2023.0831 - BBP to DEQ - Notice of Intent Pilot Treatment Assessment.pdf

Badin Business Park LLC
201 Isabella Street
Suite 500
Pittsburgh, PA 15212-5858 USA
Tel: [phone]
August 31, 2023
Michael Montebello
Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Notice of Intent to Commence Pilot Treatment Assessment
Badin Business Park LLC, Badin, NC
NPDES Permit No. NC0004308
Dear Mr. Montebello,
Badin Business Park LLC (BBP) is in receipt of the Division of Water Resources (DWR)
NPDES permitting section's June 14, 2023, letter (Letter) regarding the recent Treatability
Presentation. In accordance with the Letter, BBP is providing this notice of intent to begin
field testing the use of activated alumina to treat water discharged at Outfall 005. Further,
BBP interprets the Letter that DWR considers the proposed field pilot testing to be acceptable
activity under BBP's current permit (NC0004308) and does not require a permit modification.
The field testing will begin immediately as the activated alumina is onsite, and support
materials are readily available for purchase.
BBP intends to pilot the use of activated alumina as discussed in the December 16, 2022,
Focused Treatability Study Work Plan (Work Plan) with a revised approach. In lieu of
pumping fluoride -bearing water into a treatment system, the activated alumina will be
installed in the Outfall 005 storm sewer for direct contact with the effluent. This will provide
an initial assessment of treatment performance. Modifications may be proposed and
communicated to DWR following the initial assessment.
This field trial is being conducted as a presumptive treatment remedy while the Treatability
Study, as presented in the Work Plan, progresses. Presently, vendors are evaluating site
specific water quality information in review of various treatment technologies; completion of
the Treatability Study is expected later in 2023.
Activated alumina, a form of aluminum oxide, was selected for the pilot based on experience
with its use for the treatment of process water and stormwater at active aluminum smelting

Notice of Intent — Badin Business Park
August 31, 2023
Page 2
sites. Further, it is commonly used in municipal and industrial water filtration applications and
is very stable; it will bond with other substances without changing its own chemistry or form.
Should you have questions, please contact me at 412.389.1768 or Robyn. Gros s(c�r�,alcoa.com.
Sincerely,
Robyn L. Gross
Director, Asset Management Americas
Badin Business Park LLC
ec: Jason Mibroda, Alcoa Corporation
Amir Adaryani, PhD, NCDEQ
Doug Dowden, NCDEQ
John Hennessey, NCDEQ
Julie Grzyb, NCDEQ
Richard Rogers, NCDEQ
Anna Gurney, NCDEQ
Andrew Pitner, NCDEQ