NC0000353_Memo_19930511

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DIVISION OF ENVIRONMENTAL MANAGEMENT
May 11, 1993
MEMORANDUM
TO: Randy Kepler
THRU: Ruth Swanek
Carla Sanderson
FROM: liserremisert
SUBJECT: Comments on the Draft Permits for UNIMIN Corp.Spruce Pine-Quartz
(NC0000175),UNIMIN Corp.Spruce Pine-Mica(NC0000361) and
Feldspar Corp.(NC0000353)
Per review of the April 30th memorandum from Mike Parker concerning the
Feldspar Companies,Technical Support will defer to the Asheville Regional Office on all
recommendations.
cc: Forrest Westall

c .STATE
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State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
James B. Hunt, Jr., Governor Jonathan & Howes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
April 30, 1993
MEMORANDUM
TO: Coleen Sullins
Randy Kepler �
Permits and Engineering ectio /i1QVV�,'��
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THROUGH: Forrest R. Westall
(fay' ,
Regional Water Quality Supervisor
FROM: Michael R. Parker
Environmental Specia ist
SUBJECT: Feldspar Companies Draft
NPDES Permits
As you know the draft NPDES Permits for The Feldspar Corporation,
K-T Feldspar Corporation, Unimin Corporation-Quartz Operation and
Unimin Quartz-Mica Operation, were sent to public notice and comments
were received from The Feldspar Corporation and Unimin Corporation
objecting to several items in each draft permit but specifically the
lowering of the fluoride limitations.
Staff of the Asheville Regional Office met with officials of The
Feldspar Corporation on April 6, 1993, and worked out their concerns
with the draft permit. Additionally, we have had several telephone
conversations with Unimin Corporation officials and have worked out
solutions to their problems with the draft permits. Refer to the
attached letter from Mr. Bill Shalter dated April 7, 1993 .
Unimin Corporation has agreed to eliminate any fluoride
discharge at the Mica facility (NC0000361) until such time as the
Company determines if they will construct a fluoride processing plant
at that facility. It is estimated that it will be at least two years
before any decision is made. Please be aware that Mr. Shalter was
assured that he could apply for an NPDES Permit that would allow for a
fluoride discharge at some future date should the company decide to
build another plant.
Interchange Building. 59 Woodfin Place, Asheville. NC. 28801 •Telephone [phone]
An Equal Opportunity Affirmanve Acnon Employer

4
Coleen Sullins
Randy Kepler Memo
April 30, 1993
Page Two
It was agreed that the draft permit (NC0000175) for Unimin' s
Quartz facility would be modified to reflect the fluoride limits of
the existing permit.
The Feldspar Corporation' s draft permit would be modified to
reflect the fluoride limits of the existing permit.
K-T Feldspar did not object to the draft NPDES Permit
(NC0000400) . However, in fairness to all concerned, it is recommended
that their draft permit be modified to show the existing fluoride
limits.
Attached to this memo are amended copies of the draft NPDES
permits. It is recommended that the limits be sent out as draft to
each company for comment or to public notice if that is required.
If you have questions, please call me at 704/251-6208.

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ural Reso. � �. Box 2768i >. - 1�eigh, NC 2761.r Ms. Sullins:ay phone conversation " . Cj e�min requests that NC000017_ ,s r'
changed to reflect the curre. �Q 6
day maximum daily fluoride asch is representative of the curt. '' . e
rs of hydrofluoric acid in the Spi. :-4:::::" ., 413).
l:ionally, at this time Unimin Corporawhether
iwater remediation at the Mica plant t. `"� ,. /'" , will be
'ed by the state as a part of an approves ,,3 -'` ' action
Thus, Unimin requests that monitoring fc. 4,, benzene,
'yl tert butyl ether (MTBE) be required oi. and when
er remediation is conducted.
`nd that if future fluoride discharges are needed at --
`uartz or Mica plants, that the right to obtain these `
thorizations will not be diminished, and the
11 be reviewed without prejudice.
questions, please give me a call.
Sincerely,
U24-e-e,c-a -z• )C. aclidde4„
William D. Shelter
Mgr. , Environmental Affairs
\nd Natural Resources
• Utica,IL 61373 • [phone]-Fax[phone]

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THE COR /�s „
PORAT/ON
Post Office Box 99, Spruce Pine, NC 28777
A subsidiary of ='Corporation [phone] FAX: [phone]
•March 15, 1993
Ms Coleen Sullins
NC Division of Environmental Management "'
P, 0, Box 29535
Raleigh, NC 27626-0535
Dear Ms Sullins,
As per our conversation on 3-12-93, please note that these comments will be sent
after the 3-15-93 deadline.
After reviewing the draft NPDES Permit # NC0000353, for The Feldspar
Corporations, Spruce Pine, NC operation, we would comment as follows:
1. The Public Notice list The Feldspar Corporation and Permit # NC0000353
as being in the Neuse River Basin. This should be corrected to read French Broad
River Basin.
2. The Draft Permit cover sheet list the expiration date of the permit as 12-31-
96, making the permit effective for less than 5 years. We understand your reasons
for this change, but feel that some adjustments should be made to adjust the fees
and permit application requirements. The fees and expense incurred to reapply
before the 5 year period is over should be considered when new Permits are
required.
3. Item #1 on the supplement to the Cover sheet states that acid feed systems
are used for pH adjustments. The acid feed systems that are in place are for
process pH adjustments and not for wastewater treatment purposes.
4. The Effluent limitations for discharge 001 states that setteable solids are to
be sampled upstream and downstream. With the issuance of our present permit
this requirement was dropped. We feel that. this sampling is not needed and object
to the new requirements.
5. The Effluent limitations for discharge 001 gives no maximum daily flow.
Will there be no maximum daily flow?
6. The Effluent limitations for discharge 001 gives a monthly average for
turbidity of 10 NTU. Our present permit, and also this one limits the amount the
turbidity can be raised in the stream. We object to the monthly average and
request that only the stream limit be required.

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page 2
7. The Effluent limitations for discharge 001 list the Fluoride limits as 183
#/day average with a daily maximum of 366 #1 day. It is our understanding that
this limit is taken from the data collected several years ago and the pie
configuration that was developed by the Asheville Regional Office. We would ask
that special attention be given to the division of the Fluoride available so no one
company has an unfair advantage. Under the pie configuration one company can
dominate the fluoride allocations by their use of HF acid and therefore limit the
other companies production. Due to the lack of technical data on Fluoride removal
in Wastewater we are at or near the point of maximum removal. We ask that the
original limits not be reduced, as our future production levels will be increased and
lower fluoride limits will pose an undue hardship on our company.
8. The Effluent limitations for discharge 001 states that daily stream
sampling is reduced to three times per week, as is our present permit. The
statement on pH below this indicates that samples are to be collected daily. We
feel that three stream samples each week are sufficient.
9. The stormwater requirements that are a part of this draft permit will
require additional time for compliance, as we are now under a mine permit that
was issued in the early 1980's when the laws were not as stringent. It should also
be noted that new soil and erosion controls measures will be on our new mine
permit which is under review.
10. We object to the wording in item L in Part 3 of the draft. As noted above
the fluoride allocation was taken from the pie configuration which we understand
was to taken out to simplify the permit. This item leaves an open door to the
problems of the past. Production at one company should not limit the ability of
another company to survive in the market place.
Please correspond with Bill Condron (Plant Manager) or myself when you have
reviewed these comments. We can be reached at 704-765-5500 if you have
questions.
Thank you for your consideration in these matters.
Sincerely Yours,
The Fel par Co oration
o
omas ( om ) Freeman
Environment& Safety Supt.

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UNIMIN CORPORATION
Corporate Geology
Environmental Affairs
Mine Planning Certified Mail
March 5, 1993
Ms. Coleen Sullins
Dept. of Environment, Health, and
Natural Resources
P.O. Box 27687
Raleigh, NC 27611-7687
Dear Ms. Sullins:
RE: DRAFT NPDES PERMIT INC0000175 .
Unimin Corporation's Spruce Pine - Quartz plant can not meet the
proposed 179 lbs/day of fluorides monthly average, or the 358
lbs/day maximum proposed for Permit NC0000175. Unimin was over the
proposed limit for the last ten months of 1992 . We can and have me`
our current permit condition of. 218 lbs/day average for fluoride.
Unimin requests that NC0000175 discharge limitation be changed to
reflect the current 218 lb/day monthly average and 436 lb/day
maximum daily fluoride as specified under Configuration II, which is
representative of the current conditions among the three users of
hydrofluoric acid in the Spruce Pine area.
RE: DRAFT NPDES PERMIT INC0000361
In our application for renewal for Unimin Corporation' s Spruce Pine
- Mica plant permit, our intention was to preserve the option of
adding a quartz/feldspar flotation at Mica, as described in
Configuration IV, for the next five year permit period. This
proposed process change is not expected to occur in the next two
years.
In order to obtain fluoride limits of 218 lbs/day monthly average,
and 436 lbs/day daily maximum in NC0000175, Unimin proposes two
solutions:
1. Issue the new NPDES permits with similar configuration and the
related discharge limits as are in the current NPDES permits.
Configurations I and III are, of course, non-applicable and need
not be listed. Configurations V and VI may or may not be
Lapplicable based upon K-T Feldspars intentions.
This option is the one Unimin prefers. It preserves the status
quo, grants the most flexibility, and reflects truer operating
conditions than the draft permit proposes.
402 Mill Street • P.O. Box 297 • Utica, IL 61373 • [phone] - Fax [phone]

.
Ms. Coleen Sullins
Page 2
2. The second solution would be for Unimin to withdraw its request
for a proposed future fluoride discharge at Mica in exchange
for:
a. the return to Configuration II fluoride limits as they exist
now, and
b. an agreement that if future fluoride discharges are needed
at either our Quartz or Mica plants, that the right to
obtain these permits or authorization is not diminished, and
the application will be reviewed without prejudice.
Additionally, at this time Unimin Corporation does not know whether
groundwater remediation at the Mica plant will be required by the
state as a part of an approved corrective action plan. Thus, Unimin
requests that monitoring for toluene, benzene, and methyl tert butyl
ether (MTBE) be required only if and when groundwater remediation is
conducted.
Unimin would be happy to meet with you and your staff to discuss
these items. If you have any questions, please give me a call.
Sincerely,
UNIMIN CORPORATION
1'
William D. Shalter
Mgr. , Environmental Affairs
WDS:NCNPDES93 :klh
CC: Roy Riddle (UNIMIN)
C.F. Stover (UNIMIN)
A.J. Regis (UNIMIN)
Mike Parker
Dept. of Environment, Health and Natural Resources
59 Woodfin P1. , P.O. Box 370
Asheville, NC 28802