WI0700012_Correspondence_19951219

Phosphate AURORA DIVISION
P.O. BOX 48, AURORA, NC 27806
December 13, 1995
Attn: Karen Harmon
Underground Injection Control Program
Groundwater Section
NC - DEHNR, Division of Environmental Management
P. O. Box 29578
Raleigh, North Carolina 27626-0578
Subject: PCS Phosphate Company, Inc.
Pilot Plant Study - Injection Well Water Supply
Tank Farm Remedial Action System
Permit - WI0700012
Dear Karen:
CP
p
As requested by Elizabeth Morey's letter: dated March 17, 1995, PCS Phosphate submits the
attached report to address the information concerning the Tank Farm Remediation System. The
attached report contains the following information:
1) The results of the pilot study,
2) the plan for treating depressurization well (DPW) water prior to injection, and
3) the schedule for construction and operation of the proposed system to replace the well
water supply.
The attached report indicates that use of treated DPW water as a supply to the Tank Farm
remediation system will require a modification of three of the limitation values contained in the
subject permit. If the DEM concurs that treated DPW water is the best alternative to the present
well water supply, PCS Phosphate requests that the pH range of the water supplied to the
injection system be expanded to a range of 6.0 to 8.5, that the TOC limitation value be increased
from 4.3 mg/I to a value of 8.0 mg/1, and that the TDS limitation value be increased from 475
mg/1 to 500 mg/1.
If there are any further questions about this report please contact me @ [phone].
Sincerely,
/7_
Timothy F. Walls
Environmental Engineer
pc: Willie Hardison/ Guy Pierce- DEM WaRO BAP/00-18-000
W. A. Schimming T. L. Baker
15-03-003-02

Tank Farm Remediation System Injection Well Water Replacement
Introduction
A pilot water treatment system was rented in June 1995 to determine if the facility's
depressurization well (DPW) water could be used as a replacement water source for ground
water supply to the Tank Farm remediation system. The pilot system consisted of a multi -media
anthracite/sand filter (ASF) and a ultraviolet (UV) light treatment tube. The purpose of the ASF
was to remove any suspended solids from the DPW water. The ASF was followed by treatment
with UV light to disinfect any bacteria in the water stream.
The pilot system began operation on 07/13/95 and operated until 12/04/95. The pilot system
operated at a flow rate of 4 gallons per minute. The water from the pilot system was disposed
into the plantsite's water management system and not introduced into the remediation system.
Results of the Pilot Study
Attachment 1 summarizes the water quality data taken during the pilot study. As shown, the
ASF/UV system produced a water stream from the DPW that was in compliance with the
limitations of the subject permit with two exceptions - TOC and pH. The TOC values averaged
5.2 mg/1 versus the permitted limitation value of 4.3. pH values ranged from 7.1 to 7.9
throughout the study which were above the 6.0 to 7.0 range required by the permit. It was
expected that the pH range of the DPW water would be above these values because its normal
pH ranges from 6.7 to 8.2 (year-to-date 1995 values). All of the analysis were negative for the
presence of any coliform bacteria indicating that UV light disinfection was successful.
Proposed Treatment System
Attachment 2 is an illustration of the proposed ASF/UV treatment system, which, if approved,
will operate as a full scale water supply source for the Tank Farm injection well water system.
This system will ASF/UV treat the DPW water to use as injectate water in the remediation
system. The full scale system will have a design flow rate of 16 gallons per minute (the normal
steady state flow rate into the injection system). The ability to use steam condensate as a
supplement to this water source will also remain.
Monitoring Activities
PCS Phosphate proposes to maintain the quarterly sampling schedule and analysis requirements
of CIW-7 outlined in the subject permit. We also propose to sample and analyze the injection
well system Water Level Control Tank (WLCT) and the product water from the SCF/UV
treatment system on a quarterly basis. CIW-7 samples will continue to be analyzed for the
parameters of cadmium, chromium and manganese. The concentrations of these metals remain
constant throughout the system so the WLCT and the SCF/UV will not be sampled for these
parameters.

Tank Farm Remediation System Injection Well Water Replacement Page 2
Implementation Schedule
Upon concurrence of DEM to proceed with this project, PCS Phosphate will begin a
procurement process of an ASF/UV treatment system. Purchase, delivery, installation and start-
up of the treatment system equipment will be completed within seven months of the approval
date by the DEM. Until the new treatment system can be put into operation, PCS Phosphate
requests DEM permission to continue use of the present injection well water supply system as
the remediation system supply.
Permit Modification Request
If treated DPW water is allowed as a water supply to the remediation system, PCS Phosphate
requests that DEM revise the permit conditions to allow for an increased pH range, a higher
TOC value, and a higher TDS ]imitation. A pH range of 6.0 to 8.5, a limitation for TOC of
8.0 mg/1, and an increase in the TDS limitation to 500 mg/1 are requested.

PCS Phosphate - Aurora Division
Pilot Plant Study - Injection Well Water Supply
Parameter
08/01/95
08/15/95
09/07/95
09/21/95
10/11/95
11/01/95
11/30/95
Avgs
Limits
Total Phosphorus mg/I
0.027
0.024
0.024
0.010
0.014
0.025
0.025
0.021
0.150
Fluoride mg/1
0.73
0.69
0.69
0.68
0.70
0.68
0.71
0.70
1.00
Chloride mg/1
10.8
10.7
9.0
10.6
13.0
10.0
11.5
10.8
55.0
Sulfate mg/1
<10
<10
<10
<10
<10
<10
<10
<10
50
'
TOC mg/1
4.0
6.0
6.0
4.8
4.2
6.0
5.2
5.2
t ,
1' 4.3
TDS mg/1 1
528
412
330
380
496
357
354
408
,,0475
Cadmium mg/1
<0.005
<0.005
<0.005
<0.001
N/A
<0.001
N/A
<0.005
0.005
Chromium mg/l
<0.05
<0.05
<0.005
<0.001
N/A
<0.001
N/A
<0.001
0.05
Manganese mg/I
<0.05
<0.05
<0.05
<0.05
N/A
<0.01
N/A
<0.01
0.05
Total Coliform /100 ml
<1
<1
<1
<1
<1
<1
N/A
<1
<1
pH
7.9 @19 oC
7.4 @26 oC
7.5 @22 oC
7.4 @24 oC
7.1 @21 oC
7.2 @19 oC
7.4
N/A
6.0 - 7.0
'
Ci it
,_r"i... •
'1.0
Pt+

NOTES
Lf ALL EOUIPMENT SK/P MOUNTED
2.) ALL ELECTRIC AUTOMATED
JJ INSIDE A Tex 241x 12' PREFABRICATED BUILD/NC
\ E11SRnG DPW
/ SUPPLY
2" SCHEDULE 40
C4 D4
v
n
LX
MULTIMEDIA f7LTER
24"x 60
24"x 60"
/50 PS/ MAX. PRESS.
MULTIMEDIA f7LTER
24'x 60"
V
AL
A
CT
/8 GPM
BACKWASH PUMPS (2HP)
50 GPM, 30 PS/g
D4
071
UV STERILIZER
UV STERIL/ZER
BACxWASY !O
AREA ORAMAGE >
POL YETHEL YENE BACKWASH TANKS
86" D/AM x 96" TALL
D4
C4
Po (AISIMG HA'1
2" BLENDING SYSIDI >
DRAWN L.M.MONTCOMERTY
CHECKED
APPROVED
APPROVED
PCS
Phosphate AURORA DIVISION
DRAWING TITLE
MECHANICAL FLOW
/NJECTTON WATER TREATMENT SYSTEM
ENGINEERING
JOB No.
DATE:
I/5/95
SCALE:
NONE
DRAVANG No.
H2OINJSY

PCS
Phosphatee AURORA
PCS PHOSPHATE COMPANY, INC.
P.O. BOX 48, AURORA, NC U.S.A. 27806
June 25, 2007
Thomas Slusser
Water Quality
Groundwater Protection Unit
NCDENR
1636 Mail Service Center
Raleigh, NC 27699-1636
Re: Injection Well Permit No. WI0700012
PCS Phosphate Inc. - Beaufort County
Dear Thomas:
RECEIVED / DENR / DWQ
Aquifer Protection Section
JUN 27 2008
Thanks for taking the time to discuss the complexities of our site and the impact the
proposed R/O plant will have on the Injection Well Permit. Enclosed is the data
requested which supports consideration of a variance concerning injection of waters
containing "wastewater".
Our boiler water treatment consultant produced the spreadsheet entitled Projected
Blended RO Reject/DPW Header Characterization. The Projected Blended DPW/RO
Reject H2O column and the PCS DPW Historical column is not a true measurement of
TDS. The data presented is an ion balance used to predict the TDS.
The spreadsheets entitled PCS Phosphate Operation — Tank Farm Wells is historical data
taken from the Injection Well Water Level Control Tank (WLCT). The average TDS
observed from January 2002 until July 2007 is 428 mg/L.
The ratio of the average TDS in DPW water and the predicted TDS from the ionic
balance was used to calculate a predicted TDS in the DPW water with the concentrate
from the proposed R/O. This predicted TDS is 525 mg/L. This calculation is presented
in the attached item entitled Predicted DPW TDS with R/O Concentrate Stream.
Table A3 and Figure 3 were gleaned from the original design documents. Table A3
shows the groundwater quality in the Croatan Formation. Figure 3 shows the injection
wells CIW 1 through CIW 7, which are screened in the Croatan Formation as well as the
monitor well collection zones specifically MWTF-lC which is also screened in the
Croatan.
H:\Tank Fann Remediation System `,2008'Injection Supply.doc

The Surfical Aquifer is recharged through precipitation and thus is not impacted by the
change in DPW water chemistry.
Should additional information be necessary or if you have any questions please do not
hesitate to call me at 252-322-8283.
Sincerely,
D. Daniel Winstead III
Environmental Engineer
PCS Phosphate
Attachment
pc: R. M. Smith / 12-07-00 (w/ attach)
Mike Brom
H:\Tank Farm Remediation System \2008\Injection Supply.doc

Header Characterization
Protected Blended RO Reject/DPW
Projected
PCS
Projected
Blended
PCS
DPW
Blended
DPW/RO
Reject H2O,
ppm
7.49
416
220
80
301
22
DPWIRO
DPW
1st Stage
Conc.
Flow, gpm
397.18
1st Stage
Conc.
ions
7.651
673.23
_
2nd Stage
Conc.
Historical
Projected
Reject H2O,
Historical
2nd Stage
Conc.
Averages,
RO Reject,
ppm
TDS,
TDS,
Parameter
ppm
ppm
ppm
Flow, gpm
ions
pH 1
7.45
7.71
846
12
235.69
7.81
1135.82
M-Alkalini , as CaCO3
342'
507
417
as HCO3
Calcium Hardness, as CaCO3
256
88
102
as Ca
_
9.875 16.625
Magnesium Hardness, as CaCO3
941- 2
350r- 14
19
23
as Mg
1.648'
2.7604
19.3854
72.35
247.5
Total Hardness, as CaCO3
11.523
Chloride, as CI
17
54
184.5i
1.0(
22
9-12
17
as CL
SiO2
43.03
Silica, as SiO2
76.1
92.1
0.5
0.4
75.3
1.4
16.5
0
0.85
0.88
0.002
76Ls
147.19
Phosphate, as PO4
0.4
Iron, as Fei
0.5
0.015,
751
19
Sodium, as Na
18.7
403
as Na
321.12
539.82
Sulfate, as SO4
0.6
6.2
4.94
8.32
Potassium, as K
13.6
33.3
17
14
as K
26.57
44.57
Aluminum, as Al
0
0
Fluoride, as F
0.70
1.73
1.38
2.32
Strontium.
Barium, as
as Sr
0.72
1.79
1.43
2.40
Ba
0.002
0.005
Total
820
668
Notes: 1) Assume 590 gpm RO Reject flow
2 Assume 4000 gpm DPW Header flow to PAP
3) Concentrate ions per Crown Projection 2/6/2008
4) Numbers in "RED" are from Chemtech analyses

PCS Phosphate Operations - Tank Farm Wells
Page 1 of2
WLCT
DATE SAMPLE COLLECTED:
01/28/02
04/08/02
07/22/02
10/23/02
01/21/03
04/22/03
07/15/03
10/15/03
07/29/05
10/31/05
LAB SAMPLE ANALYZED START
01/28/02
04/08/02
07/22/02
10/23/02
01/21/03
04/22/03
07/15/03
10/15/03
07/29/05
10/31/05
LAB SAMPLE ANALYZED FINISH
02/19/02
05/02/02
08/19/02
11/25/02
02/07/03
05/21/03
07/28/03
11/17/03
08/01/05
11/16/05
DEPTH TO WATER LEVEL (FT.)
NIA
N/A
N/A
N/A
N/A
NIA
N/A
NIA
NIA
NIA
WATER LEVEL(MSL)
0
0
0
0
0
0
0
0
0
0
GAL. PUMPED/BAILED BEFORE SAMPLING
CONTINUOUS
CONTINUOUS
CONTINUOUS
CONTINUOUS
CONTINUOUS
CONTINUOUS
CONTINUOUS
CONTINUOUS
CONTINUOUS
CONTINUOUS
FIELD ANALYSIS: pH
7.4
7.1
7.1
7.2
7.5 ,
7.2
7.0
7.0
7.2
7.0
SPEC. COND. (uMhos)
599
597
617
593
552
591
597
597
606
611 •
TEMP. (oC)
18.8
18.7
22.1
18.6
16.6
19.5
21.6
19.5
19.7
19.2
ODOR
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
NONE
APPEARANCE
CLEAR
CLEAR
CLEAR
CLEAR
CLEAR
CLEAR
CLEAR
CLEAR
CLEAR
CLEAR
DISSOLVED SOLIDS: TOTAL (mg/I)
416
493
429
424
438*
436
N/A
403
N/A
360
pH (WHEN ANALYZED)
7.3
7.4
7.1
7.1
7.7
7.2
N/A
7.0
N/A
7.1
TOC (mg/I)
7.0
6.2
6.1
5.18
5.0
8.2
N/A
5.5
N/A
5.03
CHLORIDE (mg/I)
14.2
13.7
14.0
14.4
15.3
12.8
N/A
14.5
N/A
18.4
SULFATE(mg/I)
<10.0
<10.0
<10.0
<10.0
<10.0
<10.0
N/A
<10.0
N/A
<10.0
PHOSPHORUS: TOTAL AS P (mg/I)
0.025
0.048
0.025
0.014
0.034
0.034
N/A
0.033
N/A
0.059
FLUORIDE (mg/I)
0.52
0.51
0.52
0.56
0.53
0.49
N/A
0.48
N/A
0.56
CORRECTED SPECIFIC CONDUCTANCE
673
672
653
669
645
656
638
663
670
681.9
CADMIUM mg/I
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
N/A
<0.001
N/A
<0.001
CHROMIUM mg/I
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
N/A
<0.005
N/A
<0.02
MANGANESE mgll
<0.010
<0.010
<0.010
<0.010
<0.010
<0.010
N/A
<0.010 •
N/A
<0.010
COLIFORM/100 MLS
<1.0
<1.0
<1.0
<1.0*
<1.0
<1.0
<1.0
<1.0
140
<1.0
SAMPLED BY:
R. LEE
R. LEE
R. LEE
R. LEE
R. LEE
R. LEE
R. LEE
R. LEE
R. LEE
R. LEE
`Original was "Original was 530
(Resampled on 2/25/03)
`Original was 7( /21/04)
FirstResample 3(2/4/04))
FinalResample<1.0(2/9/04)

PCS Phospha
Page 2 of 2
WLCT
DATE SAMPLE COLLECTED:
01/24/06
04/05/06
07/13/06
10/30/06
01/10/07
04/25/07
07/17/07
LAB SAMPLE ANALYZED START
01/24/06
04/05/06
07/13/06
10/30/06
01/10/07
04/25/07
07/17/07
LAB SAMPLE ANALYZED FINISH
01/25/06
04/27/06
07/14/06
11/28/06
01/11/07
05/11/07
07/18/07
DEPTH TO WATER LEVEL (FT.)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
WATER LEVEL (MSL)
0
0
0
0
0
0
0
GAL. PUMPED/BAILED BEFORE SAMPLING
CONTINUOUS
CONTINUOUS
CONTINUOUS
CONTINUOUS
CONTINUOUS
CONTINUOUS
CONTINUOUS
FIELD ANALYSIS: pH
6.9
7.0
6.9
7.2
7.2
7.0
7.2
SPEC. COND. (uMhos)
605
618
674
593
542
604
639
TEMP. (oC)
18.4
19.5
22.3
18.9
15.8
19.1
22.7
ODOR
NONE
NONE
NONE
NONE
NONE
NONE
NONE
APPEARANCE
CLEAR
CLEAR
CLEAR
CLEAR
CLEAR
CLEAR
CLEAR
DISSOLVED SOLIDS: TOTAL (mg/I)
N/A
456
N/A
432
N/A
423
N/A
pH (WHEN ANALYZED)
N/A
7.1
N/A
7.0
N/A
7.3
N/A
TOC (mg/1)
N/A
4.9
N/A
5.5
N/A
4.9
N/A
CHLORIDE(mg/I)
N/A
18.2
N/A
15.4
N/A
16.9
NIA
SULFATE (mg/1)
N/A
<10.0
N/A
<10.0
N/A
<10.0
N/A
PHOSPHORUS: TOTAL AS P (mg/I)
N/A
0.022
NIA
0.048
N/A
0.015
N/A
FLUORIDE (mg/I)
N/A
0.54
N/A
0.59
N/A
0.56
N/A
CORRECTED SPECIFIC CONDUCTANCE
685
686
710
665
642
675
668
CADMIUM mg/I
N/A
<0.001
N/A
<0.001
N/A
<0.001
N/A
CHROMIUM mg/
N/A
0.006
N/A
<0.005
N/A
<0.005
N/A
MANGANESE mg/l
N/A
0.019
N/A
<0.010
N/A
<0.010
WA
COLIFORM /100 MLS
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
SAMPLED BY:
R. LEE
R. LEE
R. LEE
R. LEE
R. LEE
R. LEE
R. LEE

Predicted DPW TDS with RIO Concentrate Stream
WLCT TDS Jan 02 through July 07
416
493
429
424
438
436
403
360
456
432
423
Average TDS 428.1818
Actual DPW Ion Balance
,(TDS) (TDS)
428 / 668 = 0.64
Predicted
(TDS)
525
820 X 0.64

`Total organic carbon concentration is bias due to suspected propanol contamination from EPA cleaning method.
fGroundwater also analyzed for cadmium, chromium, manganese and total collform bacteria for comparison with Injection well water requirements. M Parameter WIF-1C Requirement
Cadmium, Cd (mg/i) <0.005 50.005
Total Chromium, Cr (mg/l) <0.01 50.05
Manganese, Mn (mgli) 0.138 50.05
Total Coldorm Bacteria (/100 mis) <1 51
• FIELD DATA
Specific Conductance (umhoslcm)
at Field Temperature
Corrected to 25°C
pH
Water Temperature CC)
Water Level, feet (MSL)
Gallons Purged Before Sampling
• PHYSICAL APPEARANCE
Odor
Apparent Color
• LABORATORY DATA
Lab pH
Total Phosphorus, P (mg/1)
Fluoride, F (mgil)
Chloride, CI (mgh)
Sutfate, SO4 (mg/I)
Total Dissolved Solids. TDS (mg/1)
Total Organic Carbon, TOC (mg/I)
L
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GROUNDWATER QUALITY IN TANK FARM AREA AT MONITOR WELL MWTF-1C
0
0
m

ELEVATION
20
0
-10
-20
-30
-40
-50
-60
CLAYEY FINE SAND TO
SANDY
m
EAN SANDY CLAY TO
PLASTIC CLAY ' !•
CLAY‘4\1\\\NANWA<T%\l‘Nlytk,kEY FINE SAND TO SANDY
CLAY WITH SOME SHELL•
.. \\\\\• FRAGMENTS
LEGEND
1A
MONITOR WELL COLLECTION ZONE
INJECTION WELL COLLECTION ZONE
AND WELL SCREEN
VERTICAL SCALE: 1"=20'
HORIZONTAL SCALE: 1"=50'
CROATAN FORMATION
YORKTOWN FORMATION
ti
U
PROFILE ALONG INJECTION WELLS
FIGURE 3