.HERCULES. October 25, 2005 CERTIFIED MAIL- RETURN RECEIPT REQUESTED CERT. NO.:

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Megan Hicks
8 years ago
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1 .HERCULES October 25, 25 Hercules ncorporated 613 West 7th Street Hattiesburg, MS 3941 ( 61 ) Fax: (61) CERTFED MAL- RETURN RECEPT REQUESTED CERT. NO.: Ms. Carla Brown Chemical Manufacturing Branch Environmental Permitting Division Mississippi Department of Environmental Quality P.O. Box 1385 Jackson, MS Dear Mrs. Brown: Re: Hercules, nc. Water Ref. No. MSP91286 Hattiesburg, Mississippi Forrest County Following recent discussions between MDEQ and Hercules ncorporated, please find the following proposed wastewater treatment plan for your concurrence. The purpose is to address wastewater issues as a result of major demolition work scheduled at the Hattiesburg, Ms., facility, and the recent applicability of OCPSF pretreatment guidelines. Attached are three schematics which outline: 1) The current wastewater treatment system; 2) A proposed phase-one wastewater system; and 3) A proposed phase-two wastewater system. Also attached are two previous letters, May 2, 25, and July 29, 25, addressing these issues. As you are aware major portions of the Hattiesburg facility have been permanently shutdown. This downsizing & scheduled demolition, resulted in a change in SC code reporting. This change, OCPSF applicability, has a toluene limit which our previous permitted discharge did not have. Additional sampling indicates the original source of toluene to be from previous identifiable operations that are no longer 111 operation. Additionally, there is apparent bleed-out from our plant effluent treatment

2 Ms. Carla Brown October 25, 25 Page 2 wastewater sludge in the mpounding Basin (LB.) and the equalization tank (ET -1 ), both of which were previously in contact with past operation wastewaters. Other sampling of the rell}ainij:lg c:urrent plant wastewater area discharges shows None l)etected analysis for toluene in the remaining combined current plant wastewater area discharges. Based upon this other sampling data, of the remaining current plant wastewater area discharges, we are proposing the following wastewater treatment plan. 1) Current wastewater treatment system - The current system utilizes the LB. for all process wastewater and potential contaminated storm water from all areas. We propose to acquire capital money for CY -26 budget to initiate the phase-one proposal outlined below. We also request the sampling for OCPSF compliance be the combination of the remaining combined current plant wastewater area discharges prior to entering the.b. Once the above ground tank is utilized, as outlined below in phase-one, the sampling for OCPSF compliance would be the tank discharge. 2) Proposed phase-one wastewater system- (3316 to 12316) Prepare a capital project (CY26) to route all remaining process wastewaters into an above ground tank, thus bypassing the LB with industrial wastewater. There will be interchangeable tanks in the system to facilitate any cleaningremoval of solidssludge. The only remaining flow to the LB. would be potential contaminated rainfall, mostly gravity flow, from the active demolition areas. This would allow the pumping of potential contaminated rainfall into the industrial sewer system until demolition is completed. Demolition is scheduled to start in November, 25 and is anticipated to finish by the end of 26. This proposal would also allow ET -1 to be taken out of service. nitial data referred to in the 7295 letter indicates taken ET- 1 out of service will reduce the toluene more than half. 3) Proposed phase-two wastewater system- (33117 to 12317) Prepare a capital project (CY27) to bypass the LB. with all rainfall which is no longer potentially contaminated once demolition is completed. This would be accomplished by completion of all scheduled demolition activities by the end of CY-26. The rainfall from these areas would then be directed to the existing storm water outfalls covered in our Storm Water Baseline General Permit. This proposal would also allow us to include taking the.b. out of service in the capital project (CY27). Taking the LB. out of service, coupled )

Based upon this other sampling data, of the remaining current plant wastewater area discharges, we are proposing the following wastewater treatment plan.

3 Ms. Carla Brown October 25, 25 Page 3 with taking ET -1 out of service, will eliminate the toluene issue in our waste water effluent discharged to the POTW. We feel this approach, w_ll.c: \\'()l!ld take both the.b. and ET-1 out of service, would be the besfapproach -going forward. f can answer any additional questions or provide any additional information, please contact Charles Jordan at Based on this information and belief formed after reasonable inquiry, the statements contained herein are true, accurate, and complete. Sincerely, HERCULES NCORPORATED ( WDL Attachments: cc: Toby Cook, MDEQ Rick Sumrall, MDEQ Jan Patton, MDEQ Roger Moore, Hercules ncorporated Charles Jordan, Hercules ncorporated

f can answer any additional questions or provide any additional information, please contact Charles Jordan at 61 584 336.

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5 WASTEWATER AREA H i!! " Sludge NONCONTACT COOUNG WATER _.,...--"' '\ '\ ( Two ') 1 t!_( Equa- \! -llintio \ D.A.. F. 1 \ hzo.tlon l ' ' ' : :! \\. '--r--" \ L L ' Bottoms,, Treated EHiuent -- Sp:or t Carb(. i RegenereHc CSJ6

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6 --- -., \...,.!- :1:7 'V,-- Nit Phase to Kymene AKO a G EJ EJ f ' El. 14 Uft Paracol HRA sa2 #3 t.ft ;Poly-Pate Station Sump on n Station sfation! \ ; Storm Water and Process Water Storm Water P-65, 56, 81 and 82 u Basin ph Mixer ET-1 to be bypassed u POlW Sump ET-1

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7 ' POiy.P! :,7;"'2-':; (";i,, ;$\ 'Vtf;1,_.,_ Neuphor Sump Pump Phase to Labtl-2 Lift Station GEJ EJ l3.. Pll. 116, 61 and 62 As demolition proceeds each of these lift stations will be routed to stonnwatar (NPDES) _1_ Storm Water Outfall Storm Water BasJn to be ken oof+rv) ph Mixer u Sump ET-1 G ET -1 to be taken out of Service Kymene 14 Uft Station Pump AKD Para col Sump Pump Storm Water and Process Water

116, 61 and 62 As demolition proceeds each of these lift stations will be routed to stonnwatar (NPDES)

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Rouge River Watershed, MI Region 5. Community Case Study ROU-1. Number of CSO Outfalls. Combined Sewer Service Area. Wastewater Treatment Capacity

Community Case Study Rouge River Watershed, MI Region 5 Number of CSO Outfalls 168 Combined Sewer Service Area 93 square miles Wastewater Treatment Capacity 1,700 mgd (primary) 930 mgd (secondary) Receiving