WQ0001105_Final Permit_20140325

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
March 25, 2014
Steven A. Beckel, General Manager
PCS Phosphate Company, Incorporated
1530 NC Highway 3065
Aurora, North Carolina 27806-9245
Subject: Permit No. WQ0001105
Cooling Pond Closed Loop
Recycle System
PCS Phosphate - Aurora
Beaufort County
Dear Mr. Beckel:
In accordance with your permit renewal request received December 13, 2013, we are forwarding
herewith Permit No- WQOOOII05 dated March 25, 2014, to the PCS Phosphate Company for the
continued operation of the subject wastewater treatment and closed-loop recycle facilities. Please note
that this renewed permit shall become effective on July 1, 2014 (i.e. the day after the expiration date of
the existing permit), which differs from the date of this letter.
This permit shall be effective from July 1, 2014 until June 30, 2019, shall void Permit No.
WQOOO1105 issued February 6, 2009, and shall be subject to the conditions and limitations as specified
therein. Failure to establish an adequate system for collecting and maintaining the required operational
information shall result in future compliance problems.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall 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 at 6714 Mail
Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and
binding.
If you need additional information concerning this permit, please contact Alice M. Wessner at
[phone] or [e-mail].
Sincerely,
�,/hom�A.eeder
cc: Beaufort County Health Department
Washington Regional Office, Water Quality Regional Operations Section
Permit File WQ0001105
Notebook File WQ00011405
WATER -QUALITY PERMITTING SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Locathn: 512 N. Salisbury St.. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: htto:!loortal.ncdenr.o[l/weblwa
An Equal opportunity 1 Affirmative Action Employer

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT 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
PCS Phosphate Company, Inc.
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 IA);
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 faun and acid tanks and rail cars);
construction and operation oftwo(2) additional 25,000 GPM pumps and all associated appurtenances to
supply cooling water from Cooling Pond I 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 13, 2013, 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 July 1, 2014 until June 30, 2019, shall void Permit No. WQ0001105
issued February 6, 2009 and shall be subject to the following specified conditions and limitations:
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I. SCHEDULES
1. 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 Rule 15A
NCAC 02T .0105(4) requires an updated site map to be submitted with the permit renewal
application.
H. PERFORMANCE STANDARDS
I. The subject non -discharge facilities shall be effectively maintained and operated at all times so 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 Division required actions, such as the construction of additional or
replacement wastewater treatment or recycle facilities.
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or
surface water resulting from the operation of this facility.
3. All wells constructed for purposes of groundwater monitoring shall be constructed in accordance with
15A NCAC 02C .0108 (Standards of Construction for Wells Other than Water Supply), and any other
jurisdictional laws and regulations pertaining to well construction.
4.
5. The compliance boundary for the disposal system shall be specified in accordance with I5A NCAC
02L .0107(b). This disposal system was individually permitted on or after December 30, 1983;
therefore, the compliance boundary is established at either 250 feet from the effluent disposal area, or
50 feet within the property boundary, whichever is closest to the effluent 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.
6. In accordance with 15A NCAC 02L .0108, the review boundary is established midway between the
compliance boundary and the effluent disposal area. Any exceedance of groundwater standards at the
review boundary shall require action in accordance with 15A NCAC 02L A 106.
7. The facilities permitted herein shall be constructed according to the following setbacks:
The setbacks for storage and treatment units permitted under 15A NCAC 02H .0200 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
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III. OPERATION AND MAINTENANCE REOUCREMENTS
1. The facilities shall be properly maintained and operated 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, which at a minimum shall include operational
functions, maintenance schedules, safety measures and a spill response plan.
2. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non -discharge facilities, in accordance with 15A NCAC 08G .0200 the
Permittee shall designate and employ a certified operator in responsible charge (ORC) and one or
more certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in
accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the
previously cited rules.
3_ Public access to the wastewater treatment facilities and closed-loop recycle system shall be
prohibited.
4. The residuals generated from the wastewater treatment facilities shall be disposed or 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 or partially treated 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
Resources to add any new sources of wastewater. The makeup water 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 feet at any time.
8. A gauge to monitor waste levels in the cooling ponds shall be provided. This gauge shall have readily
visible permanent markings, at inch or tenth of a foot increments, indicating the following elevations:
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.
9. Solids removal is Cooling Pond I 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 MSL.
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 andtruck 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.
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sampling reporting schedule shall be followed.
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2. Per I5A NCAC 02H .0800, a Division certified laboratory shall conduct all laboratory analyses for
the required effluent, groundwater or surface water parameters.
3. Freeboard (i.e., waste level to the lowest embankment elevation) in the cooling ponds shall be
measured to the nearest inch or tenth of a foot, and recorded weekly. Weekly freeboard records 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. The twenty-one (21) existing monitoring wells (MW1-3A, MWl-313, MW14A, MWI-4B, MW1-5A,
MWI-5B, MWI-6A, MWi-6B, MW1-7A, MW1-7B, MWI-8A, and MWI-8B surrounding Cooling
Pond 1, and MW2-IAR, MW2-IBR, MW2-3A, MW2-3B, MW2-4A, MW24B, MW2-4C, MW2-
513, and MW2-5C surrounding Cooling Pond 2) shall be sampled after construction and within 3
months prior to initiating non -discharge disposal operations. Monitoring wells shall be sampled
thereafter at the frequencies and for the parameters specified in Attachment C. All mapping, well
construction forms well abandonment forms and monitoring data shall refer to the 12ermit number and
the well nomenclature as pmvided in Attachment C.
5. Two copies of the monitoringwell sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW -59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form (GW -
59) shall include this permit number, the appropriate well identification number, and one GW -59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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 facility resulting in the treatment of significant amounts of wastes that is
abnormal in quantity or characteristic, including the known passage of a hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons,
rendering the facility incapable of adequate wastewater treatment.
c. Any facility failure resulting in a by-pass directly to receiving surface waters.
d. Any time self-monitoring indicates the facility has gone out of compliance with its permit
limitations.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].
Persons reporting such occurrences by telephone shall also file a written report in letter form within
five days following first knowledge of the occurrence. This report shall outline the actions taken or
proposed to be taken to ensure the problem does not recur.
V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
wastewater treatment and recycle facilities.
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2. The Permittee or their designee shall inspect the wastewater treatment and recycle facilities to prevent
malfunctions, facility deterioration and operator errors resulting in discharges, which may cause the
release of wastes to the environment, a threat to human health or a public nuisance. The Permittee
shall maintain an inspection log that includes, at a minimum, the date and time of inspection,
observations made, and any maintenance, repairs, or corrective actions taken. The Permittee shall
maintain this inspection Iog for a period of five years from the date of the inspection, and this log
shall be made available to the Division upon request.
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the wastewater treatment and recycle facilities
permitted herein at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records required to be maintained under the terms and conditions of this
permit, and may collect groundwater, surface water or leachate samples.
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to
an enforcement action by the Division in accordance with North Carolina General Statutes 143-
215.6A to 143-215.6C.
2. This permit shall become voidable if the permitted facilities are not constructed in accordance with
the conditions of this permit, the Division approved plans and specifications, and other supporting
documentation.
3. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, Division approved plans and specifications, and other supporting documentation. No
variances to applicable rules governing the construction or operation of the permitted facilities are
granted, unless specifically requested and approved in this permit pursuant to 15A NCAC 02T
.0105(n).
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 jurisdictional government agencies
(e.g., local, state, and federal). 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 NCGO10000; any requirements pertaining to wetlands under
15A NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of
Chapter 143 of the General Statutes.
5. In the event the permitted facilities change ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be trade on official
Division forms, and shall include appropriate property ownership documentation and other supporting
documentation as necessary. The Permittee of record shall remain fully responsible for maintaining
and operating the facilities permitted herein until a permit is issued to the new owner.
6. The Permittee shall retain a set of Division approved plans and specifications for the life of the
facilities permitted herein.
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 pursuant to 15A NCAC
02T _01050).
S_ This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T.01 10.
9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein
shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b).
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10. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to
pay the annual fee accordingly shall be cause for the Division to revoke this permit pursuant to 15A
NCAC 02T .0105(e)(3).
Permit issued this the 25th day of March 2014
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
iomOAReeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0001105
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ATTACHMENT C — GROUNDWATER MONITORING AND LIMITATIONS Permit Number: WQ0001105 Version: 3.0
Monitoring wells: MW1-3A, MW1-3B, MW14A, MW1-4B, MW1-5A, MW1-5B, MW1-6A, MW1-6B, MW1-7A, MW1-7B, MWI.8A, MW1-813
MW 13 (MW2-1AR), MW 14 (MW2-IBR), MW2-3A, MW2-3B, MW24A, MW2-4B, MW24C, MW2-5B, and MW2-5C
GROUNDWATER CHARACTERISTICS
PCS Code Parameter Description
82546 Water level, distance from measuring point
GROUNDWATER STANDARDS
Daily Maximum
feet
MONITORING REQUIREMENTS
Frequency Measurement Sample Type Footnotes
Semi -Annual Calculated 1, 2, 3
40945
Sulfate, Total (as 504) -
250
mg/l
Semi -Annual
Grab
1
00951
Fluoride, Total (as F) -
2.0
mg/1
Semi -Annual
Grab
1
00940
Chloride (as CI) -
250
mg/l
Semi -Annual
Grab
1
00665
Phosphorus, 'Total (as P) -
mg/l
Semi -Annual
Grab
1
70300
00400
Solids, Total Dissolved- 190 Deg.0 -
pH -
500
6.5-8.5
mg/l
s. u.
Semi -Annual
Semi -Annual
Grab
Grab
1
1
00929
Sodium, Total (as Na) -
mg/l
Semi -Annual
Grab
1
00680
Carbon, Tot Organic (TOC) -
mg/l
Annual
Grab
1,5
78732
Volatile Compounds, (GC/MS) -
mg/l
Annual
Grab
1, 3, 4
01027
Cadmium, Total (as Cd) -
0.00175
mg/l
Annual
Grab
1
01034
Chromium, Total (as Cr) -
0.05
mg/l
Annual
Grab
1
01051
Lead, Total (as Pb) -
0.015
mg/l
Annual
Grab
1
01067
Nickel, Total (as Ni) -
0.10
mg/l
Annual
Grab
1
01147
Selenium, Total (as Se)
0.05
mg/l
Annual
Grab
1
1. Semi-annual monitoring shall be conducted in May and November; Annual monitoring shall be conducted every November.
2. 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.
WQ0001105 Version 3.0 Attachment C Pagel of 3

3. Volatile Organic Compounds (VOC) -In November only, analyze by one of the following methods:
a. Standard Method 6230D, PQL at 0.5 gg/L or less
b. Standard Method 621OD, PQL at 0.5 ltg/L or less
C. EPA Method 8021, Low Concentration, PQL at 0.5 µg/L or less
d. EPA Method 8260, Low Concentration, PQL at 0.5 pg/L or less
C. Another method with prior approval by the Water Quality Permitting Section Chief
Any method used trust meet the following qualifications:
a. A laboratory must be DWR certified to run any method used.
b. The method used must, at a minimum, include all the constituents listed in Table VIII of Standard Method 6230D.
c. The method used must provide a PQL of 0.5 gg/L or less that must be supported by laboratory proficiency studies as required by D WR. Any constituents detected above the MDL but below
the PQL of 0.5 µg/L must be qualified (estimated) and reported.
4. If any volatile organic compounds (VOC) are detected as a result of monitoring as provided in Attachment C, then the Washington Regional Office supervisor, telephone number [phone],
must be contacted immediately for further instructions regarding any additional follow-up analyses required.
5. If TOG concentrations greater than 10 mg/L 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.
6. Monitoring wells shall be reported consistent with the nomenclature and location information provided in this attachment.
WQ0001105 Version 3,0 Attachment C Page 3 of 3