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HomeMy WebLinkAboutLETTER-ST LUCIE CONSERVATION ALLIANCE VERIFIED COMPLAINTLa, Offices OERTEL, FERNANDEZ, COLE & BRYANT, P.A. TIMOTHY P. ATKINSON JEFFREY BROWN M. CHRISTOPHER BRYANT C. ANTHONY CLEVELAND TERRY COLE SEGUNDO J. FERNANDEZ SCOTT W.FOLTZ KENNETH G.OERTEL TIMOTHY J. PERRY OF COUNSEL'.50AN ED PATRICIA A. RENOVIW StLudprnlfro 301 SOUTH BRONOUGH STREET i SUITE 500 TALLAHASSEE, FLORIDA 32301 / (850)521-0700 FAX (850) 521-0720 June 2, 2009 Doug Beason Office of General Counsel Florida Department of Environmental Protection 3900 Commonwealth Boulevard Tallahassee, Florida 3239.9-3000 RE: Response to St. Lucie Conservation Alliance Verified Complaint Dear Mr. Beason: TERRY COLE tcole@ohfc.com This will address allegations raised by the St. Lucie Conservation Alliance in its Verified Complaint filed with the ;Department on May 5, 2009. The Alliance incorrectly alleges that an industrial wastewater permit modification is required for improvements to the Allied facility in St. Lucie County. The existing plant presently operates under a valid industrial wastewater permit from the Department. Below is a summary of current operations and then a description of the changes being made, which will drastically reduce the use of liquefied chlorine gas by producing bleach from salt, using state of the art membrane cell technology. mem rare ce + lant wi'1Lnot disce to surface ,or ground CURRENT OPERATIONS The existing bleach plant has been operating since 1984, producing bleach using the "batch method." Allied operates three closed -loop recycle systems at the existing plant. Two of the closed -loop recycle systems are cooling towers using potentially contaminated well water and chemicals are added to treat the water. The third system involves the treatment of process water generated from hydrostatic testing of chemical containers/cylinders that may contain heavy metals. An Industrial Wastewater Permit was originally required for the existing facility since 1) the closed -loop systems currently use potentially contaminated well water; 2) anti -scaling chemicals are added to the water obtained from wells; and 3) cleaning of containers/cylinders in the hydrostatic testing area resulted in wastewater with metal content. The facility has a current Industrial Wastewater Permit for these systems valid through 2012. Doug Beason dune 2, 2009 Page 2 NEW OPERATION The improvements to the system involve adding a state of the art bleach plant utilizing membrane cell technology (commonly referred to as a "salt to bleach" plant) rather than the older "batch method". This new ";'salt to bleach" process is recognized as an inherently safer technology by the Department of Homeland Security. Originally, the plan in the application submitted to the Department for an IW permit modification was to use well water in the new closed system. The well water would have been drawn from a surficial aquifer potentially containing contaminants. Allied subsequently imprbved the plan, paying the City of Port St Lucie to run a potable water line to the facility. lshed°will :now use my pofable water 'in tleooingtow�r ecrculaton sys. em ' All wastewater, Ion exchange, demineralization, soft water and weak brine, remaining after the process, will be contained and stored on Allied's site (see the enclosed drawing from Culpepper and Turpening, signed by Steve Doyle, a Florida PE) and then will be disposed of in a permitted POTW injection well. It will be tested both at the Allied facility and at the POTW to ensure compliance with applicable permit terms and conditions. RCRA The Verified Complaint filed with the Department erroneously alleges that mixing certain waste streams could trigger the requirement of a permit under RCRA. The mixing of these streams within the bleach process, shown on the attached diagram, is exempt from RCRA permitting. The combined stream goes to the water discharge storage tank. The Department has evaluated that issue. I have attached an opinion of John Robbins, a Florida PE, who previously provided his evaluation of that issue to the Department, concluding the discharge water storage tank is exempt from RCRA permitting. Summary Doug Beason _ J tune 2, 2009 Page 3 l Terry Cole