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HomeMy WebLinkAboutNC0020737_Status Report_20171218Tur. C'TTV n1P KT1VrC M(1TTlVTATlV December 18, 2017 P O BOX 429 • KINGS MOUNTAIN, NORTH CAROLINA 28086 • 704-734-0333 Derek Denard North Carolina Department of Environmental Quality Water Quality Division 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: January 2018 Status Report for Pilot Creek WWTP Mr. Denard, RECEIVED/DENR/DWR DEC � 9 2017 VVater Resources Permitting Section The City of Kings Mountain holds NPDES Permit NC0020737. After receipt of the Special Order of Consent (SOC) by the Environmental Management Commision, Pilot Creek has submitted quarterly Status Reports; informing the State, of ongoing efforts made to reduce thallium in the collection system for the City of Kings Mountain. These reports will be submitted quarterly until May 31, 2018, as stated in the Scheduled Activity section, Section 2. (b). The following has taken place between Steag Energy Services and Pilot Creek WWTP (POTW) in order to reduce/monitor thallium in the facility and POTW effluent. Steag and City of KM TI data to date: The following monthly data has been collected reagrding testing results for thallium at both Pilot Creek WWTP and Steag SCR -Tech (results are in mg/L): 004 0.035 003 0 025 002 0 015 0.01 0.005 0 Sept 2017 Oct. 2017 Nov 2017 The Historical City ■ Steag KM Compared to previous submitted data, you can see the downward trend which is taking place with the thallium results. August 29, 2017 The City performed their second semi-annual sampling event at Steag. Thallium results yeilded 0.0546 mg/L, Zinc was 0.995 mg/L. Steag was issued an NOV for Zn and re -sampled on 10/3/2017. Results for the resample were 0.312 mg/L, which was still a violation. In accordance with the City's ERP, a NOV and penalty was issued for the non-compliance on this second event in the amount of $250.00. October 9th, 2017 The City received the SOC from Derek Denard for review. Ricky Duncan (Water Resource Director) signed both copies and submitted to the DEQ. Steag was issued an NOV for foam. At 08:18am on 10/9/17, the City noticed foam entering the plant. After investigating, the pretreatment department found the foam coming from the manhole outside of Steag's facility. Steag is the only flow entering this manhole. POTW received the response from Steag on 10/18/17. Here is the response: STEAG SCEP -Tech ' An Enrl.an n.nl.1 •rr rlc r• Ca mi.nv S� SSE4d SGR- 1, 1— POD.. ncAQDox 1727 Yi L -11-6L 11N PM1:cY 7" 734 0— City of Kings Mountain Attn Richello Meek, L^MrFP Superintendent PO Box 429 Kings Mountain, NC 28086 October 17, 2017 Subject, Response to NOV dated 10192017 for Vco!ation of Section 2 1(22) of the City of Kings Mountain's Sewer Use Ordinance (Causing Excessive Foaming at the POTW) Dear Ms Moak 'Are are in receipt of the NOV letter dated October 9, 2017, regarding the foam detected entering the City of Kings Mountain POTW on October 9, 2017, at 8 18AM and the subsequent manhole investigation from Which you concluded that STEAG SCR -Tech, Inc %vas the source of the foam As you are aware, wastewater discharge from our Kings Mountain facility was immediately halted upon your phone notification to me regarding the foam, and we Immediately rmtiated an Investigation into the cause of the foam Our investigation indicated that the surfactant In the Poly S used for Thalhunl treatment of our wastevvater v✓as the only possible source of the foam @Aanual addition of defoamer %vas Immediately implemented to control foam thereby allovAng us to resume wastewater discharge Our operations management has contacted the Poly S manufacturer and they are removing the surfactant that we tellove was causing the foam from their formulation for future shipments In addition, we have continued the manual addition of dofoamer and are installing an automated defoamer dosing system (rnstafi complehorr date of Novombor22 2017) for use of the defoamer as needed to ensure we avoid foaming issues in the future Please advise should you ha✓e questions regarding this communication or should you require further Information Kind regards, p STEAG SCR -Tech, Inc Lanette H Plyler Director Environmental, Health & Safety October 121h. 2017 The City of Kings Mountain's POTW laboratory was inspected by Jason Smith and Beth Swanson from DWR/Department of Environmental Quality. October 18th, 2017 The POTW received Steag's September monthly Progress Report. This report stated that Steag is in the process of completing their 'Membrane Technology Pilot Unit Trial'. The following was stated reagarding this pilot trial: Membrane Technology Scenario The scope is to reduce level of contamination of T9 to possibly below detection limit by applying further treatment (secondary treatment). To achieve this, one option is to apply membrane technology (trial will be conducted as per/by J&T Technology), resultant outcome would be more concentrated T9 liquid. The concentrated liquid would be further treated to remove contaminates. The concentrate liquid will not only be high in metal concentration but would be also strong in salt/chloride and other impurities. In the lab, trials will be carried out by generating high salt/high contaminated T9 liquid by applying an evaporation technique. Other approaches will also be tried to generate concentrated flow. Once the concentrated form of T9 liquid is generated, different chemical treatments will be applied to study the removal efficiency. Results: The results are positive indicating High Salt solution can be treated using (1) Sulfide (2) KMn04 (3) Nalmet Processes. Each process has shown potential to work. These processes can also be used as Secondary treatment process. Membrane Technology Pilot Unit Trials Three trials were completed with help from Dura Flow. Different formulations were tried. Results are promising. Additional trials to be run to further explore the chemistry. Steag also stated the following additional information in this report: Daily composite are continuously collected and analyzed (internally). Last two weeks trend indicates significant downward trend for thallium. Zinc is also monitored. We are continuously balancing high contamination projects to optimize removal of TI and As. Line 2 project with high Arsenic caustic tanks were monitored closely, 5lbs. sulfide works well at high pH formulations. A low pH formulation requires at least a pH of 8.5 to work effectively with As and TI. More emphasis is given on making sure final pH is adjusted accurately. Individual tanks were also monitored to make sure As and TI are balancing out. Line 1 recently started with high Arsenic job. Currently both lines have very strong chemistry. On line 2 the TI was noticed as high as 48 ppm. The treatment still removes most of the contaminations; Steag has adjusted drop rates and formulations with target pH. In strong jobs, any deviation in treatments or any cross contamination of liquids or any minor leak in filter press could cause spike in T9 chemistry. November 3`a, 2017 Steag SCR -Tech announced the company finalized the purchase of Cormetech Inc. Steag has opted to use the Cormetech Inc. name due to brand recognition. They expect finalization of all legal documents for the name change to take place the first of 2018. November 9th, 2017 The POTW received the formal 'communication' letter referencing the name change mentioned above. This letter was sent stating the following: • On 11/1/2017 Steag SCR -Tech, Inc. purchased Cormetech, Inc. • The entire company will now be branded as Cormetech, Inc. due to brand recognition in the SCR catalyst industry • Effective immediately, Steag will sell products and services under the Cormetech, Inc. name and will likely change the signage at KM to reflect the new branding • The legal entity holding the wastewater permit, STEAG SCR -Tech, Inc., will continue to exist and will continue to be the entity subject to the permit. • They do intend to merge all of the existing STEAG SCR -Tech, Inc. legal entities at some point in 2018, but that will not happen until the second quarter 2018 at the earliest. • Once all of the paperwork necessary for consolidating the legal entities under the Cormetech, Inc. name is complete, they will submit the necessary forms for changing the company name on their wastewater permit. • This acquisition of Cormetech adds new catalyst manufacturing to the company business, but it will have no impact on the operations at the KM facility. Kings Mountain will continue to be the base of operations for catalyst regeneration, and thus there will be no change in the business activities that are currently the subject of the wastewater permit. Upon submittal of the legal confirmation on the name change, the City will issue the wastewater permit to Cormetech, Inc. All the permit conditions and limits will remain the same at this time. November 17th, 2017 POTW received the October monthly progress report from Steag. This report contained further information on the 'Membrane Technology Trial'. The following was found in this report: Membrane Technology Scenario The scope is to reduce level of contamination (especially Thallium) of our discharge to possibly below detection limit by applying further chemical and mechanical treatments (secondary treatment). Three trials were completed with help of Mr. Mike Chen from Dura Flow. Different formulations were tried. Sulfide chemistry tried with very positive results, the changes with high turbulance mixing avoided minimizing air oxidation and deviation of ORP. The formulation seems to capable of working in wide pH ranges of 8.5 to 11.2. Also provides flexibility in adjusting sequences in which the chemicals can be added. Trials used MF Pilot unit completed successfully. Moving forward: Continue flow of streams from T9 will be connected to MF unit for monitoring the effect of oxidation chemistry in respect to variation of T9 characteristics. The trial may continue over a month. Chemicals: Remotox (Poly -Sulfide) with surfactant removed is now in use. This formulation modification made to eliminate foaming issues. November 27th, 2017 The pretreatment department collected the third sample for zinc re -analysis due to the violation which took place during the first sampling event. These results yeilded <0.025mg/L. December 6th. 2017 The POTW received confirmation on the penalty that was assessed on 8/29/17 in the amount of $ 250.00. December 12th, 2017 The POTW provided contact information to Steag for Terry Albrect from the Division. Marcia Allocco informed the City Manager that Mr. Albrect would be willing to assist Steag in their thallium reduction process. Steag plans on contacting Mr. Albrect to assist in this process. The City will submit updates from this event once completed. Pilot Creek will continue to run the belt press and monitor thallium as required. Meetings between Steag and the City will continue to take place in order to reduce the amounts of thallium both leaving Steag's facility and the POTW. If you have any questions, feel free to contact me anytime. Sincerely, Richelle Meek City of Kings Mountain WWTP Superintendent/Pretreatment Coordinator Richelle.meek@citvofkm.com Office #: (704)739-7131