Document 71d85BzpnYKQw0bQprba4GDb8

United States Environmental Protection Agency Region 4 Enforcement and Compliance Assurance Division Water Enforcement Branch 61 Forsyth Street, SW Atlanta, Georgia 30303 New-Indy Catawba, LLC Industrial Wastewater Treatment System 5300 Cureton Ferry Road Catawba, South Carolina NPDES Permit Number: SC0001015 Compliance Evaluation Inspection: April 26 - 27, 2021 Reconnaissance Inspection with Sampling Diagnostic: May 25 - 26, 2021 Compliance Evaluation Inspection Project No. CV-SC0001015-042621 Reconnaissance Inspection Project No. CV-SC0001015-052621 COMPLIANCE EVALUATION INSPECTION and RECONAISSANCE INSPECTION REPORT New-Indy Catawba, LLC Table of Contents I. INTRODUCTION ................................................................................................................................... 3 II. PARTICIPANTS ..................................................................................................................................... 3 III. FACILITY DESCRIPTION ..................................................................................................................... 3 IV. BACKGROUND...................................................................................................................................... 5 V. INSPECTION PROCEDURES ................................................................................................................. 5 VI. FINDINGS AND CONCLUSIONS......................................................................................................... 6 VI. PERMIT REVIEW................................................................................................................................... 8 VII. RECORDS AND REPORTS .................................................................................................................. 8 VIII. FLOW MEASUREMENT..................................................................................................................... 8 IX. SAMPLING REVIEW ............................................................................................................................. 8 X. DISCUSSION............................................................................................................................................ 9 XI. ATTACHMENTS .................................................................................................................................... 9 2 of 9 COMPLIANCE EVALUATION INSPECTION and RECONAISSANCE INSPECTION REPORT New-Indy Catawba, LLC I. INTRODUCTION Representatives of the United States Environmental Protection Agency (EPA) and the South Carolina Department of Health and Environmental Control (SCDHEC) conducted a Compliance Evaluation Inspection (CEI) on April 26 and 27, 2021, on the New-Indy Catawba, LLC (New-Indy) facility's Industrial Wastewater Treatment System (IWTS). A follow-up Reconnaissance Inspection (RI) with Sampling Diagnostics was conducted by the EPA on May 25 and 26, 2021. New-Indy operates and maintains the associated IWTS. New-Indy Containerboard is New-Indy's corporate owner, and their office is located at 3500 Porsche Way, Suite 150, Ontario, California. Both inspections were conducted under the authority of Section 308 of the Clean Water Act (CWA), as amended. This report provides a summary of the inspections. EPA and SCDHEC inspectors met with New-Indy representatives at the facility located at 5300 Cureton Ferry Road in Catawba, South Carolina and conducted an opening conference on April 26, 2021, followed by a walk-through of the IWTS. EPA inspectors and sampling team also met with New-Indy's Environmental Manager on May 25, 2021 to collect samples and conduct a RI to record any changes in operations or conditions of the IWTS since the CEI. SCDHEC inspectors were not onsite for the RI/sampling. A summary of findings is detailed below. II. PARTICIPANTS Key personnel participating in the CWA inspection include: Name Dennis Sayre Brad Ammons Matt Miller Sonya Johnson Bryon Amikc Pete Cleveland Daniel Mallett Steve Weber Mita Ghosh Mary Rose Position EPA Inspector EPA Inspector SCDHEC Inspector SCDHEC Inspector SCDHEC Permit Writer New-Indy Technical Manager New-Indy Environmental Manager New-Indy Legal Council EPA Legal Counsel (Water) EPA Legal Counsel (Air) Phone Number 404-562-9756 404-562-9769 803-896-0620 803-896-0620 803-898-4236 803-981-8206 803-981-8010 704-372-9000 404-562-9568 404-562-9023 Legal counsel for New-Indy and EPA only participated in the opening and closing conference for the CEI. Other participants attending the CEI opening and closing conferences that did not participate in the CEI or RI included Katherine Haile (EPA Region 5 - Air and Radiation Division (ARD)), Scott Hamilton (EPA Region 5 - ARD), and Andrew Mills (EPA Region 4 - Enforcement and Compliance Assurance Division, Air Enforcement Branch). III. FACILITY DESCRIPTION The New-Indy IWTS is an aerated lagoon system used to treat industrial wastewater produced in wood pulping and paper production, (Figure 1). The IWTS has a flow capacity of greater than 75 million gallons per day (MGD) according to the latest National Pollutant Discharge Elimination System (NPDES) permit application, dated September 27, 2019. However, the IWTS's average flow since full operational start-up in February 2021 has been approximately 25 MGD. There are 3 of 9 COMPLIANCE EVALUATION INSPECTION and RECONAISSANCE INSPECTION REPORT New-Indy Catawba, LLC four influent flow paths to the IWTS and three permitted outfalls. Permitted outfalls include Outfall 001, 01A and 01B. Outfall 001 is located at the Post-aeration Basin (Figure 2) on the banks of the Catawba River. Outfall 001 transmits all treated wastewater to the Catawba River from the #1 Holding Pond through a diffuser pipe in the Catawba River. Outfall 01A is located next to the Primary Clarifier and discharges approximately 0.06 MGD of domestic wastewater that comingles with the Primary Clarifier effluent. Outfall 01B discharges into Sludge Pond #2. Influent flow paths to the IWTS includes flow from the headworks to the Primary Clarifier, flow from the former bleaching process to Sludge Pond #2 through Outfall 01B, domestic waste through Outfall 01A, and foul condensate that is piped directly to the Aeration Stabilization Basin (ASB). Outfall 01B is no longer in use. Approximately 20 to 26 MGD of process wastewater enters the Primary Clarifier through a bar screen at the Headworks, along with stormwater runoff during rain events. Primary Clarifier effluent is currently being routed directly to the ASB through the EQ Basin Bypass Pipe and the open channel Inlet Ditch. The Primary Clarifier has a 4.7 million gallon capacity and is used to settle influent solids prior to aeration in the ASB. Sludge removed from the bottom of the Primary Clarifier is discharged into the Equalization (EQ) Basin for settling and initial dewatering. The ASB is a 64-acre aerated lagoon consisting of 52 aerators. Effluent from the ASB flows to the #1 Holding Pond by gravity then to the Post-aeration Basin for final aeration and discharge into the Catawba River through Outfall 001 using a submerged diffuser pipe, (Figure 2). Sludge removed from the EQ Basin and ASB is either hauled or piped directly to Sludge Pond #4 for dewatering and permanent storage. Figure 1. Aerial display of the IWTS. 4 of 9 COMPLIANCE EVALUATION INSPECTION and RECONAISSANCE INSPECTION REPORT New-Indy Catawba, LLC Figure 2. Post-aeration Basin, Outfall 001 and discharge diffuser pipe location. IV. BACKGROUND New-Indy took possession of the kraft pulp and paper manufacturing mill through a purchase agreement with Resolute Forest Products US, Inc- Catawba (Resolute), on or about December 31, 2018. Resolute operated the mill as a Bleached Papergrade Kraft mill for "white paper" production. New-Indy continued to operate the mill from January 1, 2019 as a white paper production mill, to September 2, 2020, at which time the mill was shut down for redesign as an Unbleached Kraft paper mill to manufacture cardboard, also referred to as "brown paper." In November 2020, New-Indy began mill start-up with intermittent operations. Full brown paper production operations began on February 1, 2021. The facility's wastewater is regulated under the CWA, 40 CFR Part 430, (Pulp, Paper, and Paperboard Point Source Category), Subpart C (Unbleached Kraft Subcategory). The white paper manufacturing process was regulated under 40 CFR Part 430, Subpart B (Bleached Papergrade Kraft and Soda Subcategory). V. INSPECTION PROCEDURES The overall objective of this CEI was to evaluate the conditions and operational performance of the IWTS and New-Indy's self-monitoring program and offer compliance assistance as needed. The objective of the RI was to discuss any operational or maintenance changes made since the April 27th CEI. Specific tasks included conducting interviews with New-Indy staff, reviewing Discharge Monitoring Reports (DMRs) and other records and conducting a site visit throughout the IWTS. 5 of 9 COMPLIANCE EVALUATION INSPECTION and RECONAISSANCE INSPECTION REPORT New-Indy Catawba, LLC VI. FINDINGS AND CONCLUSIONS Site Visit Findings: (refer to Attachment 1 for all "Photo" references) 1. The Headworks showed signs of excessive surface corrosion, but otherwise appeared to be operating as designed, (Photo 1). 2. The Primary Clarifier weirs appeared to be level and discharging uniformly; however, the Vnotches in the continuous V-notch weir were not visible due to an excessive build-up of process fibers clogging the weir (Photo 2 ). The Primary Clarifier effluent is discharged into the EQ Basin Bypass Pipe to the Inlet Ditch then to the ASB. Settled sludge from the Primary Clarifier is discharged into the EQ Basin. 3. Flow is measured from the domestic wastewater discharge at Outfall 01A using an ultrasonic flow measuring device and a Palmer-Bowlus flume, (Photo 3). The effluent was clear and flow was estimated to be approximately 25 to 50 gallons per minute. Flow from Outfall 01A is mixed with the Primary Clarifier effluent. Outfall 01A flow measurements were not verified due to the de minimus impact on the total wastewater flow entering the ASB. 4. The Primary Clarifier effluent and Outfall 01A is channeled through an open ditch to the EQ Basin Bypass Pipe located along the side of the EQ Basin. A gate valve is used to divert flow to the EQ Basin or to the EQ Basin Bypass Pipe inlet, (Photo 4). All flow from the open channel ditch was being diverted to the EQ Basin Bypass Pipe at the time of inspection. 5. The EQ Basin was approximately 75 percent full of sludge deposits. New-Indy was in the process of excavating the sludge using a long-arm excavator, (Photos 5 and 6). Dredged material is hauled to Sludge Pond #4 for dewatering and permanent storage. Flow from the EQ Basin is discharged into the Inlet Ditch. EQ Basin flow and EQ Basin Bypass Pipe flow merges at the beginning of the Inlet Ditch which flows to the ASB, (Photo 7 and 8). 6. Sludge removal operations were in progress at the inlet side of the ASB, (Photo 9). Sludge excavated from the ASB is hauled to Sludge Pond #4. 7. Foul condensate1 enters into the ASB through a 10" HDPE pipe, (Photo 10). The foul condensate discharge pipe was originally an 8" HDPE pipe. New-Indy replaced the pipe with a 10" HDPE pipe to accommodate increased flow. Increased flow of foul condensate to the ASB was the result of an internal mill configuration change. The mill's previous pollution control configuration used a steam stripper to partially remove sulfonated compounds from the foul condensate prior to discharging to the IWTS. New-Indy's Bureau of Air Quality Construction Permit (Permit number 2440-0005-DF, 5/13/2020), allows New-Indy to decommission the steam stripper and to hard pipe 100 percent of the foul condensate directly to the IWTS. 8. The ASB was approximately 80 to 90 percent covered with a sludge blanket that is believed to be 3 to 4 feet in depth, (Photos 9, 10, and 11). The ASB is approximately 20 feet in depth. There is a total of 52 aerators located throughout the ASB, 33 were operational on April 26th and 38 were operational on May 26th. New-Indy plans to repair the remaining aerators when sludge removal operations clear the sludge away from the inoperable aerators. 9. A dredging barge located at the northeast end of the ASB pumps sludge to Sludge Pond #4 through a pipe laid along the bank of the ASB, (Photo 11). The barge was not operating during the inspection. Sludge piped to Sludge Pond #4 is discharged into geotextile sludge dewatering bags. 1 Foul condensate is wastewater collected from the mill wood chip digesters and evaporators. Foul condensate contains reduced sulfur compounds, concentrated Biochemical Oxygen Demand and Volatile Organic Compounds. (EPA/310-R-02002, Profile of Pulp and Paper Industry, 2nd edition, 2002) 6 of 9 COMPLIANCE EVALUATION INSPECTION and RECONAISSANCE INSPECTION REPORT New-Indy Catawba, LLC 10. Observations on May 26th shows that New-Indy has removed approximately 70 to 80 percent of the total floating sludge from the ASB, (Photo 12). Sludge removal operations were ongoing. 11. The ASB was initially designed with floating baffles to increase retention time in the lagoon. According to the Environmental Manager, prior to New-Indy ownership, the baffles were overcome by the weight of sludge deposits in the ASB and are submerged. 12. The Post-aeration Basin receives flow from Holding Pond #1. A thick layer of foam believed to be from high concentrations of lignin and tannin, was observed in the Post-aeration Basin aeration tank, (Photo 13). Observations on May 26th shows very little foaming in the Postaeration Basin, (Photo 14), 13. Dissolved Oxygen (DO) and pH are measured continuously in the equipment room at the Postaeration Basin, (Photo 15). The DO and pH probes are located in a sampling box outside of the Post-aeration Basin equipment room. Significant foaming was observed at the sampling box on April 26th, (Photo 16). No foam build-up was observed at the sampling box on May 26th, (Photo 17). 14. New-Indy uses "PI ProcessBook" automated monitoring software for real-time monitoring of pH, DO and other processes and instruments used throughout the mill. 15. A fatty acid solution2 is used as a defoaming agent that is injected into the Post-aeration Basin at the aeration tank and at the Post-aeration Basin discharge pipe (Outfall 001), (Photos 18). 16. A submerged diffuser pipe disburses effluent from the Post-aeration Basin into the Catawba River. Brown flumes were noted in the river at the diffuser pipe, (Photo 19). Brown flumes were also noted on May 26th, (Photo 20). One location on the diffuser pipe appeared to discharge much larger volumes than other locations downstream in the pipe indicating that there may be clogging or corrosion at the diffuser outlets. Site Inspection Conclusions: The Environmental Manager explained that the ASB filled rapidly with fibrous sludge due to difficulties during plant start-up. The redesigned pulp drier and paper machine experienced start-up issues causing excess fibrous solids in the effluent which rapidly filled the ASB between January and March 2021. Concerns about compromising the integrity of the ASB berms from the weight of heavy dump trucks and excavators, as well as restricted access to Sludge Pond #4 due to the excessively wet conditions prevented New-Indy from initiating solids removal from the ASB until mid-April 2021. Aggressive sludge removal operations have facilitated repair of five aerators between April 26th and May 26th. On April 26th, inspectors noted that 19 of 52 aerators were inoperable in the ASB, and on May 26th, 14 aerators were inoperable. Most of the remaining nonoperational aerators are located on the east side of the ASB where sludge was being removed. Complaints of Hydrogen Sulfide (HsS) odors have been persistent off-site from February 1, 2020, up to the time of the CEI. On May 26th, inspectors noted that New-Indy began injecting Calcium Ammonium Nitrate (CAN) in the Inlet Ditch, just before entering the ASB. CAN injection began approximately four weeks prior to the RI conducted on May 26 and 27, 2021. The Environmental Manager stated that complaints have significantly decreased since the introduction of CAN into the treatment process. Hydrogen Peroxide (H2O2) injection, in conjunction with CAN injection, was scheduled to begin on May 28th. The introduction of CAN and H2O2 provides oxidization to the ASB influent which aids 2 Safety Data Sheet description: Hydrotreated Heavy Paraffinic Distillate, Octadecanoic acid, reaction products with triethylenetetramine, CAS No. 64742-54-7 7 of 9 COMPLIANCE EVALUATION INSPECTION and RECONAISSANCE INSPECTION REPORT New-Indy Catawba, LLC conversion of sulfides to sulfates. Sulfates are less likely to produce HsS. Repairing the remaining nonoperational aerators should also aid in reducing HsS emissions. VI. PERMIT REVIEW NPDES permit number SC0001015 was issued to Resolute Forest Products, Inc. on July 27, 2009, with an effective on October 1, 2009. The permit expired on September 30, 2014. New-Indy is currently operating under an administratively continued NPDES permit. The permit was modified, effective on January 1, 2019, to reflect the change in ownership. The administratively continued permit was issued to reflect CWA requirements for pulp and paper mills using the Bleached Papergrade Kraft process and is not reflective of the Unbleached Kraft process. New-Indy submitted a permit application to SCDHEC on, or about September 27, 2019, which included the new Unbleached Kraft process. VII. RECORDS AND REPORTS EPA's Compliance History Online1(ECHO), located at www.echo.epa.gov, is a public website repository for data and displays compliance history of facilities, including reported DMR data, inspections, enforcement activity, and other relevant information. The EPA reviewed New-Indy's DMR data from January 1, 2018 to March 31, 2021. Records indicate that New-Indy, and Resolute prior to the transfer of ownership, has been in compliance with NPDES permit effluent limits for the period reviewed with exception of a fecal coliform violation at Outfall 01A for the month of November 2020. Inspectors reviewed laboratory reports, chain-of-custody (COC) sheets used for on-site lab testing of biochemical oxygen demand (BOD5), and total suspended solids (TSS), for samples analyzed at the New-Indy laboratory, as well as COC sheets for ammonia samples collected by Shealy Environmental Services, Inc. Testing methods were in accordance with 40 CFR Part 136. Inspectors also verified calculations used to calculate Ultimate Oxygen Demand. No discrepancies were noted, with exception of the January 2020 COC which did not annotate the location being sampled. New-Indy uses NCASI3 Technical Bulletin (TB) 803 (May 2000), Method 71.01 to measure effluent color. The NPDES permit prescribes NCASI TB 253. TB 803 is an update of procedures outlined in TB 253 for the measurement of color in pulp mill wastewaters. VIII. FLOW MEASUREMENT Flow discharged from Outfall 001 is measured using a Fischer-Porter magnetic flowmeter. Calibration is performed annually. IX. SAMPLING REVIEW Sample results from samples collected during the RI will be sent in a separate report from the EPA Region 4 Laboratory Services and Applied Science Division. The EPA inspectors observed an individual volume sample collected from the composite sampler located at Outfall 001. The composite sampler pulled 118ml of effluent, well over the 100ml minimum recommended. 3 NCASI - National Council for Air and Stream Improvement 8 of 9 COMPLIANCE EVALUATION INSPECTION and RECONAISSANCE INSPECTION REPORT New-Indy Catawba, LLC New-Indy laboratory analyzes samples for color, BOD5 and TSS. DO and pH are monitored continuously, as described above. Shealy Environmental Services collects samples and analyzes effluent for all other NPDES permit required parameters. New-Indy no longer collects samples for constituents listed under Outfall 01B in the NPDES permit. Outfall 01B is no longer in use. X. DISCUSSION IWTS Configuration: The current IWTS is not operating in a configuration approved by SCDHEC in the most current NPDES permit or through any NPDES permit modification. However, prior to New-Indy ownership, Resolute obtained a Wastewater Construction Permit, enclosed as Attachment 2 (Wastewater Construction Permit No. 20098-IW and Wastewater Construction Application Package), that allowed Resolute to modify the existing EQ Basin and sludge dewatering system and to conduct a pilot study aimed at increasing the efficiency of sludge management. The current operating configuration conforms to the Wastewater Construction Permit, issued on April 25, 2017 and is shown in Figure 2 of Attachment 2. The permit application applicable to the current NPDES permit show that the Primary Clarifier sludge underflow was pumped directly to Sludge Pond #4 for dewatering and decant from Sludge Basin #4 flowed by gravity to the EQ Basin. Section 2.2 of Attachment 2, which is the configuration currently in use, shows that the underflow from the Primary Clarifier is diverted to the EQ Basin for sludge dewatering, and Primary Clarifier overflow is diverted around the EQ Basin to the ASB Inlet Ditch through the EQ Basin Bypass Pipe. The Wastewater Construction Permit stipulates that the permittee is to obtain "Approval to Place in Operation" the configuration proposed in Attachment 2 no later than April 25, 2020. No such approval has been made by SCDHEC thus far; however, New-Indy submitted a NPDES permit modification package to SCDHEC, dated September 27, 2019, that reflects the use of the configuration and Unbleached Kraft process currently in use. Dioxin contamination: The white paper manufacturing process created deposits of dioxin in the wastewater sludge. Dioxin is a toxic byproduct of the chorine-bleaching process. Sludge removed from the treatment basins are stored in Sludge Pond #4 for permanent disposal, in accordance with the NPDES permit. New-Indy is currently in discussions with SCDHEC regarding dioxin contaminates in the sludge. Dioxin contamination and permanent sludge storage is beyond the scope of this report; however, the outcome of the discussions will likely affect the future configuration of the IWTS. XI. ATTACHMENTS 1. Inspection Photographs 2. Construction Permit No. 20098-IW and Wastewater Construction Application Package END OF REPORT 9 of 9 Attachment 1, Photographs New-Indy Catawba, LLC Photo 1. Headworks/Bar Screen Photo 2. Primary Clarifier Photo 3. Outfall 01A, domestic wastewater outfall. Photo 4. Open channel ditch directing flow from the Primary Clarifier to the EQ Basin and EQ Basin Bypass Pipe inlet. Photo 5. EQ Basin, west/influent side. Photo 6. EQ Basin, influent side, west to east. Attachment 1, Photographs New-Indy Catawba, LLC Photo 7. EQ Basin and EQ Basin Bypass Pipe outlets to the Inlet Ditch. Photo 8. Inlet Ditch from EQ Basin outlet. Photo 9. ASB northwest end new the Inlet Ditch. Excavator dredging operations in progress. Photo 10. ASB northwest end looking southsoutheast. The HDPE pipe is a 10" inlet pipe used to discharge foul condensate directly into the ASB from the process area. Photo 11. Dredging barge located on the northeast side of the ASB. Photo 12. ASB observations on May 26th shows positive effects of aggressive sludge removal. Attachment 1, Photographs New-Indy Catawba, LLC Photo 13. Post-aeration Basin interior holding tank. Photo 14. Post-aeration Basin interior, May 26th. Photo 15. Dissolved Oxygen and pH meter display. Post-aeration Basin equipment room. Photo 16. Post-aeration Basin. Sampling box indicated by the red boxed outline. Orange outline shows defoaming agent inflow. Significant foaming observed at the sampling box, indicated by red oval outline. Photo 17. Post-aeration Basin. Sampling box observed Photo 18. Defoaming agent discharge pipe, discharging on May 26th. into the Post-aeration Basin outlet to Outfall 001. Attachment 1, Photographs New-Indy Catawba, LLC Photo 19. Outfall 001 diffuser pipe location on the Catawba River. Brown flumes noted at the river surface. Photo 20: Outfall 001 diffuser pipe, May 26th. Brown flumes noted at the river surface. April 25, 2017 Wayne Griffin RESOLUTE FP US INC 5300 CURETON FERRY RD CATAWBA, SC 29704 Re: Construction Permit No. 20098-IW RESOLUTE FP US INC CATAWBA OPERATIONS EQ BASIN & SLUDGE DEWATERING IMPROVEMENTS York County Dear Mr. Griffin: Enclosed is a SC Wastewater Construction Permit for the above referenced project. Construction is to be performed in accordance with this permit and supporting engineering report, plans, and specifications approved by this Office. This system cannot be placed into operation until final approval is granted by the appropriate Bureau of Environmental Health Services (BEHS) Regional Office. Your Regional contact is Kristen L Jones, in the MIDLANDS REGION BEHS LANCASTER. This regional office should be notified when construction begins at the following address and phone number: 2475 DHEC RD, LANCASTER SC 29720, 803-285-7461. Upon completion of any construction, a letter must be submitted to the BEHS Regional Office from the registered engineer certifying that the construction has been completed in accordance with the approved plans and specifications. An inspection may then be scheduled. The BEHS Regional Office will approve the system for operation upon successful completion of this project. Sincerely, Byron M Amick Industrial Wastewater Permitting Section Water Facilities Permitting Division cc via email: Kristen L Jones, MIDLANDS REGION BEHS LANCASTER James M Kirlin, TRC Environmental Corporation Wastewater Construction Permit Bureau of Water PROJECT NAME: RESOLUTE FP US INC - CATAWBA OPERATIONS EQ BASIN & SLUDGE DEWATERING IMPROVEMENTS COUNTY: YORK PERMISSION IS HEREBY GRANTED TO: RESOLUTE FP US INC Catawba Operations 5300 Cureton Ferry Rd Catawba SC 29704 for the construction of an upgrade to an existing wastewater treatment plant in accordance with the construction plans, specifications, engineering report and the Construction Permit Application signed by James M Kirlin, Registered Professional Engineer, S.C. Registration Number: 19829. PROJECT DESCRIPTION: Modification of the existing Equalization (EQ) Basin and Sludge Dewatering system. See Page 2. The effluent will be discharged to the Catawba River at a daily average rate of 25,000,000 (no new flow) gallons per day. The effluent concentrations of those constituents the wastewater treatment system is designed to remove or reduce are contained in NPDES Permit #SC0001015. CONDITIONS: See page 3. In accepting this permit, the owner agrees to the admission of properly authorized persons at all reasonable hours for the purpose of sampling and inspection. This is a permit for construction only and does not constitute DHEC approval, temporary or otherwise, to place the system in operation. An Approval to Place in Operation is required and can be obtained following the completion of construction by contacting the LANCASTER EQC OFFICE at 803-285-7461. Additional permits may be required prior to construction (e.g., Stormwater). PERMIT NUMBER: ISSUANCE DATE: EXPIRATION DATES: 20098-IW April 25, 2017 April 25, 2019 (to begin construction) April 25, 2020 (to obtain Approval to Place in Operation) _____________________________ Jeffrey P. deBessonet, P.E., Director Water Facilities Permitting Division BMA Page 2 Permit #20098-IW PROJECT DESCRIPTION The modifications, will consist of the following: installation of approximately 500 LF of 12-inch HDPE gravity piping, to divert primary sludge to a new pipe discharge outlet on the EQ Basin sludge dredging equipment dredged material conveyance piping will be provided by a third-party contractor installation of Geotextile Tubes for sludge watering, while maintaining the option to use third-party mobile sludge dewatering units installation of a polymer feed system, with an 8,000-gallon holding/mix tank for the 1% polymer solution and a chemical feed pump capable of pumping up to 200 gpm installation of three finger dikes in the EQ Basin, to enable shore-based mechanical excavation replacement of two (2) existing aspirating aerators with a 75-HP and a 84-HP aspirator aerators. all associated piping and appurtenances The existing process wastewater treatment system which consists of: Bar Screens a 275-foot diameter Primary Clarifier a 31 acre, 840 acre-foot (approx. 275 million gallons) Sludge Basin (No. 1 Sludge Basin) a 16.3 acre, 495 acre-foot (approx. 162 million gallons) Sludge Basin (No. 2 Sludge Basin) a 16.2 acre, 55 million gallon Equalization (EQ) Basin (aka No. 3 Sludge Basin) a 64 acre, 375 million gallon Aerated Stabilization Basin (ASB) a 132 acre, 1675 million gallon effluent Holding Basin (No. 1 Holding Basin) a 160 acre, 1400 million gallon effluent Holding Basin (No. 2 Holding Basin) a 80 foot long by 40 foot wide by 35 foot deep concrete Post Aeration Basin with three (3) aerators (75- HP surface aerator, 75-HP aspirator aerator and 84-HP aspirator aerator) and a chemical defoaming feed system a 0.5 million gallon Sludge Storage Tank sludge removal and dewatering system a 89 acre, 3280 acre-feet Sludge Basin (No. 4 Sludge Basin) a Color Removal System, which consists of four (4) 3,000 gallon Alum/Cationic Polymer storage tanks, one 8,000 gallon Acid storage tank, one 3,000 gallon Polymer mix tank, one 3,000 gallon Polymer Day tank, one 20,000 gallon coagulant mix tank, one 20,000 gallon Flocculent mix tank, one circular (70 ft. Dia.) Dissolved air flotation clarifier, and one 12,000 gallon sludge tank a lined 84 acre 2-Cell Temporary Wastewater Storage Basin (No. 5 Sludge Basin; aka Dove Pond) an effluent diffuser system (which consists of three (3) 100 foot sections of HDPE piping with each sections diameters being 48 inches, 36 inches, and 30 inches, fifty-one (51) 8-inch diffuser check valves as nozzles spaced equally along the diffuser) all associated piping and appurtenances * Items in bold are new to the overall system Page 3 Permit #20098-IW PROJECT DESCRIPTION The treated sanitary wastewater enters the process wastewater system at the primary clarifier overflow structure. The existing sanitary wastewater treatment system which consists of: two (2) in-ground in-series digester/settling tanks a chlorine contact chamber located at the end of the second tank of the series mechanical agitator a 1150-gallon hypochlorite solution storage poly-tank with secondary containment a metering chemical feed pumps an 8-inch Palmer-Bowlus Flume flow measuring device all associated pumps, piping and appurtenances CONDITIONS 1. This Permit supersedes the following Permits to Construct: 136 issued March 6, 1957, 287 issued June 20, 1960, 1138 issued November 8, 1967, 1660 issued August 21, 1970, 4519 issued March 29, 1977, 4672 issued June 14, 1977, 5864 issued December 1, 1978, 12670 issued October 20, 1986, 15045 issued March 8, 1989, 16745 issued October 24, 1990, 17706-IW issued July 18, 1994, 18010-IW issued July 5, 1996, 18209-IW issued October 22, 1997, 18220-IW issued December 8, 1997, 18395-IW issued June 1, 1999, 18449-IW issued November 8, 1999, 18535-IW issued August 21, 2000, 19109-IW issued April 5, 2007, 19148-IW issued September 19, 2007 and 19349-IW issued January 29, 2010. 2. All waste oil and solid and hazardous waste shall be properly disposed of in accordance with the rules and regulations of the Bureau of Land and Waste Management of SCDHEC. 3. Resolute has used mobile sludge dewatering systems provided by a third-party contractor in the past and may continue to use third-party owned dewatering equipment. The owner of the mobile dewatering equipment must have a DHEC issued Wastewater Construction Permit for the mobile equipment, and must receive a written approval from the Bureau of Water to use the equipment at the site. 4. In accordance with Regulation 61-67, Standards for Wastewater Facility Construction, all wastewater treatment facilities shall be closed out within one hundred eighty (180) days when the facility is closed or the effluent disposal permit is inactivated, terminated or revoked, unless otherwise determined by the Department. Closure of wastewater treatment facilities necessitates the submittal of a closure plan and approval of the plan by the Department in accordance with R.61-82 prior to closure of any wastewater treatment unit(s).