FUSRAP_DuPont_-_NPDES_DSW_Permit_Equivalent_INITIAL_052914.pdf

Dupont Chambers Works

Permit Equivalent

June 2014

RELEVANT STATUTES

Permit effluent limitations, monitoring requirements, and other conditions are authorized by the Federal Water

Pollution Control Act, 33 U.S.C. 1251 et seq., also known as the Clean Water Act, and the State Water Pollution

Control Act, N.J.S.A. 58:10A-1 et seq. These statutes are implemented by the National Pollutant Discharge

Elimination System (NPDES), 40 CFR Part 122, and the New Jersey Pollutant Discharge Elimination System

(NJPDES), N.J.A.C. 7:14A-1 et seq., permit programs. On page 1,736 of the New Jersey Register, in the response to comments for the May 5, 1997 NJPDES Regulations at N.J.A.C. 7:14A-1 et seq., it is stated that discharges from

Comprehensive Environmental Response Compensation and Liability Act (CERCLA) remediation projects are exempted from a NJPDES permit.

Site Overview

The U.S. Army Corps of Engineers (USACE) - Philadelphia District is conducting an environmental remediation and restoration of the DuPont Formerly Utilized Sites Remedial Action Program (FUSRAP) Chambers Works Site

(Chambers Works or Site). The Site is located in Deepwater, New Jersey. It is an active chemical manufacturing facility owned and operated by E.I. du Pont de Nemours and Company (DuPont). See the attached Site Location

Map (Figure 1).

The proposed project involves remediating contaminated soils from approximately 2 acres identified as three areas-of-concern (AOCs), Operable Unit 1 (OU 1), consisting of AOC 1 and AOC 2, and Operable Unit 3 (OU 3), consisting of AOC 6. The Contaminants of Concern (COCs) are uranium (U), including U-234, U-2:35, and U-238, as well as Thorium (Th-230) and Radium (Ra-226). Based on review of the data contained in the Remedial

Investigation (Rl) Report [USACE and Cabrera, June 2011], as well as subsequent groundwater sampling events

(USAGE, July 2012 and January 2014), soil containing chemical constituents coal tar/coal tar distillates, metals, volatile organic compounds (VOC), semi-VOCs (SVOC), polycyclic aromatic hydrocarbons (PAH), etc.

commingled with FUSRAP material in excess of 65 picocuries per gram (pCi/g) of total uranium will be encountered during remediation.

The site contacts are Steve Creighton, U.S. Army Corps of Engineers-Philadelphia District, 856-794-9925, and

Linda Range, Case Manager, NJDEP, 609-984-6606. Information is also listed on the EPA web-site at http://www.epa.gov/region02/waste/fschamb.htm

Project Description

This NJPDES Discharge to Surface Water (DSW) permit equivalent is being issued for the following treated groundwater and construction water generated from remediation activities:

• Groundwater from dewatering of excavation areas before excavation, during active excavation, and during backfilling operations;

• Truck and equipment decontamination; and

• Stormwater that enters excavations or that comes in contact with contaminated surfaces/equipment in the

Site Support Areas during precipitation events.

The discharge of treated groundwater and construction water will be discharged to the on-site Central Drainage

Ditch (CDD) which flows to Basin B. Basin B discharges to the Delaware River via Outfall DSN002A, which is the primary outfall used by DuPont Chambers Works manufacturing facility regulated under NJPDES DSW Permit

No. NJ0005100 .

The total excavation area is approximately 2 acres (ac) for all AOCs combined. In AOC 1, depth of contaminated http://www.epa.gov/region02/waste/fschamb.htm

June 2014 soil ranges from 4' to 8' below ground surface, approaching the A/B Aquitard with water depth at 4' to 7.4'; in

AOC 2, it ranges from 4' to 12' below ground surface, with water table located between 4' and 11'; and in AOC 6, it ranges from 4' to 8' below ground surface, with the water table located between 7.7' and 10.7' below ground surface. All the excavated areas will be backfilled with clean fill and restored to its original condition and grade.

The USACE has determined by conservative estimates/calculations that the FUSRAP groundwater flows that will require treatment will not exceed 62 gpm for AOC 2, and 15 gpm each for AOC 1 and AOC 6. For AOC 2, dewatering via trenches, sumps, and/or well points is planned. For AOC 1 and AOC 6, trenches/sumps will be used for excavation dewatering.

The estimated 24-hour dry-weather (baseline) flow for each AOC is summarized in Table 1 below.

Table 1: Baseline Dry-Weather Construction Water Flows

AOC AOC 6 AOC 1 AOC 2

Excavation and Dewatering Period

July 2014 to Oct. 2014 Aug. 2014 to Nov. 2014 Sep. 2014 to Feb. 2015

Backfill Period Sep. 2014 to Oct. 2014 Nov. 2014 Nov. 2014 to Feb. 2015

Excavation Dewatering Normal Weekday Operation Baseline Flow (gpd) (1)

21,600 21,600 89,280

Equipment Decontamination Baseline Flow (gpd)

2,400 (2) 2,400 (2) 2,400 (2)

Total Flow (gpd) 24,000 24,000 91,680

Notes:

1. gpd = gallons per day

2. This flow includes pumping from decontamination of equipment.

Table 2 summarizes the estimated wet-weather flows for the short-term, high intensity (2 -hour) and longer term, lower intensity (10 -year- 24 -hour) storm events. Adequate storage capacity will be provided for wet weather flows for processing through Construction Water Treatment Plant (CWTP). Refer to Appendices A, Band C for detailed calculations.

Table 2: Wet-Weather Construction Water Flows

AOC AOC 6 AOC 1 AOC 2

Flow for 2-hour Storm Event (gallons)

13,577 13,577 27,152

Flow for 10-yr. 24-hour Storm Event (gallons)

54,304 54,304 108,610

The project will commence with mobilization in June 2014 and is scheduled to be completed by September 2015.

Treatment System

The facility plans to use an existing CWTP from the Welsbach Superfund Site in order to treat water generated from construction activities. The CWTP will include Influent Storage Tanks (approximate 207,000 gallon capacity), an oil-water separator, a flocculation-sedimentation trailer, bag filter, pressure filter, granular activated carbon and ion exchange. Treated water is stored in multiple frac tanks with a total capacity of 168,000 gallons.

The discharge is estimated to occur from June 2014 to February 2015 on a 10 hour per day basis and 4 days per week. The discharge for AOC 2, will occur on a 24 hour per day basis for 5 months.

Spent media from the treatment system along with sludge will be disposed of by mixing with the other contaminated waste generated on site during the excavation process and disposed of with the contaminated soil at an approved offsite landfill.

June 2014

DESCRIPTION OF LIMITATIONS AND CONDITIONS SPECIFIC TO THIS PERMIT

EQUIVALENT

Monitoring for flow is required pursuant to N.J.A.C. 7:14A-13.13 and 13.14. Flow shall be monitored on a continuous basis with a metered sample type.

The Total Suspended Solids (TSS) Daily Maximum limitation of 40 mg/L is economically and technologically achievable for all dischargers based on the monitoring effluent data from other remediation discharge permits which shows average TSS levels well below the proposed limitation. The monitoring frequency shall be as stated in the permit equivalent application (see the table below).

In order to maintain a reasonable treatment efficiency level and in order to protect against pollutants which may be present in various concentrations in the effluent but where no specific numerical limitations have been imposed in this permit, the Department has imposed a limitation for Total Organic Carbon (TOC). A daily maximum limitation of 20 mg/L is applied. This limit has proven to be technologically and economically achievable based on a review of existing data from other discharges. The monitoring frequency shall be as stated in the permit equivalent application (see the table below).

The pH range of 6.0 to 9.0 standard units is being imposed. This range is routinely imposed on all wastewater discharges in the state and is technologically and economically achievable. The monitoring frequency shall be as stated in the permit equivalent application (see the table below).

Based on the permit equivalent application data, this surface water permit equivalent includes limitations and sampling requirements for VOCs, SVOCs, Metals, Cyanide, Pesticides, Acids and PCBs. The limitations are in accordance with N.J.A.C. 7:14A-12, Appendix B-Effluent Standards for Site Remediation Projects. The monitoring frequency shall be as stated in the permit equivalent application (see the table below).

Radionuclides

Based on the permit equivalent application data, radionuclides are contaminants of concern. Therefore, in accordance with the Bureau of Environmental Radiation (BER) requirements, effluent limitations for the following radiological parameters are included in this permit equivalent. The monitoring frequency shall be as stated in the permit equivalent application (see the table below).

Parameter Limitation Minimum Detectable Level (MDL)

Gross Alpha Radiation 15 picocuries/L 3 pCi/L (A)

Gross Beta Radiation 50 picocuries/L 4 pCi/L (B)

Radium 226 + Radium 228, Total 5 picocuries/L 1.0 pCi/L each

Uranium, Total 30 ug/L 1.0 ug/L (C)

Effluent limitations are in accordance with the Safe Water Drinking Standards (40 CFR 141.66) and are referenced in N.J.A.C. 7:9B-1.1. The radiological effluent limitations are included on the effluent limits table.

June 2014

Whole Effluent Toxicity (WET)

Section 101(a) of the Clean Water Act (CWA) establishes a national policy of restoring and maintaining the chemical, physical and biological integrity of the Nation's waters. In addition, section 101(a)(3) of the CWA and the

State's Surface Water Quality Standards (SWQS) at N.J.A.C. 7:9B-1.5(a)3 state that the discharge of toxic pollutants in toxic amounts is prohibited. Further, 40 CFR 122.44(d) and N.J.A.C. 7:14A-13.6(a) require that where the

Department determines that a discharge causes, shows a reasonable potential to cause, or contributes to an excursion above the SWQS, the permitting authority must establish effluent limits for WET. In order to satisfy the requirements of the CWA, the State’s SWQS and the NJPDES Regulations, the need for a water quality based effluent limitation (WQBEL) for WET was evaluated for this discharge.

There are two types of WET tests, acute toxicity testing which measures only the lethal effects (mortality) of the effluent on the test organisms, and chronic toxicity testing which measures the lethal and sublethal effects (i.e.

Growth and/or reproduction) of the effluent on the test organisms. The type of WET test required for a particular facility is determined by evaluating the mixing characteristics of the effluent (i.e. dilution factor) in the receiving water. The acute mixing zone and the chronic mixing zone are compared, and whichever results in a more stringent limit is used to regulate the discharge. While this is a permit equivalent, it is the Department's policy to include

WET conditions for all discharge to surface water permits; therefore, a WET evaluation was conducted to ensure consistency.

The Department determines if a discharge causes, shows the reasonable potential to cause, or contributes to an excursion above the narrative criteria using the factors outlined in 40 CFR 122.44(d)(1)(ii). These factors are discussed in further detail in Chapter 3, Section 3.2 and 3.3 of the Technical Support Document for Water Quality-based Toxics Control (TSD), March 1991, United States Environmental Protection Agency . If this evaluation indicates that the discharge causes, shows the reasonable potential to cause, or contributes to an excursion above the narrative criteria, the permitting authority must establish a WET limit for the discharge in accordance with 40 CFR

122.44(d)(1)(iii).

Factors which the Department considered in making a determination regarding the reasonable potential for this discharge to violate water quality standards, and the need for a WET limit for the discharge are as follows:

Facility Type: Groundwater remediations deal with the treatment and discharge of groundwater contaminated with toxic pollutants. Therefore, this type of discharge has a high potential to be toxic.

Chronic WET

WQBELs for acute and chronic WET were calculated in accordance with N.J.A.C. 7:14A-13.6 and USEPA’s TSD.

Since the discharge is to a municipal storm sewer, these limits were developed using an acute dilution factor (Dfa) of 1 and a chronic dilution factor (Dfc) of 1.

The CMC and CCC were then used to determine acute and chronic Wasteload Allocations (WLAs) consistent with

N.J.A.C. 7:14A-13.5, using a steady state model, as specified in section 5.4.1 of the TSD. Consistent with recommendations in the TSD, values of 0.3 acute toxic unit (TUa) and 1.0 chronic toxic unit (TUc) were used to interpret the narrative water quality criteria for WET contained at N.J.A.C. 7:9B-1.14(c) (see Response to

Comments 13-74 through 13-89, 29 NJR 1861, (May 5, 1997)). The acute WLA (WLAa) was translated to equivalent chronic toxic units (WLAac), to enable comparison of acute and chronic WET limits, by multiplying the

WLAa by an acute to chronic ratio (ACR) of 10.

In the absence of any acute or chronic toxicity data, the ACR was set at the default value of 10 in accordance with the TSD. The acute and chronic WLAs were then converted to an acute Long Term Average (LTAac) of 0.963 and a chronic LTA (LTAc) of 0.527, using a default coefficient of variation (CV) of 0.6, and multipliers of 0.321 and 0.527 for the acute and chronic LTAs respectively. Those multipliers are based on the 99th percentile consistent with Response to Comments 13-74 through 13-89, 29 NJR 1861 and are found on Page 102 of the TSD.

June 2014

The resultant LTAac of 0.963 and LTAc 0.527 were evaluated and the more protective (e.g. lower) value selected for translation into a daily maximum WET limit using the applicable 99th percentile multiplier, as found on Page

103 of the TSD.

The daily maximum chronic WET limit of 1.64 TUcs was then converted to a permit limitation expressed as an

IC25. The resultant applicable limitation is an IC25 ≥ 61 % effluent.

Test Species and Method

The test species method to be used for chronic testing shall be the Ceriodaphnia dubia, Survival and Reproduction

Test, 40 CFR 136.3, method 1002. Such selection is based on the freshwater characteristics of the receiving stream, N.J.A.C. 7:9B-1.5 and the Department’s “Chronic Toxicity Testing Specifications for Use in the NJPDES

Permit Program” document. This document is included as an appendix of this permit equivalent, in accordance with N.J.A.C. 7:14A-6.8, 11.2(a)2.iv., and 40 CFR 136.

Expression of Limitations

Limitations will be expressed in terms of concentration only in accordance with N.J.A.C. 7:14A-13.14(a)4. Test results shall be performed as the IC25 for each test.

The Toxicity Reduction Implementation Requirements (TRIR) are included in accordance with N.J.A.C. 7:14A-

13.17(a), 7:14A-6.2(a)5 and recommendations in Section 5.8 of the TSD. The requirements are necessary to ensure compliance with the applicable WET limitation. As included in section B.1 of the TRIR requirements, the initial step of the TRIR is to identify the variability of the effluent toxicity and to verify that a consistent toxicity problem does in fact exist.

Effluent samples for WET testing are to be collected once per 12 months as a composite sample type after the last treatment step, consistent with the collection location for other parameters.

June 2014

I. EFFLUENT LIMITATIONS FOR DUPONT CHAMBERS WORKS FORMERLY UTILIZED SITES

REMEDIAL ACTION PROGRAM (FUSRAP) SITE

There shall be no discharge of floating solids or visible foam in other than trace amounts. There shall be no visible sheen.

Samples taken in compliance with the specified monitoring requirements shall be representative of the discharge and taken after the final treatment step, prior to discharge to the Delaware River, Zone 5.

PARAMETER DISCHARGE REQUIREMENT MONITORING

REQUIREMENT

Units Minimum

Monthly

Average

Daily

Maximum

Sample

Frequency

RQL

(1)

Sample

Type

Conventional Pollutants

Flow, In Conduit or Thru Treatment

Plant GPD -- Report Report Continuous -- Metered pH SU 6.0 -- 9.0 See below -- See below

Solids, Total Suspended mg/l Report 40 See below -- See below

Carbon, Total Organic (TOC) mg/l Report 20 See below -- See below

Chronic Whole Effluent Toxicity, Ceriodaphnia dubia

Effl.

61 -- --

1/ 12

Months -- Composite

VOCs

Acrolein µg/l MR 100 See below 50 See below

Acrylonitrile µg/l MR 50 See below 50 See below

Benzene µg/l MR 7 See below 7 See below

Bromoform µg/l MR 8.6 See below 8 See below

Carbon Tetrachloride µg/l MR 6 See below 6 See below

Chlorobenzene µg/l 15 28 See below 6 See below

Chlorodibromomethane µg/l MR 8.2 See below 6 See below

Chloroethane µg/l 104 268 See below -- See below

Chloroform µg/l MR 11.4 See below 5 See below

Dichlorobromomethane µg/l MR 5 See below 5 See below

1,1-Dichloroethane µg/l 22 59 See below 23.5 See below

1,2- Dichloroethane µg/l MR 3 See below 2 See below

1,1-Dichloroethylene (ethene) µg/l MR 6 See below 6 See below

1,2-Dichloropropane µg/l 153 230 See below 5 See below

1,3-Dichloropropylene µg/l 10 20 See below -- See below

Ethylbenzene µg/l 32 108 See below 6 See below

Methyl Bromide µg/l 20 40 See below 9 See below

Methyl Chloride µg/l 86 190 See below 10 See below

Methlylene Chloride µg/l 40 89 See below 6 See below

1,1,2,2- Tetrachloroethane µg/l MR 10 See below 10 See below

Tetrachloroethylene (ethene) (PCE) µg/l MR 16 See below 9 See below

Toluene µg/l 26 80 See below 6 See below

1,2-trans-Dichloroethylene µg/l 21 54 See below 4 See below

1,1,1-Trichloroethane µg/l 21 54 See below 6 See below

1,1,2-Trichloroethane µg/l MR 12 See below 6 See below

Trichloroethylene (ethane) (TCE) µg/l MR 5.4 See below 5 See below

Vinyl Chloride µg/l 104 268 See below 10 See below

Acid Compounds

2-Chlorophenol µg/l 31 98 See below 20 See below

2,4 Dichlorophenol µg/l 39 112 See below 10 See below

2,4 Dimethylphenol µg/l 18 36 See below -- See below

4,6 Dinitro-O-Cresol µg/l MR 60 See below 60 See below

June 2014

2,4 Dinitrophenol µg/l 71 123 See below 40 See below

2-Nitrophenol µg/l 41 69 See below -- See below

4-Nitrophenol µg/l 72 124 See below -- See below

Pentachlorophenol µg/l MR 30 See below 30 See below

Phenol µg/l 15 26 See below 10 See below

2,4,6 Trichlorophenol µg/l MR 20 See below 20 See below

SVOCs

Anthracene µg/l 22 59 See below 10 See below

Benzidine µg/l MR 50 See below 50 See below

Benzo (a) Anthracene µg/l MR 10 See below 10 See below

Benzo (a) Pyrene µg/l MR 20 See below 20 See below

Benzo (b) fluoranthene µg/l MR 10 See below 10 See below

Benzo (k) fluoranthene µg/l MR 20 See below 20 See below

Bis (2-Chloroethyl) Ether µg/l MR 10 See below 10 See below

Bis (2-Chloroisopropyl) Ether µg/l 301 757 See below 10 See below

Bis (2-Ethylhexyl)Phthalate µg/l MR 36 See below 30 See below

Butyl Benzyl Phthalate µg/l MR 24 See below 20 See below

Chrysene µg/l MR 20 See below 20 See below

Dibenzo (a,h) Anthracene µg/l MR 20 See below 20 See below

1,2-Dichlorobenzene µg/l 77 163 See below 9 See below

1,3-Dichlorobenzene µg/l 31 44 See below 20 See below

1,4-Dichlorobenzene µg/l MR 28 See below 9 See below

3,3 Dichlorobenzidine µg/l MR 60 See below 60 See below

Diethyl Phthalate µg/l 81 203 See below 10 See below

Dimethyl Phthalate µg/l 19 47 See below 10 See below

Di-N-Butyl Phthalate µg/l 27 57 See below 20 See below

2,4 Dinitrotoluene µg/l MR 10 See below 10 See below

2,6 Dinitrotoluene µg/l 255 641 See below -- See below

Fluoranthene µg/l 25 68 See below 10 See below

Fluorene µg/l 22 59 See below 10 See below

Hexachlorobenzene µg/l MR 10 See below 10 See below

Hexachlorobutadiene µg/l MR 10 See below 10 See below

Hexchlorocyclopentadiene µg/l 240 480 See below 10 See below

Hexachloroethane µg/l 19 38 See below 10 See below

Indeno (1,2,3-cd) Pyrene µg/l MR 20 See below 20 See below

Isophorone µg/l MR 20 See below 10 See below

Naphthalene µg/l 22 59 See below 8 See below

Nitrobenzene µg/l 17 34 See below 10 See below

N-Nitrosodimethylamine µg/l MR 20 See below 20 See below

N-Nitrosodiphenylamine µg/l MR 20 See below 20 See below

Phenanthrene µg/l 22 59 See below 10 See below

Pyrene µg/l 25 67 See below 20 See below

1,2,4 Trichlorobenzene µg/l 68 140 See below 10 See below

Pesticides

Aldrin µg/l MR 0.04 See below 0.04 See below

Alpha-BHC µg/l MR 0.02 See below 0.02 See below

Beta-BHC µg/l 0.137 0.274 See below 0.04 See below

Gamma – BHC (Lindane) µg/l MR 0.08 See below 0.03 See below

Chlordane µg/l MR 0.2 See below 0.2 See below

4,4 DDT µg/l MR 0.06 See below 0.06 See below

4,4 DDE µg/l MR 0.04 See below 0.04 See below

4,4 DDD µg/l MR 0.04 See below 0.04 See below

Dieldrin µg/l MR 0.03 See below 0.03 See below

Alpha-Endosulfan µg/l MR 0.02 See below -- See below

June 2014

Beta-Endosulfan µg/l MR 0.04 See below -- See below

Endosulfan Sulfate µg/l 0.93 1.86 See below 0.08 See below

Endrin µg/l MR 0.04 See below 0.04 See below

Endrin Aldehyde µg/l 0.76 1.52 See below 0.1 See below

Heptachlor µg/l MR 0.02 See below 0.02 See below

Heptachlor Epoxide µg/l MR 0.4 See below 0.4 See below

Toxaphene µg/l MR 1 See below 1 See below

Metals and Cyanide

Arsenic µg/l 50 100 See below 8 See below

Cadmium µg/l 50 100 See below 4 See below

Chromium µg/l 50 100 See below 10 See below

Copper µg/l 50 100 See below 10 See below

Iron µg/l MR MR See below 10 See below

Lead µg/l 50 100 See below 10 See below

Mercury µg/l MR 1 See below 1 See below

Nickel µg/l 72 144 See below 10 See below

Selenium µg/l 50 100 See below 10 See below

Silver µg/l 25 50 See below 2 See below

Zinc µg/l 100 200 See below 30 See below

Cyanide µg/l 100 200 See below 40 See below

Dioxin

2,3,7,8-Tetrachlorodibenzo-p-Dioxin µg/l MR 0.01 See below 0.01 See below

PCBs

PCBs 1242, 1254, 1221, 1232, 1248, 1260, 1016 µg/l MR 0.5

See below 0.5

See below

Radionuclides

Gross Alpha Radiation pCi/L -- 15 See below 3 See below

Gross Beta Radiation pCi/L -- 50 (2) See below 4 See below

Radium 226+Radium 228, Total pCi/L -- 5 See below 1.0 See below

Uranium, Total µg/l -- 30 See below 1.0 See below

(1) The permittee shall ensure that analytical data is sampled at detection levels as sensitive as the

Recommended Quantitation Levels (RQL’s) for any of the above parameters limited in this individual permit equivalent.

(2) Minus contribution from K-40

GPD - Gallons per day mg/l - Milligrams per liter ug/l - Micrograms per liter pCi/L – Picocuries per liter

June 2014

I. A. MONITORING REQUIREMENTS FOR DUPONT CHAMBERS WORKS FORMERLY

UTILIZED SITES REMEDIAL ACTION PROGRAM (FUSRAP) SITE

AOC #6 Batch Treatment - Regular Treatment Operation

Sample Location Frequency Parameters

Final Treated Water Frac Tank Once per batch- assume

60,000 gallon per batch

VOCs, Acids, SVOCs, Pesticides, Metals

& Cyanide, Dioxin, PCBs Radionuclides, pH, TSS and TOC

AOC #1 Batch Treatment - Regular Treatment Operation

60,000 gallon per batch

VOCs, Acids, SVOCs, Pesticides, Metals

AOC #2 Batch Treatment - Prove Out Phase

100,000 gallon per batch

VOCs, Acids, SVOCs, Pesticides, Metals

AOC #2 Continuous Discharge - Regular Treatment Operation (1 st Week after Prove Out)

Final Treated Water Discharge pipe prior to

CDD

One per shift. Sampling for st week.

VOCs, Acids, SVOCs, Pesticides, Metals

AOC #2 Continuous Discharge - Regular Treatment Operation (2nd Week onwards till end of project)

Final Treated Water Frac Tank One per week. VOCs, Acids, SVOCs, Pesticides, Metals

Online continuous (real time) monitoring will be conducted for pH, Turbidity and Conductivity.

June 2014

Compliance Sampling During Batch Treatment Discharge: Composite sampling for all parameters except for VOC for Batch Treatment.

One grab sample will be collected from each frac tank using a bucket and all these samples will be mixed in a 55 gallon drum to make it a composite sample. This composite sample will be sent to a lab for analysis.

Sampling For VOC for Batch Treatment:

The sample for VOC will be collected from the sampling port after the last set of Ion Exchange Vessels. The sampling will be done after 2 frac tanks have been filled and during the start of filling for the 3rd frac tank. This sample will be sent to lab for analysis.

Compliance Sampling During Continuous Discharge:

During a continuous discharge process, the compliance sample for all parameters will be collected from

Monitoring Point 777A prior to discharging the treated water to the CDD.

During discharge of treated water, if the turbidity is measured as greater than or equal to 50 NTU, the water will be sent to the influent tank via the recirculation line for retreatment prior to discharge.

All test results shall be summarized in a format previously approved by the Bureau of Case Management and reported monthly to the following address within 25 days of the start of the following month after commencement of discharge and every month thereafter until the discharge is permanently terminated:

Linda Range

Department of Environmental Protection

Bureau of Case Management

Mail Code 401 05F

PO Box 420

Trenton, NJ 08625-0420

II. Reopener Clause

This bureau may modify or suspend this permit equivalent to incorporate additional limitations or monitoring requirements if deemed appropriate.

III. Suspension of Permit Equivalent

Violations of any condition of this permit equivalent shall be cause for a suspension of the permit equivalent. Upon suspension of this permit equivalent, the discharger shall cease direct discharge to surface water and take corrective actions to achieve compliance.

DOC001