Draft Fact Sheet Aquifer Protection Permit 100381 by fat11113

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									                                                        Fact Sheet
                                                  Aquifer Protection Permit 100381
                                                     Place ID 873, LTF 47884
                                                      Significant Amendment
                                                   Frito-Lay North America, Inc.

The Arizona Department of Environmental Quality (ADEQ) proposes to issue an aquifer
protection permit for the subject facility that covers the life of the facility, including
operational, closure, and post closure periods unless suspended or revoked pursuant to
Arizona Administrative Code (A.A.C.) R18-9-A213. This document gives pertinent
information concerning the issuance of the permit. The requirements contained in this
permit will allow the permittee to comply with the two key requirements of the Aquifer
Protection Program: 1) meet Aquifer Water Quality Standards (AWQS) at the Point of
Compliance (POC); and 2) demonstrate Best Available Demonstrated Control
Technology (BADCT). BADCT's purpose is to employ engineering controls, processes,
operating methods or other alternatives, including site-specific characteristics (i.e., the
local subsurface geology), to reduce discharge of pollutants to the greatest degree
achievable before they reach the aquifer or to prevent pollutants from reaching the
aquifer.

I. FACILITY INFORMATION
   Name and Location
    Permittee’s Name:                  Frito-Lay, Inc.
    Mailing Address:                   1450 West Maricopa Highway
                                       Casa Grande, AZ 85222
    Facility Name and Location:        Frito-Lay, Inc. - Casa Grande Facility
                                       1450 West Maricopa Highway
                                       Casa Grande, AZ 85222

   Regulatory Status
   • Notice of Disposal submitted November 26, 1988
   • Aquifer Protection Permit (APP) issued on October 16, 1998, for the closure of a
      leach pit
   • APP issued on July 21, 2000, for the land application of industrial wastewater
   • Amendment application submitted on December 4, 2003
   • Notice of Violation dated April 20, 2004
   • APP issued on June 13, 2005, for a Significant Amendment
   • APP issued on March 6, 2006 for an Other Amendment
   • Frito-Lay, Inc. applied for an Other Amendment on March 9, 2006, to establish
      alert levels (ALs) and aquifer quality limits (AQLs) for total nitrogen and total
      Kjeldahl nitrogen (TKN). This amendment was issued on October 11, 2006.
   • An Arizona Pollutant Discharge Elimination System (AZPDES) permit Permit
      No. AZ0025798, for the outfall to the North Branch of the Santa Cruz Wash
      (NBSCW), issued to Frito-Lay, Inc. on June 4, 2009.
APP Fact Sheet                                                               Page 2 of 6
Frito-Lay North America
   Facility Description
   Frito-Lay, Inc. (Frito-Lay) owns and operates a snack food manufacturing facility in
   Casa Grande, Arizona. The facility has been in operation since 1984, and
   manufactures potato chips and corn chips. Frito-Lay operates a newly constructed
   industrial wastewater treatment system (IWTS) at the facility to treat process
   wastewater.     The IWTS consists of primary clarification, nitrification and
   denitrification systems, and activated sludge treatment utilizing a membrane
   bioreactor (MBR) followed by low-pressure reverse osmosis (LPRO) membrane
   process. Process wastewater treated by the new IWTS will be of high quality and
   may be recycled into the manufacturing facility. Recycling of the high quality
   effluent from the new IWTS will enable Frito-Lay to reduce water demand by 80
   percent.

   Process wastewater treated at the IWTS includes water used to clean the potatoes,
   cook and clean the corn, as well as starch water, oily wastewater, and battery
   neutralization tank overflow. Wastewater generated at the facility consists of 10,000
   gallons per day (gpd) of domestic wastewater and 590,000 gpd of industrial
   wastewater. Sanitary wastewater, laboratory wastewater, LPRO reject, and all other
   emergency discharges shall be discharged to the City of Casa Grande Publicly Owned
   Treatment Works (POTW) facility. Treated water from the MBR and the MBR in
   combination with the LPRO shall meet AWQS prior to discharge to the permitted
   AZPDES Outfall 001. The maximum allowable discharge volume to the NBSCW
   under the AZPDES permit and shall not exceed 692,187 gpd.

   During start-up of the MBR and LPRO Frito-Lay may discharge the permeate from
   both the MBR and LPRO to the Land Disposal Area (LDA) or the AZPDES outfall.
   The LDA consists of 95 acres of irrigated cropland. The entire LDA is bermed to
   contain a 10-year, 24-hour storm event. Waste activated sludge generated by the
   MBR shall not be disposed of by discharge to the LDA.

   Amendment Description
   Frito-Lay installed a new wastewater treatment system, which will consist of a
   primary clarifier, a nitrification and denitrification system and a MBR followed by
   LPRO. The treated water (permeate) will be recycled into the manufacturing facility.
   Treated water from the MBR and the MBR in combination with the LPRO may be
   discharged to the AZPDES Outfall 001.

   During the start-up process of the IWTS, Frito-Lay proposes to dispose of the MBR
   and subsequently LPRO permeate to the LDA. All other industrial discharges to the
   LDA shall cease. Sanitary wastewater, laboratory wastewater, LPRO reject and
   emergency discharges, shall be sent to the City of Casa Grande POTW facility.

   The permittee shall conduct an assessment of the groundwater at the facility and shall
   propose and install vadose zone monitoring wells as part of their compliance schedule
   requirements included in this permit amendment. The compliance schedule also
APP Fact Sheet                                                                  Page 3 of 6
Frito-Lay North America
   includes installation of POC MW-2 and ambient groundwater monitoring at this POC
   well.

II. BEST AVAILABLE DEMONSTRATED CONTROL TECHNOLOGY
    The wastewater treatment system has been designed to meet AWQS prior to
    discharge to the AZPDES Outfall 001, Permit No. AZ0025798. Process wastewater
    generated by the plant shall be treated by a newly installed IWTS that will consist of a
    primary clarifier, nitrification and denitrification system, and MBR, and may receive
    additional treatment by LPRO. The wastewater management systems and operational
    methods are included as part of the BADCT design. Sanitary wastewater, laboratory
    wastewater, LPRO reject, and all other emergency discharges shall be discharged to
    the City of Casa Grande POTW. All quality assurance and control procedures
    applicable to construction and operation of the treatment components, as approved by
    ADEQ, shall be followed.

   During the start-up Phase 1 of the new IWTS, as the treatment units become filled
   with water, partially treated wastewater (screened) may be discharged to the LDA via
   the transfer sump. The permittee shall notify ADEQ in writing of start-up within 5
   days of initial discharge to the treatment system. Phase 1 of the start-up shall last no
   longer than 30 days. The volume of discharge to the LDA shall not exceed an
   average of 432,000 gallons per day (gpd).

   During Phase 2 of start-up, partially treated water through the MBR may be
   discharged to the LDA, via the transfer sump, until the water quality meets the
   AZPDES permit requirements for discharge to the AZPDES Outfall 001. The
   volume of discharge to the LDA shall not exceed an average of 432,000 gpd and shall
   last no longer than 30 days from the date of completion of Phase 1 of system start-up.

   During Phase 3 of start-up, the wastewater will be treated through the MBR process,
   with some portion of the treated water (ranging from zero to 100%) receiving further
   treatment by the LPRO. The flow to the LDA shall not exceed an average of 432,000
   gpd and shall last no longer than 30 days from the date of completion of Phase 2 of
   system start-up.

III. COMPLIANCE WITH AQUIFER WATER QUALITY STANDARDS

   Hydrogeological Setting
   The Frito-Lay facility is located within the Eloy Sub-basin of the Pinal Active
   Management Area (AMA). According to ADWR, there are four distinct subsurface
   hydrogeologic units in this area, described in descending order below.

   The Upper Alluvial Unit (UAU)
   This unit is primarily unconsolidated sands and gravels with some interbedded finer
   sediments. Within the Eloy Sub-basin, thickness of the UAU varies from 200 to 1,000
   feet.
APP Fact Sheet                                                                Page 4 of 6
Frito-Lay North America
   Middle Silt and Clay Unit (MSCU)
   The MSCU varies in thickness from 0 to about 4,000 feet in the Eloy Sub-basin.

   Lower Conglomerate Unit (LCU)
   The LCU ranges in thickness from 50 feet to an unknown thickness in the center of
   the Eloy Sub-basin.

   Hydrologic Bedrock Unit (HBU)
   A local perched aquifer is present within the UAU in the area of the Frito-Lay
   facility. Depth to groundwater has recently (December 2007) been measured at 29.78
   feet below ground surface (bgs) (1,323.29 feet above mean sea level [amsl]).
   According to the permittee, depths to groundwater in the facility area vary from 27.8
   feet bgs to 46.4 feet bgs. Groundwater flow in the perched aquifer appears to be
   parallel to the direction of flow in the North Branch of the Santa Cruz Wash, or to the
   west-northwest.

   Monitoring and Reporting Requirements
   Routine discharge quality monitoring and daily flow monitoring shall be performed
   for the discharge from the MBR and/or LPRO to the AZPDES Outfall 001. Daily
   flow monitoring and discharge quality shall be monitored for the operational life of
   the facility. The permittee shall collect representative samples from the AZPDES
   outfall according to Section 4.2, Table 1A. The permittee shall perform discharge
   quality monitoring and daily flow monitoring of the discharge from the MBR/LPRO
   permeate during start-up of the treatment system. The permittee shall collect
   representative samples from the transfer sump according to Section 4.2, Table 1B.

   Routine groundwater monitoring is required for POC well MW-1a in accordance with
   Section 4.2, Table 2A of the permit. Ambient groundwater sampling shall be
   conducted at POC well MW-2 to establish background water quality in the new well
   in accordance with the Compliance Schedule in Section 3.0.

   Points of Compliance
   The POCs are at the following location:

    POC Locations                     Latitude                    Longitude
    Monitoring Well 1 (MW-1a)         32° 54’ 26” North           111° 48’ 14” West
    Monitoring Well 2 (MW-2)          32° 54’ 30.79” North        111° 48’ 15.9” West
    AZPDES Discharge to the
    NBSCW
    Proposed Monitoring Well at       32° 55’ 55.55” North        111° 52’ 57.14” West
    the edge of the DIA for the
    NBSCW
APP Fact Sheet                                                                Page 5 of 6
Frito-Lay North America
IV. STORM WATER AND SURFACE WATER CONSIDERATIONS
    The ephemeral and westward-flowing NBSCW is located about one-half mile north
    of the Frito-Lay, Inc. facility. The wash only flows in response to precipitation
    events, generally summer thunderstorms and winter rains. Santa Rosa Wash and
    Greene Wash are ephemeral tributaries to the Santa Cruz Wash and are located to the
    southwest of the Frito-Lay facility. The Casa Grande WWTP and the Salt River
    Project (SRP) Desert Basin electrical generating station have AZPDES permits,
    which allow discharges to the North Branch of the Santa Cruz Wash. There are no
    storm/surface water considerations for this facility. The facility is outside the 100-
    year flood plain.

V. COMPLIANCE SCHEDULE
   The following items are required in accordance with the Compliance Schedule in
   Section 3.0 of the APP:
   1. The permittee is required to submit a groundwater assessment work plan for
      ADEQ approval within 60 days of permit issuance to assess groundwater
      conditions at the site. The work plan shall include a hydrogeological report, a
      work plan for implementing components identified in the report, and a plan to
      investigate soil condition at the disposal area. Within 60 days of ADEQ approval
      of the work plan the permittee shall commence work.

   2. The permittee shall submit a well location and construction diagram for POC well
      MW-2 within 30 days of permit issuance. Within 60 days of ADEQ approval, the
      permittee shall install the POC well and submit the well installation report to
      ADEQ. The permittee shall commence ambient groundwater monitoring within
      30 days of ADEQ approval of the well installation report. Within 90 days of
      completing ambient groundwater monitoring, the permittee shall submit an
      ambient groundwater monitoring report to set the ALs and AQLs for the POC
      well MW-2.
   3. Within 30 days of completion of the treatment system start-up the permittee shall
      submit a report to ADEQ summarizing the start-up discharge activities to the land
      disposal area.

VI. OTHER REQUIREMENTS FOR ISSUING THIS PERMIT

   Technical Capability
   Frito-Lay, Inc. has demonstrated the technical competence necessary to carry out the
   terms and conditions of the permit in accordance with A.R.S. § 49-243(N) and
   A.A.C. R18-9-A202(B).

   ADEQ requires that appropriate documents be sealed by an Arizona registered
   geologist or professional engineer. This requirement is a part of an on-going
   demonstration of technical capability. The permittee shall maintain technical
   capability throughout the life of the facility.
APP Fact Sheet                                                                 Page 6 of 6
Frito-Lay North America
   Financial Capability
   Frito-Lay, Inc. has demonstrated the financial responsibility necessary to carry out the
   terms and conditions of the permit in accordance with A.R.S. § 49-243(N) and
   A.A.C. R18-9-A203. The permittee is expected to maintain financial; capability
   throughout the life of the facility.

   Zoning Requirements
   Frito-Lay, Inc. is properly zoned for the permitted use and the permittee has complied
   with all Pinal County zoning ordinances in accordance with A.R.S. § 49-243(O) and
   A.A.C. R18-9-A201(B)(3).

VII.ADMINISTRATIVE INFORMATION

   Public Notice (A.A.C. R18-9-108(A))
   The public notice is the vehicle for informing all interested parties and members of
   the general public of the contents of a draft permit or other significant action with
   respect to a permit or application. The basic intent of this requirement is to ensure
   that all interested parties have an opportunity to comment on significant actions of the
   permitting agency with respect to a permit application or permit. This permit will be
   public noticed in a local newspaper after a pre-notice review by the applicant and
   other affected agencies.

   Public Comment Period (A.A.C. R18-9-109(A))
   The aquifer protection program rules require that permits be public noticed in a
   newspaper of general circulation within the area affected by the facility or activity
   and provide a minimum of 30 calendar days for interested parties to respond in
   writing to ADEQ. After the closing of the public comment period, ADEQ is required
   to respond to all significant comments at the time a final permit decision is reached or
   at the same time a final permit is actually issued.

   Public Hearing (A.A.C R18-9-109(B))
   A public hearing may be requested in writing by any interested party. The request
   should state the nature of the issues proposed to be raised during the hearing. A
   public hearing will be held if the Director determines there is a significant amount of
   interest expressed during the 30-day public comment period, or if significant new
   issues arise that were not considered during the permitting process

VIII.ADDITIONAL INFORMATION
   Additional information relating to this proposed permit may be obtained from:

   Arizona Department of Environmental Quality
   Water Quality Division – APP and Drywell Unit
   Attn: Kathryn Boland, Project Manager
   1110 W. Washington St., Mail Code 5415B-3
   Phoenix, Arizona 85007
   Phone: (602) 771- 4573

								
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