NC0000175_Wasteload Allocation_19861112

NPDES DOCUMENT SCANNIN` COVER 5c1EET
NPDES Permit:
NC0000175
Unimin Quartz Operation
Document Type:
Permit Issuance
(Wasteload
Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
November 12, 1986
This document is printed on reuse paper - ignore any
content on the re-srerse side

Dae Rc.
8
H
O
0
a
8
H
Z
NPDES WASTE LOAD ALLOCATION
Facility Name :. Z.ar"..0 +-T;.N r!..+.i A L- 4 G +W! 4P! 1- Gan.P
Existing 0
Proposed O Permit ND.: N & D D Do / 7-S-- Pipe No.: Q-D /
Design Capacity (MGD): K•a Industrial (% of Flow): iel Domestic (% of Flow):
LAG- ae". Gas.E•
Receiving Stream: i/e vrc Tat Acair Class: G 'rKT Sub -Basin: r.82 D G Oil 43-d6
Engineer
iza
as.Pfers
ot/39
Date a. /. ist - ` i, -,
Reference USGS Quad: C. !/ . �✓
County: n,Tc4 LL
•
(Please attach) Requestor: F li•JR-iv Regional Office 44..0
(Guideline limitations, if applicable, are to be listed on the back of this form.)
Design imp.: Drainage Area (mi2): t33 (. D Avg. Streamflow (cfs) : 2140/ 2 , b
7Q10 (cfs) 4 6 / D . 3 Winter 7Q10 (cfs) 55- 30Q2 (cfs)
Location of D.O. minimum (miles below outfall): Slope (fpm)
Velocity (fps):
Kl (base e, per day):
K2 (base e. Der day) :
IJ a .-4-4. Toe_
Effluent
Characteristics
Monthly I
Average %me
l
GEuaa►e
132-0 /2Ctic)
i '55 &ib)
LSD)
G-g
V)4
F I,, e.�. L L 1 b)
I, ,.,,.-�: 5
. D-.�'�./y',�,,.
., -/ ,.
_
_ Ae_i'--
�R,
i -
�x
/o TV
4%. - ?J ......0— L..,., 4. e. �,...1
..,...C. 411,A.0 . ,
Original
Revised 1
ConfiraJa
Comments: --V ic-ita
Effluent
Characteristics
1
;'Dnthly
i`_verage
Comments
...t_ `h 1.1
C
Co.. 4 `t-, t ex4)
lee 114 J4.v
QJJ/ e , cz..Meviewed By.
PLOarl
` Date: // �Z v
-8V
c_
•

i
•
• For Appropriate Dischargers, List Complete Guideline Limitations Below
•
Effluent
Characteristics
McVay
Maximum Daily
Average
Comments
Average
T' S .S
/ 3 2 6 L&t/sl
2 Gro G L.r/dq y
c Lv'
/p ».-; r ,) 0
6 PT.r
F 1*/ati,r�-ips
a 3 S--- `I
L1 -4 ��
Z4
P
6 _ 16
,�
TtlaCb
la J'TU 1a RR'-
"- j w.4TTQlL
iI
Type of Product Produced
Lbs/Day Produced
Effluent Guideline Reference

. Request No. :2139
^
------ WASTELOAD ALLOCATION
APPROVAL FOAM
Facility Name
Type of Waste
Status
Receiving Stream
Stream Class
Subbasin
County
Regional Office
Requmstnr
Date of Request
Quad
Dissolved
TSS
Fecal CnIiform
pH
Wasteflow
5-Day BOD
Ammonia Nitrogen
Oxygen
IMC CORP
FELDSPAR MINING
EXISTING
NORTH TOE RIVER
C-TA
000206
MITCHELL
ASHEVILLE
DOUG FINAN
2/B9/85
C115W
Drainage Area
Summer 7Q10
Winter 7q10
Average Flow
30Q2
� �� �����A���l�
� ���� ��� , ^�^�
vv",*, (:)t',//r/ Cx~i**n
(sq mi>
(cfs)
(cfy)
(cfs)
(cfs)
� 183
� 45
� 55
� 270
RECOMMENDED EFFLUENT LIMITS -------------------------
DA AVG DA MAX
3.60 '1.32
1320 P640
6-9
---------------------------------- COMMENTS -------------------------------
THE DISCHARGE DISCHAAGE SHALL NOT CAUSE THE TURBIDITY OF THE RECEIVING WATERS TO
EXCEED 10 NTU. IF THE TURBIDITY EXCEEDS 10 NTU DUE TO NATURAL CONDITIONS,
THE DISCHARGE SHALL NOT CAUSE ANY INCREASE IN TURBIDITY.
TOXICITY MONITORING REQUIREMENTS AND FLUORIDE WASTELOAD ALLOCATION ATTACHE[).
Aecommended by
Reviewed by:
Tech. Support Supervisor ___
Regional
Permits & Engineering __
(e �
Date
Date
Date

t �� s ��•w-� 4-6 N Tm
1.) The permittee shall conduct chronic toxicity tests on a quarterly
basis using protocols defined in E.P.A. Document 600/4-85/014
entitled "Short -Term Methods for Estimating the Chronic Toxicity
of Effluents and Receiving Waters to Freshwater Organisms". The
testing shall be performed as a Ceriodaphnia Survival and Repro-
duction Test. Effluent collection will be performed twice during
each test as 24 hour composite samples. Toxicity test exposure
using the first composite sample will include the first three full
days of testing. Exposure to the second composite sample will in-
clude the last four full days of testing. Effluent samples will
be taken immediately prior to disinfection, but below all other
treatment processes. 'The Chronic Value (ChV) must be greater than
12,7.44. There will be minimally five effluent concentrations and a
control exposure treatment. One effluent concentration shall equal
121 44 %, which represents the instream waste concentration (I.W.C.)
during 7Q10 low flow conditions and daily permitted dischar a volume.
The remaining concentrations shall bell 44 95�-
There may not be more than 202 mortality -in- )-- -r= effluent
after 48 hours of exposure. 17°
Note:- Failure to achieve test conditions as specified ini:the cited
document, such as minimum control organism survival and appropriate
environmental controls, shall constitute an invalid test and will re-
quire immediate retesting. Failure to submit-suitarblE test results
will constitute a permit violation.

-5-
fluoride processes (fluoride interference with other ore processing
activities). Therefore, while the waste handling demands for pure
quartz are -higher than for feldspar, that demand is likely to be
lower than indicated by HF use information. Another factor available
that points to this conclusion is that IMC which has the only operat-
ing high purity quartz system, also has the lowest mass discharge of
three facilities. It is true, however, that IMC's wastewater control
system represents what the Regional Office considers the standard for
the industry. What these points show is that there are technologies
which can, when applied with a strong management commitment, effec-
tively reduce the quantity of fluoride released to the receiving
waters.
The final issue that must be discussed in recommending a weight-
ing factor, is certainly equal to those just noted: i.e.,the real
world impact of the facilities receiving the allocations. In this
matter we are dealing with four separate industrial corporations
involved (or soon to be involved) as competitors in the same busi-
ness, all located in the same general area, and all sharing a common
riparian resource. Real and perceived conflicts make negotiating
very difficult. Add to this a common view from all the companies
that the fluoride standard is too restrictive and the recent emer-
gence of the fourth competitor and you have a sensitive environment
in which existing allocations must be reduced. The only way to
examine this aspect of the allocation process is to calculate fluo-
ride distributions for a variety of weighting factors. In doing so
it will be necessary to provide the distributions over the entire
range of near term configurations:
Configuration I - Unimin Corporation not producing feldspar or
Configuration II
Configuration III
Configuration IV
quartz. The Feldspar Corporation operating
without the planned high purity quartz
facility, Indusmin at current feldspar
production, and IMC producing feldspar and high
purity quartz at current levels.
- Unimin Corporation not producing feldspar or
quartz, The Feldspar Corporation operating with
the high purity quartz facility and Indusmin,
Inc. and IMC as described in I.
- Unimin Corporation producing feldspar and quartz,
and other three companies as described in I.
- Unimin Corporation as in III, The Feldspar
Corporation producing high purity quartz and the
other two companies as described in I.

-6-
Configuration V - Unimin Corporation as in III, The Feldspar
Corporation and Indusmin, Inc. producing high
purity quartz and IMC as described in I.
Configuration VI - The Feldspar Corporation, IMC, Indusmin, Inc.
and Unimin Corporation as described in V and
Indusmin, Inc. with a 50% expansion of the
feldspar plant.
The process in developing a specific allocation can be described
as follows:
A. Calculate an allocation factor (Af) for each facility
within a specific configuration:
Af = F + Wf x Q
where:
Af = Allocation factor,
F = Finished feldspar in tons per month (information
supplied by the company),
Wf = Weighting factor for quartz production,
Q = Finished high purity quartz, tons/mo.
B. Project a percentage share (PS) of available fluoride for
each facility under each configuration.
PS = Af x 100
SUM Af
where:
SUM Af = sum of all four Af's for a particular
configuration.
C. Calculate the specific fluoride allocation (A-lbs/day) for
each company.
A= PS xAW
100
where:
AW = Available wasteload to North Toe River = 574
• lbs/day.

Allocations Proposed
Facility AF PS (%) A (#/day)
Configuration I
Unimin 0 0 0
Feldspar 21181 32 183
Indusmin 17043 26 149
IMC 2730642 242
65530 100 574
Configuration II
Unimin 0 0 0
Feldspar 28082 39 224
Indusmin 17043 23 132
IMC 27306 38 218
72431 100 574
Configuration III
Unimin 15800 19 109
Feldspar 21181 26 149
Indusmin 17043 21 121
IMC 27306 34 195
81330 100 574
Configuration IV
Unimin 15800 18 103
Feldspar 28081 32 183
Indusmin 17043 19 109
IMC 27306 31 179
88230 100 574
Configuration V
Unimin 15800
Feldspar 28081
Indusmin 20043
IMC 27. 6
91230
17 98
31 178
22 126
30 1_
100 574
Configuration VI
Unimin 15800 16 92
Feldspar 2808 28 161
Indusmin 2 3 15041 29 166
IMC 27306 27 155
99630 100 574

�
Facility Name
Type of Waste
Status
Receiving Stream
Stream Class
Sub basin
County
Regional Office
Requestor
Date of Request
Quad
Wasteflow (mgd)
5-Day BOD (mg/1)
Ammonia Nitrogen
Dissolved Oxygen
TSS +mg/l> A/ICI>
Fecal Coliform
pH (SU)
Fluoride (#/d)
WASTELOAD ALLOCATION APPROVAL
IMC CORP.
FELDSPAR MINING
EXISTING
NORTH TOE RIVER
C-TR
040306
MITCHELL
ARO
DOUG FINAN
2/28/85
C11SW
(mg/l)
(mg/l)
Drainage Area
7Q10 (cfs)
Winter 7010 (cfs)
3002 (cfs)
Average Flow ((::fs)
RECOMMENDED EFFLUENT LIMITS
: LITTLE BEAR
: 4.32
:
:
:
(#/100ml>:
: 6-9
: 67.7
1320 2640
N.TOE
4.32
w~ I
1�P0 P�40
VIA
6-9
--
,�'./
6-9
184
FORM
Request No. : 2139
cc
_______-_~�_'____
V"
-`' Q/ |f/ Division
MAY15 1986
,vwoe,n ktv�^":w/ ()f;ics
"mm�Hm North [m,oUmw
pr,44-, -Ate L.M k.11
(sq mi) : 13Y
: 44;'
: _55
:
: 2T.)
/'o
0,3
2.0
-------------------- --------- COMMENTS --------------------------------
SEE ATTACHED MEMO. THE DISCHARGE SHALL NOT CAUSE THE TURBIDITY OF THE
RECEIVING WATERS TO EXCEED 10 NTU. IF THE TURBIDITY EXCEEDS 10 NTU DUE
TO NATURAL CONDITIONS, THE DISCHARGE SHALL NOT CAUSE ANY INCREASE IN
TURBIDITY.
FLUORIDE LIMITS BASED ON 7010 (7010=0.3 IN LITTLE BEAR CREEK) AND BACKGROUND
CONCENTRATION=0.05 MG/L.
TOXICITY LIMITS AND MONITORING REQUIREMENTS ALSO ATTACHED.
Recommended by
Reviewed by:
Tech. Support Supervisor__
Regiona
IS> -----
Date ��
Date-1500/1
a / � jj
I �
i -��-� D t
v sor_ �������_���� a e_��
Permits &'8hgineering__
�
Date_��

DIVISION OF ENVIRONMENTAL MANAGEMENT
May 12, 1986
MEMORANDUM
TO: Arthur Mouberry
Forrest Westall
FROM: Randy Dodd QZL�
THRU: Meg Kerr iK
SUBJECT: Effluent Limitations for Feldspar Mines,
North Toe River
Please find attached proposed effluent limits for three Feldspar
mines which discharge to the North Toe River. TSS limits are based on
current permits. Please note that allowable loadings and concentrations
are considerably above current discharge levels. Fluoride loadings are
based on an allowable loading of 574 #/D based on a 7Q10 of 45 cfs at
the mouth of Little Bear Creek, the current standard of 1.8 mg/1, 0.05
mg/1 background fluoride concentrations, and the previously defined
allocation among the three dischargers. Please note that a permitted
discharge by IMC Corp. to Little Bear Creek will require a fluoride
limit of 67.7 #/D, based on a 7Q10 of 0.3 cfs. Please note that an
additional loading of 506.3 #/D could be allocated to Feldspar and
Indusmin if 67.7 #/D were allocated to IMC.
Toxicity limits and monitoring requirements have also been developed
for each discharger based on the instream waste concentration and recently
developed Division protocol.
Please advise if questions.
RCD:mlt
Attachment

C
4-0 eta,)
1.) The permittee shall conduct chronic toxicity tests on a quarterly
basis using protocols defined in E.P.A. Document 600/4-85/014
entitled "Short -Term Methods for Estimating the Chronic Toxicity
of Effluents and Receiving Waters to Freshwater Organisms". The
testing shall be performed as a Ceriodaphnia Survival and Repro-
duction Test. Effluent collection will be performed twice during
each test as 24 hour composite samples. Toxicity test exposure
using the first composite sample will include the first three full
days of testing. Exposure to the second composite sample will in-
clude the last four full days of testing. Effluent samples will
be taken immediately prior to disinfection, but below all other
treatment processes. 'The Chronic Value (ChV) must be greater than
Z. There will be minimally five effluent concentrations and a
control exposure treatment. One effluent concentration shall equal
qb %, which represents the instream waste concentration (I.W.C.)
during 7Q10 low flow conditions and daily permitted dischar a volume.
The remaining concentrations shall be 4 '° Z 4,1e ? z° (, 6
There may not be more than 202 mortality in a q6 effluent
after 48 hours of exposure.
Note: Failure to achieve test conditions as specified in;:the cited
document, such as minimum control organism survival and appropriate
environmental controls, shall constitute an invalid test and will re-
quire immediate retesting. Failure to submit suitable teat results
will constitute a permit violation.

~
^
.
-----------------'--- WAGTELOAD ALLOCATION APPAOVAL FOPM
FaoilitU Name
Type of Waste
Statum
AeceiVA. nQ Stream
Stream Class
Subbasin
Count�j
Ae191.13na1 O-Pfice
Requestop
Date of Aequest
(Auad
� IMC Corp.
� FELDSPAA MINING.,
� EXI8TINQ
� NOATH TOE AIVEA
� C-TA
� 040306
� MITCHELL
� ARO
� DOUM F%NAN
� 2-28-85
� C119W
Drainage Area (sg mi>
7Q10 (cfs)
Winter 70.10 (cfs)
80Q2 <mfs>
Average Flow cc -Pis
Aequesx Nm. 2189
: 23.9
RECOMMENDED EFFLOENT LIMITS ~------~-----------------
Waytef1ow (In 32
5-Day BOD <mQ/l)
Ammonia Nitrogen (mg/1> �
Disyolved Oxygen (mg/1> �
TSS (#/D> 1@20 26/10
Feca1 Co1iform (#/100ml>�
pH (SU) 6-9
1:'*1uopide (#/d126.6
253.2
.... .... ................ .... .... ............ .... .... ........ .... .... ........ ....... .... .... ........ .... .... .................... ___ COMMENTS --------------------
The discharQe shall not cause the turbiditU of thm receivino
waters to on, xceeu 10 NTU. If them, turbidity exceeds 10 NTU due to
natural ba/zkQround conditions^ the diycharQe sha1l not caume anU
increase in 11urbid1.t11.
F1umridm 1imit revised. Previous1U based on 80112. This limit based
on 7q10.
Ae4iewed bU�
Tee oh. Suppmrt Supon, rvismrDate__________
Rmgional Supervismr. Daoe............... ................... ....
01pprova1 is C > pre1iminin. rU ( ) final
Permits &

(JoY,
f(6-'64.4.6
,„ -4. ..t,Q .
ti3
oY.X afib,•6_ A too.J( 0‘J 4a. ,k
s, �a,� b� �.
7QI© (45
r- tc,c,c e&s,-- a , a ('ij
)216+4_ - 1 J�
)
2 g i J
3. *A o A) Je2 I e el 8-r`. f to c Q_ .(
(jay, C 17.
c/-r- 7 */b

(6-Aft
�., C
L' 5—
Li 3
(.12s t L.-..A .
a
3,
Zr o2
d Gt. s s
'IS S?, g 26, Y. l 2 6.0
LI4 TeL"?._
2,� z6,y c3,•Z (Q

f
k-Zote„x0
y l UM1ft�
ek.,- 2s 4,0 L t..� k_
-OA
--rss L.-4s
N,_ok-L.,1_ cc— 41Q17
pi4
s
�¢a

•
RECE1 V .
JU!_ q - 1986
TECHNICAL SERVICES BRANC:H
kr-kr
State of North Carolina
Department of Natural Resources and Community Development
Asheville Regional Office
James G. Martin, Governor S. Thomas Rhodes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
July 1, 1986
MEMORANDUM
a-.
JUL
TO: R. Paul Wilms, Director WATER QUALIT
Division of Environmental Management SECTION
Page Benton, Deputy Director
Division of Environmental Management
George Everett, Chief
Water Quality Section
FROM: Roy M. Davis, Regional Supervisor
Division of Environmental Management
ti
SUBJECT: Allocation of Fluorides
Spruce Pine Mining Industries
Mitchell County and
Avery County
On June 26, 1986, Mr. Mike Parker, Mr. Forrest Westall and I
met with representatives of the Spruce Pine Mining Industries who
are now or would in the near future discharge fluorides in their
wastewater,. The meeting was held at.ourrequest to discuss
possible approaches to allocation of the total ability of the
North Toe River to dilute fluorides. Attached is a list of those
attending.
At issue are the fact that we now use 7Q10 rater than 30Q2 .
flow to calculate dilution which reduces from 754 lbs/day to 574
lbs/day the amount of fluorides. which may be released to the
North Toe River and the desire of an existing industry to enter a
market which would necessitate the release of fluorides in its'
wastewater; both of which will have the effect of substantially
reducing the amount of fluorides the three.present fluorides
discharges may release. International Mineral and Chemicals
(IMC), Feldspar and Indusmin presently discharge fluorides and
Unimin which recently purchased Harris Mining wish to discharge
fluorides in its waste stream Fermit application already made.
Interchange Building-59 Woodfin Place. P.O Box 370, Asheville, N.C. 28802.0370 • Telephone [phone]
..r,.•_• _ An Equal Opportunity Affirmative Action Employer - -
i•

•
;
R. Paul Wilms
Page Benton
George Everett
Memorandum
July 1, 1986
Page Two
We are presently gathering production and other data which will
allow us to allocate fluorides among the four dischargers.
Our recently published report "Toxicity of Fluoride to
Freshwater Biota" dated June, 1986, concludes that we need more
data relating to acute and chronic toxicity effects of fluorides
in order to consider whether or not to modify the present 1.8
mg/1 Water Quality Standard. Representatives of the Spruce Pine
mineral processing industry expressed an interest in supplying
this data in the hope that it will result in an increase in the
numeric Water Quality Standard for fluorides.
During the meeting, the four industries met in our absence
for &short time. Three of the four (Unimin being the exception)
informed us that they will adjudicate their permits if issued
based upon present Water Quality Standards and -dilutions. All
four of the industries indicate a willingness to conduct •
acute/chronic toxicity studies in hope of achieving a relaxation
of the Water Quality Standards for fluorides and will in the near
future call you asking for a meeting to discuss the possibility.
There was no consensus among the industries as to how the State
might allocate fluorides to those discharging to the North Toe
River. • •
We hope in a few weeks to have developed a Waste. Load
Allocation for fluorides for these industries. I should add that
the Division is in the process of renewing IMC's, Feldspar's and
Indusmin's NPDES Permits.
RMD:ls
Enclosure
xc: Forrest R. Westall

r•
�O\ �AYtS
YYVKE PAikvrEl-
s-r We s-t-(�1,►�
Dctv,
Alf . 6471Z:vso .v
e (-71- CAR
ST51/6 300-77%
/E
4t: fivec .
/ A R.R.) s
c,yif2,r '
mts
Whrifif; Ai/64Zr/
RA'/Aerds4 7: W66 iS
J0\114`oct.soN
V:(S.
i/
/ mac.
D '11 76,te,57
iA/i2 7/s,.1;
ay/iv/kJ
V�N�cc1� N
c
1
_ t. _ �
c ..ice
tr. :•.,---a:c.•..Y. .:— _ ._ ;ippnt4L.r.{,:wear..:1K{'tL�'•Yf+!-J1�aYl'..�
t' lY� `t._-:•7' Lr.trn:t1 +.yam -- •`f

lame (. ,. ,�iartir�, (overt
State of North Carolina
Department of Natural Resources and Community Development
.�...•-►�-•' Asheville Regional Office
‘ S. Thc,ma. Rhodes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
June 27, 1986
r- R
\N f� - _ C-rk0"
Mr. Andrew J. Regis, Vice -President
Geology and Environmental Affairs
Unimin Corporation
258 Elm Street
New Canaan, CT 06840
Subject: Questionnaire Relating to Allocation of
Fluoride
Unimin Corporation
Avery County, North Carolina
Dear Mr. Regis:
Pursuant to our discussion on June 26, 1986, we have
developed the attached questionnaire for purposes of gathering
information which will allow us to allocate the fluorides
discharged to the North Toe River. I am asking for your
suggestions regarding any aspect of this questionnaire.
Thursday, July 3, 1986, I am going to send the questionnaire out
in final form so please phone your suggestions to Mr. Mike
Parker,.Mr. Forrest Westall, or me before that date. I very much
appreciate your taking time to meet yesterday to discuss the .
issue of fluoride allocations to the North Toe River industries.
I look forward to hearing from vou.
RECE\VEfl
301 7 - A986
( 1
?�kll? ! �, • �flC 'I11 • •.
. 1,,.yi.c• iuri��ir„ ^•+ \\i,� �., , ;{�•� ��-�tc•�•iilr \( ►=•ici ^i,

Mr. Andrew J. Regis
June 27, 1986
Page Two
It occurs to me that it would be helpful if you started
assembling the information required on the draft form for the
reason that when it finally goes out I will be feeling the need
for a fast turn around time. Thanks!
RMD:ls
Enclosure
xc: R. Paul Wilms /
George Everett ✓
Forrest R. Westall
Sincerely,
Ti—r—c,.„J
Roy M. Davis, Regional Supervisor
Division of Environmental Management

The information provided should represent feed/production
for the highest month in the past twelve or the monthly average
of the highest of the previous five years. In the case of a new
source we are requesting projections on the same basis as
described above. This is drawn from 40 CFR 122.45(b) 2 dated
July 1, 1985. Please indicate how you choose to provide this
information. Additionally please indicate the number of days
worked by the particular plant during the months used as a basis
for the information provided.
Total raw ore feed tonnage to all processes on site.
tons/month
Feed tonnage to all processes which utilize fluorides.
tons/month
Feed tonnage to feldspar recovery processes which utilize
fluoride. tons/month
(a) Amount of hydrofluoric acid used in this process.
gallons/month
(b) Percentage of HF acid in solution used. %
(c) Amount oT finished material produced by this process.
tons/month
Feed tonnage to high purity Quartz recovery processes which
utilize fluorides. tons/month
(a) Amount of hydrofluoric acid used in this process.
gallons/month
(b) Percentage of HF acid in solution used.
(c) Amount of finished material produced by this process.
tons/month
Feed tonnage to any other recovery processes on site which
utilize fluorides (please indicate type of product recovered).
tons/month
(a) Amount of hydrofluoric acid used in this process.
gallons/month
(b) Percentage of HF acid in solution used.
(c) Amount of finished material produced by this process.
tons/month

-2-
The information provided is based upon; highest month of the
:ast twelve or monthly average of the highest of the past
-:•welve or projections based upon above . (Please
-:-.neck)
I
Signature
Company Represented
Date