WQ0001105_Final Permit_20090206

IF
HICDERR
North Carolina Departmc-,it of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Dee Freeman
Governor Director
Secretary
February 6, 2009
Ross M. Smith — Environmental Affairs Manager
PCS Phosphate
1530 NC Hwy 306 South
Aurora, North Carolina 27806-9245
Subject:
Permit No. WQ0001105
PCS Phosphate
Closed -Loop Recycle System
Beaufort County
Dear Mr. Smith:
In accordance with your modification request received December 17, 2008, and subsequent
additional information received January 12, 2009, we are forwarding herewith Permit No. WQ0001105,
dated February 6, 2009, to PCS Phosphate for the construction and continued operation of the subject
closed -loop wastewater recycle facilities. This modification authorizes the addition of two (2) 25,000
GPM cooling water supply pumps to increase the recycle rate from 180 MGD to 252 MGD.
This permit shall be effective from the date of issuance until June 30, 2010, shall void Permit No.
WQ0001105 issued November 30, 2007, and shall be subject to the conditions and limitations as
specified therein. Please pay particular attention to the monitoring requirements in this permit. Failure to
establish an adequate system for collecting and maintaining the required operational information will
result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within thirty (30) days following receipt of
this permit. This request must be in the form of a written petition, conforming to Chapter 150B of the
North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made this permit shall be final and binding.
AQUIFER PROTECTION SECTION
1633 N;aii Service Cernev, Raleigh, Nort , Carolina 27699-1636
Locatic- 2728 Capital Boulevard, Raleigh, Forth Carolina 27604
Phonw: 919-733-3221 t FAX 1: 919-715-0588 FAX [phone] Customer Service: 1-877-623.6748
Internet mm.nmaterauality.org
Nne
a fthCarolina
Natundi,l

One set of approved plans and specifications is being forwarded to you. If you need additional
information concerning this matter, please contact Lori Montgomery at [phone] or
[e-mail].
Sincerely,
U .
�r oleen H, Sullins
cc: Beaufort County Health Department
Washington Regional Office, Aquifer Protection Section
Robert M. Chiles, PE — PO Box 3496, New Bern, North Carolina 28564
APS Central Files
LAU Files

NORTH CAROLINA
ENVIRONMENTAL ,MAN.A 44EMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
CLOSED -LOOP RECYCLE SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
PC S PHOSPHATE
Beaufort County
FOR THE
continued operation of a 180 million gallon per day (MGD) wastewater recycle system consisting of a
120-acre pond (Cooling Pond 1); a 60-acre pond (Cooling Pond 2); a 50-acre pond (Cooling Pond 1A);
bentonite slurry walls on the perimeter of the cooling ponds to prevent migration of groundwater
contaminants; the routine materials dredging of solids from the cooling ponds and depositing of the solids
on an active gypsum stack; and all associated appurtenances for the recirculation and cooling of water
from the gypsum stacks; the acid plant, the fertilizer plant, the purified acid plant, the super phosphoric
acid plant and the shipping area (acid tank farm and acid tanks and rail cars);
construction and operation of two(2) additional 25,000 GPM pumps and all associated appurtenances to
supply cooling water from Cooling Pond 1 to the phosphoric acid plants creating an additional 72,000
MGD of recirculation capacity, for a total system recycle capacity of 252 MGD;
to serve PCS Phosphate, with no discharge of wastes to the surface waters, pursuant to the application
received December 17, 2008, and subsequent additional information received by the Division of Water
Quality (Division), and in conformity with the project plan, specifications; and other supporting data
subsequently filed and approved by the Department of Environment and Natural Resources and
considered a part of this permit.
This permit shall be effective from the date of issuance until June 30, 2010, shall void Permit No.
WQ0001105 issued November 30, 2007, and shall be subject to the: following specified conditions and
limitations;
1. SCHEDULES
Upon completion of installation and prior to operation of the new pumping system., a certification (see
attached form.) must be received from a professional engineer certifying that the permitted facility has
been installed in accordance with this permit, the approved plans and specifications, and other
supporting materials including the location of all monitoring wells as applicable. If this project is to
be cam leted in phases and partially certified ou shall retain the responsibility to track further
construction approved under the same permit, and ,shall provide a final certificate of completion once
the entire project „has been ,con1 1p eted. Mail the Certification to the Aquifer Protection Section,
Division of Water Quality, 1636 Mail Service Center, Raleigh, NC 27699-1636.
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2. The Washington Regional Office, telephone number [phone], shall be notified at least forty-
eight (48) hours in advance (excluding weekends and holidays) of operation of the new pumping
system so that an in -place inspection can be made. Such notification to the regional supervisor shall
be made during the normal office hours from' 3:00 a.r until 5:00 p.m. on Monday through Friday,
excluding State Holidays.
No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note that Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
II. PERFORMANCE STANDARDS
The closed -loop recycle system shall be effectively maintained and operated at all times so that there
is no discharge to the surface waters, nor any contravention of groundwater or surface water
standards. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions due to improper operation and maintenance, the Permittee shall take immediate
corrective actions including those actions that may be required by the Division, such as the
construction of additional or replacement wastewater treatment, recycle, or disposal facilities.
2. The issuance of this permit shall not relieve the Per:m.ittee of the responsibility for damages to ground
or surface waters resulting from the operation of this facility. Since this is a North Carolina permitted
non -discharge process wastewater system, 40 CFR 418.12(b) does not apply.
3. The facilities permitted herein must be constructed according to the following setbacks:
a. The setbacks for treatment and/or storage units shall be as follows (all distances in feet):
i. Surface waters: 50
ii. Any well with the exception of a Division approved groundwater monitoring well: 100
iii. Any property line: 50
4. The compliance boundary for the disposal system is specified by rules in 15A NCAC 02L,
Groundwater Classifications and Standards. This disposal system was individually permitted on or
after December 30, 1983; therefore, the compliance boundary is established at either 250 feet from
the waste disposal area, or 50 feet within the property boundary, whichever is closest to the waste
disposal area. An exceedance of groundwater standards at or beyond the compliance boundary is
subject to remediation action according to 15A NCAC 02L .0106(d)(2) as well as enforcement
actions in accordance with North Carolina General Statute 143-215.6A through 143-215.6C.
5. The review boundary is established around the disposal systems midway between the compliance
boundary and the perimeter of the waste disposal area. Any exceedance of standards at the review
boundary shall require action in accordance with 15A NCAC 02L .0106.
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III. OPERATION AND MAINTENANCE RE UIREMENTS
1. The facilities shall be properly maintainer and op,;tated at all times. The facilities shall be effectively
maintained and operated as a non -discharge system to prevent the discharge of any wastewater
resulting from the operation of this facility. The Permittee shall maintain an Operation and
Maintenance Plan pursuant to 15A NCAC 02T .1007 including operational functions, maintenance
schedules, safety measures, and a spill response plan.
2. Upon classification of the wastewater treatment and closed -loop recycle facilities by the Water
Pollution Control System Operators Certification Commission (WPCSOCC), the Permittee shall
designate and employ a certified operator to be in responsible charge (ORC) and one or more certified
operator(s) to be back-up ORC(s) of the facilities in accordance with 15A NCAC 08G .0200. The
ORC shall visit the facilities in accordance with 15A NCAC 08G .0200 or as specified in this permit
and shall comply with all other conditions specified in these rules.
3. Public access to the wastewater treatment equipment, wastewater storage structure(s), and closed -loop
recycle system shall be controlled.
4. The residuals generated from these treatment facilities must be disposed / utilized in accordance with
15A NCAC 02T .1100. The Permittee shall maintain a residual management plan pursuant to 15A
NCAC 02T. 1008.
5. Diversion or bypassing of untreated wastewater from the treatment facilities is prohibited.
6. No wastewater other than that approved by this permit shall be disposed of in the cooling ponds or
allowed to enter the recycle system. A permit amendment is required from the Division of Water
Quality to add any new sources of wastewater. The make-up to the recirculating system is
stormwater and/or mine process generated wastewater, which is defined in 40 CFR 436.181 e.
7. Freeboard in the cooling ponds shall not be less than two (2) feet at any time.
8. A waste -level gauge, to monitor waste levels in the cooling ponds, shall be provided. This gauge
shall have readily visible permanent markings indicating the maximum liquid level at the top of the
temporary liquid storage volume, minimum liquid level at the bottom of the temporary liquid storage
volume, and the lowest point on top of the dam elevations.
9. Solids removal in Cooling Pond 1 shall be limited to a depth of 7.5 feet msl and solids removal in
Cooling Pond 2 shall be limited to a depth of 7.0 msi.
10. Dredging of gypsum solids from the cooling pond(s) is approved using either methods of wet
dredging to the active gypsum stack or by dry excavation and track hauling to the reclamation
gypsum stack. The ultimate disposal of gypsum from the PCS Phosphate (Aurora) gypsum stacks is
through the gypsum/clay blend system into a mine reclamation area.
11. At least thirty (30) days prior to the start of a dredging operation, the permittee must notify the
Division's Washington Regional Office of its intentions in writing. This written notification shall
include the extent of the intended dredging and the specific gypsum pile on which the solids will be
disposed.
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1V. MONITORING AND REPORTING REOUIItEMENTS
Any monitoring (including groundwater, surface water, soil or plant tissue analyses) deemed
necessary by the Division to ensure surface and ground water protection will be established and an
acceptable sampling reporting schedule shall be followed.
2. All laboratory analyses for effluent, ground waters, or surface waters shall be made by a laboratory
certified by the Division for the required parameter(s) under 15A NCAC 02H .0800.
3. Freeboard (waste level to the lowest elevation on the top of the embankment) in the cooling ponds
shall be recorded weekly. Freeboard recording results shall be maintained at the facility for a period
of no less than five years, and shall be made available to the Division upon request.
4. A record shall be maintained of all residuals removed from this facility. This record shall include the
name of the hauler, permit authorizing the disposal or a letter from a municipality agreeing to accept
the residuals, date the residuals were hauled, and volume of residuals removed.
The twenty-one (21) existing monitoring wells (MWI-3A, MWI-3B, MWl-4A, MWI-4B, MW1-5A,
MWI-5B, MWl-6A, MWI-6B, MW1-7A, MWI-7B, MW1-8A, and MWI-8B surrounding Cooling
Pond 1, and MW2-iAR, MW2-IBR, MW2-3A, MW2-3B, MW2-4A, MW2413, MW2-4C, MW2-
5B, and MW2-5C surrounding Cooling Pond 2) wells shall be sampled at the frequencies and for the
parameters specified in Attachment C. All mUping, well construction forms, well abandonment
forms, and momtormiz data shall refer to the permit n _ _ umber and „the well nomenclature as provided in
, , ,
Attachment C.
6. Noncompliance Notification:
The Permittee shall report by telephone to the Washington Regional Office, telephone number (252)
946-6481, as soon as possible, but in no case more than 24 hours or on the next working day
following the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the wastewater treatment facility which results in the treatment of significant
amounts of wastes which are abnormal in quantity or characteristic, such as the dumping of the
contents of a basin or tank; the known passage of a slug of hazardous substance through the
facility, or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of
adequate wastewater treatment such as mechanical or electrical failures of pumps, aerators,
compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to
receiving waters.
d. Any time that self -monitoring information indicates that the facility has gone out of compliance
with its permit requirements.
For any emergency that requires immediate reporting (e.g., discharges to surface waters, imminent
failure of a storage structure, etc.) outside normal business hours must be reported to the Division's
Emergency Response personnel at telephone number [phone], [phone], or (919) 733-
3300. Persons reporting such occurrences by telephone shall also file a written report in letter form
within five (5) days following first knowledge of the occurrence. This report must outline the actions
taken or proposed to be taken to ensure that the problem does not recur.
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V. INSPECTIONS
1, Adequate inspection and maintenance shall be provided by the Permittee to ensure proper operation
of the subject facilities.
2, The Permittee or his designee shall inspect the wastewater treatment and disposal facilities to prevent
malfunctions and deterioration, operator errors, and discharges which may cause or lead to the release
of wastes to the environment, a threat to human health, or a nuisance. The Permittee shall keep an
inspection log or summary including at least the date and time of inspection, observations made, and
any maintenance, repairs, or corrective actions taken by the Permittee. This log of inspections shall
be maintained by the Permittee for a period of five years from the date of the inspection and shall be
made available upon request to the Division or other permitting authority.
3. Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the disposal site or
facility at any reasonable time for the purpose of determining compliance with this permit; may
inspect or copy any records that must be maintained under the terms and conditions of this permit,
and may obtain samples of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
1. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee
to an enforcement action by the Division in accordance with North Carolina General Statute 143-
215.6A to 143-215.6C.
2. This permit shall become voidable unless the facilities are constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is effective only with respect to the nature and volume of wastes described in the
application and other supporting data. No variances to applicable rules governing the construction
and / or operation of the permitted facilities are granted unless specifically requested and granted in
this permit.
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other government agencies (local, state,
and federal) that have jurisdiction. Of particular concern to the Division are applicable river buffer
rules in 15A NCAC 02B .0200, erosion and sedimentation control requirements in 15A NCAC
Chapter 4 and under the Division's General Permit NCG010000, and any requirements pertaining to
wetlands under 15A NCAC 02B .0200 and 02H .0500.
5. In the event there is a desire for the facilities to change ownership, or there is a name change of the
Permittee, a formal permit request must be . submitted to the Division on official Division fonn(s),
documentation from the parties involved, and other supporting materials as may be appropriate. The
approval of this request will be considered on its merits and may or may not be approved. The
Permittee of record shall remain fully responsible for compliance until a permit is issued to the new
owner.
6. The Permittee shall retain a set of approved plans and specifications for the life of the facilities
permitted herein.
7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority.
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The Permittee must pay the annual fee within thirty (30) days after being billed by the Division.
Failure to pay the fee accordingly may cause the Division to initiate action to revoke this permit
pursuant to 15A NCAC 02T .0105(e).
Permit issued this the 6`b day of February, 2009
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
tolcenTl. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0001105
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Permit No. WQOOO1105
February 6, 2009
ENGINEER'S CERTIFICATION
Partial Final
as a duly registered Professional Engineer in the State
of North Carolina, having been authorized to observe (periodically, weekly, fall time) the construction of
the project,
Project Name
Location and County
for the Permittee hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the construction such that the construction was observed to be built within substantial
compliance and intent of this permit, the approved plans and specifications, and other supporting
materials.
Signature
Date
Registration No.
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ATTACHMENT C — GROUNDWATER MONITORING AND LIMITATIONS Permit Number: WQOOOI I05 Version: 2.2
Monitoring wells: MWI-3A, MWI-313, MW14A, MWI-413, MWl-5A, MWI-513, MWI-6A, MWI-613, MW1-7A, MW1-713, MWI-8A, MWI-813
MW24AR, MW2-IBR, MW2-3A, MW2-313, MW24A, MW2-4B, MW2-4C, .MW2-5B, and MW2-5C
GROUNDWATER CHARACTERISTICS
GROUNDWATER STANDARDS
MONITORING REQUIREMENTS
Parameter Description - Parameter Code
Dnily Maximum
Frequency Measurement
Sample Type
Footnotes
Water level, distance from measuring point - 82546
Semi -Annual
Calculated
a, b, c
Sulfate. Total (as SO4) - 00945
250
mg/I
Semi -Annual
Grab
a
Fluoride, Total (as F) - 00951
2.0
mg/I
Semi -Annual
Grab
a
Chloride (as Cl) - 00940
250
mg/l
Semi -Annual
Grab
a
Phosphorus, Total (as P) - 00665
Semi -Annual
Grab
a
Solids. Total Dissolved- 180 Deg.0 - 70300
500
mg/l
Semi -Annual
Grab
a
pH - 00400
6.5-8.5
s.U.
Semi -Annual
Grab
a
Sodium, Total (as Na) - 00929
Semi -Annual
Grab
a
Carbon. Tot Organic (TOC) - 00680
Annual
Grab
a f
Volatile Compounds, (GC/MS) - 78732
Annual
Grab
a, d, e
Cadmium, Total (as Cd) - 01027
0.005
mg/l
Annual
Grab
a
Chromium, Total (as Cr) - 01034
0.05
mg/1
Annual
Grab
a
Lead. Total (as Pb) - 01051
0.015
mg/i
Annual
Grab
a
Nickel,'I'otal (as Ni) - 01067
0.10
mg/l
Annual
Grab
a
Selenium, Total (as Se) - 01147
0.05
mg/l
Annual
Grab
a
a. Senti-annual monitoring shall be conducted in May and November, Annual monitoring shall be conducted every November.
b. The measurement of water levels shall be made prior to purging the wells. The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement
of pH shall be made after purging and prior to sampling for the remaining parameters.
c. The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for each monitoring well. The measuring points (top
of casing) of all monitoring wells shall he surveyed relative to a common datum.
WQ0001 105 Version 2.2 Attachment C Page I of 2

d. Volatile Organic Compounds (VOC) - In November only, analyze by one of the following methods:
1. Standard Method 6230D. PQL at 0.5 pg/L or less
2. Standard Method 62101), PQL at 0.5 pg/L or less
3. EPA Method 8021, Low Concentration, PQL at 0.5 pg/L or less
4. EPA Method 8260, Low Concentration, PQL at 0.5 pg/L or less
5. Another method with prior approval by the Aquifer Protection Section Chief
Any method used must meet the following qualifications:
a. A laboratory must he DWQ certified to run any method used.
b_ The method used must, at a minimum, include all the constituents listed in Table V III of Standard Method 6230D.
c. The method used must provide a PQL of 0.5 µg(L or less that must be supported by laboratory proficiency studies as required by the DWQ Laboratory Certification Unit. Any constituents
detected above the MDL but below the PQL of 0.5 pg/L must be qualified (estimated) and reported.
e. If any volatile organic compounds (VOC) are detected as a result of monitoring as provided in Attachment C, then the Washington Regional Office Aquifer Protection Supervisor, telephone
number [phone], must be contacted immediately for further instructions regarding any additional follow-up analyses required.
f. If TOC concentrations greater than 10 mg/I are detected in any downgradient monitoring well, additional sampling and analysis must be conducted to identify the individual constituents
comprising this TOC concentration. If the TOC concentration as measured in the background monitor well exceeds 10 mg/l, this concentration will be taken to represent the naturally occurring
TOC concentration. Any exceedances of this naturally occurring TOC concentration in the downgradient wells shall be subject to the additional sampling and analysis as described above.
g. Monitoring wells shall be reported consistent with the nomenclature and location information provided in this attachment.
WQOOO 1105 Version 2.2 Attachment C Page 2 of

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