is processed through a physical/chemical treatment system consisting of fast mix
tank for coagulation, a slow mix tank for flocculation, and a belt press for solids separation. The clean
water is discharged through Outfall 003. This outfall discharges roughly 30,000 gal per day on average.
The current concentration in the effluent is about 43 ug/L compared to the new limit of 25.5 ug/L. The
current treatment system is much closer to meeting the new limit without additional treatment
processes.
Status of Alternatives evaluated Outfall 001
From the initial list of approximately 8 alternatives for potential evaluation, 4 alternatives were selected
based on the probability of success. The four alternatives to be evaluated were chemical precipitation,
Nexom technology filtration, Membrane filtration, and ion exchange. These technologies were intended
to be evaluated primarily for additional treatment to the biological system discharging to Outfall 001.
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Nexom Filtration was the first to be evaluated. This technology involves reactive filtration in a sand filter
platform. Primary applications are advertised as removal of trace metals and phosphorus. The process
involves a continuously regenerated hydrous ferric oxide coating on the sand media, which results in
attraction of the low levels metals to the media. After detailed discussion with the vendors, it was
determined that Outfall 001 was not a good candidate for this technology due to the inconsistency of
flow and the fact that the typical flow was so low. In order for the filtration system to work effectively, a
continuous flow is needed and with a discharge of 2500-5000 gal per day, consistent flow would be very
difficult to obtain on the final effluent. Based on these discussions, further evaluation of this technology
was abandoned.
The initial plan was to evaluate membrane filtration between October 2019 and March 2020. Evaluation
of membrane technology has been reprioritized since the initial indications are that membrane filtration
of wastewater tends to be extremely difficult to reliably operate and keep in service. Further literature
research will be done prior to pilot testing of membranes.
During the Outfall 003 evaluation of chemical precipitation modification, a new product called ProMoss
was introduced as a possibility. ProMoss acts as an adsorbent for positively charged metal ions. Since
copper is positively charged, ProMoss was added to the effluent chamber to test for use in improving
copper removal. ProMoss showed improvements in the copper levels,though it did not perform well
enough to be the only treatment needed for Outfall 001. With the testing of ProMoss showing
improvements in copper removal, priority was given to testing ion exchange.
Evaluation of ion exchange will begin in November 2019 using a copper specific resin. Once ion
exchange has been evaluated, membranes may be tested depending on the research into the exact
membrane technology needed for copper removal. The pore size will determine what may reliably
remove copper and if reverse osmosis is the pore size required, significant pre-treatment will be
required to create clean enough water to send through the reverse osmosis membrane.
Status of Alternatives evaluated Outfall 003
Chemical precipitation is the current primary treatment for Outfall 003 and will be modified and
optimized to meet the new copper limit. If simple modification to the existing treatment does not
provide copper concentrations in the discharge low enough to reliably meet the limit,then a polishing
step utilizing one of the other evaluated technologies will likely be implemented to ensure consistently
meeting the effluent limit of 25.5 ug/L.
The first treatment technology evaluated was chemical precipitation. Since the wastewater discharged
through Outfall 003 is already treated by a chemical precipitation process, it seemed logical to test this
technology first. Working with the current chemical vendor and the equipment already present in the
physical/chemical treatment system, evaluations were completed on modifying the coagulant and
polymer used for precipitation in the physical/chemical treatment system to provide better removal of
copper in order to meet the new copper discharge limits. The addition of a metal scavenger to the
5

physical/chemical treatment system at Outfall 003 brought the copper concentration very near the
discharge limit, but did not reliably maintain the low concentrations.
The chemical supplier introduced ProMoss, an adsorbent, to the system as a possible removal
technology. ProMoss has been introduced throughout the water systems discharging through Outfall
003 as the primary chemical treatment for the cooling tower water and non-contact cooling systems. So
far,this has reduced the copper levels in the effluent to levels very near the discharge limit. Final
treatment using precipitation technology adjustments may create effluent that can reliably meet the
discharge limit of 25.5 ug/L.
6

Updated Schedule of Compliance
Date Task Status
11/5/2018 Begin studies on precipitation for Complete
physical/chemical treatment optimization
on Outfall 003
11/5/2018 Begin treatment testing for precipitation Complete
use post biological treatment for Outfall
001
2/28/2019 Complete Precipitation studies Complete
3/4/2019 Begin studies on Nexom Filtration for Option discarded due to low
both outfalls flows at 001
9/30/2019 Complete studies on Nexom Filtration Option discarded due to low
flows
10/7/2019 Begin studies on membrane filtration on Option evaluation delayed due
both outfalls if determined necessary to potential plugging issues
11/1/2019 Status Report Due on test status Issued 10/25/19
3/31/2020 Complete membrane filtration studies Option evaluation delayed
4/6/2020 Begin studies of ion exchange polishing Option under investigation and
on either outfall as deemed necessary by testing as of 11/1/19
previous experimentation
6/30/2020 Complete polishing studies on both
outfalls
11/1/2020 Status Report Due
12/1/2020 A to C paperwork due
3/15/2021 A to C approval
3/22/2021 Order long lead time equipment
10/1/2021 Complete Installation of necessary
treatment additions
11/1/2021 Outfalls 001 and 003 running new
systems in compliance with Total Copper
limit
7

Selected Alternative Implementation Plan
The Capital Expenditure request can be developed after financial considerations of successful treatment
technologies. Once funding is approved,the Authorization to Construct will be developed and
submitted, with an intended submission goal of November 2020 for hopeful approval by March 2021.
Once the ATC has been approved, then construction will begin to have the best treatment system
installed and fully operational by November 1, 2021.
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