NC0003875_Authorization to Construct_20030212

NPDES DOCUHENT SCANNING; COVER SHEET
NC0003875
Elementis Chromium VVWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
'`Authorization
to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Staff Comments
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
February 12, 2003
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CHROMIUM
February 12, 2003
North Carolina DENR-DWQ
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Sirs,
Enclosed please find a P. E. Certification for the completion of the Sulfur Dioxide
Addition System.
Permit NO. NC0003875
ATC Number 003875ACB
Issued on 7/30/2001 to Occidental Chemical Corporation, now Elementis Chromium LP
Castle Hayne Facility
New Hanover County
If you have any concerns or questions regarding this project please contact Robert
Running at [phone].
chard Lowrey
HES Manager
Enclosure
cc: Rick Shiver, Division of Water Quality, Wilmington Regional Office
Wayne Cook, Division of Air Quality, Wilmington Regional Office
Elementis Chromium LP
5408 Holly Shelter Rd.
P.O. Box 368
Castle Hayne, NC 28429

'Permit No. NC0003875
Authorization to Construct
Occidental Chemical Corp. -Castle Hayne Facility- NOW ELEMENTIS CHROMIUM LP
July 30, 2001
Page 3
Engineer's Certification
I, Robert E. Running , as a duly registered Professional Engineer in the State of
North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of
the project, Sulfur Dioxide Addition System , Elementis Chromium LP for the
Project Name Location
Permittee hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the following installations:
• the installation of : 1) an evaporator, 2) a sulfonator, 3) a mass flow meter, 4) an ejector,
• the installation of miscellaneous piping, pinch valves, and appurtenances
for the above referenced project such that the construction was observed to be built within substantial
compliance and intent of the approved plans and specifications.
The permittee must comply, even during the construction phase, with all limits required by the NPDES
permit. Once construction under this ATC has been completed and an Engineer's Certificate has been
submitted, the permittee is authorized to operate the new treatment units.
Signature
•
Registration No.
Date 02/12/2003
In addition, please check one of the following:
7736
•
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There are still some major components that require completion. Another Engineer's
Certificate will be submitted once all substantial construction has been completed.
All substantial construction has been completed.
The Division of Wax Quality �
acknowledgesreceipt and ac
this netall
Mail this Certification to the
NPDES Unit
DENR/DW
1617 Mail `' ice Center
Raleigh, NC 27699-1617

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
July 30, 2001
Mr. Gene R. Renzaglia
Occidental Chemical Corporation
5408 Holly Shelter Road
P. O. Box 368
Castle Hayne, North Carolina 28429
Subject:
Dear Mr. Renzaglia:
A"*A
NCDENR
Permit No. NC0003875
ATC Number 003875ACB
Occidental Chemical Corporation
Castle Hayne Facility
New Hanover County
The Division received a letter of request for Authorization to Construct on March 23, 2001. Final plans and
specifications for the subject project have been reviewed and found to be satisfactory. Authorization is hereby granted for
the installation of a sulfur dioxide addition. Specifically, this ATC allows:
• the installation of : 1) an evaporator, 2) a sulfonator, 3) a mass flow meter, 4) an ejector,
• the installation of miscellaneous piping, pinch valves, and appurtenances
This Authorization to Construct is issued in accordance with Part III, Paragraph C of NPDES Permit No.
NC0003875 issued September 30, 1996 and shall be subject to revocation unless the wastewater treatment facilities are
constructed in accordance with the conditions and limitations specified in Permit No. NC0003875. Failure to abide by the
requirements contained in this Authorization to Construct may subject the Permittee to an enforcement action by the Division
of Water Quality in accordance with North Carolina General Statute 143-215.6A to 143-215.6C. The issuance of this
Authorization to Construct does not preclude the Permittee from complying with any and all statutes, rules, regulations, or
ordinances which may be imposed by other government agencies (local, state, and federal) which have jurisdiction.
In the event that the facility fails to perform satisfactorily, including the creation of nuisance conditions, the
Permittee shall take immediate corrective action, including those as may be required by this Division, such as the
construction of additional or replacement wastewater treatment or disposal facilities.
The Wilmington Regional Office, telephone number [phone], shall be notified at least forty-eight (48) hours
in advance of operation of the installed facilities so that an on -site inspection can be made. Such notification to the regional
supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday,
excluding State Holidays.
Upon completion of construction and prior to operation of this permitted facility, a certification must be received
from a professional engineer certifying that the permitted facility has been installed in accordance with the NPDES Permit,
this Authorization to Construct, and the approved plans and specifications. Mail the completed certification to: North
Carolina DENR-DWQ, NPDES Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Permit No. NC0003875
Authorization to Construct
Occidental Chemical Corp. -Castle Hayne Facility
July 30, 2001
Page 2
One (1) set of approved plans and specifications is being forwarded to you. A copy of the approved plans and
specifications shall be maintained on site by the Permittee for the life of the facility. If you have any questions or need
additional information, please contact Jacquelyn M. Nowell, telephone number [phone], extension 512.
Sincerely,
Kerr T. Stevens
cc: Central Files
NPDES Unit
Wilmington Regional Office, DWQ
Technical Assistance and Certification

OxyChem
CERTIFIED MAIL — 7099 3220 0007 9005 1431
RETURN RECEIPT REQUESTED
March 19, 2001
Mr. David Goodrich
NCDENR
Division of Water Quality
1313 Mail Service Center
Raleigh, NC 27699-1617
r
RE: Authorization to Construct
NPDES Permit Number NC0003875
Occidental Chemical Corporation, Castle Hayne Plant
Castle Hayne, NC, New Hanover County
Dear Mr. Goodrich:
•
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rz
Responsible Care
4
A Public Commitment
This letter is a request for Authorization to Construct additional piping and associated process controls at Occidental
Chemical Corporation's Castle Hayne Plant in order to utilize sulfur dioxide as an alternative reducing agent at the
plant's NPDES wastewater treatment facility. The basis for this request is that the supply of spent pickle liquor
generated by the steel industry, the current reducing agent utilized at the plant, has become increasingly erratic. This
has placed an urgency on the utilization of an alternate reducing agent. Sulfur dioxide addition at the wastewater
treatment area will provide the necessary flexibility to maintain overall production requirements at the Castle Hayne
plant.
The addition of sulfur dioxide will not increase the plant's permitted production capacity, hydraulic profiles, nor will
it affect the current permitted effluent limitations and monitoring requirements for outfalls 001 and 002. Sulfur
dioxide addition will simply allow the facility to operate without interruption during times when pickle liquor supply
is scarce. The construction of the proposed project will not in anyway disrupt the treatment capability of the
existing facility. Furthermore, this alternative will provide potential environmental benefits by reducing the amount
of metal hydroxides in the treated residue, as well as reducing total dissolved solids loadings on the Northeast Cape
Fear River.
Attached for your review are three copies of the proposed project's description, engineering specifications, and
detailed plans. If you have any questions or need additional information concerning this request, please contact me
at [phone] or Frank Barone at [phone].
Sincerely,
2
ene F. Renzaglia
Plant Manager
Occidental Chemical Corporation
cc: Mr. Ed Beck — NCDENR WRO
Mr. Rick Shiver— NCDENR WRO
Mr. Charlie Stehman — NCDENR WRO
Occidental Chemical Corporation
�`� 5408 Holly Shelter Road, P.O. Box 368, Castle Hayne. North Carolina 28429
910/675-7200 FAX: [phone]
Carolina Star Site

Proposed Sulfur Dioxide Addition System
The plant currently utilizes spent pickle liquor to reduce the valence state of the chromium in the plant's wastewater
stream from hexavalent to trivalent. This is a requirement of our NPDES wastewater permit, NC0003875. Spent
pickle liquor is the residual liquid generated when hydrochloric acid is used to remove rust and scale from the
surface of plate steel; pickle liquor is approximately 20 percent ferrous chloride. The availability of pickle liquor is
related to a number of factors that are outside of the plant's control. Supply has become increasingly erratic and
often unreliable at times when steel production is low. Sulfur dioxide has proven to be a suitable replacement for a
portion of the pickle liquor used at the Castle Hayne plant. Sulfur dioxide is a commodity chemical that is readily
available and will increase the plant's operating flexibility.
The proposed project will utilize sulfur dioxide which is currently stored in an existing storage tank in the US Filter
Salt Cake Purification facility, located on Occidental Chemical's Castle Hayne Plant property. The system will
transport, meter, and mix the sulfur dioxide into the plant wastewater stream within Occidental Chemical's
industrial wastewater treatment area. The system is designed to supplement a portion of the plant's pickle liquor
usage with up to two tons per day (2 tpd) of sulfur dioxide. Additionally, sulfuric acid or another acid source such
as spent hydrochloric acid will be used to acidify the solution in order to optimize the reaction rate and retention
time needed to reduce hexavalent chromium.
The utilization of sulfur dioxide as a reducing agent for hexavalent chromium is well understood and widely
practiced. The US Filter Salt Cake Purification facility uses sulfur dioxide gas in their reduction process. The
sulfur dioxide is stored under pressure as a liquefied gas in a building equipped with its own emergency ventilation
system. The properties and hazards of sulfur dioxide gas and liquid are well known. This project will incorporate
the most effective design, equipment, and procedures in full compliance with the requirements of regulatory,
corporate, and industry standards. Appropriate hazard identification techniques will be employed at all stages of
this project. Sulfur dioxide will only be used in a manner that is safe and environmentally sound.
The sulfur dioxide addition project will yield the following potential environmental benefits:
1) Reduction in treated residues generated due to a decreased amount of pickle liquor used to reduce hexavalent
chromium to the trivalent state. Substantially more treated residues are generated using pickle liquor as a
reducing agent since ferric chloride is precipitated from solution with chromium hydroxide.
2) Reduction in metals due to a decreased amount of pickle liquor used to reduce hexavalent chromium to the
trivalent state. Pickle liquor contains small quantities of copper, zinc, nickel, and other metals.
3) Potential reduction of total dissolved solids in the 001 outfall due to the lower chloride content associated with
the decreased amount of pickle liquor in the treatment process. However, there is some degree of uncertainty/
on how the use of sulfur dioxide will impact the total dissolved solids concentrations in the plant's wastewater''
discharger
Currently, total dissolved solids and chloride levels in the 001 effluent are estimated to average 10,000 mg/L and
5000 mg/L, respectively. During sulfur dioxide addition, total dissolved solids and chloride levels in the 001
outfall are projected to average 9,000 mg/L and 3000 mg/L, respectively. It is estimated that the sulfate
concentration in the 001 outfall will range between 1000 to 2000 mg/L depending on the amount of sulfur dioxide
added during the treatment process. tti. s
Closely monitored plant trials will be performed in order to obtjn mor accurate data and to evaluate any change in
the characteristics of wastewater discharge. During the evaluation, the amount of sulfur dioxide used in the
treatment process will be gradually increased to insure that permit limits are not exceeded.
The main reactions associated with SO2 addition are as follows:
2Na2Cr04 + 2H2SO4 4 2H2Cr04 + 2Na2SO4
3S02 + 2H2CrO4 Cr2(SO4) 3 + 2H20
Cr2(SO4) 3 + 3Ca(OH) 2 2Cr(OH) 3 + 3 CaSO4
MAR 2. 3 2601
DiliWATER QUALITY
POINT SOURCE BRANCH

DIVISION OF WATER QUALITY
March 30, 2001
MEMORANDUM
To: Christie Jackson
From: Ed Beck
Through: Rick Shiver-1--�-
Subject: OxyChem
Authorization to Construct Request
New Hanover County
- , 2001 i'
i c.aR— Y(;11E`t QUALITY
SOURCE BRANCH
OxyChem proposes to utilize sulfur dioxide as an alternative reducing agent,
and to install the necessary associated appurtenances required to transport, meter,
and mix the material into the plant wastewater system. Spent pickle liquor, which
is generated when hydrochloric acid is used to remove rust and scale from steel, is
currently used to reduce hexavalent chromium to the trivalent state. Since the rate
of steel production is low and erratic at times, the supply of spent pickle liquor is
not reliable. Sulfur dioxide is readily available and effective is to be used as an
alternative when spent pickle liquor is in short supply.
Sulfur dioxide is currently stored, in the form of liquefied gas under pressure,
in a facility on the OxyChem plant site. The equipment to be installed to transport
and utilize the sulfur dioxide is to include an evaporator, a sulfonator, a mass flow
meter, piping and valves, and an ejector.
The permittee states that the use of this alternative reducing agent should
result in reduced effluent levels of total dissolved solids and in reduced levels of
metals in the residuals. They will carefully develop the operational methods when
beginning this process to refine the process and to assure compliance with effluent
limits. It is recommended that authorization be given for the proposal.
Consideration may be given when the NPDES permit is renewed to determine if
modification of limits or monitoring requirements is needed.
cc: Wilmington Regional Files, Central Files