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• Request No. :2139•
-----WASTELOAD ALLOCATION APPROVAL FORM ----------- -•- �-------^•---
RECEIVED.
Wstw OIS441^, Division
Facility Name IMC CORP "
Type of Waste f: FELDSPAR MINING OCT 29 19M
Status ,' f EXISTING
Ica
Receiving Stream- NORTH TOE RIVER
wiry' Ratw��
Stream. Class ; C-TR �ItMs+i(1h, Nlartr Grot►sr
Subbasin 040306
County MITCHELL Drainage Area <sq mi) : 133'
Regional'Of.fice : ASHEVILLE Summer 7Q10 (cfs) 45
.Requestor DOUG FINAN Winter 7Q10 `(cfs). 55
Date of Request 2/28/85 Average Flow (efs) 270
Quad- C3.1SW 30Q2 (cfs)
-_-rrr.,.,...:s:......,..---r.....-- RECOMMENDED EFFLUENT LIMITS----------------•----•-�----;....••,,_w
DA AVG DA MAX
Wasteflow s (mgd): 3.60 4.32. s
5-Day BOD .(mg/l):
Ammonia Nitrogen (mg/1):
Dissolved Oxygen (mg/1),: _
TSS (4 / D ) : .1320 ": 2640 ', •' - .
Fecal Coliform (*/100ml)c
PH (SU � . 6•-9
wr---rw----r----------..-r-------- COMMENTS s---••-•-r,..,.,,� .r..--.»............_--_r .»r•,...---..,,.........,.
THE DISCHARGE SHALL NOT CAUSE THE TURBIDITY'OF THE RECEIVING WATERS TO
EXCEED 10 NTU. IF THE TURBIDITY EXCEEDS 10 NTU DUE TO NATURAL ZONDITIONS,
THE DISCHARGE'SHALL NOT CAUSE ANY INCREASE IN TURBIDITY. -
TOXICITY MONITORING REQUIREMENTS AND FLUORIDE-WASTELOAD ALLOCATION ATTACHED,"'
.7. _
--- ---r ------w-------- -------- y
Recommended •by�_- pate
Reviewed .b
Toch. .Suppo" Supervisor w _ ;+ - V Date
' r^Regional Su r _ Sie.r.:: Date JR
Permits 9 Engineering Date -� ,
( N s AV_ A-6 N 01 - ve Q Q„04-
1.) The permittee shall conduct chronic toxicity tests on a quarterly
basis using protocols defined in E.P.A. Document 60014-851014
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. Ike Chronic Value (ChV) oust be greater than
There will be minimally five effluent concentrations and a
control exposure treatment. One effluent concentration shall equal
J2.1 44**X, 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"3,,,G4,;�� Gl!, z s
There may not be more than 20X mortality Zn- )Y -_ I.W effluent
after 48 hours of exposure. .3110
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-suit:bl1 test results
will constitute a permit violation.
6
-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
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.
Configuration II - 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.
Configuration III - Unimin Corporation producing feldspar and quartz,
and other three companies as described in I.
Configuration IV - Unimin Corporation as in III, The Feldspar
Corporation producing high purity quartz and the
other two companies as described in I.
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 xQ
' 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
21181
0-
32
0
183
Feldspar
indusmin
17043
26
149
IMC
27306
65530
42
100
242
574
Configuration II
Unimin
0
28082
0
39
0
224
Feldspar
Indusmin
17043
23
132
IMC
27306
72431
38
100
218
574
' Configuration III
Unimin
15800
19
26
109
149
Feldspar
Indusmin
21181
17043
21
121
IMC
27306
81330
34
100
195
574
Configuration IV
Unimin
15800
18
32
103
183
Feldspar
28081
17043
19
109
Indusmin
27306
31
179
IMC
88 330
100
574
Configuration V
Unimin
15800
17
31
98
178
Feldspar
Indusmin
28081
20043,
22
126
IMC
27306
91230
30
100
172
574
Configuration VI.
Unimin
15800
16
28
92
161
j- Feldspar
2808
2 32604
29
indusmin
2730627
.166
55
IMC
i
99630
100
-
574
Request No. : 2139,
--------- ----------- WASTELOAD ALLOCATION APPROVAL FORM --- - E C-ElIT-ELL----
H' "*f Quality Division
Facility Name
:
I MC CORP.
MAY 13 1986
Type of Waste
:
FELDSPAR MINING
Status
:
EXISTING
*estorn krt,onal Offict
Receiving Stream
:
NORTH TOE RIVER
iWealk North. Caroling
Stream Class
:
C-TR
j -14 'Tie 4f ►
Subbasin
:
040306
County
:
MITCHELL
Drainage Area (sq
mi) : 13Y, 1.0
Regional Office
:
ARO
7Q10 (cfs)
: 4i► 0.3
Requestor
:
DOUG FINAN
Winter 7Q10 (cfs)
:: 5
Date of Request
:
2/28/S5
3OQ2 (cfs)
:
Quad
:
C11SW
Average Flow (cfs)
2';0 2,0
-------------------------
RECOMMENDED EFFLUENT LIMITS------------�!_____________
: LITTLE BEAR
N.TOE
Wasteflow (mgd)
: 4.32
4.32
5—Day,BOD (mg/1)
a
Ammonia Nitrogen
(mg/1)
Dissolved Oxygen
(mg/1) : " A'j w. 41 t�•. w.K
TSS a'(o
: 1320 2640
(0.&
1320 2640
Fecal Coliform (#/100ml): ''��S (�3;
q4
i
pH (SU)
6-9
6-9
Fluoride (*/d)
-------------------------------------------------------------------------------
67.7
184
COMMENTS
%OM•f" rACWD' �MEM& 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.
TPX T SIX
IX T i c�.,Un H+nNI t7RiNti.RE1� Z�M.EIU t BI 1~ � .
Recommended by S-tj &9 _ 4(® Date_S 14 _
Reviewed by:
Tech. Support Supervisor___
Regions visor__
Permits b gineering__1
Date_ --3jr
Date__
Date___
DIVISION OF ENVIRONMENTAL MANAGEMENT
May 12, 1986
MEMORANDUM
TO: Arthur Mouberry
Forrest Westall
FROM: Randy Dodd QLL**�
THRU: Meg Kerr MK
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 /l 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
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. 'She Chronic Value (ChV) must be greater than
1.l X. There will be minimally five effluent concentrations and a
control exposure treatment. One effluent concentration shall equal
16 %, 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 '� [ o
There may not be more than 20X mortality in a�17 effluent
after 48 hours of exposure.
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 suit IE test results
will constitute a permit violation.
2199
-. • _--.......__.<.<_, -------- WASTELOAD ALLOCATION APPROVAL FORM --------------------
Facility, Name : IMC Corp.
..Type of Waste FELDSPAR MINING
status EXISTING
Receiving Stream NORTH TOE RIVER
Stream(Maas$ �--TR t ,
Subbasin 040306 1
County MITCHELL DraIneage Area (sq - mi )
Regional Office ARO 7Q10 (cfs) 13.9
Requeestor - ^: DOUG FINAN Winter 7Q10 (cfs)
r .Date of. Reequest _ 2--2(3--('35 30Q2 (afs)
G Quad ,, C115W, Average Flow (cfs )
__.,.__..------- c,..<..r.__=.,.....-- RECOMMENDED EFFLUENT LIMITS --_ -------- .�....,..------- _....
•Wasteeflow (mgd) 4..32'_ `.
5--Day BOO (m g / 1)
Ammonita. Nitrogen (mg/ 1) a �
Dissolved Oxygen (mg/,I).�
TSS (f!D) : 1920 2640
` ,Fel�cal calif arm, (*/100m1)
PH' (.SU)' : 6-9-
Fluoride (0/0 126.Arl 253.2 i
_..... ...._ ......__.... ..-- __ COMMENTS.
The discharge shall not causer the turbidity, o':F the receiving -
�. waters to, exceed 10 `NTU. If the turbidity exceeds 10 NTU due to _ {
natural background -conditions, the discharge shall not causee,acny
increase in turbidity.
Fluoride limit .revisead. Pree%iously based on'30g2. This limit based
on 7g10. ,
Recommended by. -- Date....._
- Reviewed by: s
i. Tech':: Support Supervisory __ . - - Date -------
Regional SupeO.visor------
___.....»..........___..__ Dates_____ ,_•,,_,,. .
�. '; Approval Is A- 1 preliminary (, ) final
` Permits & Engineering -------- ...«..„...Date,,,,_<,,,,_,,,,,.s,..,,_,,
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RECEIVED r
4
JUL 9 - 1986
TECHNICAL SERVICES BP,Ah�':Fi •� nor• J
State of North Carolina
Department of Natural Resources and Community Development
Asheville Regional Office
It James G. Martin, Governor S. Thomas Rhodes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
• July 1, 1986
�., MEMORANDUM
JUL `
TO: R. Paul Wilms, Director WATER QUALIT
Division of Environmental Management SECTION
Page Benton, Deputy Director
Division of Environmental) Management
i1
2 George Everett, Chief v
Water Quality Section
FROM: Roy M. Davis, Regional Supervisor^�
Division of Environmental Management (r \
SUBJECT: Allocation of Fluorides
Spruce Pine Mining Industries
Mitchell County and i
Avery County
3
u•
On June 26, 1986, Mr. Mike Parker, Mr. Forrest Westall and I
met with representatives of the Spruce Pine Mining Industries who
;6 are now or would in the near future discharge fluorides in their
wastewater,. The meeting was held at -our request to discuss
possible approaches to allocation of the total ability of the
9 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
t 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) ermit application already made.
Inwmhuv &gild s 59 VGbodfin Place. P.O. Boot 370, A4wAlk N f. 28802.0370 • Telephone 700-253-3341
;,t; .. ... ........:-.. - . ..'..fib., - � . , ,-•-..:.�•-:_ An Equal Oppon�unie�►• Ai4irinative Action Emplover- . -. - = -. - . . - - -
WIN
R. Paul Wilms
Page Benton
George Everett
Memorandum
July 1, 1986
Page Two
f
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
r mineral processing industry expressed an interest in supplying
this data in the hope that it will result in an increase in the
r numeric Water Quality Standard for fluorides.
t During the meeting, the four industries met in our absence
for a•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
Ib
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.
r There was no consensus among the industries as to how the State
might allocate fluorides to those discharging to the North Toe It
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
•t
Indusmin's NPDES Permits.
y
RMD:ls
Enclosure
xc: Forrest R. Westall
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-
State of North Carolina
Department of Natural Resources and Community Development
....•�+= A%heville Regional Office
lame (,. ;Martin, S. 11u,ma, Rhodes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
June 27, 1986
rR. vNO,,
W sec-[�()Td
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 you.
�iV ` P)
-19a6
inn—, haner• Hurldin.r cp W'(wP hn ha,:' PO ar,, --t A,hcrillc \( ?rwna):-•„ 0 'iikph:,nc'lus:::.:.=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,
Roy M. D vis, 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 of 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
3last twelve or monthly average of the highest of the past
:-welve or projections based upon above (Please
-
-.heck)
Signature
Company Represented
Date
a