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HomeMy WebLinkAboutNC0004308_PERMIT MODIFICATION_20100203MPDES DOCUWEMT SCAMMIM& COVER SNEET NPDES Permit: NC0004308 ALCOA — Badin Works Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Correspondence Instream Assessment (67b) Environmental Assessment (EA) Permit History Document Date: February 3, 2010 ThiM documearYt is pri'mted on rexxne paper - 119n401re arwy contexxt ork the resrerse aide AMA (--J 6rle AENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Mr, Mark J. Gross Alcoa, Inc.- Badin Works P.O. Box 576 Badin. North Carolina 25009 Dear Mr. Gross: Division of Water Quality Coleen H. Sullins Director February 3, 2010 Subject Permit Modification NPDI?S Permit NC0004308 Alcoa- Badin Works Stanly County Dee Freeman Secretary The Division of Water Quality is forwarding herewith the NPDI S permit modification for Alcoa's Badin Works. Please replace the old Supplement to Permit Cover Sheet with this modified version. This permit modification is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). This permit modification provides for the following permit change: Outfalls 012/013. Stormwater flow from the lormer SWMIJ No. 22 area (which indirectly discharges to Badin Lake via Outlall_013) may be re-routed to Outihll 012 (which discharges directly to Badin Lake via diffuser). This stormwater flow re -direct represents a small increase in volume flowing to Outfall 012 (<3% increase in drainage area flowing to 012). There are no proposed changes in permit limits or monitoring requirements at either outfall. Overall, there is not net increase in flow or fluoride to Badin Lake. If any parts, measurement frequencies, or sampling requirements contained in this permit modification are unacceptable to YOU, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office ol'Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699- 6714. Unless such a demand is made, this permit modification shall be final and binding. Please take notice that this permit is not transferable except alter notice to the Division of Water Quality. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or any other federal or local governmental permit. 1617 Mail Service Center, Raleigh, No«h Carolina 27699-1617 location: 512 N. Salisbury St Raleigh, Norih Carolina 27604 Phone 919-807-63001 FAX. 919-807-64921 Customer Service: 1 '377-623-6748 Internet: vAm.nmaterrluality.org One NoallCaroliiia An Ecual Opporlumu `, At6rma;v;e Action Employer IFyou have any questions about the NI'DEFS permit process, please contact me at 919-807-6390 or via email at tom. hcIiiick@n cdc n r.gov. 4Sin crely, "vl II m Belnick upervisor. NPDE-S West Program E-larcicopy: NPDI S I-ilc NC00043O8 Central Files NCOOO43O8 Email copy: US EPA Region 4, Marshall Hyatt MRQ SWPS 1617 Mail Service Center, Ralegh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One Phone: 919-607-63001 FAX: 919-807-6492 V Customer Service: 1-877-623-6748 North Cill o I`na Internet: vnvw.ncvvaterquaiity org �,�r�1/N/�/f An Equal Opportunity 1 Alfirmiive Action Employer t Ll L 11 `l J Permit No. NCO004308 SUPPLEMENT TO PERMIT COVER SHEEP The mrtlhority to operate nrrd discliargc frour 11ris fiicility rinses exchrsively mnlcr the torus arm conditions of this NPDFS Permit. Therefore, upon the effective date of this perurit, any iiad all previous NPDES Permits issued for this facility and Dearing tlus 17cnnrt inmiher are revoked. Alcoa Inc. is hereby authorized to: 1. Discharge the following: • non -contact cooling and make-up waters, condensate, fire protection water, groundwater, and stormwater at Outfall 002/SO2; • non -contact cooling and make-up waters, condensate, fire protection water, groundwater, and stormwater at Outfall 004/504; • non -contact cooling water, condensate, fire protection water, groundwater, and stormwater at Outfall 005/SO5; • non -contact cooling water, condensate, fire protection water, groundwater, and stormwater (including flow re -direct from SWMU No.22 area) at Outfall 012/S12 (and at Outfall 011/S11 when flows exceed the capacity of the diffuser); • groundwater and stormwater at Outfall 013; • groundwater seepage from the Old Brick Landfill and stormwater at Outfalt 019/S19; and • stormwater at Outfalls 017, 018, and 020; all outfalIs being located at or near the AIcoa - Badin Works in Stanly County; and 2. Discharge such process and ancillary process wastewaters, groundwater, and stormwater from locations specified on the attached map into an unnamed tributary to Little Mountain Creek (Outfalls 004/SO4, 005/SO5, 017, and 018) and into Badin Lake (Yadkin River) (Outfalls 002/SO2, 011/S11, 012/S1.2, 013, 019/S19, 020) which are classified as Class "C" waters and Class "WS-IV CA & B" waters, respectively, in the Yadkin -Pee Dee River Basin. All discharges shall be in accordance with the attached schedules as follows: Part 1: Monitoring, Controls, and Limitations for Permitted Discharges A. Effluent Limitations and Monitoring Requirements B. Stormwater Management C. Special Conditions Part 1I: Standard Conditions for NPDES Permits Part III: Other Requirements Part IV: Special Conditions for Municipal Facilities Any other point source discharge to surface waters of the state is prohibited unless covered by another permit, authorization, or approval. This permit does not relieve the Permittee from responsibility for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree. 6 - VVA!z � F1Irn,r y Facility Name: Permitted Flow (MGD): WWTP Grade: WWTP Status: Permit Status: County: Regional Office: USGS Topo Quad: Fact Sheet - NPDES Permit Modification Alcoa, Inc. NPDE�S No. NCO004308 Facility Receiving Stream Alcoa Bailin Works Receiving Stream: Little \•lountain Creek, 13adin Lake (Yadkin River), k- UTs to each Not Limited Sub -basin: 030708 N/A Index No.: 13-5-1-(2); 12-(12 t.5) N/A Stream Class: C; Ws -Iv CA & li i'zisting 303(d) Listed: Yes (IAIC); No (nil) Stanitr Use Support: \looresviIle Drainage Area (mi2): 171 8\ F, F 15l\11r Summer 7Q10 (cfs) (liadin & New London, NC) Winter 7Q10 (cfs): 30Q2 (cfs): Average Flow (cfs): IWC (%): Varies W/ outfaill PROPOSED PERMIT t1�IODIFICA`l'ION- Reroute Stormwater from Outfall 013 to 012 Alcoa, lnc. has requested al permit modification of its NI'I)I S Permit No. NC0004308. The modification is for the re-routing of stornlwater flow from the former SWMU No. 22 area (which indirectly discharges to Bailin Lake vial Outfall 013) to OL01all 012 (which discharges diret;tly to Badin Lake via LIiffuser).'I'lle Division finds Alcoa's reiluest to be acceptable and has made a tentative determination to modify the facility's permit. CURRENT CONDITIONS In August 2002, Alcoa curtailed operations at the Badin facility.T11C curtailnlcllt eliminated nearly all of Alcoa's wastewater discharges. Current discharges consist primarily of stornl%Vater runoff and groundwater seepage. Site assessment under the RCRA program is underway. Ontfall 012 (North Stornl Drain). Current permitted discharges from Oulfall 012 include non -contact cooling; water, condensate, fire protection water, groundwater, and stornlwater. This outfall to Badin Lake has a single - Port diffuser to ensure rapid mixing with receiving water, clue to presence of cyanide ill the discharge and proximity of svviililning area. Previous COMMIX nlodelirig estimates that 25:1 dilution is achieved within 1 meter of the diffuser (IWC =4%), but the currenl permit has maintained a more conservative 16% 1VVC for toxicity testing given Alcoa's demonstrated ability to pass the test at this concentration. The current permit 11lCludes limits alld 11101litol'In,, requirements for total cyanide, oil and grease, TSS, pH, and chronic toxicity (I'/F at-16% IWC); and monitoring; requirements tier ilow, alttminulll, fluoride, and total residual chlorine. Oulfall 0"13 (NcarthFvest Valley G•eek). l low io this outfall consists r>I slormwater, spring water, and groundwater drainage from an area that includes a former Alcoa landfill site•(SWNIUs #"1 & 22). In order to eliminate the potential for discharge of contaminants from the landfill, Alcoa has capped the site and provided diversion str•uetures to isolate the site front any ru11-011 flows. T11C original storm sewer draining; this area was located in contaminated groundwater table. In remediating the SW\4Us (1996), Alcoa replaced the pipe (new line was hydrostatically tested) and raised it above the water table to eliminate any possibility of seepage entering; the line. Monitoring data since 2002 still indicate the presence of 11uoride and, occasionally, cyanide. T11C current permit includes limits and monitoring; requirements for "i'SS, PH, fluoride (effective November "I, 2009), and acute toxicity (24-hr. P/F at 90% 1 WC); and monitoring requirements for flow, cyanide, and Version: 12/8/09 NPDI;S fact Sheet Alcoa, Inc.- NC0004';08 , aluminum. Discharge is to a flitch, an unnamed tr•ibutarV to Badin Isake. "IThe Division considered whether the receiving; hvater (approx. 50 ft, of man -shade flitch flowing to a culvert then to Badin Lake) could qualify as an effluent channel. It floes not meet the criteria set in T15A NCAC 0213 .0228, because the discharge is Ihot limited to overland runoff but includes grotrnclwater drainage as well. Thus, the limits are calculated as for a water of the state and a zero-Ilow strum, hence, using an instream waste concentration, or IWC, of 100%. ANALYSIS This permit modification would allow Alcoa to re-route stormwater flow from the former SWN/IU No. 22 area to Outfall 012, which provides the benefit of a diffuser outfall with 25:1 dilution. Alcoa has implemented several measures at SVti NIIJ No. 22 to reduce the variable concentration of fluoride that migrates from soils to the stormwater. These activities included: installation of a Claymax liner to prevent contact of storm%eater with the underlying, soils; pressure washed the pipe from tlhe jNortlhern Junction 13ox to Outfall 013 and the pipe from SWMU 22 to the Southern junction Box; and recoMed all the joints between the Southern Junction 13ox and Outfall 0'13 with grout cement. The re-route is projeCed to slightly increase the volume discharged via OL4,111 0'12 (a <3% increase in the drainage area flowing to Outfall 012). Under worstcase conditions, the re-route is Projected to slightly increase (by <0.5 mg/1) the fluoride concentration at Outfall 012, which is currently averaging; 325 mg/I. In comparison, the allowable fluoride concentration at Outtall 0'12 is 45 mg/l (1WS for fluoride = -1.8 mg/] x 25 dilution provided by diffuScr'). TIIIIs, rho changes to pernhit limits or monitoring requirements are necessary for Outfalls 012/0'13 as a result of this modification. Overall, there is no net increase in flow or fluoride to Raclin Lake. Version: 12/8/09 NPDES Fact Sheet Alcoa, Inc.- NC0004308 aluminum. Discharge is to a ditch, an unnamed tributary to Raclin Lake. -The Division considered whether the receiving water (approx. 50 ft. of man-made ditch flowing to a culvert then to l3adin Lake) could qualify as an effluent channel. It does not meet the criteria set in `l 15A NCAC 0213 .0228, because the discharge is not limited to overland runoff but includes groundwater drainage as well.Thus, the limits are calculated as for a water of the state and a zero -flow stream, hence, using ail instream waste concentration, or IWC, of 100%, ANALYSIS This permit modification would allow Alcoa to re-route stormwater flow from the former SWMU No. 22 area to Outfall 012, which provides the benefit of a diffuser outfall with 25:1 dilution. Alcoa has implemented several measures atSWMU No. 22 to reduce the variable concentration of fluoride that migrates from soils to the stormwater. 'these activities included: installation of a Claymax liner to prevent contact of stormwater with the underlying soils; pressure washed the pipe from the Northern Junction Box to Outfall 013 and the pipe from SWMU 22 to the Southern Junction Box; and recoated all the joints betWP.en the Southern Junction Box and Outfall 0-13 with grout cement. The re-route is projected to slightly increase tile volume discharged via Outfall 0"12 (a <3%, increase in the drainage area flowing to Outfall 0-12), Under worst case: conditions, the. re-route is projected to slightly increase (by <0.5 mg/1) the fluoride concentration at Outfall 0-12, which is currently averaging 3 25 mg/l. In comparison, the allowable fluorine concentration at Outfall 012 is 45 mg/1(WQS for fluoride = 1.8 mg/I x 25 dilution provided by diffuser). 'Thus, no clhanges to permit limits or monitoring requirements are necessary for Outfalls 01`'/013 as a result of this modification. Overall, there is no net increase in flow or fluoride to Badin Lake. Version., 12/8/09 The Charlotte Observer Publishing Co. Charlotte, NC North Carolina } ss Affidavit of Publication MeckLenburg County} THE CHARLOTTE OBSERVER DINA SPRINKLE NCDENR/DWQ/POINT SOURCE BRANCH 1617 MAIL SERVICE CENTER RALEIGH NC 27699 I I REFERENCE: 30063432 6420688 multi -permit request Before the undersigned, a Notary Public of said County and State, duly authorized to administer oaths affirmations, etc., personaLLy appeared, being duly sworn or affirmed according to -taw, doth depose and say that he/she is a i representative of The Charlotte Observer Publishing Company, a corporation organized and doing business under the laws•of the State of Delaware, and publishing a newspaper known as The Charlotte Observer in the city of- Charlotte, County of Mecklenburg, -and State of North Carolina and that as such he/she is familiar with the books, records, files, and business of said Corporation and by reference to the files of said publication, the attached advertisement was inserted. The following is ccrrectLy copied from the books and files of the aforesaid Corporation and Publication_ I I I i PUBLISHED ON: 12/18 AD SPACE FILED ON 96 LINE 12/25/09 In Testimony Whereof I have hereunto set my hand and affixed my seal, the day and y r aforesaid, (' Notary. / X"Pfy/Commission Expires: Y I Ij My Commission Expires May 27, 2011 Beverly Eaves Perdue Governor NCVENR North Carolina Department of Environment and Natura Division of Water Quality Coleen H. Sullins Director December 16, 2009 Mr. Mark J. Gross Alcoa, Inc.- Badin Works P.O.Box 576 Badin, North Carolina 28009 Resources Subject: Draft Permit Modification NPDES Permit NCO004308 Alcoa- Badin Works Stanly County Dear Mr. Gross: Dee Freeman Secretary Enclosed with this letter is a copy of the draft modified pages of your current NPDES permit. This draft permit modification includes the following permit changes: Outfalls 0121013. This proposed permit modification allows for stormwater flow from the former SWMU No. 22 area (which indirectly discharges to Badin Lake via Outfall 013) to be re-routed to Outfall. 012 (which _ discharges directly to Badin Lake via diffuser). This stormwater flow re -direct represents a small increase in volume flowing to Outfall 012 (<3% increase in drainage area flowing to 012). There are no proposed changes in permit limits or monitoring requirements at either outfall. Please submit any comments to me no later than thirty days following your receipt of the draft permit modification. This draft permit modification will also be noticed in a public newspaper with a 30 day public comment period. If you have any questions about the NPDES permit process, please contact me at 919-807-6390 or via email at tom.belnick@iicdenr.gov. ncdenr.gov. Sincerely, O44 orm'BeInick Supervisor, NPDES West Program I-lardcopy: NPDES File NCO004308 Email copy: US El'A Region 4, Marshall Hyatt MRO SWPS MRO DEl-I 1617 Mail Service Genter, Raleiah North Carolina 27699-1617 Location: 512 N. Salishury St. Raleigh, Norlh CarOh na 27504 One 1 Phone: 919-807-6300 4 FAX: 919-31P-64921 C Iislomer Service: 1-877-623-6748 1 V Q1"1 ] l C�i101111a Internet: wwvi-nCwatergnalily org /fit An Equal (FpporluOy � Allir�nalr4e Aclion ExployEr (��'+�+'imally Permit No. NC0004308 SUPPLEMENT TO PERMIT COVER SHEET Tire arrthorify to opernte turd discharge front this facility arises eXclirsivcl y udder file tenus arm coridifiofis of this NPDES Permit. Urcreforc, ripon the effective date of this pens it, ally avid all previoris NPDES Penitits issued for this facility and bearing this peniit nuraber are revoked. Alcoa Inc. is hereby authorized to: 1. Discharge the following: • non -contact cooling and make-up waters, condensate, fire protection water, groundwater, and stormwater at Outfall 002/S02; • non -contact cooling and make-up waters, condensate, fire protection water, groundwater, and stormwater at Outfall 004/504; • non -contact cooling water, condensate, fire protection water, groundwater, and stormwater at Outfall 005/SO5; • non-contactcooling water, condensate, fire protection water, groundwater, and stormwater (including flow re -direct from SWMU No.22 area) at Outfall 012/Sl2 (and at Outfall 011 /S11 when flows exceed the capacity of the diffuser); • groundwater and stormi-vater at Outfall 013; • groundwater seepage from the Old Brick Landfill and stormwater at Outfall 019/519; and • stormwater at Outfalls 017, 018, and 020; all outfalls being located at or near the Alcoa - Badin Works in Stanly County; and 2. Discharge such process and ancillary process wastewaters, groundwater, and storm,.vater from locations specified on the attached map into an unnamed tributary to Little Mountain Creek (Outfalls 004/SO4, 005/S05, 017, and 018) and into Badin Lake (Yadkin River) (Outfalls 002/502, 011/S11, 012/512, 013, 019/S19, 020) which are classified as Class "C" waters and Class "WS-IV CA & 13" waters, respectively, in the Yadkin -Pee Dee River Basin. All discharges shall be in accordance with the attached schedules as follows: Part 1: Monitoring, Controls, and Limitations for Permitted Discharges A. Effluent Limitations and Monitoring Requirements B. Stormwater Management C. Special Conditions Part Il: Standard Conditions for NPDES Permits Part III: Other Requirements Part IV: Special Conditions for Municipal Facilities Any other point source discharge to surface waters of the state is prohibited unless covered by another permit, authorization, or approval. This permit does not relieve the Permittee from responsibility for compliance with any other applicable federal, state, or local Iaw, rule, standard, ordinance, order, judgment, or decree. 11 h41 0 4V +. f_ 5elnick Tom L From: Templeton, Mike Sent: Tuesday, October 06, 2009 4:41 PM To: Belnick, Tom; Parker, Michael Subject: FW: Alcoa Badin - Conference Call Attachments: image001.gif; G055041 (Stormwater Management Plan).pdf; Figure 1-2 (SW Pipe Correction).jpg; Figure 2-1C.pdf; Figure 2-2B.pdf Just received these and am forwarding them FYI. Are you both available to talk about these if we need to, at about 8:30 or 8:45 a.m, Friday? From: Tim White(maiito:twhite@environeeringinc.com] Sent: Tuesday, October 06, 2009 4:16 PM To: Templeton, Mike Cc: Randall Kiser; Robert Prezbindowski Subject: Alcoa Badin - Conference Call Mike Pursuant to your request I'm forwarding to you the attached documents in preparation of our conference call on Friday morning at 9.00 AM EDT. As we discussed, Alcoa intends redirect a culvert that currently leads to Outfall 13 to Outfall 012. Figure G055041 shows the drainage basins for the plant outfalls. The correction in the drainage piping is shown in the attached Figure 1-2. The remaining figures (2-1 C & 2-213) provide the sampling results of the investigation in and around Outfall 13 drainage basin. l look forward to our call on Friday. 1 will send you the conference line call in number and web access information in a separate email in the next day or so. III, H.W. Tim r Timothy 1-1. White, R1?Nl ENVIRONS RING, Inc. 810 S. Highway 6, Suite 200 1-101.1ston, Texas 77079 28.1-493-9005 281-493-9007 (fax) Cut' lidentialily Nuth e.'I'hi, for nsmiltal ,vul/or altaihomnl (Iho "COM IIlnnli dtiU n") is nwlidrntial (u IiN'VIRONEERIN'G, Inr, and maq also lx� othvrr iw pri viEegnl. It snu aw nut Vu+intended rstiipiunl, you arr h",mlh nolihesl th,rt } uu h,n-P Ik01%r-d this (:O nl rnnrlli alien In ears ami anc' dissemi it.] [it'll, dill ri bution orrupyint; ut (his Cunununiia(ion is striith prop ihi it II you havt- received IIIis Con In It Iwatinn in orror, h' 0Ll- nulilc us inrrnud is lrrc I'y wi,I), o-mail or IW Irlephona (1-281493-90115) and promptly rieletc and puriftr this Cum nw I'ii at ion. 76—— l�i Ke/A aAlkll C - q o I Z, _e'v,4, /////w /�- A 0 4 w (PG � I,,AO% 06 j--Q al Ao 2o�D7/o � F/— S c roc la►+�rs F. A�tLa� Fl#Rc�� //OC Fi.�arfS A, (d - deg ov N C+.r r V__� } / 1 �._Belnick, Tom From: Setzer, Britt Sent: Tuesday, December 15, 2009 8:23 AM To: Hyatt. Marshal I@epamail. epa.gov; Belnick, Torn Cc: Parker, Michael; Krebs, Rob Subject: RIF NCO004308 Permit Mod/Alcoa NCDENR-DEH-Public Water Supply Section in the Mooresville Regional Office has no comments on this draft modification. -----Original Message ----- Prom: Hyatt.Marshall@epamail.epa.gov[rnailto:Hyatt.Marshall@epamail.epa.gov] Sent: Tuesday, December 15, 2009 8:22 AM To: Belnick, Tom Cc: Setzer, Britt; Parker, Michael, Krebs, Rob Subject: Re: NC0004308 Permit Mod/Alcoa EPA has no comments on this.draft modification. 1 Ulu ez�i _ h Ynelnick, Tom From: Hyatt.MarshaII@epamail.epa.gov Sent: Tuesday, December 15, 2009 8:22 AM To: BeInick, Tom Cc: Setzer, Britt; Parker, Michael; Krebs, Rob Subject: Re: NCO004308 Permit Mod/Alcoa EPA has no comments on this draft modification. 1 Alcoa Mn(_ QWM feedbs� K i z/o9 Belnick, Tom From: Mcdaniel, Robert Sent: Monday, December 14, 2009 1:46 PM To: Belnick, Tom Subject: RE: Alcoa Question Tom, Sorry I have not been able to get back with you. in 1994 interim measures were conducted on SWMU 22 —Scrap Yard at the Alcoa facility in Badin. Contaminated soil was excavated and soil samples were collected and analyzed to verify the effectiveness of the soil excavation prior to backfilled placed in the excavated area. A 30-mil EIDPE liner was placed over the area and covered with washed stone. No further investigation is foreseen at this time concerning the Scrap Yard. Thanks, Rob From: Belnick, Tom Sent: Monday, December 14, 2009 1:12 PM To: Mcdaniel, Robert Subject: Alcoa Question Robert- I've left several phone messages with you but have not heard back. I understand that you were the RCRA Project Manager for the Alcoa site. I'm going to public notice with a draft NPDES permit modification for Alcoa on Tuesday 12/15/09, and wanted to verify that any cleanup actions at former SWMU 4#22 have been fully implemented. If I do not hear back from you by noon Tuesday I will assume there is no further DWM cleanup action still pending at SWMU #22. Thanks. Tom Belnick Supervisor, NPDES West Program NC DENR/Division of Water Quality 1617 Mail Service Center, Raleigh, NC 27699-1617 (919) 807-6390; fax (919) 807-6495 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. i Belnick, Tom From: Templeton, Mike Sent: Thursday, October 22, 2009 12:37 PM To: Beinick, Tom Subject: FW: alcoa - badin works - obl Here is an email to Rob McDaniel at DWM. Rob is the RCRA project manager for the Alcoa site, Bud is his supervisor (I think). Sorry, didn't find a phone number in the emails. -----Original Message ----- From: Rob McDaniel[mailto:robert.mcdaniel@ncmail.net] Sent: Tuesday, December 11, 2007 3:25 PM To: Mike Templeton —�— Cc: BUD MCCARTY Subject: Re: alcoa - badin works - obl. Mike, IA1coa approached the Hazardous Waste Section in 3uly 2006 regarding a Ipermitting issue with stormwater runoff from the Old Brick Landfill. IWe participated in a conference call with Alcoa and their consultant on 13uly 17th concerning issues at the Old Brick Landfill. Since the Old Brick Landfill is a RCRA solid waste management unit, Alcoa wanted to Id:iscuss the proposed work at the landfill, determine if we had any concerns with the proposed activities or any impacts on the unit, and Ito provide a few diagrams of the proposed work. It was our (understanding that the approval of the design and the wort: was to be Iconducted under the authority of the Division of Water Quality. I IThe Old Brick Landfill is listed as a solid waste management unit in IA1coa's Hazardous Waste Management Permit. Therefore, Alcoa is Iresponsible and must address any hazardous constituents originating Ifrom the landfill above the applicable standards or background levels Ifor that constituent. I Jl-you e yEon o c ns, ease feel free to ntact me. IRob McDaniel f h� jZ.�1��� "' Q; AvA 5� e*fMike Tem on �> o - I> I> Alcoa's NPDES permit has requirements for a discharge from the Old I> Brick Landfill, designated as Outfall 019. The discharge was long I> treated as a stormwater discharge, and the permit required monitoring I> but had no discharge limits. In the late '90s, Alcoa discovered a I> seep coming from the landfill, and their monitoring showed CN and F I> in significant concentrations (three samples, 2000-2002: approx. 300 I> ug/L CN, 15 mg/L F). The permit we issued in Sep 2006 (now contested) I> has limits for CN and F, calculated to protect surface water quality I> standards. I> I> Alcoa proposes to rework the cap on the OBL to prevent stormwater I> from entering the waste matrix, thereby eliminating the leachate I> seep. They would also add an infiltration pond to capture stormwater Vol (.r 04, J-1 EZ C Y > runoff and eliminate the discharge to surface waters altogether. The > information I have was submitted in early October, and it is possible > that Alcoa has completed these improvements by now. > Alcoa suggests that with these improvements there will be no > discharge to surface waters from the OBL and requests that DWQ remove > Outfall > 019 from the NPDES permit. I am not aware of anyone in DENR approving > the design of these improvements or otherwise agreeing that this will > eliminate the direct or indirect discharge of pollutants from the > landfill to surface waters. Alcoa's proposal does not suggest how > they will verify that the seep has been eliminated. > Before DWQ responds to Alcoa, I need to check with you. Has DWM > reviewed the design of these improvements? If so, have you approved > them? And are you satisfied that the new cap will sufficiently > control the seep? If the seep continues at some level, are you > concerned about potential exceedance of GW standards? Have you > verified that the pond is sufficiently sized to provide containment > up to and including the 25-yr 24-hr storm event? Do you have any > issue with this SWMU not having coverage under an NPDES permit? > If Alcoa has eliminated the discharge of pollutants at this site, I > am willing to recommend we drop the outfall from our permit. At this > point, I am looking for assurances that they have or will eliminate > 'the seep or that, if it continues after we drop the outfall, it will > be regulated under RCRA. > Thanks for your help. > - Mike Templeton > Michael E. Templeton, P.E. > Point Source Branch/ NPDES Permits > Surface Water Protection Section > NCDENRu DWQ Raleigh, NC > Tel: (919) 733-5083 x541 > Fax: (919) 715-0719 N Ifs v� ►1 �COA �G�tA"� /v !'c f1'1'y� �jr� �/f n NV �N v v .,., Belnick, Tom From: Belnick, Tom Sent: Tuesday, November 10, 2009 6:36 PM To: 'Gross, Mark' Cc: Prezbindowski, Robert; Kiser, Randall E.; Gross, Robyn L.; Parker, Michael; Poupart, Jeff; Matthews, Matt; Krebs, Rob Subject: RE: Request for Extension of Outfall 013's Fluoride Limit Effective Date - NCO004308 Mark- After consideration of your request for an additional 4 month extension of the compliance schedule to meet the fluoride limit at Outfall 013, the Division cannot concur with this request. Discussions regarding compliance schedules to meet fluoride limits at Outfall 013 date back to 2005, and the November 1, 2009 deadline was originally part of a 36- month compliance schedule provided in the September 25, 2006 Final Permit (later contested). Thus, the Division believes that Alcoa has had sufficient time to study the issue and implement appropriate corrective measures. If you have any questions on this decision, or need additional information regarding the proposed Outfall 013 re-routing, feel free to contact me. Tom Belnick Supervisor, NPDES West Program NC DENR/Division of Water Quality 1617 Mail Service Center, Raleigh, NC 27699-1617 (919) 807-6390; fax (919) 807-6495 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. -----Original Message ----- From: Gross, Mark [mailto:Mark.Gross@alcoa.com] Sent: Friday, November 06, 2009 3:41 PM To: Belnick, Tom Cc: Prezbindowski, Robert; Kiser, Randall E.; Gross, Robyn L.; Parker, Michael Subject: Request for Extension of Outfall 013's Fluoride Limit Effective Date - NC0004308 Tom, As you know, the current NPDES Permit (NC00004308) at Alcoa Badin Works has a fluoride limit at Outfall 013 which became effective on November 1, 2009. Since the issuance of the permit in 2008, Alcoa has spent over $180,000 to identify and reduce the source(s) of fluoride which contribute to the variable presence of fluoride at Outfall 013. Below is a summary of the activities completed thus far: * In three drainage channels leading to Outfall 013, a "Claymax" liner was installed and the areas covered in stone to facilitate drainage and prevent contact of stormwater with the underlying soils. Claymax is a non -reinforced Geosynthetic Clay Liner (GLC) with two lightweight nonwoven geotextiles encapsulating a layer of Volclay® sodium bentonite. * In the vehicle roadway and parking area, a barrier consisting of GCL overlain by a geogrid and covered with stone was also installed to minimize contact between stormwater and the surface soils. * Alcoa is evaluating means to reduce migration of fluoride from soils to the stormwater. * Alcoa conducted a camera review of the subsurface drainage piping for Outfall 013. Based on this examination the following actions were taken: 1. Pressure washed the pipe from the northernmost stormwater collection junction box (Northern Junction Box) to Outfall 013. 2. Pressure washed the pipe from SWMU 22 to the Southern Junction box. i 3. Recoated all the joints between the Southern ]unction Box and Outfall 013 with grout cement. In addition to these efforts, Alcoa conducted a comprehensive investigation to try and narrow down the specific area of the Outfall 013 drainage basin that is the primary source of the fluoride. The investigation included soil sampling, sediment sampling, and water sampling while simulating rain events on selective areas of the drainage basin. This comprehensive study led us to believe storm water contacting the former SWMU No. 22 (triangle -shaped) area at the north end of the plant is the primary fluoride source. This area is very small (approximately % acre) and it is our belief that during certain seasons in combination with certain rainfall events stormwater from this area has the potential to exceed the new effluent limitation. As a result, Alcoa would like to re-route storm water flow from the former .SWMU No. 22 area to Outfall 012 where we have the benefit of the diffuser. We firmly believe that we will be able to continue to meet the existing fluoride limits at Outfall 012 after the re-routing is complete. During recent discussions with NCDENR, Alcoa was notified that rerouting of this stormwater would be considered a major permit modification. Soon you will receive a formal request from Alcoa for this modification but at this time Alcoa is requesting an extension of Outfall 013's fluoride limit effective date from November 1, 2009 to February 28, 2010 which we believe will give us adequate time to obtain the permit modification, make the structural changes to the flow from the SWMU No. 22 area, and test the result. We appreciate your help on this matter and look forward to hearing from you. ,Please feel free to contact me or Randall Kiser of my staff with any questions you might have. Mark D. Gross APGI Yadkin Division Technical Manager Badin Works Facility Manager Office - 704-422-5774 Cell - 704-517-8364 2 Q Alcoa Badin Works 14 IA Highway 740 PO Box 576 Badin, NC 28009 USA Return Receipt Requested 0003 6918 6279 TOM, As you know, the current NPDhS Permit (NC00004308) at Alcoa Badin Works has a fluoride limit at Outfall 013 which became effective on November 1, 2009. Since the issuance of the permit in 2008, Alcoa has spent over $180.000 to identify and reduce the sourcc(s) of fluoride which contribute to the variable presence of fluoride at Outfall 013. Below is a summary of the activities completed thus far: • In three drainage channels leading to Outfall 013, a "Claymax" liner was 0 0 installed and the areas covered in stone to facilitate drainage and prevent contact z4 fTl of stormwater with the underlying soils. Claymax is a non -reinforced M Geosynthetic Clay Liner (GLC) with two lightweight nonwoven geotextiles U) % encapsulating a layer of Volclay sodium bentonite. 0 C In the vchicle roadway and parking area, a barrier consisting of GCL overlain by > a geogrid and covered with stone was also installed to minimize contact between rm _� stormwater and the surf ice soils. ,�, OoO • Alcoa is evaluating means to reduce migration of fluoride from soils to the stormwater. • Alcoa conducted a camera review of the subsurface drainage piping for Outfall z r 0 i 3. Based on t':;is examination the following actions were taken: 1. Pressure washed the pipe from the northernmost stormwater collection _ junction box (Northern Junction Box) to Outfall 013. 2. Pressure washed the pipe from SWMU 22 to the Southern Junction box. 3. Recoated all the joints between the Southern Junction Box and Outfall 013 with grout cement. In addition to these efforts, Alcoa conducted a comprehensive investigation to try and narrow down the specific area of the Outfall 013 drainage basin that is the primary source of the fluoride. The investigation included soil sampling, sediment sampling, and water sampling while simulating rain events on selective areas of the drainage basin. This comprehensive study led us to believe storm water contacting the former SWMU No. 22 (triangle -shaped) area at the north end of the plant is the primary fluoride source. This area is very small (approximately %z acre) and it is our belief that during certain seasons in combination with certain rainfall events stormwater from this area has the potential to exceed the new effluent limitation. As a result, Alcoa would like to re-route storm water flow from the former SWMU No. 22 area to Outfall 012 where we have the benefit of the diffuser- Per our earlier discussions, you indicated than an email (and accompanying check for the permit modification fee of $1030 which will be mailed to your attention) is sufficient to make this request. The current flow of this triangular - shaped area to Outfall 013 is shown in Figure 1-1. Alcoa intends to direct the storm water flow to Outfall 012 and through the diffuser in Badin Lake. The modification in drainage piping is shown in the attached Figure 1-2. Groundwater in the vicinity of this area is approximately 10 feet below grade. The storm drains in this area are 1 to 3 feet below grade. Therefore, the infiltration of impacted groundwater into the storm drain is not likely to occur in this area of the plant. This planned re -direct presents little significant change to the existing volume of flow to Outfall 012. The total area for the drainage basin for Outfall 012 is 17.64 acres. The triangular area is 0.49 acres in size. This represents less than a 3% increase in drainage area flowing to Outfall 012. Secondly, the increase in Fluoride loading to Outfall 012 from this re -direct is insignificant. The maximum concentration of Fluoride detected at the triangular area was 15 mg1L, with an average of 4.5 mg/L. Figures 1-3 and 1-4 show the surface water sampling results for the area of concern collected during the area run-off investigation in 2009. Compared to the average flow (0.021 MGD) and Fluoride concentration (3.25 mg/L) at Outfall 012 for the time period from July 2008 — July 2009, the approximate increase of Fluoride concentration at Outfall 012 is estimated in the graph below. As the graph indicates, even in a worst case scenario using the maximum detected concentration of Fluoride found in the triangular area, the increase in fluoride concentration at Outfall 012 would expected to be less than 0.5 mg/L. Using the average fluoride concentration at the triangular area, less than 0.03 mg/L increase would be expected to occur at Outfall 012. A summary of the calculations and assumptions used to create the graph are attached. ProjectedTotal Outfall 12 Concentration Based on Range of Triangle Concentrations and Average Existing Outfall 12 Concentration —� ��„aje.tau 'total �1U�tY C E'4t 3riiF1 i,t�y�Ll 1 •1 11 G. S 9 1 fs 1 1 12 11 14 1:� Range of FI Cone, trom'rrlangle (mofLi The data indicates that this modification would in no way impact our ability to meet existing permit criteria for Outfall 012. Lastly, regardless of which of the two outfalls the storm water from the triangle -shaped area exits, Badin Lake is the receiving body of water. Therefore, there is no net increase of flow or loading to the lake. We look forward to working with the Department to finalize this permit modification request as soon as possible. Please advise if you need anything else from us. Thanks in advance. Please feel free to contact me or Randall Kiser of my staff with any questions you might have. 011111 Badi Permit Modific i... PE Mark4SS APGI Yad ' Division Technical Manager Badin Works Facility Manager Office - 704-422-5774 Cell - 704-517-8364 Stela 1 Area Measurements Area Calcs Estimated Runoff Coefficient Runoff Area Plant Area (Industrial) RC 0.85 A 403719 feet Pine Grove Area (Forest) RC 0.15 A 103233 feet Admin Building Area (grass) RC 0.27 A 261633 feet Existing Total Area to Outfall 012 A 768585 feet New Triangle (Impervious) RC 0.95 A 21377 feet Step 2 Estimatina Averaae Rainfall and FI Concentration at Outfall 012 Outfall 011/012 Discharge Data (From DMRs) Date Flow (MGD) Concentration (mglL) 7/7/2008 0.119 0 8/11/2008 0 1 9/3/2008 0.052 1.6 10/25/2009 0.0068 1.1 11 /25/2008 0.0001 2.9 12/5/2008 0.01 0 12/17/2008 0.024 0 1 /26/2008 0.006 8.4 1/17/2009 0.00059 3.2 3/5/2009 0.00612 12 4/14/2009 0.0662 7.6 5/19/2009 0.0038 0 5/19/2009 0.0061 0 6I512009 0.0089 8.9 7/13/2009 0 2.1 Average �0:020640667 -,;3:253333, July 2008-Jul 2009 (Outfall 011/012 Onl ) Average flow per event to Outfall 012 10.020641 MGD Average conc per event to Outfall 012 3253333 mg/L Avg mass per event to Outfall 012 254194.1 mglD 78133.42 LID % Total Combined Area 51.11% 13.07% 33.12% 2.71 % 100.00% Determination of rainfall event intensity Flow 0.020640667 1 MGD 0.031936 cfs Intensity* 2.60753E-06 ftlsec 0,112645 inlhr 2.703490026 in/day Average rainfall event intensity generating average concentration *Intensity estimated by dividing average flow by run-off areas and run-off coefficients. Step 3 Estimating FI Loading at Outfall 012 FL Mass Calcs (Avera Size of Existing Outfall 012 Area 768585 sq ft 1.11E+08 sq inches Average rainfall event F-2-7703491 inches Volume water per rainfall event 2.99E+08 cu inches 4903189 L FL concentration from Outfall 012 Area 1 �3253333 mglL Mass FL from Outfall 012 Area 15951708 mg Step 4 Estimating FI Loading from Triangle Area Size of Triangle 21377 sq ft 3078288 sq inches Average rainfall event 2.70349 inches Volume water from Triangle 8322121 cu inches 136374.6 L Step 5 Estimating new FI Conc. at Outfall 012 Projected Total Outfall 0111012 Concentration Based on Range of Triangle Concentrations Range of Triangle Concentration (mglL) Projected Total Concentration. (mg/L) 0 3.165296 1 3.192356 2 3,219417 3 3.246478 4 3.273539 5 3.3006 6 3.32766 7 3.354721 8 3.381782 9 3.408843 10 3,435903 11 3,462964 12 3.490025 13 3.517086 14 3.544147 15 3.571207 Projected concentration at Outfall 012 calculated by the following equation: ((Mass to Outfall 012 + (Triangle Area Conc. x Triangle Area Runoff Volume)) (Runoff Volume to 012 +Runoff Volume from Triangle Area) Example Calculation: Projected Total FI Concentration at Outfall 012 (Triangle = 1 mg/L) ((1,5951,708 mg+ 0 mglL x 136,374.6 L)) t4903189 L + 136,374.6 L) = 3.192356 mg1L s NOTES: l �I{{I I; ro W41_ FS SLNER SEE C-^•'.�.-R. ,1 , nk3. -1J1N1 lLtV11r„f:S n-t �� >t[ •'%:K� 7�s­rNT ruTw vr wvn E I Al'_I IYl U Y I D[nW O LB API bYND w ;. N C : r-1 _�frzw - r �i � 5 ��,•, WTlS�IJ1 _ LI -•- 0 'AQ:�OLE :ROLD Cr'C=1 v- alP.'.n I 0 1NLrT "i,, u w - *rLL 0,L- • ~ 0 1NLCT S.O:C VSiE. CES1fJW-Ul NL4$fA 5555 TW 0[ CAETMO ELR.TOI 55:A iMICpT ELE"TGNI51 ��' '.15051UC9-5F-n SMA �OELfCTFO AT 810:; 05e 3LNlr1CILi INuT $� ` yr , - ,. i5n44'iG Wfi++:i �RERS 0:0�3'�9-Si- 44YI • 'sff��- lrr��N Ai4CwfW '� •I ,•rrti: �•Evl :II 0?-:S-i M9 � f� W'- /fir ^'k f-` 7 Y . "' cTA :� l� !=1 1•T.: T.iG.L K�JCF.Y:RI.T Vi Lw !I) ,vc-2Y _ _ ! •__ �� �' -ems s`4 - S^AR-' A,.fCf �7 fRCAI $iPr ICE u•. ^ "_ ���. �•_>.�-"N-meµ -�,�� \� $Y/-3 �' % W_3 'S --'OU•. RYA. C.EI:r r I` - ^__.''a'. 05077.^0c_SYI-1 / pq •• .. �� !.� ••,^._ �� 0S0S7COL-5W-J� `>iy �� � I I / -'�� =�_ i JI �05053009-51.-5� `- _s (17J OUTFA! - - _ -- - _ ___- - -- - --- u 13 f RIF DWG EWRONEERINO. 1 MAY 5. 2CO9 RAIN EVE, 5'JP.FACE WATER SAN'L r� ANALYTICAL RESULTS M, i A!CDA — DIN W�RAID] rA.ILI i S 1 F. s131v. 40E ri ; AF?0'lNh w�rr kAik4 U NOTES: Fc- SEX1. �Ez Jjl I- rLt 'G— LM[v" SSTE. Whi LQk X, 1.0 :4 CONTROL. 6 - OLE ' . SIX D CCYC;) P- Pt 1p I ffl.i a NLj1 lt4r:koLt .CLL OI" 0 INLET 5 occ S,STEM DE&WWro,, NomWR IC S5J5 TOV Ot fj--TJSG CLC.'s701 r,Y 55,.0 11,EP7 ELEIATION(S) D I AWL f,%,t4 LX0014 Er -E 4,E-3 52--SR-12�, (2. -40 $2V-SR 2 D 1 522-SP-x 0 a+r. .1111 AA-rr] cxw. ZI S.-PLIF LOCA'iM .5501,AED .:« WER WUC' aLhP;T SAWPLW, t.F r D. ST7 Sp ;,W,04 .W.C.TE�, A.7-1 K14- (I) —L"CAI --E& TRUE: QUUCF: S-Pt11:c EvEt IS -I.TrALL 013 (JQ� uU -i[-,AL- T -SR-11 a OG L?a F WIC / ' \A 22-,417-PE / &".1", I ENVIRONEERING. I y„}TEP !x,IrTKO-WFF —LW- EVEIL.r�TM u* �WL! CXLECTIoN SWFK;� FLiA QRX-:L)N ul ff,T:l Ill OC&TL:,Pl n2 t �U b�:t b.Z-w-b S72-s-t s2?-5P-v .GC -00-411Pw r 90 r., �'7 �OJTFALL Ol i b ^�_ 9.27 AC (403,719 sq ft)- t NE _ W PIKE -- -c=0.85� PROPOSEDy� _ t $ -CLOSED' PMIYG - 0 49 (21,377 sq ft) !0l f -- -- �,% C=0.95 2.37 AC 0 103,233 sq f > (PULP C=0.15 SYSTEM •ii:i / .' 1 . ' �~ �� `.,� IOC 2:. 6.01 AC >,� tea« w ILLi (261,633 sq ft) --- C=0.27 ENVIROINEERING, INC. OUT O11 & 012 0 4n\N LL (SO!m FlCURE STORMWATER PIPING CORRECTION -- _ �- -- - ALCOA - BADIN WORKS FAC!UrY STOIWWUER OBTFALE IOENnFiGnp lS .� BADIN,*NORTH CAROLIIN w` -- O_ - , 7a FALL 01 ,29 C! -53 C, _c DIFFUSER a. PUMP SYSTEM WALL IN Ia. I Gol 0 UTrALL 011 & 012 LEGEN IENVIRONEERING. INC. "N"I" (sot,D CcIrR) FIGURE 1-1 a -ul &-�_ -OLE AREA STORMWATER DRAINAGE NLC BASIN OVERVEW MAP A4COA — NADIN WORKS FAC,UTY Ac 4p TM, rplm 041 R"; aADIN, NORTH r.4[ J PLAN) ids CAROLINA 15717,MWATM, NIA10C STOWWAIER OriTFAU IDrNTIVItAT*N, BE C 4tv Belnick, Tom From: Templeton, Mike Sent: Thursday, October 15, 2009 4:52 PM To: Belnick, Tom Subject: FW: Outfall 013 modification Attachments: 013 letter to state final. pdf Here's the Alcoa letter FYI. I probably won't get to it till next week. -----Original Message----- JFrom: Kiser, Randall E.[mailto:Randall.Kiser@alcoa.com] Sent: Thursday, October 15, 2009 10:23 AM JTo: Templeton, Mike JCc: Gross, Robyn L.; Prezbindowski, Robert; Tim White; Dworek, Rick; JKrebs, Rob JSubject: Outfall 013 modification 1 <<013 letter to state final.pdf >> Mike, JPer you request the attached letter outlines Badin Works plan to reroute some of the storm water flow from outfall 013 to outfall 012/011. 1 II will also follow up this email with a certified copy of the attached file by mail to your attention. r JIf you have any questions please give me a call.�- � D Randall Kiser PE Senior Staff Engineer 49.FRC L4� 18-230-5685 /M V 1704-422-5685 1704-422-5776 Fax LRandall.Kiser;:Alcoa.com �, � �r'�f L-104.-- 1f 1 October 14, 2009 Mr. Michael 11. Templeton, Division of Water Quality NC Department of 1 nvironmental and Natural Resources 401 Oberlin Road Raleigh, NC 27605-1350 Ile: Alcoa Badin Works — Badin, North Carolina NPDP'S Permit No. NC 0004308 Dear Mr. Templeton: Alcoa proposes to re-route storm water flow from the former SWMU No. 22 (triangle -shaped) area at the north crtd of the plant to Outfall 012. The approxilllately '/ acre area currently flows to Outfall 013 as depicted oil facility drainage maps (Sec Figure 1-1). Alcoa intends to plug that drain and direct the storm water flow to Otrllall 012 and through the diffuser in Badin Lake. I'r•ior to plu1��11in" the lines, the existing piping will be back-11us11ed to remove any deposited sediments in the line that may be present. The Proposed correction in drainage piping is shown in the attached Figure I-2. This triangle -shaped area has undergone investigation tinder the RCRA Facility Investigation ("RFI") process. The finding of the I IJ rc ort for the�U No. 22 area, which has been acre tcd by the NCDI NR Wastei�lana��cment Division. states t le o owiri �'The,��F!_ data verify the removal of soil and debris from this area _in wand. aft__ detected soil concentrations are below conservative risk -based levels. As a result of the soil,LemQvqi actin a findin s no art er action rs recommended or U Groundwater in the vicinity of this SWMU is being addressed in the SWMU-Area concept with the entire North End of the plant. Groundwater in the vicinity of'this area is approximately 10 feet below grade. The storm drains in this area are l to 3 feet below grade. The infiltration of, impacted groundwater into the storm drain is not likely to occur in this area of the plant. Groundwater on the northern portion ol'the plant is currently beill" addressed as part ol'the on (foing Corrective Measures Study for the facility. I'll],; planned re -direct presents little signilicant change to the existing volume oi' flow to Outfall 012. The total area 1,61. the drainage basin for Outf"rll 012 is 17.64 acres. The triangular area is 0.49 acres in size. This represents less than a 3yo increase i11 draina��e area flowing to Outlall 012. Secondly, the increase in FILIMidc loading to Outlall 012 Irom this re -direct is insit-nilicant. The maximum concentration of Fluoride detected at the triangular area was 15 mg/L, with an average of 4.5 mg/L.. F iv�ures 1-3 and 1-�4 show the surface water sampling results for the area of concern collected during the area run-off investigation in 2009. Compared to the average flow (0.021 IMGD) and Fluoride concentration (3.25 mg/L) at Otrlfall 012 for the time period from July 2008 .tiny 2009, the approximate increase of Fluoride concentration at Outlall 012 is estimated in the graph below. As the graph indicates, using the maximum detected concentration Mr. N ichacl Templeton NCDENR -Division of Water Quality October 14, 2009 Wage 2 of Fluoride found in the trianglllal• area, an expected increase of less than 0.5 ni-1- would be seen at the outiall. Using the average concentration, less than 0.03 rng/L increase would be expected to occur at the Olrtiall. A SLIn7mal'y O1 the Ct11C1.11atlC7nS and aSSLlmptlUnS used t0 create the graph arc provided as all attachment to this letter. _37 J is 3,E i — N 3 `• �sn 3,2 w 31 0 u 3 J 'a 4 a` 2 0- Projected Total OutfalI 12 Concentration Based on Range of Triangle Concentrations and Average Existing 4utfall 12 Concentration 0 1 2 3 4 j r 7 B 9 IU 11 1213 14 15 Range ��f FI Conc. frontT wU1e(mglL) —�—Projected Total Cwitrntr ytfvn (molt-) ca Lastly, regardless of' which of the two owl Ills the storm Nwater from the triangle -shaped area exits, 13adin Lake is the receiving body of water. 'Therefore, there is no net increase of flow or loadim-to the lake. Unless otherwise directed by your office AICOa would like to proceed with the proposed activities after November 1. 2009. Based on these actions Alcoa believes that compliance with the new Fluoride ci,lluent limitation at Outfall 013 can be achieved by the November 1, 2009 scheduled compliance date ifallowed to rc-direct the flow of storm water from the area in question. Further, since this is an insignificant change in flow and loading and Only related to movement of'stormwater, Alcoa believes that this action doesn't warrant a modification to the planCs existing NPDES permit. Alcoa respectfully request your C0I1CLIrrCI1CC with this Illatter and W011ld like t0 thank y01.1 in advance IOr yOLll' UMCIV rCSpOI1sC. Should YOU have any questions or concerns regarding this approach. or would like to discuss in more detail, please CIO not hesitate to call me it 704-422-5685. Siticercly. Randall Kiscr Alcoa 13adin Works cy > CA F-1 Q J, y TFALL 0 9.27 AC (403,719 sr, f f _� L) 525) 252A it 20 8 5 - Q �_ _ _� - .,`.y� - = y -'f• � PROPCSED T F L 0, 4c AC 2 '1 7,W7 qq f V c - C), 9.5 2.37 AC 1 3, 2 33 -q q ft" -DIFFL'li c �R PUMP 0 15 SYSEw 117 C6.011 AC (26 1 ,633 7 C=0.27 LEU13 ENVIRONEERING, INC. OUTFALL 0-,i 1 012 �,Lv —OLL 1VC:�-MWAUR PIPING w, COFZRrlCTlO.'-' ALCO& - Bl-DIN 'HD;-.S --A:U-. UAr)114. NORT11 CA3CLIN& 1.1—ARR OdIrAU XIFMC-Mlll (,5r3rmgu� r K;i*CrVCw PLA:l) Mr. AMichael Templeton NCD1 NR —Division ol' Watcr Quality Octobcr 14. 2009 Page 3 < mom' . ,nse Mi., Michael Templeton NCDL.NR —Division of Water Quality October 14, 2009 I)a-e 9 Step 5 Estimatina new FI Conc. at Outfall 012 Proiected Total Outfall 011/012 Concentration Based on Rancie of Trianale Concentrations Range of Triangle Concentration (mg1L) Projected Total Concentration. (mglL) 0 3.165296 1 1192356 2 3.219417 3 3.246478 4 3.273539 5 3.3006 6 3.32766 7 3.354721 8 3.381782 9 3.408843 10 3.435903 11 3.462964 12 3.490025 13 3.517086 14 3.544147 15 3.571207 Projected concentration at Outfall 012 calculated by the following equation: ((Mass to Outfall 012 + (Triangle Area Conc. x Triangle Area Runoff Volume)) (Runoff Volume to 012 +Runoff Volume from Triangle Area) Example Calculation: Projected Total FI Concentration at Outfall 012 (Triangle = 1 mq/L) ((15,951,708 mg +_(1_mg1L x 136 374.6 L)) (4903189 L + 136,374.6 L) = 3.192356 mglL Fluwrid? , s, %A P c o d C�1�11 0 1'2_ Fk v v ocCf 2, '13:-3 ym Jeo �r ^4,r e �_C�;rl mil Wit a<<s acre- _ So y I S enn a-4ed il1"P4i1�oJ,�w �PJL� addrPstel O(WAX) Ex ec,W 1 F1 11P ` o 12, 0514J MAX=ISM�11, e)(L (AlfVI) Fl av� = y.se7ty -expo PN' c p.snad 7'�P 0 t Z 0 3 y,e �' a 1z- 8 .s,wM v.'. sr►�I I l n� .S�J G�'r�l �`� � QI �. Mr. Michael Tcmpleton NCDINR —Division of Water Quality October 14, 2009 Paoc 7 ATTACHMENT I OUTFALL 012 RUN-OFF CALCULATIONS Step 1 Area Measurements Area Calcs Estimated Runoff Coefficient Runoff Area Plant Area (Industrial) RC 0.85 A 403719 feet Pine Grove Area (Forest) RC 0.15 A 103233 feet Admin Building Area (grass) RC 0.27 A 261633 feet Existing Total Area to Outfall 012 A 768585 feet New Triangle (Impervious) RC 0.95 A 21377 feet Step 2 Estimating Average Rainfall and FI Concentration at Outfall 012 Outfall 0111012 Discharge Data (From DMRs Date Flow (MGD) Concentration (mgll_) 7/7/2008 0A 19 0 8/11 /2008 0 1 9/3/2008 0.052 1.6 10/25/2009 0.0068 1.1 11 /25/2008 0.0001 2.9 12/5/2008 0.01 0 12/17/2008 0.024 0 1 /26/2008 0.006 8.4 1 /17/2009 0.00059 3.2 3/5/2009 0.00612 12 4/14/2009 0.0662 7.6 5/19/2009 0.0038 0 5/19/2009 0.0061 0 6/5/2009 0.0089 8.9 7/13/2009 0 2.1 Average 0.020640667 3,253333 % Total Combined Area 51.11% 13.07% 33.12% 2.71 % 100,00% Mr. IVlichael TC111Pleton NCDI NR —Division ol' Water Quality October 14, 2009 Pave 8 July 2008-July 2009 (Outfall 011/012 Only) Average flow per event to Outfall 012 0.020641 MGD 78133,42 LID Average cone per event to Outfall 012 3.253333 mg/L Avg mass per event to Outfall 012 254194.1 mg/D Determination of rainfall event intensity Flow 0.020640667 MGD 0.031936 cfs Intensity* 2.60753E-06 ft/sec 0.112645 in/hr 2.703490D26 in/day Average rainfall event intensity generating average concentration *Intensity estimated by dividing average flow by run-off areas and run-off coefficients. Step 3 Estimating_FI Loading at Outfall 012 FL Mass Calcs (Average) Size of Existing Outfall 012 Area 768585 sq ft Average rainfall event 2.70349 inches Volume water per rainfall event 2.99E+08 cu inches FL concentration from Outfall 012 Area 3.253333 1 mg/L Mass FL from Outfall 012 Area 15951708 mg Step 4 Estimating FI Loading from Triangle Area Size of Triangle 21377 sq ft Average rainfall event F2—+7-03491 inches Volume water from Triangle 8322121 cu inches 1.11E+08 sq inches 4903189 L 3078288 sginches 136374.6 L Mr. Michacl Templeton NCDENR —DIvIslon 01'WItCl- Quality October K 2009 Pa-e 6 g Z flu M m fi o e;A Mr. Michael Templeton NCINENR -DlVISIOII 01'W',IICI- Quality October 14. 2009 Page 5