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HomeMy WebLinkAboutWQ0003468_Report_20220809Geosyntec l> consultants Geosyntec Consultants of NC, P.C. To Ms. Morella Sanchez King Wilmington Regional Office 127 Cardinal Drive Extension Wilmington, NC 27405 morella.sanchez-king@ncdenr.gov 910-796-7218 Subject: West Fraser Armour Mill CLRS Permit WQ0003468 Inspection Comment Responses Dear Ms. Sanchez King, 2501 Blue Ridge Road, Suite 430 Raleigh, NC 27607 PH 919.870.0576 www.geosyntec.com August 9, 2022 Geosyntec Consultants of NC, P.C. (Geosyntec) has prepared this letter on behalf of West Fraser, Inc. (West Fraser) in response to your April 6, 2022, inspections report providing comments on the closed loop recirculation system (CLRS) Permit WQ0003468 for the Armour Mill Plant in Riegelwood, North Carolina (Site). During the North Carolina Department of Environmental Quality (NCDEQ) routine inspection of the Site, NCDEQ noted that several minor modifications had been made to the CLRS. The four main modifications identified were: (i) the removal of the centrifuge system; (ii) the replacement of the recirculating pump; (iii) the addition of a new oil/water separator (OWS); and (iv) modifications to the Ash Pond 2 outlet pipe that supplies the CLRS recirculation pump. NCDEQ requested that these modifications be documented with a modification permit application. On July 14, 2022, Geosyntec and West Fraser met with NCDEQ via teleconference to provide an update on project status and to discuss potential additional modifications to the CLRS that West Fraser may implement. Based on the outcome of the phone conversation with NCDEQ on July 14, 2022, a modification permit application, including previous modifications and planned future modifications, will be submitted at a later date in conjunction with the Site's permit renewal application. The purpose of this letter is to provide responses to the comments in the inspection letter. For ease of review, this letter is formatted such that each NCDEQ comment is repeated and then followed by West Fraser's response to the comment. Ms. Morella Sanchez King August 2022 Page 2 NCDEQ Comment No. 1: Provide a written narrative of activities for which the permit modification is being requested. Response to NCDEQ Comment No. 1: A description of each previous modification is included below: Centrifuge: The Swaco 414 centrifuge dewatering system was installed in 2005 adjacent to the boiler and scrubber to aid in the separation of ash and water exiting the scrubber. At the time of installation, it was assumed that both ash ponds would soon close, however, the ash ponds remained in operation at the Site, eliminating the need for the centrifuge. To reduce operations and maintenance costs at the Site, the centrifuge was decommissioned and removed from the Site in 2019. Recirculation Pump: The Gorman -Rupp Super T Series self -priming centrifugal pump (Model No. T3A60S-B /F) was installed in December 2021 at the pump house on the west side of Ash Pond 2. This modification was a like -for -like replacement for the original 500 gallons per minute (gpm) pump which had reached the end of its functional lifetime. The replacement pump was selected to decrease operations and maintenance efforts and provide easier functionality for Site personnel. Oil/Water Separator: A model 6V Oil Skimmers Inc. OWS was installed in August 2021 in the vehicle washdown area. This new separator reduces solids, is more efficient, and involves easier operations and maintenance than the previous OWS, a Sandpiper PN S30B1ANNANS700. While the previous OWS is not currently being utilized for separation of oil and water, it is still being utilized to pump residual water from the vehicle washdown area into Ash Pond 1. Note that the use of the old OWS to pump water into the Ash Pond is only employed intermittently as needed at the Site and does not represent a continuous source of water to the Ash Ponds. Outlet from Ash Pond 2: A new inlet pipe to the recirculation pump was installed at Ash Pond 2 in December 2021 to replace the old, damaged pipe. This pipe was modified during the installation of the new recirculation pump. Previously, the intake was located against the bottom of Ash Pond 2, which resulted in elevated solids content being introduced into the recirculation system at the pump suction inlet. The new pipe intake is submerged just below the surface of the pond to reduce solids; its position relative to the pond surface level is held in place by an attached buoy. engineers I scientists I innovators Ms. Morella Sanchez King August 2022 Page 3 As discussed above, a modification permit application will be submitted at a later date in conjunction with the Site's permit renewal application. NCDEQ Comment No. 2: Provide a detailed revised process diagram. The process diagram is recommended to: 1. Demonstrate that the system operates as a closed loop system (e.g., that the flow following the dumpster flows to Pond #1). 2. Depict how all the flows associated with the water softener are directed (e.g., flow into and out of the unit as well as backwash water); 3. Depict all inlet structures (e.g., surface drop inlets, etc.); and 4. Indicate if potable water for the on -site buildings is provided through the same water meter or other(s). Indicate the location of the water meter(s) on a site diagram. Considering the modifications to the system over the years, additional site diagrams are recommended to depict the location of structures referenced within the process diagram to assist in a timely review of the permit modification application. Response to NCDEQ Comment No. 2: Figure 3 of the Closed Loop Evaluation Report (Attachment A; Geosyntec, 2022) depicts the process flow diagram of the current system and demonstrates that the system operates as a closed loop. Figure 3 also depicts how the inflow, outflow, and backwash flows associated with the water softener are directed within the system. As illustrated, county water flows into the softener, and subsequently exits the softener and flows into the boiler. Softener backwash exits the softener and flows into a collection pit located near the softener. Process water collected in the collection pit continues to flow through a series of additional collection pits that also receive stormwater. Ultimately, these collection pits transmit flows to Ash Pond 1. Figure 2 of the Closed Loop Evaluation Report (Attachment A) depicts the locations of structures identified in the process flow diagram. The locations of inlets and outlets of the ash ponds and the location of the county water meter can be found in Figure 2. engineers I scientists I innovators Ms. Morella Sanchez King August 2022 Page 4 County water is provided to the Site through the single meter located at the scrubber as shown on Figure 2 of the Closed Loop Evaluation Report (Attachment A). The county water meter measures combined flow for the following on -Site demands: process water, fire water, and potable water. NCDEQ Comment No. 3: Request confirmation that system operates as a closed -loop system. This can be accomplished either through an assessment with a water balance approach or by providing documentation of the characteristics of the impermeable layer(s) of the settling basins to demonstrate that infiltration is not occurring. Response to NCDEQ Comment No. 3: The Closed Loop Evaluation Report (Attachment A; Geosyntec, 2022) describes activities completed to assess whether the Site CLRS operates as a closed loop. A water balance was performed around the ash ponds utilizing a combination of flows measured at the Site, precipitation data gathered from a local weather station, and transpiration/evapotranspiration estimated using the Thornthwaite method. Ultimately, the Closed Loop Evaluation Report indicates that the system operates as a closed loop. Please note that based on the water balance evaluation, West Fraser is planning additional modifications to the CLRS to decrease uncertainties associated with the closed loop calculation. As discussed previously, West Fraser will submit a permit modifications package at a later date. For more details, refer to Attachment A. engineers I scientists I innovators Ms. Morella Sanchez King August 2022 Page 5 CLOSING We trust that these responses address the comments provided by the NCDEQ. Please feel free to contact either of the undersigned if there are further comments or questions. Sincerely, ,,,„„,,,,,49,1„i Jim Deitsch, Ph.D., P.E. (NC, GA, MA, MD, NC, OH) Hari Parthasarathy, Ph.D., P.E. (sc) Sr. Principal Engineer Senior Engineer Attachment A Closed Loop Evaluation Report, Geosyntec, 2022. engineers I scientists I innovators ATTACHMENT A Closed Loop Evaluation Report LEI West Fraser Prepared for West Fraser Inc. 361 State Rd 1879 Riegelwood, NC 28456 CLOSED LOOP EVALUATION REPORT Armour Mill Plant Prepared by Geosyntec D consultants Geosyntec Consultants of NC, P.C. Geosyntec Consultants of NC, P.C. 2501 Blue Ridge Road, Suite 430 Raleigh, North Carolina 27607 Project Number GR8879 August 2022 Geosyntec ° consultants Geosyntec Consultants of NC, P.C. TABLE OF CONTENTS 1. Introduction 1 2. Background 2 3. Process Components and Flow 3 4. Closed Loop Evaluation Methods 4 4.1. Water Balance Framework 4 4.2. Flow Rate Data 5 4.2.1. Installation of Flow Meter 5 4.2.2. Collection of Flow Rate Data 6 5. Results 8 5.1. Water Balance 8 5.2. Uncertainties 8 6. Summary 10 7. References 11 Table 1 Table 2 Table 3 Figure 1 Figure 2 Figure 3 LIST OF TABLES Pipe #1 Flow Meter Data and Flow Analysis Precipitation Flow Rates into Ash Ponds 1 and 2 Potential Evapotranspiration Flow Rates from Ash Ponds 1 and 2 LIST OF FIGURES Site Location Site Diagram Process Flow Diagram GR8879/CLRS Evaluation Report_Rev 0 i 08.09.22 1. INTRODUCTION On behalf of West Fraser, Inc., Geosyntec Consultants of NC, P.C. (Geosyntec) has prepared this Closed Loop Evaluation Report for the Armour Mill Plant in Riegelwood, North Carolina (Site). Currently, the facility operates under North Carolina Department of Environmental Quality (NCDEQ) Permit No. WQ0003468, issued January 9, 2019, and effective from June 1, 2019, through November 30, 2023. Alterations to processes at the Site have prompted the need for a permit modification of the Closed Loop Recycle System (CLRS) in accordance with 15A NCAC 02T .1000 of the North Carolina Administrative Code (NCAC). NCDEQ performed a routine inspection of the Site and provided comments on the CLRS on April 6, 2022. This report, and associated figures and tables, addresses Comments 2 and 3 from the NCDEQ inspection report. The remainder of this report is organized as follows: • Section 2 — Background, including Site ownership history and modifications; • Section 3 — Process Components and Flow, including detailed descriptions of pertinent equipment; • Section 4 — Closed Loop Evaluation Methods, including data collection and the water balance method utilized to assess the closed -loop nature of the Site; • Section 5 — Results, including the ensuing analysis from the water balance calculation; • Section 6 — Summary; and • Section 7 — References. GR8879/CLRS Evaluation Report_Rev 0 1 08.09.22 2. BACKGROUND The Site is located at 361 Federal Road, Riegelwood, Columbus County, North Carolina (Figure 1). The facility accepts cut logs and produces finished lumber. Wastewater generated through the lumber processing is treated through settling and managed by the CLRS. The Site's permit was first issued on August 9, 1990 to Federal Paper Board Company, Inc., superseding Permit No. 5402R. In 1995, International Paper Co. (International Paper) acquired Federal Paper Board Company, Inc. The subsequent permit dated October 22, 1999 was issued to International Paper. In 2006, International Paper agreed to sell the Site to West Fraser, Inc.. A request was made to NCDEQ on February 28, 2007 to change the permit holder from International Paper, Wood Products, to West Fraser, Inc. To date, West Fraser, Inc. continues to operate the Armour Mill Plant. Over the years, the Site has made changes to the CLRS, including decommissioning of the centrifuge system, installation of a belt -type oil/water separator (OWS)in the vehicle washdown area, replacement of the recycle pump, and modifications to the outlet structure of the ash ponds. The NCDEQ performed a routine inspection of the Site on April 6, 2022. In their inspection report, NCDEQ noted that the aforementioned modifications had been made to the CLRS. Based on the findings of the inspection, NCDEQ informed West Fraser, Inc. that, due to the changes to the CLRS, a modification to the CLRS permit will likely be required. The NCDEQ also requested that the Site evaluate whether the system is still operating as a closed loop. The purpose of this report is to document the water balance evaluation undertaken to address the NCDEQ's comment about the closed nature of the CLRS. GR8879/CLRS Evaluation Report_Rev 0 2 08.09.22 3. PROCESS COMPONENTS AND FLOW This section provides a comprehensive overview of the CLRS to better understand the equipment and flow rates associated with this system. Figure 2 depicts the locations of inlets and outlets of the ash ponds, the location of the county water meter, and the locations of other relevant structures. A process flow diagram illustrating this process is shown in Figure 3. County water provides water for the vehicle wash down area and a Culligan CSM Duplex alternating flow water softener. The softener prepares water for entry into a wood -fired boiler with a maximum heat input of 104,336 British thermal units (BTU)/hour. The boiler produces steam to power two continuous kilns (drying rate of 137,415 thousand board -feet [MBF] of lumber per year) and one batch kiln (drying rate of 20,000 MBF of lumber per year) used to dry lumber. Ash produced from the boiler enters a multicyclone and venturi wet scrubber with a capacity of 350 gallons per minute (gpm). The scrubber collects ash directly from the boiler and separates the ash from the boiler exhaust using water from a 13,000-gallon makeup tank. Backwash from the softener, blowdown from the boiler, overflow from the makeup tank, water from the kilns, and blowdown from the scrubber enter a centralized system of collection pits. Water from these processes, as well as stormwater in the vicinity of the collection system, enters the collection pits and ultimately flows into two 0.167-million-gallon ash ponds. The purpose of the ash ponds is to provide hydraulic residence time for ash settling. Water enters Ash Pond 1 from the collection pits and then overflow water from Ash Pond 1 is gravity fed to Ash Pond 2 through a connecting pipe. A self -priming centrifugal recirculation pump (Super T Series Gorman Rupp Model T3A60S-B/F) pumps water from Ash Pond 2 to the makeup tank where it is held and ultimately reused by the scrubber. Simultaneously, the vehicle wash down area that is used to clean vehicles and other equipment contains an OWS and an additional pump that transmits wastewater to Ash Pond 1 through a second inlet pipe. A standalone OWS (Oil Skimmers Inc. Model 6V) removes oil from washdown water. The old OWS machinery (Sandpiper PN S30B1ANNANS700) is still in use in the vehicle wash down station, though it is no longer used for separation. Instead, the pump is used to transport the skimmed wastewater from the wash down area to Ash Pond 1. The new OWS operates intermittently on an as needed basis at low flow rates and does not represent a source of continuous flow to the ash ponds. GR8879/CLRS Evaluation Report_Rev 0 3 08.09.22 4. CLOSED LOOP EVALUATION METHODS 4.1. Water Balance Framework A water balance calculation to evaluate the closed nature of the CLRS was performed as per NCDEQ 15A NCAC 02T .1004(b)(4). This calculation compares the flows into and out of the Ash Ponds. The inflows and outflows from the Ash Ponds are outlined below: Inflows • Pipe #1: Pipe #1 refers to the final section of process flow pipe before entering Ash Pond 1 (Figures 2 and 3). Just upstream of the entrance to Ash Pond 1 is a collection pit, which aggregates a combination of stormwater and process water. Stormwater is collected from runoff over impervious pavement in and adjacent to the milling operation of the facility. Process water includes (i) blowdown from the scrubber and boiler, (ii) backwash from the softener, (iii) overflow from the makeup tank, and (iv) condensate from the kilns. Flow from the collection pit is transported through Pipe #1 to Ash Pond 1. • Pipe #2: Pipe #2 refers to the pipe that connects the vehicle washdown area to Ash Pond 1 (Figures 2 and 3). The flow entering Pipe #2 is wastewater from the OWS. This flow rate is minimal and not continuous and calculated to be approximately 0.65% of total inflow at the Site; as such, it is assumed to be negligible for this water balance calculation. • Precipitation: Precipitation is collected in Ash Ponds 1 and 2. Stormwater that falls in the vicinity of the collection pits is diverted into collection pits, which ultimately flow into Ash Pond 1 through Pipe #1. Therefore, this precipitation inflow refers only to precipitation that falls directly over the Ash Ponds. Outflows • Potential Evapotranspiration (PET): Water exits the system through PET from Ash Ponds 1 and 2. • Recirculation Pump: Water from Ash Pond 2 is pumped via the recirculation pump to the makeup tank. This water is then reused by the CLRS. GR8879/CLRS Evaluation Report_Rev 0 4 08.09.22 Storage • The water balance assumes that the water levels of Ash Ponds 1 and 2 do not fluctuate. This assumption was corroborated by water level data collected by the water level sensors located in the ash ponds from June 27, 2022, through June 30, 2022. Therefore, there is assumed to be negligible change in the storage capacity of the ash ponds over the period of this water balance calculation. 4.2. Flow Rate Data This section describes the field effort of the flow meter installation and how the field data was processed. It also describes how flow rate data was managed for the water balance calculation. 4.2.1. Installation of Flow Meter Geosyntec performed a flow meter installation at the Site from June 27 to 30, 2022. An ISCO 750 area velocity flow meter, in conjunction with an ISCO 6712 portable sampler, was used to collect flow rate data for this field event. This flow meter uses Doppler ultrasonic technology to measure the average velocity of a flow stream and a submerged pressure transducer to measure depth of the flowing liquid. The level measurement of this instrument can measure a range of 0.033 to 10 feet, with accuracy within 0.008 feet for measurements below 5 feet. The average velocity can be measured from ranges of -5 to 20 feet per second (ft/s), with accuracy within 0.1 ft/s for velocities up to 5 ft/s and within 2% of the reading for velocities between 5 and 20 ft/s. The flow meter was installed on the bottom of the wastewater/stormwater collection pit just upstream of Pipe #1 to measure the flow rates entering Ash Pond 1 through Pipe #1. This collection pit contains two inlet pipes and one outlet pipe. The transducer sensor was installed facing the primary inlet (operations water inlet), approximately 1 foot from the apparent highest velocity observed in the sump, following guidelines from the ISCO 750 Area Velocity Module Installation and Operation Guide (Teledyne Isco, 2013). The flow meter and sampler were powered via an external battery located at the surface of the collection pit. Daily average, maximum, and minimum velocities and liquid heights within the collection pit were recorded. GR8879/CLRS Evaluation Report_Rev 0 5 08.09.22 4.2.2. Collection of Flow Rate Data As described in Section 4.1, five inflows/outflows to/from Ash Ponds 1 and 2 were identified to form the framework to calculate the water balance. Data sources and management are described below for each flow stream. Inflows • Pipe #1: Average, maximum, and minimum velocities and water levels were recorded from the field event. Table 1 provides the daily measurements and associated flow rate calculations. The cross -sectional area of the flow path was calculated to assess flow rate. The collection pit was roughly 4 feet by 4 feet; a buildup of ash within the pit created a flow path that was reduced to approximately 3 feet in width. The measured water levels provided the height of water within the flow path. Flow rate was calculated by multiplying the flow velocity by the cross - sectional area (CSA), as follows: Flowrate (Q) = Velocity x CSA • Pipe #2: Inflow from Pipe #2 is assumed to be negligible, as described in Section 4.1. • Precipitation: Thirty years of daily precipitation data (January 30, 1992 to January 30, 2022) was retrieved from a National Oceanic and Atmospheric Administration (NOAA) gauge in Whiteville, North Carolina (USC00319357). The 80th percentile of the daily precipitation rate was calculated per month. As the flow rate measurement of Pipe #1 was performed in June, the precipitation input for the water balance included the calculated June data. The surface areas of Ash Ponds 1 and 2 were obtained from measurements taken from satellite images of the Site. The precipitation inflow was calculated by multiplying the June precipitation by the total surface area of the Ash Ponds. The volume entering the ash ponds from precipitation was converted from a monthly flow rate to gpm for the water balance. Table 2 outlines the precipitation data calculated per month and the inflow estimated for the month of June. Outflows • PET: Thirty years of observed daily maximum and minimum temperature data was retrieved from the NOAA gauge described above. The surface areas of Ash GR8879/CLRS Evaluation Report_Rev 0 6 08.09.22 Ponds 1 and 2 were obtained from measurements taken from satellite images of the Site. The Thornthwaite method (Ponce, 1989) was used to calculate average PET per month over the surface area of Ash Ponds 1 and 2. PET was converted from an average monthly flow rate to flow rate in gpm for the water balance. Table 3 provides further details regarding the calculation of PET. • Recirculation Pump: The rolling thirty -day average flow rate in gpm for the pump was measured by Site personnel. GR8879/CLRS Evaluation Report_Rev 0 7 08.09.22 5. RESULTS The results and uncertainties of the water balance evaluation are described in the sections that follow. 5.1. Water Balance The results of the water balance calculation are shown in the inset table below. Average flow rates for inflows and outflows were used to perform the calculation. The water balance was calculated as the sum of inflows minus the sum of outflows from the Ash Ponds. The overall balance for the month of June, when the flow rate was measured at Pipe #1, is 16.5 ± 48.2 gpm. Although the calculation suggests a positive water balance, the calculated balance is within one standard deviation of the measured inflows from the collection pits (Pipe #1) which indicates that the CLRS operates as a closed loop although the uncertainty associated with inflows is high. Inflows (gpm) Outflows (gpm) Balance (Inflows - Outflows) (gpm) Pipe #1 (Collection Pits)Washdown Pipe #2 (Vehicle Area) Precipitation Recirculation Pump Potential Evapotranspiration PET (PET) 65.6* ± 48.2 0 2.78 49.1 2.82 16.5 45.1 (median) 0 2.78 49.1 2.82 -4.04 *Note: Flow rates presented here are average values. See Section 4.2.2 for details on calculation of these averages. 5.2. Uncertainties Daily average flow rates measured at Pipe #1 during the field event ranged from 41.6 to 137.4 gpm. The overall average flow rate during the measurement period was 65.6 gpm with a median of 45.1 and standard deviation of 48.2. The 95% confidence interval (CI) for Pipe #1 measurements was calculated as follows: Standard deviation CI = Mean flow rate ± (.95) x .Number of samples GR8879/CLRS Evaluation Report_Rev 0 8 08.09.22 The CI for Pipe# 1 ranged from 42.7 to 88.5 gpm. Since the average is greater than the median, it is likely that Pipe #1 flows would be below 65.6 gpm for a majority of the time. This is supported by the highest average Pipe #1 flow rate being out of range of the CI (137.4 gpm). This outlier is likely driving the average flow rate higher than the median resulting in a skewed average. Using the median inflow (45.1 gpm), the water balance was calculated as -4.04 gpm. The flow rate for Pipe #2 measured by Site personnel was a rolling 30-day average flow rate of the recirculation pump. This measurement does not capture daily variability like and may contribute uncertainty to the water balance. Precipitation flow rates into the Ash Ponds exhibit less variability than the measured Pipe #1 flow rates. Monthly precipitation flow rates range from 0.44 to 3.80 gpm. Potential evapotranspiration flow rates out of the Ash Ponds also exhibit less variability. Monthly flow rates range from 0.18 to 3.06 gpm. GR8879/CLRS Evaluation Report_Rev 0 9 08.09.22 6. SUMMARY As shown in Section 5, the inflows and outflows from the Ash Ponds are similar; the difference between them is within one standard deviation of the inflows measured at Pipe #1 (± 48.2 gpm). As described, the average Pipe #1 flow rate appears to be skewed high. Based upon the statistics for Pipe #1 flow rates, it can be inferred that future inflows from Pipe #1 will likely be less than 65.6 gpm, which brings the overall water balance closer to zero. If the median flow rate from Pipe #1 is used in this calculation, the balance decreases to -4.04 gpm. Therefore, it appears that the CLRS operates as a closed -loop system although the uncertainties appear to be high. Alterations to the Armour Mill Plant in recent years have prompted a modification to the Site's CLRS permit. To confirm the closed -loop nature of the Site, CLRS processes were evaluated to develop a water balance for the CLRS. A review of the CLRS identified three sources of inflow and two sources of outflow from the Ash Ponds. Flow rate measurements, as well as historical weather and temperature data, were utilized to calculate flow rates to and from the Ash Ponds. Based on the calculated balances of inflows and outflows, and considering the observed data variability, the evaluation indicates that the CLRS operates as a closed -loop system. In response to the uncertainties identified during the water balance study, West Fraser, Inc. is evaluating options for further modifications to Site infrastructure to be able to better assess water flows at the Site. GR8879/CLRS Evaluation Report_Rev 0 10 08.09.22 7. REFERENCES North Carolina Department of Environmental Quality. Permit No. WQ0003468: Armour Lumber Mill CLRS. Linda Culpepper. North Carolina Environmental Management Commission, 2019. Ponce, V.M. 1989. Engineering Hydrology: Principles and Practices. Englewood Cliffs, New Jersey: Prentice Hall. Teledyne Isco. 2013. 750 Area Velocity Module: Installation and Operation Guide. GR8879/CLRS Evaluation Report_Rev 0 11 08.09.22 TABLES Table 1. Pipe #1 Flow Meter Data and Flow Analysis Geosyntec Consultants of NC, P.C. West Fraser, Inc. Riegelwood, NC Date Width of Flow Path (ft) Height (ft) CSA (sq ft) Velocity (fps) Flow Rate (cfs) Flow Rate (gpm) Average Max Min Average Max Min Average Max Min Average Max Min Average Max Min 6/27/2022 3 0.451 0.62 0.37 1.353 1.86 1.107 0.08 0.15 -0.08 0.1 0.3 -0.1 48.6 125.4 -39.7 6/28/2022 3 0.518 0.78 0.43 1.554 2.34 1.287 0.05 0.24 -0.23 0.1 0.6 -0.3 34.9 252.0 -132.8 6/29/2022 3 0.486 0.61 0.44 1.458 1.84 1.314 0.21 0.21 0.07 0.3 0.4 0.1 137.4 173.0 41.3 6/30/2022 3 0.343 0.58 0.28 1.029 1.74 0.837 0.09 0.29 -0.08 0.1 0.5 -0.1 41.6 226.1 -30.1 Assumptions: were measured within the collection pit. See Section 4.2 for details. Average 65.6 194.1 -40.3 Median 45.1 199.6 -34.9 1. Height and Velocity Stdev 48.2 56.4 71.5 2. Collection pit dimension = 4 ft x 4 ft 3. Estimated width of flow path (due to ash buildup) = 3 ft 4. CSA = width of flow path x height of water 5. The geometry of the CSA is assumed to be rectangular. 6. For simplicity, the flow path at the measurement point is assumed to be straight and laminar. 7. Friction losses due to ash buildup were not calculated. 8. Flow rate = CSA * velocity Acronyms: cfs = cubic feet per second CSA = cross -sectional area fps = feet per second ft = feet gpm = gallons per minute stdev = standard deviation sq ft = square feet GR8879 August 2022 Table 2. Precipitation Flow Rates into Ash Ponds 1 and 2 Geosyntec Consultants of NC, P.C. West Fraser, Inc. Riegelwood, NC Month Daily Precipitationll'21 (80th Percentile, in/day) Volume of Precipitation Over AP 1131 (ft3/day) /day) Volume of Precipitation Over AP 2 [41 (ft3/day) Total Precipitation /day) (ft3/day) Total Precipitation (gal/day) Flow Rate of Precipitation into Ash Ponds (gpm) January 0.11 211 99 310 2,318 1.61 February 0.14 268 126 394 2,950 2.05 March 0.1 192 90 282 2,107 1.46 April 0.068 130 61 192 1,433 0.99 May 0.1 192 90 282 2,107 1.46 June 0.19 364 171 535 4,003 2.78 July 0.18 345 162 507 3,792 2.63 August 0.26 498 234 732 5,478 3.80 September 0.14 268 126 394 2,950 2.05 October 0.03 58 27 85 632 0.44 November 0.05 96 45 141 1,053 0.73 December 0.092 176 83 259 1,938 1.35 Notes: 1. Historical precipitation data retrieved from NOAA Station "Whiteville 7 NW, NC, US" from January 30, 1992, through January 30, 2022. 2. The 80th percentile daily precipitation is calculated per month over a 30-year dataset. 3. Surface area of AP 1 is approximately 23,000 ft2. 4. Surface area of AP 2 is approximately 10,800 ft2. Acronyms: AP 1 = Ash Pond 1 AP 2 = Ash Pond 2 ft = feet gal = gallons gpm = gallons per minute in = inches NOAA = National Oceanic and Atmospheric Administration GR8879 August 2022 Table 3. Potential Evapotranspiration Flow Rates from Ash Ponds 1 and 2 Geosyntec Consultants of NC, P.C. West Fraser, Inc. Riegelwood, NC Month Avg. TempI21 (°F) Avg. Temp (°C) I J c Flow Rate of Preci itatio p n into Ash Ponds (gpm) K�3� PET (cm/month) PET (in/month) PET in AP 1 3 (ft /month) PET in AP 2 3 (ft /month) Total PET (gal/month) Flow Rate from Ash Ponds (gpm) Annual 82.06 1.82 January 44.19 6.77 1.58 1.13 0.84 0.95 0.37 715 336 7,858 0.18 February 46.96 8.31 2.16 1.64 0.91 1.49 0.59 1,128 529 12,395 0.31 March 53.48 11.93 3.73 3.16 1.00 3.15 1.24 2,374 1,115 26,092 0.58 April 62.12 16.73 6.23 5.84 1.08 6.32 2.49 4,772 2,241 52,453 1.21 May 69.98 21.10 8.84 8.90 1.17 10.37 4.08 7,827 3,675 86,037 1.93 June 77.20 25.11 11.51 12.21 1.20 14.71 5.79 11,097 5,211 121,987 2.82 July 80.43 26.90 12.78 13.84 1.19 16.47 6.48 12,428 5,836 136,608 3.06 August 79.12 26.18 12.26 13.16 1.13 14.84 5.84 11,199 5,259 123,101 2.76 September 73.84 23.24 10.24 10.61 1.03 10.97 4.32 8,279 3,888 91,007 2.11 October 63.60 17.56 6.70 6.37 0.95 6.03 2.38 4,553 2,138 50,049 1.12 November 53.90 12.16 3.84 3.27 0.86 2.83 1.11 2,133 1,001 23,444 0.54 December 47.06 8.37 2.18 1.66 0.82 1.36 0.53 1,025 481 11,264 0.25 Notes: 1. PET flows calculated using Thornthwaite methodology obtained from: Ponce, V.M. 1989. Engineering Hydrology: Principles and Practices . Englewood Cliffs, N.J: Prentice Hall. 2. Historical temperature data retrieved from NOAA Station "Whiteville 7 NW, NC, US" from January 30, 1992, through January 30, 2022. Average was calculated from daily maximum and minimum temperatures. 3. K is calculated using latitude of the facility, 34.3399°. Acronyms: AP 1 = Ash pond 1 AP 2 = Ash pond 2 Avg = average °C = Celsius cm = centimeters °F = Fahrenheit ft3 = cubic feet gal = gallons gpm = gallons per minute in = inches K = constant, dependent on month and latitude NOAA = National Oceanic and Atmospheric Administration PET = potential evapotranspiration PET(0) = PET at 0° latitude Thornthwaite Method Equations c = 0.000000675J3 - 0.0000771/2 + 0.01792J + 0.49239 PET(0) = 1.6 (---) lOT PET = K * PET(0) T = mean monthly temperature (°C) I = monthly heat index J = annual temperature efficiency index c = constant, dependant on J GR8879 August 2022 FIGURES Miles 0 25 50 100 150 200 Legend NC Counties • Facility A SITE LOCATION RIEGELWOOD, NC Geosyntec consultants West Fraser Figure 1 Geosyntec Consultants of NC, RC. RALEIGH, NC AUGUST 2022 \\ARO-01\PRJ1$\W\WEST FRASER\01 ARM CLIENT PROVIDED\DATA GAPS INFO FROM EMILY 5.25\CAD\1 WEST FRAZIER ARMOUR MILL OVER VIEW-VER 3.1 - Last Saved by: SNichols on 7/19/22 NOTES: 1. SITE DIAGRAM BASEMAP PROVIDED BY WEST FRASER, INC. CONTINUOUS KILN r BATCH KILN COUNTY WATER METER SCRUBBER WATER SOFTENER BOILER DECOMMISSIONED CENTRIFUGE (REMOVED FROM SITE) COLLECTION PIT MAKEUP TANK II II II e__a11 may_' 1'11111 WI I IIIIIIIIINI■I \\!q! i1111 1� III '1, ;1.1� — ■IIII u i ■■'. =' InI 111 Hurl u —111 ■-- •,LF.III, lil11 u. iwu 111 I■PAiiir iiiiim I ilk 9 IliiiI I■IIIII ' 1�11 '!ague■in11i �illINII� minik ,--�n- �mi■■ "�I"IIIIILi.iI ice`_ *'illI1°;�Ii. ` 1 Mr I I I! `o, I * 4 I I 1I a, I1111i�� =111 in La mii Illy■ii !iii ii Lalll I PIPE #1 INLET RECIRCULATION PUMP PUMP HOUSE OUTLET TO RECIRCULATION PUMP ASH POND 2 VEHICLE WASHDOWN AREA 0 1,500 SCALE IN FEET PIPE #2 INLET SITE DIAGRAM RIEGELWOOD, NC Geosyntec consultants ,cosyntec Consultants of NC, P.0 PROJECT NO: GR8879 AUGUST 2022 FIGURE 2 FIRE WATER/ POTABLE WATER 1 CLOSED COUNTY WATER NOTES: MAKEUP TANK SOFTENER BOILER - CP • BLOWDOWN SOFTENER BACKWASH • VEHICLE WASHDOWN AREA OIL WATER SEPARATOR SW CP/CP SW CP/CP ASH POND 2 • OLD O/W SEPARATOR 1. PROCESS FLOW DIAGRAM BASED ON GEOSYNTEC SITE VISIT ON MAY 10, 2022. ASH POND 1 SOFTENER Legend CP — Collection Pit SW CP/CP — Stormwater Collection Pit / Collection Pit Kilns Water Softener O/W — Oil Water Separator PROCESS FLOW DIAGRAM RIEGELWOOD, NC Geosyntec consultants Geosyntec Consultants of NC, P.C. RALEIGH, NC 1111 West Fraser AUGUST 2022 Figure 3