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NCG500645_Permit (Issuance)_20091218
waihrlt._A NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary December 18, 2009 Douglas Archer, Manager Clean Bum Fuels, LLC 269 Pate Road Raeford, North Carolina 28376 Subject: General Permit No. NCG500000 Certificate of Coverage NCG500645 Clean Burn Fuels, Hoke County Plant Hoke County Dear Mr. Archer: In accordance with your application, the Division of Water Quality (DWQ) hereby forwards this Certificate of Coverage to discharge under the subject general permit. We issue this permit pursuant to the requirements of North Carolina's General Statue 143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection Agency dated July 17, 2007 (or as subsequently amended). The following information is included with your permit: • A copy of the Certificate of Coverage for your facility • A copy of General Permit NCG500000 for boiler blowdown discharge • A copy of a Technical Bulletin for General Permit NCG500000 If any parts, measurement frequencies or sampling requirements contained in this general permit are unacceptable, you have the right to request an individual permit by submitting an individual NPDES permit application. Unless such demand is made, this Certificate of Coverage shall be final and binding. Please note that this Certificate of Coverage is not transferable except after notice to the Division of Water Quality. The Division may modify, or revoke and reissue this Certificate of Coverage. This issuance does not affect your legal obligations to obtain other permits that 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 government. If you have any questions concerning this permit, please contact Joe Corporon at telephone number (919) 807- 6394 or email (joe.corporon@ncdenr.gov). or Sincerely, Coleen 1-1. Sullins, Director cc: Fayetteville Regional Office, Surface Water Protection Section Central Files NPDES General Files RST Engineering, PLLC, Raleigh, NC, Attn. Stan Taylor 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 .Phone: 919-807.63001 FAX: 919.807-64921 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity \ Affirmative Action Employer NorthCarolina Naturally Permit NCG500645 . STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY General Permit NCG500000 Certificate of .Coverage NCG500645 To discharge non -contact cooling water, cooling tower and boiler blowdown, condensate, exempt stormwater, cooling waters associated with hydroelectric operations, and similar wastewaters under the NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Clean Burn Fuels, LLC is hereby authorized to discharge wastewater from a facility located at the Clean Burn Fuels, Hoke County Plant 269 Pate Road, Raeford Hoke County to receiving waters designated as UT to Hamby Creek, a class C water in the Yadkin Pee Dee River Basin, in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV of the General Permit NCG500000, as attached. This permit shall become effective December 18, 2009. This Certificate of Coverage shall expire at midnight on July 31, 2011. Signed this day December 18, 2009. een H. Sullins., Director Division of Water Quality By Authority of the Environmental Management Commission NC HWY 20 (Southeast of Raeford) Clean Burn Fuels, LLC Receiving Stream: Little Marsh Swamp Sub -Basin: 03-07-53 Stream Class: . C, Sw Drainage Basin: Lumber River Latitude: 34° 56' 36" N Longitude: 79° 08' 34" W State Grid / USGS Quad: H 22 NW / Raeford, NC • Facia' Loca not to North NPDES General Permit NCG500645 Hoke County DIVISION OF WATER QUALITY October 9.2009 MEMORANDUM TO: Dina Sprinkle Point Source Branch FROM: Dale Lopez, Environmental Specialist THROUGH: Belinda S. Henson, Regional Supervisor Surface Water Protect' Sec 'onpo SUBJECT: Application for NPDES Permit NCG500645 Clean Burn Fuels LLC 269 Pate Road Raeford, NC 28376 Hoke County Please find enclosed a staff report and recommendations from the Fayetteville Regional Office concerning the application for a new NPDES Permit. If you have any questions or require any further information, please advise. /DL Enclosures To: Permit and Engineering Unit Water Quality Section Attention: Dina Sprinkle Date: October 9, 2009 NPDES STAFF REPORT AND RECOMMENDATION COUNTY: Hoke Permit No.: NCG500645 PART 1— GENERAL INFORMATION 1. Facility and Address: Clean Burn Fuels LLC 269 Pate Road Raeford, NC 28376 2. Date of Investigation: October 1, 2009 3. Report Prepared by: Dale Lopez, Environmental Specialist FRO 4. Person Contacted and Telephone Number: Douglas Archer (910) 875-1453 (work # ) (910) 215-2867 (cell # ) 5. Directions to Site: From Fayetteville, travel on Hwy 301 South, turn right onto Hwy 71 and pass through the Town of Parkton. A few miles later, in the Town of Lumber Bridge, turn right onto Hwy 20 North. Travel approximately eight miles and turn right onto Pate Road. The plant site is located on the right hand side of Pate Road (Road # 1431) 6. Discharge Point(s), List for all discharge points: Latitude: 34°56'36.58" N Longitude: 79°08'33.86" W1 Attach a U.S.G.S. map extract and indicate the treatment facility site and the discharge point on the map. U.S.G.S. Quad No. U.S.G.S. Quad Name: H 22 NVJI Raeford, N.C. 7. Site size and expansion area consistent with the application? IYes. 8. Topography (relationship to the flood plain): 9. Location of the nearest dwelling: INot evaluated 'Not evaluated 10. Receiving stream or affected surface waters: a. Classification: Lumber River Subbasin 03-07-53 Classification C, Swl b. River Basin No. 'Lumber River 14-22-1-3 and Sub basin No.: ILUM53 c. Describe receiving stream features and the pertinent downstream uses: The discharge from the Clean Bum Fuels facility flows to Little Marsh Swamp, at a point that appears to have a 7Q10 of 0 cfs flow. It is classified as Class C, Sw waters, that promotes aquatic life propagation and survival, fishing, wildlife, secondary recreation, and agriculture. PART II - DISCRIPTION OF WASTES AND TREATMENT WORKS 1. a. Volume of wastewater to be permitted: (Ultimate Design Capacity) b. What is the current permitted capacity of the Wastewater Treatment facility? IN/A 0.08 MGM c. Actual treatment capacity of the current facility (current design capacity)? frsT/4 d. Please provide a description of the existing or substantially constructed wastewater treatment facility: The Clean Burn Fuels is an ethanol production facility that will ferment kernels of corn and distill the ethanol that is produced for the purpose of fuel grade ethanol for fuel in automobiles. The expected start-up date for the facility is January 15, 2010, and it will have combined blowdown flow of 0.08 MGD from both the cooling tower blowdown and the boiler blowdown, 46 gallons/minute and 10 gallons/minute, respectively. There is no construction of wastewater treatment facilities that is proposed, but some treatment, through degradation of the biocides will be achieved in the stormwater retention pond. This pond is designed as a wet detention pond with a capacity of 1.695 million gallons and will provide 21.2 days of detention time before flowing to Little Marsh Swamp. Inline filters will collect air compressor condensate oil, and the filtered condensate will flow back into the process. The used oil filters will be sent to landfill. There.is an on -site septic tank and drainage field for domestic sewage only. If, in the future, the carbon dioxide byproduct facility becomes feasible for production, then this facility may pump and haul the wastewater of the CO2 facility to the Raeford POTW. e. Possible toxic impacts to the surface waters: 'None 2. Residuals handling and utilizing/disposal scheme: a. If residuals are being land applied, please specify the DWQ Permit No. Residual Contractor: Telephone: b. Residual stabilization: c. Landfill: N/A N/A e. Other disposal/utilization scheme (specify): 'There is an on -site septic tank and drainage field for domestic sewage only. 3. Treatment plant classification (attach completed rating sheet): 4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options available? Please provide the regional perspective for each of the options that were evaluated. Connection to Regional Sewer System: Discharge to a public sewer was ruled out because it is approximately 21,000 feet to the nearest location that a public sewer is available. Extensive design work would be required to develop a reliable cost estimate, but it can be assumed that the installed cost of a force main to transport the waste would be about $32 per foot. The cost for a sewer line to this location is estimated to be in excess of $600,000 and is prohibitively expensive. There is an on -site septic tank and drainage field for domestic sewage only. Land Application: Land application was evaluated. The soils on the site are typical of those found associated with Carolina Bays that have been drained and graded for agriculture. USDA mapping data indicates that these soils are hydric or partially hydric soils and may have a shallow depth to the seasonal water table. The soils may be suitable for land application of the utility blowdown if drainage is provided to lower the seasonal water table elevation. A more detailed on -site soil analysis will be required to determine if land application is possible, and if so, how the system must be designed and what, if any, additional drainage is needed. It is assumed that land application is possible, that no extensive drainage will be required, that storage equivalent to 30 days of flow will be required, and that an annual average loading rate of 0.5 inches per week can be achieved. Based on these assumptions, land application would require irrigation of an estimated 42 acres of land. The storage pond would need to hold approximately 2.5 million gallons. The cost for a land application system of similar size in North Carolina that was constructed within the last 18 months was $12,256 per acre, not including storage pond cost. It is anticipated that the cost of a land application system for the utility blowdown would be similar. That would make the estimated cost for the land application system $512,000. The cost of the storage pond is estimated to be $65,000, based on the cost to construct the existing stormwater detention pond. The total cost of this option is therefore estimated to be $577,000, which is also prohibitively expensive. Water Reuse: Inline filters will collect oil from the air compressor condensate, and the filtered condensate will flow back into the process for reuse. PART IV — EVALUATION AND RECOMMENDATIONS 1. The applicant is requesting issuance of a new general wastewater permit for boiler water blowdown and cooling tower water blowdown at a facility that is presently being constructed. 2. Based upon a site inspection that was conducted on October 1, 2009, all units were in process of construction, and the predicted start-up date for this facility is January 15, 2010. There is an on -site septic tank and drainage field for domestic sewage only. 3. Based upon the above information, this Office recommends issuance of the said permit located at the Clean Burn Fuels plant, southeast of the City of Raeford, in Hoke County. APPLICATION FOR CERTIFICATE OF COVERAGE GENERAL PERMIT NCG500000 BOILER AND COOLING TOWER BLOWDOWN PREPARED FOR: CLEAN BURN FUELS, LLC RAEFORD, NORTH CAROLINA PREPARED BY: RST ENGINEERING, PLLC RALEIGH, NORTH CAROLINA S September 2009 �ci�D y Introduction: Clean Burn Fuels is constructing a fuel grade ethanol production plant located at 269 Pate Road, Raeford, North Carolina 28376. When completed the plant will have cooling tower blowdown and boiler blowdown from the process utilities that will need to be discharged under the conditions of NPDES Permit NCG500000. This application will provide the required information for a Certificate of Coverage under that permit. Proposed Discharge Conditions: The cooling tower blowdown and boiler blowdown will be mixed together and the estimated 80,208 gallons per day of combined blowdown flow discharged to the existing stormwater retention pond. From the pond the discharge is to Little Marsh Swamp in the Lumber River Basin. There is no construction of wastewater treatment facilities proposed, but some treatment, through degradation of the biocides present, will be achieved in the stormwater retention pond. This pond is designed as a wet detention pond with an "empty" volume of 1.695 million gallons and will provide a nominal 21.1 days (506.4 hours) of detention time before the discharge reaches the concentration of the utility blowdowns. During periods of rainfall the detention time will be lower, but the rainfall run-off will provide additional dilution. For that reason, the "no rainfall" scenario should represent worst case concentrations of components in the blowdown stream in the receiving waters. Discharge Chemical Parameters: Chemicals added to the cooling tower and boilers for process control will be present in the blowdown. The chemicals will be used for pH control, corrosion control, and biological control in the boiler and cooling tower. The Nalco Company is providing the chemicals and will control their addition with a chemical process controller that receives feedback from the processes and adds only the amount of chemicals necessary to maintain proper operating conditions. The following table shows the chemicals to be used, their purpose, and the anticipated concentration of the chemical in the proposed discharge. Table 1 — Chemical use Total Disc Vol Product Disc. Product (mgd) Conc (mg/I) Product Use Cooling Tower 3DT291 0.080208 29.1 treatment Corrosion 3DT284 0.080208 33.2 Inhibitor Actibrom 1318 0.080208 0.02 Biocide Corrosion 73199 0.080208 4.1 Inhibitor 7320 0.080208 0.5 Biocide Biocide Bleach 0.080208 0.03 Activator Boiler Water Internal NexGuard 22310 0.080208 20.9 Treatment Oxygen 1720 0.080208 5.2 Scavenger 8735 0.080208 13.1 pH stabilizer Material Safety Data Sheets (MSDS) for each chemical that will be used in the boiler and cooling tower are attached to this application. The MSDS sheets, estimates of chemical useage, and estimates of the flows and chemical characteristics of the blowdown streams have been provided by the Nalco Company. The quantity of each chemical added and used in the calculation of in -stream concentration of each chemical was calculated ,41`, using the flows and concentrations provided by Nalco. There is particular concern about the in -stream impacts of the biocides used and about the salt content of the blowdown streams. The likely in - stream concentration of each of these constituents is evaluated below with the result that there is likely to be no serious impact on water quality from the blowdown stream. Salt Content: Treatment of the boiler feed water to remove hardness will necessitate the use of ion exchange resins that will be regenerated by backwashing with a salt solution. Data provided by Nalco, based on analysis of the boiler feed water source, indicates that a regeneration cycle will be once each 6.7 days of operation. The regeneration will require approximately 911 gallons of water and will use 225 pounds of salt. The regeneration backwash will be captured and bled into the total backwash stream over time to avoid the discharge of a concentrated salt solution to the basin receiving the blowdown flows. Dispersing 225 pounds of salt into the backwash flow that will occur in 6.7 days will result in a salt concentration of 50 mg/I. The water quality standards for the receiving water (Class Cswp) contain an action level for chlorides of 230 mg/I. This indicates minimal impact from salt on the receiving stream. Biocides: Three of the materials are listed as biocides. These are NALCO 7320, a broad-spectrum, non -oxidizing biocide approved for use in recirculating cooling towers, closed loop cooling systems, air washers and brewery pasteurizers; NALCO ACTI-BROM® 1318 biocide; and sodium hypochlorite (bleach). The active ingredient in NALCO 7320 is 2,2-Dibromo-3- Nitrilopropionamide. The half life of this material is highly pH dependent with the half life decreasing rapidly as pH increases. Data provided by Nalco was used to estimate a half life of 31 hours at the pH of 7.5 which is less than or equal to the pH of the combined blowdown stream. In order to assure that insignificant concentrations of this and other biocides carry through into the blowdown discharge, NALCO is proposing to feed sodium bisulfate into the cooling tower blowdown prior to mixing with the boiler blowdown as a part of the cooling tower water treatment package. This will effectively remove the active biocide. Sodium hypochlorite is a biocide in its own right, but in this application is used as an activator for the ACTI-BROM 1318. The registered active ingredient of ACTI-BROM 1318 is an aqueous solution containing sodium bromide. In its neat form, ACTI-BROM 1318 has no biocidal activity. However, when added to a chlorine source, the concentrated bromide salt solution is converted to hypobromous acid, a very efficient, fast -acting biocide. The hypochlorite is consumed in this reaction, so little (less than 1 mg/I) remains in solution. In order to assure that insignificant concentrations of this and other biocides carry through into the blowdown discharge, NALCO is proposing to feed sodium bisulfite into the cooling tower blowdown prior to mixing with the boiler blowdown. This will effectively remove the biocide before it discharges to the stormwater detention pond. Data provided by Nalco states that the half life of ACTI- BROM 1318 ranges from seconds to days, depending on conditions, with reducing conditions and the presence of organic matter resulting in the most rapid decay. The probability that any active biocide will be discharged to the surface waters is nil. In order to facilitate calculation of an in -stream concentration, the half life of NALCO 7320 at a pH of 7.5 was used. The concentrations used in the calculations are the anticipated concentrations in the combined blowdown stream as provided by Nalco. Discussion of half life and LC50 values: The LC50 values for the biocides used in the process are well documented. The half life of Nalco 7320 can be estimated with confidence from available data, and the half life of ACTI_BROM 1318 and sodium hypochlorite become moot because of the addition of sodium bisulfate to the cooling tower blowdown prior to discharge. The corrosion inhibiters, pH adjustment chemicals, and other water treatment chemicals present some problems. How each of these was handled in the biocide worksheet calculations is explained below. Nalco 3DT291 is an internal water treatment that does not contain hazardous materials according to the MDSD. The half life is not provided, but the material is readily biodegradable. For this reason, a half life of 5 days was assumed for the calculations. LC50 data is provided for the product and was used in the calculations. Nalco 3DT284 is a corrosion inhibitor containing phosphoric acid. No half life is given, but it is likely that, at the pH of the blowdown, the phosphoric acid will have reacted to form phosphate salts and that this will be the material in solution. For this reason a half life of 5 days was assumed. LC50 values are given for the product itself and these are used in the calculations. Nalco 73199 is a corrosion inhibitor containing sodium benzotriazole and sodium hydroxide. No half life is given but the material is inherently biodegradable, so a half life of 5 days is assumed. LC50 values are given for the product itself. The lowest value for a warm water fish was used in the calculations. It is worth note that the pH of the product, and thus the material tested, is greater than 11, which will result is fish toxicity. When mixed in the water treatment process, the toxicity will likely be lower. Nalco NexGuard 22310 is an internal boiler water treatment that lists no hazardous ingredients. No half life is given. The material is known to be slowly biodegradable, so a half life of 10 days was used. The LC50 value given for the most sensitive warm water fish, which was less than that for Daphnia magna, was used in the calculations. Nalco 1720 is an oxygen scavenger containing sodium and potassium bisulfite. No half life is given, but the material will react readily with oxidizing compounds or oxygen in solution or from the atmosphere. For this reason, a half life of 5 days was assumed. The LC50 for the fathead minnow was the lowest listed, and this is used in the calculations. Nalco 8735 is a mixture of sodium and potassium hydroxide and is use for pH control. No half life is given in the MSDS. The LC50 values given are for the product itself, but this is not the form in which it will be discharged. At the pH of the blowdown, 7.5 to 8.0, it will be in the form of Na and K salts, not the hydroxide. No LC50 values were discovered for the sodium and potassium salts, so no further calculations were done and no biocide worksheet is provided. ,••\ Biocide Worksheets: Biocide worksheets were prepared for each of the biocides used and are attached. Nalco provided estimated concentrations of each chemical in the blowdown water from the specific process, and this documentation is shown on the calculations under "Nalco Notes". The biocide worksheet asks for feed rates of the biocide, and these are not available. The feed rates will be variable and will be controlled by real time inputs to a PLC from each process. It is believed that the designed concentrations in the discharge as provided by Nalco are the most reliable data to use in estimating the quantity discharged. The mass discharge rate was calculated and included based on the given concentrations and flow data provided. Note that the biocide worksheet indicates that DWQ will provide the 7Q10 flow of the receiving stream. DWQ was contacted to get this information, but due to budget constraints, this information could not be provided, so a worst case estimate of 0 cfs was used in the calculations. Biocide worksheets are also included for the corrosion inhibitors and other inorganic chemicals that will be used. These chemicals will react within the process and will discharged in the form of dissolved salts. Nalco 8735 is a mixture of sodium and potassium hydroxide use for pH control. At the pH of the blowdown, 7.5 to 8.0, it will be in the form of Na and K salts, not the hydroxide. When the total mass loading of additives that is expected in the discharge is considered, the resulting solution would have a TDS of 106 mg/I. This is clearly well below any action levels in the receiving waters. Alternatives to Discharge to the Surface Waters: The alternatives of discharge to a public sewer system and land application rather than a surface water discharge were evaluated. Discharge to a public sewer was ruled out because it is approximately 21,000 feet to the nearest location that a public sewer is available. Extensive design work would be required to develop a reliable cost estimate, but it can be assumed that the installed cost of a force main to transport the waste would be about $32 per foot. The cost for a sewer line to this location is estimated to be in excess of $600,000 and is prohibitively expensive. Land application in lieu of discharge was also evaluated. The soils on the site are typical of those found associated with Carolina Bays that have been drained and graded for agriculture. Soils data from the USDA soil survey web site shows that the soils on the site are predominately made up of Coxville loam, Duplin sandy loam, Goldsboro sandy loam, Johnston loam, and Norfolk loamy sand. The USDA mapping data indicates that these soils are hydric or partially hydric soils and may have a shallow depth to the seasonal water table. The data also shows, however that the saturated hydraulic conductivity (Ksat) is moderate to high, so the soils may be suitable for land application of the utility blowdown if drainage is provided to lower the seasonal water table elevation. Portions of the site are already drained with a ditch system and are actively farmed, so they may be suitable as is. A more detailed on -site soil analysis will be required to determine if land application is possible, and if so, how the system must be designed and what, if any, additional drainage is needed. For the purposes of this analysis, however, it is assumed that land application is possible, that no extensive drainage will be required, that storage equivalent to 30 days of flow will be required, and that an annual average loading rate of 0.5 inches per week can be achieved. Based on these assumptions, land application would require irrigation of an estimated 42 acres of land. The storage pond would need to hold approximately 2.5 million gallons. The cost for a land application system of similar size in North Carolina that was constructed within the last 18 months was $12, 256 per acre, not including storage pond cost. It is anticipated that the cost of a land application system for the utility blowdown would be similar. That would make the estimated cost for the land application system $512,000. The cost of the storage pond is estimated to be $65,000, based on the cost to construct the existing stormwater detention pond. The total cost of this option is therefore estimated to be $577,000, which is also prohibitively expensive. Attachments: Application Form Material Safety Data Sheets Calculations Biocide Worksheets 3DT284: Actibrom 1318: 73199: 7320: Bleach: Flows -- From Greg Jensen (Nalco) The pH will range from 7.8 to 8.2 for the combined boiler and cooling tower flow. Remember that the residuals in each blowdown stream are in that flow only. Example: The nexguard is at 120 PPM in the 9.7 gallons per minute blow down. Hope this helps. Let me know if you need anything else. Cooling Tower Chemicals/Reslduels: 3DT291: 35.2 mg/l 40.2 mg/I 22.7 mg/I 5 mg/I 12 mg/I 0.64 mg/I 46 gpm 0.06624 mgd Total Flow 0.080208 mgd Storage pond volume from Justin 2.388 Million Gal 1.695 Million Gal Detention Time in pond 21.1 days --assume no rain from Billy Chloride action level in Class Cswp water 230 mg/I Boiler Chemical Residuals: 22310 120 mg/1 1720 30 mg/I 8735 75 mg/I (0-Alkalinity) 9.7 gpm 0.013968 mgd Boiler Treatment Blowdown 225 pounds of NaCL every 6.7 days 911 gallons per cycle 537,394 gallons dispersed into 2,034,250 liters dispersed into discharge has 450,000 grains hardness 29,159,510 mg of hardness 288,994 mg CaCO3 14.3 mg/I CaCO3 in discharge 50.20 mg/I salt in discharge One gallon is equal to 3.785412 liters 1 grain = 64.79891 milligram MW of CaCO3= 100.9 Utility Blowdown from Bioler and Cooling Tower —Clean Burn Fuels Product Total Disc Vol Product Disc. Identification (mgd) Conc (mg/I) 3DT291 3DT284 Actibroml 318 73199 7320 Sodium hypochlorite NexGuard 22310 1720 8735 0.080208 0.080208 0.080208 0.080208 0.080208 0.080208 0.080208 0.080208 0.080208 29.1 33.2 0.000 4.1 0.5 0.000 20.9 5.2 1 3.1 Lowest LC50 (mg/I) 938 3,360 0.038 164 0.53 0.033 1086 382 NA Product Use Cooling Tower treatment Corrosion Inhibitor Biocide Corrosion Inhibitor Biocide Biocide Activator Boiler Water Internal Treatment Oxygen Scavenger pH stabilizer gm/24 hour in discharge 8,825.29 10,078.88 1,253.59 150.43 6,344.27 1,586.07 3,965.17 Notes: The LC50 value given for ActiBrom 1318 is for the hyprobormous acid generated from sodium bromide and hypochlorite Sodium hypochlorite and Actibrom 1318 are removed by adding sodium bidulfite to blowdown as part of process control Nalco Notes Note 1 Note 2 Note 3 Actibrom 1318 will be neutralized with bisulfite addition in CT blowdown resulting in NaBr salt. Column C lists concentration of product in outfall Colum F lists total mass grams/day discharged ) Half Life vs pH for 7320 (from Nalco) Hours pH 1608 5 63 7 3.0 9 let y= 7.5 -0.6377*LN(x)=9.6864-y Ln(x)= 3.428571429 x= 30.8 hours Storage pond volume from Justin 2.388 Million Gal "empty" volume from Billy (designer) 1.695 Million Gal y =-0.6377Ln(x) + 9.6864 R2 = 0.9996 For Actibrom 1318 Assume same as 7320= 30.8 hours Note: Actibrom 1318 is an oxidizing biocide and will not persist as long as 7320, particularly in the blowdown stream Clean Bum Fuels, LLC Data for Hoke County Equations and Given Values Assume the following: Average Daily Discharge (ADD)= 0.0802 MGD Instream Waste Conc. (IWC)= 100% Dosage Rate (DR) given in g/24 hr IN BLOWDOWN STREAM from vendor data Volume = 1,695 MG Decay Rate (DK )=[(1/HL)*0.69] Half Life (HL) in days from vendor data or assumed Degradation Factor (DF)=[(ADD/Volume)+DK] Discharge conc = [DR/(DF*Volume*3785)] Receiving Stream Conc. =(Disc Conc)*IWC%/100) =Disc Conc for this case Individual Product Data Product 3DT291 3DT284 Actibtom1318 73199 7320 Soduim hypochlorite 22310 1720 8735 RCC 3DT291 3DT284 Actibrom1318 73199 7320 Soduim hypochlorite 22310 1720 8735 DR 8,825.29 10,078.88 1,253.59 150.43 6,344.27 1,586.07 3,965.17 =Disc Conc 7.423 8.477 0.0000 1.054 0.040 0.000 8.502 1.334 NA Volume 1.695 1.695 1.695 1.695 1.695 1.695 1.695 1.695 1.695 Lowest LC50 938 3,660 0.038 164 1.24 0.033 1086 382 NA DK HL 0.1380 5.00 0.1380 5.00 0.5371 1.28 0.1380 5.00 0.5371 1.28 0.5371 1.28 0.0690 10.00 0.1380 5.00 NA NA Allowable OK? 9.380 YES 36.600 YES 0.002 YES 1.640 YES 0.062 YES 0.002 YES 10.860 YES 3.820 YES NA YES ADD IWC DR Volume DK HL DF Disc Conc RCC DF 0.185315634 0.185315634 0.5844 0.185315634 0.5844 0.584410103 0.116315634 0.185315634 NA WOW dig U.S. DEPARTMENT OFTHIT E IERIOR .r.r..r.ray..+l U.B. GEOLOGICAL SURVEY euirmitnalt MIL 4*.mr ..O 1w :tiVHrK *VW fir, 111 • STATE OF NORTH CAROLINA RAEFORD QUADRANGLE NORM CAROUNAGEO1tM:rA. SURVEY NORTH CAROLINA DESARTUENT Op EMWtOMMENTAMO NATURALRESOURG6 7.SM1NIE SLAWS (TOPOGRAPHIC) pa •, 1 .,,.,.... - ' IF • .rs^•j... • Sap --- 1. -- r, >f- j ` t --f w it I .:, �� ,.. _ . , Ira, I. • . i 1 A . joil ss i Ilkt. ir a•.•66ths UMW I te. 000k.0001 Sun. in wog*.C.HIir D.wmm ter— NMI soswi...am.+m••.. w.... P+ — H u 1 MIMI& •.. gqg AlmAma.vnnawmm 11*1 ..�..aw....n Hope w.sMAnM. A•111ll, 0..a� mawom r . .terr. r.— RAFFORD. NC Map of 269 Pate Rd Raeford, NC by MapQuest 9/8/09 2:20 PM MAPQusT A: 269 Pate Rd, Raeford, NC 28376-7054 MAPQUEST (21 T Raeford �0 f ; r20: 4�0l 14 dr = C+? 2009 1.' ,pOuest Ir•.,, 'SNIT Ra Rockttsh Rd re i tg 01 1500 m 24m ft pundarrach Map Data 02009NAV TEO of TeleAtlas All rights reserved. Use subject to License/Copyright Map Legend Directions and maps are informational only. We make no warranties on the accuracy of their content, road conditions cc route usability or expeditiousness. You assume all risk of use. MapQuest and its suppliers shall not be liable to you for any loss or delay resulting from your use of MapQuest. Your use of MapQuest means you agree to our Term* of Use c, 4.(t.-- -34 G(0 -)10 bif http://www.mapquest.com/maps?city=Raeford&state=NC&address=269+Pate+...e+County:l/m::10:34.950799:-79.183013:0 /to:0 f•EN:M:/e Page 1 of 1 c?,<00er\"" \i' f 1 a 1 1. ONO T1?0WIT w, ram (T774 DISTURBED AREA 57.23 AC. .aura, II t. ,, to--------- VV11 ic� i t• i vae ew a AO MAIM o.o -n w KU ®m• m:a.:. I/IOAie sw of le N Mi eY A•l[Oi emWt Sr CIL w O NI ML 1700101TML Ui SECTION — DI[QHINC OLTAIk aeon , . a• / w/ap Of DC Ut -4rm - F p©rt.' CL_FlR [2:U?I1 FUEL❑ PREIJMINARY NOT FOR CONSTRUCTION O1TL 06/39/07 aemu afl amNm rJ212..00na2 effi Mawr aT of I'y w. ac Nr. a11111•1a11w o,a,aoa �dc. L,0 T60/ q CLEAN BURN FUELS HOKE COUNTY REGIONAL INDUSTRIAL PARK HOKE CO., NORTH CAROUNA PHASE I: SEDIMENTATION & EROSION CONTROL PLAN 112aa ,rncaia-ci OWL JUNE 2007 SEC 2