NC0035173_Corrective Action Plan_20201111

Wieland Copper Products, LLC
Corrective Action Plan Status Report EGEweD
Permit Number NC0035173 Nov 11 zno
NDDE.oiD\NRINPDEs
ENVIRONMENTAL
PRia" CESS
SOLUTIONS, PLLC
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 RECEIVED
Table ofContents NOV 11 2020
NCDE[l/OVVg/NpDES Report Submission Authorization 3
Introduction 4
Purpose 4
Existing Treatment Facilities 4
Status of Alternatives evaluated Out;a||0D1 S
Status of Alternatives evaluated outfa||003 6
Updated Schedule ofCompliance 7
Selected Alternative implementation Plan 8
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Report Submission Authorization
This Corrective Action Plan is submitted by Wieland Copper Products, LLC and Environmental Pr
ocess
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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Ivan Di Stefano, President
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Jared Ranken, Director of Environmental, Health and Safety
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Tony Sprinkle, Environmental Supervisor
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Kellie Hedrick, PE,Consultant with Environmental Process Solutions, PLLC
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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 in 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. Final treatment system
installation and operation is due by 11/1/2021.
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.
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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.
After initial evaluation of precipitation failed, and an adsorption technology called ProMoss had been
introduced,testing on use of ProMoss was run for several months beginning in late 2019. The
evaluation of ProMoss did not provide significant reduction in the copper levels leaving Outfall 001,so a
pilot unit for ion exchange testing was ordered. The pilot unit was received in July 2020 and testing was
begun after installation for side stream evaluation. Initial tests showed only a slight improvement in
copper levels by passing wastewater treatment plant effluent through the ion exchange (IX) unit prior to
discharge through 001. For the test, approximately 10 gal/min was passed through the unit and tested
for copper levels at the inlet to the unit and the effluent from the unit.
Date Before IX Treatment After IX Treatment
ug/L ug/L
9/8/2020 194 138
9/9/2020 197 173
9/10/2020 197 169
This low reduction was a surprise to all involved in the testing. Consultation with the manufacturer
resulted in several other options to try in addition to the ion exchange unit to ensure contact time and
effective removal pH. Testing for enhanced ion exchange removal will take place in early 2021 due to
staffing issues for the remainder of 2020.
Precipitation enhancement was evaluated again and resulted in removal of copper to meet the limits
imposed in the permit, however,the treated water failed toxicity testing. Additional studies are taking
place by modifying chemical dosing and evaluating the possibility of adding an oxidizing chemical post
precipitation that will neutralize the toxic chemical used for precipitation. These studies are being
conducted by the chemical supply vendor and will be evaluated during the rest of 2020.
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Status of Alternatives evaluated Outfall 003
Adsorption, coagulation, and filtration are 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
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 adsorption 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.
With the ion exchange unit on site, a test was conducted on the Outfall 003 stream to determine if ion
exchange used post chemical treatment would polish the stream to within discharge limits. Results
from the test conducted are shown in the table below.
Date Before Treatment After Treatment
ug/L ug/L
9/15/2020 24 24.5
9/17/2020 19.8 21.2
9/18/2020 22.3 20
As shown in the table, the ion exchange unit resulted in no reduction in the copper concentrations in
Outfall 003. During the test period,the effluent from the physical/chemical treatment plant was already
under the discharge limit. The system can achieve the permit limits occasionally with the existing
treatment system, but not on a consistent basis. Addition of the ion exchange unit for polishing did not
aid in lowering the concentration and will not be seriously considered for permanent use.
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Updated Schedule of Compliance
Date Task Status
11/5/2018 Begin studies on precipitation for physical/chemical Complete
treatment optimization on Outfall 003
11/5/2018 Begin treatment testing for precipitation use post Complete
biological treatment for Outfall 001
2/28/2019 Complete Precipitation studies Complete
3/4/2019 Begin studies on Nexom Filtration for both outfalls Option discarded due to low
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 both outfalls Option evaluation delayed due
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 on either Option under investigation and
outfall as deemed necessary by previous testing as of 11/1/19
experimentation
6/30/2020 Complete polishing studies on both outfalls Polishing studies began 7/2020
and are still in progress.
Polishing has not been
successful to date
11/1/2020 Status Report Due Issued 10/28/2020
12/1/2020 A to C paperwork due Will be delayed
3/15/2021 A to C approval Anticipated delay
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
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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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