HomeMy WebLinkAboutLETTER-EVIRONMENTAL PROTECTIONri�55` CANNED
JOHN A. ROBBINS, P.E., DABFET, FACFEI Professional
Engineer
Creative & Technical Ca+sultant
1814 Commerce Avenue, Suite A
Vero Beach, Florida 32960
Telephone (772)562-0787 JRobb1814@aol.com Fax (772)562-1008
May 14, 2009
FL Dept. of Environmental Protection
400 N. Congress Ave., Suite 200
West Palm Beach, FL 33401-2316
Re: Allied New Technologies, Inc. (ANT)
Requested Data Submittal
Engineer's Project No. 09-103
Dear Mr. Powell:
This letter is intended to provide you with data you have requested regarding the proposed
discharge water storage tank for ANT's new bleach facility in St. Lucie County, Florida.
More specifically, you requested in our telephone discussion on May 4, 2009 that I provide you
with an opinion on the applicability of,hazardous waste regulations to the use of a discharge
water storage tank for ANT'S proposed facility.
In addition, you provided to me data for review which included examples of exemption of
permitting for elementary neutralization units (ENUs).
After our discussions, review of the data you provided to me on May 4, 2009 via email,
discussions with ANT'S in-house professional engineer/chemical engineer and discussions with
ANT'S general consultant, Culpepper, & Terpening, Consulting Engineers, I offer the follow
opinion.
The proposed discharge water storage tank for ANT'S new bleach facility is the tank which
receives backwash water from three processes and a weak brine purge stream which is integral to
the bleach production process. The bleach production process requires ultra -pure water to
prevent fouling of the membranes for the production of bleach.
f
May 14, 2009
Tim Powell, P.E.
Page Two
An ion exchange process and demineralization process along with a soft water process (pH
neutral) provide ultra -pure water feed as an integral part of the membrane bleach process. These
three processes each generate a discharge which is monitored for pH and adjusted automatically
prior to delivery to the discharge water�lstorage tank. pH adjustments occur prior to the discharge
streams entering the storage tank. The'!30,000 gallon storage tank, therefore, is not used for
chemical additions/or mixing to adjust for target pH ranges. The monitoring for pH of the ion
exchange process, soft water process and the demineralization process will occur in the process
building control room. A weak brine purge stream (pH neutral) is added to the pH adjusted
streams from the previously described three processes.
After review of the data provided regarding the applicability of the definition of an ENU, it is my
opinion the discharge water storage tank does not fall into the definition of an ENU during
normal operations.
As the ultimate disposal of the discharge water is proposed to be accomplished by deep well
injection by Fort Pierce Utilities (FPUA), the ultimate discharge will be accomplished through an
existing FDEP regulated disposal system.
i
As a quality control procedure ANT will manually test pH of the discharge water prior to
pumping it to a tanker truck for delivery jto the FPUA disposal facility. If a system malfunction
were to occur the manual pH testing in the on -site laboratory will detect pH out of range. Prior
to transferring to a transport tanker, pH adjustments will be accomplished manually by trained
personnel in the discharge storage tank. This would be considered an abnormal event.
Now with regard to abnormal events, should pH correction be required to occur manually in the
storage tank (neutralization for corrosivity), my opinion would be the storage tank is an ENU
which, in my opinion, is exempt from RCRA permitting.
In both the normal and abnormal events the tank is exempt from RCRA permitting consistent
with the data you sent to me for review.
After the tank has been tested for pH, discharge water will be transferred to a transport tanker
and delivered to the FPUA facility where it will be pH -tested again prior to the off-loading of the
discharge water to six 5,000 gallon interconnected storage tanks at the FPUA site. If, for some
reason, the tanker contents are out of required pH range, the transport tanker will be sent back to
the ANT facility for further adjustments.
After transferring the transport tanker contents to the FPUA storage tanks the discharge water
will be blended with FPUA's potable water reverse osmosis concentrate discharge and disposed
via FPUA's permitted injection well.
May 14, 2009
Tim Powell, P.E.
Page Three
I am enclosing a block diagram of the !discharge streams to the storage tank and ultimate disposal
via FPUA's injection well to assist in clarification of the facility discharge.
i
Also enclosed for your use are two copies of a letter from ANT's in-house professional
engineer/chemical engineer, Prakash S. Lodha, P.E. who is providing requested discharge
volume data.
i
I hope the information contained herein and enclosed provides you with the data you have
requested.
Should you require further inforinatiot i or further clarification, please call.
I
Very truly yours,
t
John A. Robbins, P.E.
JA/mh
cc: Allied New Technologies, Inc. (ANT)
Jim Palmer
Prakash S. Lodha, P.E.
Dan Bandklayder, Esq.
Steven Doyle, P.E
Enc.
SHEET No. t t
I of I
ANT'S
SOFT WATER
DISCHARGE
MAXIMUM DAILY w
PROCESS FLOW -21,600 gpd o
(pH NEUTRAL) 4
DEMINERALIZER w
PROCESS WITH ANT'S 30,000 a
pH CONTROL GALLON
DISCHARGE
MANUAL pH W
ION EXCHANGE WATER TESTING 0. �
PROCESS WITH STORAGE LOCATION z
pH CONTROL TANK m
m
WEAK BRINE 13
PURGE ® ® ® a
(pH NEUTRAL) z
I� _
ANT'S 3
TRANSPORT
ALLIED NEW TECHNOLOGIES (ANT) VEHICLE
BLEACH PRODUCTION FACILITY FPUA'S SIX
5,000 ,
- - - - - -- --- -- - — GALLON - - - - -
FPUA'S REVERSE OSMOSIS DISCHARGE MANUAL pH
WATER TREATMENT WATER TESTING o
FACILITY STORAGE LOCATION W
TANKS W
Q zou
QH u
FPUA'S IW-1 INJECTION WELL -'
F+
BLOCK DIAGRAM OF ALLIED'S DISCHARGE WATER
STORAGE TANK AND FPUA'S CONCENTRATE DISPOSAL VIA
FPUA'S INJECTION WELL
N.T.S.
JOHN A. ROBBINS, P.E.
W
UAQa
OO�Q
FL. REG. NO. 32038