ML20217A715

Forwards Addl Info Re Urls Project Re Recovery of Lagoon Sludge,Per 901107 Telcon.Info Partially Withheld

ML20217A715
Person / Time
Site:	07001113
Issue date:	11/13/1990
From:	Winslow T GENERAL ELECTRIC CO.
To:	Haughney C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML19310C907	List: ML20217A715
References
NUDOCS 9011210248
Download: ML20217A715 (17)

Text

~-

m m3..g GE Nuclear Energy Nuveat fd 8 Campo *ents Manu%:tw:ng Gene:S Hurtnc Comw PD Sw 7BC Mnengton. NC 2MC2 vs us uno November 13, 1990

Director-Office of Nuclear Material Safety and Safeguards

.U.S.

Nuclear Regulatory Commission Washington, D.C.. 20555 Attention:

Mr..C.

J. Haughney, Chief Fuel Cycle Safety Branch OWFN, Room 6D23, Mail'6H3-

Subject:

Additional Information on the URLS Project (License-Revision 26)

References:

1)'.NRC License SNM-1097, Docket 7$-1113 2). Letter, TP Winslow to RM Bernero, 5/23/90

'~

3)-Letter, TP Winslow to CJ Haughney, 8/2/90

4) Letter, TP Winslow to CJ Haughney, 8/24/90

5) Telephone Conversation, DA McCaughey, ED Flack, and RE Wilson, 11/7/90

6) Telephone. Conversation, DA McCaughey, RH Foleck,'

I DW' Brown, ED Flack,. 11/13/90

,a c

'During the referenced-telephone conversation of 11/7/90, the l

g efollowing issues were discussed that require additional j

clarification for' our Uranium Recovery of Lagcon Sludge- (URLS) 1 L

' project submittal.

1 Special' Process Commitments i

Control-of' Liquids in the Lagoon Sludge-d Geometry Control of the Product Filter Re-Precipitation-of' Leached Uranium l

-L Additional Environmental Information i

In1 response to these topics, the-following-information.is

-l "provided:

1 I

! General 1 Electric has determined portions.of the.information 4

contained in this request to.be proprietary in nature.

Therefore,.

/

-j pursuant to 10 CFR 2.790- (b), the required affidavit (Attachment

~

f 1)- trequests that the information in Attachment-2 of ~ this submittal,. which is designated'as proprietary be withheld from public disclosure.

j l

i jw2AB83 89shya3 1

1. Flff

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Director-ONMSS Novemberi13,fl990 PageL2

. Attachment 2 of:this application replaces inuits entirety

-Attachment 2'of the proprietary application provided to the NRC on.

,8/2/90.

The new information is shown in Sections'3.2.2,.3.2.3.3,

and 3;4.2.1 and is' asterisked in the right hand column. is the-process control and training commitments Eincluded as an update to Part I of--our current NRC materials

. license.

't Attachment'4 contains the additional necessary environmental-J information.

'All'line changes are identified with an asterisk in the right' hand ~

columniof:each page effected to facilitate the review.

1 As:a result of recent business considerations, the scheduled plan:-

toEintroduce uranium-bearing-' material into the URLS process has been rescheduled to the mid-part of January, 1991, as discussed with E. Flack-onL11/13/90.

1 General Electric-personnel would be pleased to discuss-this' matter further withDyou:and your staff,

-Sincerely, GE NUCLEAR ENERGY'

. pp - "$4 T. PrestoniWinslow,. Manager Licensing;&. Nuclear Materials Management l-/sbm cc:

TPW-90-153 m

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\\

Mr. C.

J. Haughney November 13, 1990 Page 1 of 5 EEEEEAL ELEEIEIE E2MEAEX AFFIDAVIT I, Wayne P.

Lewis, being duly sworn, depose and state as follows:

(1)

I am Manager, Nuclear Fuel and Components Manufacturing, General Electric Company, and have been delegated the

-function of reviewing the information described in Paragraph (2) which is sought to be withaeld and have been authorized to apply for its withholding.

.(2)

The information to be withheld is identified portions of the submittal to the NRC dated November 13, 1990, supporting an-application for permission to utilize the Uranium Recovery from Lagoon Sludge (URLS) project facility for the purpose of

-conducting uranium recovery development and processing.

(3)

In: designating material as proprietary, General Electric utilizes'the definition of proprietary information and trade secrets set.forth in the American Law Institute's Restatement of Torts, Section 757.

This definition provides:

A trade secret may consist;of any formula,-

pattern, device or compilation of information which is used in one's business and which i

gives him an opportunity to use it...A substantial element of secrecy must exist so that, except=by the use of improper means, there would be difficulty in acquiring information...Some factors to be considered in determining whether given information is one's trade secret are:

(1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of measures taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amount of effort or money expended by him in developing the information, (6) the ease or difficulty with l-which the information could be properly acquired or duplicated by others, l

l l

c

• ^

t Mr. C. J. Haughney November 13, 1990 Page 2 of 5 (4)

Some examples of categories of information which fit into the definition of proprietary information are:

(a)

Information that discloses a process, method or W

apparatus where prevention of its use by General Electric'r competitors without license from General l

Electric constitutes a competitive economic advantage 1

over other companies; (b)

Information consisting of supporting data and analyses, including test data, relative to a process, method of epparatus. the application of which provides a i

competitive economic advantage, e.g.,

by optimization or

{

improved marketability; (c)

Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment,-

installation, assurance of quality or licensing of a similar product; I

(d)

Information which reveals cost or price information, production capacities, budget levels or commercial strategies of General Electric, its customers or suppliers; (e).

Information which reveals aspects of past, present or l

future General Electric customer-funded development plans and programs of potential commercial value to General Electric;

!l (f)

Information which discloses patentable subject matter i

for which it may be desirable to obtain patent i

protection;

)

l (g)

Information which General Electric must treat as f

proprietary according to agreements with other parties.

(5)

In addition to proprietary treatment given to material 1

meeting the standards enumerated above, General Electric j

customarily maintains'in confidence preliminary and draft I

material which has not been subject to complete proprietary, technical and editorial review.

This' practice is based on j

the fact that draft' documents often do not appropriately i

reflect all espects of a problem, may contain tentative conclusions and may contain errors that can be corrected during normal review and approval procedures.

Also, until the final document is completed it may not be possible to make any definitive determination as to its proprietary nature.

D i

Mr. C. J. Haughney

. November ~13, 1990 Page 3 of 5 General Electric is not generally W1211ng to release such a document to the general public in such a preliminary form.

Such documents are, however, on occasicn furnished to the NRC staff on a confidential basis because in is General Electric's belief that it is in the pub:.ic interest for the staff to be promptly furnished with significant or potentially significant information.

Furnishing the document on a confidential basis pending completion of General Electric's internal review permits early acquaintance of the staff with the Information while protecting General Electric's potential proprietary position and permitting General Electric to insure the public documents are technically accurate and correct.

(6)

Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge.

Access to such documents within the Company is limited on a "need to know" basis and such documents are clearly identified as proprietary at all times.

(7)

The procedure for1 approval of external release of such a document typically requires review by the NF&CM staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate) and by the Legal Operation for technical content, competitive effect and determination of'the accuracy of~the proprietary designation in accordance with the standards enumerated above.

Disclosures outside General Electric are generally limited to regulatory bodies, customers and potent 1al customers and their agents, suppliers.and licensees, and then only in accordance with appropriate regulatory provisions or

. proprietary agreements.

(8)

The document mentioned in Paragraph (2) has been-evaluated in accordance with the above criteria and procedures and has been found to contain information which is proprietary and which-is customarily held in confidence by General Electric.

-(9)

The document mentioned in Paragraph (2) is classified as proprietary because it contains features of a uranium recovery process which were performed and developed at considerable expense to General Electric and which are not available to other parties.

The information is of a type customarily held in confidence by General Electric, since it reveals important features and contains valuable process l

information.

e i

l Mr. C. J.

Haughney November 13, 1990 l

Page 4 of'5 L

(10) The information in that document, to the best of my knowledge L

and belief, has consistently been held in confidence by the General Electric Company, no public disclosure has been made, and it is not available in public sources.

All disclosures to third parties have been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

(11) Public disclosure of the information sought to be withheld is likely to cause substantial harm to the competitive position of the General Electric Company and eliminate or reduce the availability of profit making opportunities because:

(a)

Such information is a significant part of a program which was developed with the expenditures of resources exceeding two million dollars.

(b)

Competitors in the fuel market lack the methods capability.and experience which General Electric has developed.

Knowing the process information in this presentation would allow them to reduce uncertainty factors.

This would cause General Electric to lose its current competitive advantage.

(c)

Research, development, engineering, analytical and other costs and expenses must be included in General Electric's fuel price.

The ability of General Electric's competitors to utilize such information i.nthout similar expenditure of' resources'would enable them to sell fuel at prices not reflecting similar cost.

J 7

Mr. C. J. Haughney November 13, 1990 Page 5 of 5 l

STATE OF NORTH CAROLINA ss:

COUNTY OF NEW HANOVER I, Wayne P.

Lewis, being duly sworn, deposes and says:

l That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information and belief, Executed at Wilmington, North Carolina, this /8 day of #vN*Te'A,

l i

1990, i

inusse,

{

lha r, i k do

v5 Wayne P. Lewis

\\g UBL\\ ) vf GENERAL ELECTPIC COMPANY

'k,fD".,."..'.cI

~..

Subscribed and sworn before me this- / 3 day of Nad*8**,

1990, in New Hanover County.

NdARYPUBLIC,

['

STATE OF NORTH CAROLINA-My Commission Expires. [

/fh

/

~]

i Dir00 tor-ONMSS November 13, 1990 Page 1 of 1 i

ATTACHMENT 3 DESCRIPTION OF PROCESS CONTROL AND TRAINING I

COMMITMENTS AFFECTING NF&CM'S CURRENT SNM-1097 LICENSE I

Page (s)

Description 8

1: hanged dates on pages 8 and 9 to reflect the date of this submittal, 11/13/90.

9 Changed to show the addition of a new page in Chapter 6.

l I-6.7 Special process control commitments for the Uranium Recovery of Lagoon Sludge (URLS) project y

facility,and included on this new page.

}

i i

f j

f

-l i

m REVISIONS BY PAGE Application Application Application Page Date Page Date Page Date TABLE OF CONTENTS I-1.21 5/16/88 I-3.3 10/23/87 I-1.22 I-3.4 1

10/23/97 I-1.23 I-3.5 2

I-1. ' 4 I-3.6 3

I-1.23 I-3.7 4

I-3.8 5

I-3.9 6

CHAPTER 2 I-3.10 7

I-3.11 8

11/13/90

• I-2.1 2/06/89 I-3.12 9

11/13/90

• I-2.2 I-3.13 10 7/28/89 I-2.3 I-3.14 11 2/06/89 I-2.4 I-3.15 12 I-2.5 I-3.16 I-2.6 I-3.17 I-2.7 I-3.18 I-2.8 I-3.19 PART I I-2.9 I-3.20 I-2.10 I-3.21 I-2.11 I-3.22 CHAPTER 1 I-2.12 I-3.23 I-2,13 I-3.24 I-1.1 5/16/88 I-2.14 I-3.25 I-1,2-I-2.15 I-3.26 I-1.3 I-2.16 I-3.27 I-1.4-2/16/89 I-2,17 I-3.28 I-1.5 5/16/88 I-2.18 I-1.6 I-2,19 I-1.7 8/02/90 I-2.20 I-1.8 5/16/88 I-2.21 CHAPTER 4 I-1.9 I-2.22 I-1.10 I-2.23 I-4.1 10/23/87 I-1.11 I-2.24 I-4.2 I-1.12 I-2,25 I-4.3 I-1.13 I-2.26 I-4.4

.I-1.14 I-4.5 I-1.15 I-4.6 I-1.16 I-4.7 I-1,17 CHAPTER 3 I-4.8 I-1.18 I-4.9 I-1.19 I-3.1 10/23/87 I-4.10 I-1.20 8/02/90 I-3.2 I-4.11 LICENSE SNM-1097 DATE 11/13/90 Page DOCKET 70-1113 REVISION 26

7 i*

o-REVISIONS'BY PAGE Application Application Application

Page Date

'Page-Date Page

.Date-I-4.12'-

10/23/87 I-5.22 10/23/87 i

I-4.13.

I-5.-23 I-4.14 I-5.24 I-4.15 I-5.25 I-4.'16 I-5.26 s-

.I-4.17 I-5.27 I-4.18 I-5.28

-I-4.19

-I-5.29 I-4.20' I-5.30

=I-4.21 I-5.31

.I-4.22 n

.I 4,23 I-4.24

I-4'.25_.

CHAPTER 6 I-6.1 10/23/87 I-6.2 CHAPTER'S I-6.3 5/16/88 I-6.4 I-5.1 10/23/87~

I-6.5 I-5.2 I-6.6 I-5.3-I-6.7 11/13/90 I-5.4 I-5.5-I-5.6 5/16/88-CHAPTER-7 I-5.7 10/23/87

~

I-5.8 I-7.1 10/23/87 I-5.9~

.I-5.10-

--I-5.11.-

~I-5.12

' CHAPTER-8 I-5.13

'I-5'. 'I-8.1 2/06/8'9 I

-I-5.15 r

I-5.16' i

I-5.17 I-5.~18 I-5.19 I-5.20 I-5.21

-1 LICENSE SNM-1097 DATE 11/13/90

'Paga DOCKET 70-1113 REVISION 26

,6. 6 Uranium Recovery From Lagoon Sludge (URLS) Project C

Facility 6.6.1 The following are special process commitments related to the URLS facility.

6.6.1.1 All nuclear safety interlocks which are not utilized for normal operations shall be functionally tested at least annually.

If the process has been shut down and more than one year has elapsed since the previous functional test, each nuclear safety interlock shall be functionally tested prior to startup.

6.6.1.2 All analysis equipment (including any in-line monitors) important to maintain the nuclear safety of the system shall be' calibrated at least semi-annually.

If the process has been shut down and more than six months have elapsed since the previous calibration, this analysis equipment-shall be calibrated prior to startup.

6.6.2 In addition to the training criteria established in Section 2.6, all employees working in the URLS facility will complete a chemical training program.

This training will include topics such as potential-hazards, 4

proper use of protective equipment, and remediation action.

Previously trained employees will be retrained every two years.

i LICENSE SNM-1097 DATE 11/13/90 Page DOCKET 70-1113 REVISION 26 I-6.7 l

l

t q

Mr. C.

J. Haughney November-13, 1990 Page 1 of 1 ATTACHMENT 4 ADDITIONAL ENVIRONMENTAL INFORMATION An air permit has been obtained from the North Carolina Department of Environment, Health, and Natural Resources (Appendix 1).

The chemical emissions from.the URLS process are similar to emissions from other chemical processes currently in operation on the plant site and are small in proportion to those current emissions.

The air pollution control devices installeo on the URLS process are a wet scrubber and bank of six HEPA filters.

The only air toxic that may be emitted from the URLS process is hydrogen fluoride.

The current total site stack emissions of Hydrogen Fluoride is.254 pounds per hour.

The Hydrogen Fluoride emission as permitted in the URLS process addition is.0009 pounds per hour for an increase of only 0.4 percent.

The total annual site uranium effluent for all stacks is approximately 53.4 grams U.

The estimated annual additional quantity for URLS is expected to be about 0.9 grams U for the same period of time.

All liquid waste from the URLS project will be returned to the existing waste treatment operations.

URLS is a relatively small operation compared to our other current operating facility and no significant increase in individual or cumulative occupational doses is expected.

Since the site is dedicated to industrial use, the construction impact'is negligible.

Projected postulated radiological accident scenarios are no different from those that currently exist in our facility.

A rigorous safety analysis and review has been completed for the requested operation and the review concluded that controls are in place such that the potential for an accident has been determined to be negligible.

., 1 ATTACHMENT 4 RECEIVED l

APPENDIX 1 j

i fEB 2 2 W93

o..

L l

H. R. STRICKLER State of North Carolina Department of Environment, Health, and Natural Resources Division of linvironmental hianagement 512 North Salisbury street

• Raleigh, North Carolina 27611 James G. Alartin, Governor February 21, 1990 R. Paul Wilms 4

William W. Cobey, Jr., Secretary Director Mr. lierbert R. Strickler I

General Electric Company Post Office Box 780 i

Wilmington, North Carolina 28402 1

Subject:

Air Permit No. 195R14 General Electric Company Wilmington, North Carolina i

New Hanover County i

In accordance with your completed appitcation received December 13, 1989,_ we are forwarding herewith Permit 'No.

195R14 to i

General Electric Company, Wilmington, North Carolina for the construction 4

and - operation of air emission sources or air cleaning devices and appurtenances.

'If any parts, requirements, or limitations contained in this permit i

are unaccertable to you, you have the right to request an adjudicatory hearing within thirty (30) days following receipt of this permit, Identifying the specific issues to be contended.

This request must.be

~,

in the form of a written petition, conforming to Chapter 150B of the-North Carolina General

Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer 11666,

Raleigh, North

' Carolina 27604.

Unless such demar.d is made, this permit shall be final-and binding.

This permit shall be effective from February 21, 1990, ur.t il October 1,1991, is nontransferable to future owners and operators, and j

shall be subject to the conditions and limitations as specified therein.

Sincerely, i

George T. Evere Enclosures cc: Mr. Preston lloward PO ika 27687. Ralewh Nonh Can>Inu 2% i-76x7 Tekphone m9-7H 7015 An Equal opponunny Ahirnuove Acuan Enwkwr

l NORTH CAROLINA ENVIRONMENTAL MANAGEMENT C0$1SS10N 1

DEPARTMENT OF ENVIRONMENT, HEALTH, 4 NATURAL RESOURCES DIV!SION OF ENVIRONMENTAL MANAGEMENT h 1 R f.E 8 M i 1 N 0. 195R14

'ssue Date: February 21, 1990 Efu ctive Date: February 21, 1990 Expiration Date: October 1, 1991 Replaces permit:

195R13 To construct and operate air emission sources or air cleaning devices, and for the discharge of the associated air contaminants iito the atmosphere.

In accordance with the provisions of Article 21B of Chapter 143, General Statutes of North Carolina as amended, and other applicable Laws, Rules and Regulations, PERMISSION IS llER WY GRARTED 10 General Electric Company Highway 117 North Wilmington, New Hanover County, North Carolina FOR THE construction and operation of air emission sources or air cleaning devices and appurtenances consisting of:

fluegasquencher(58gallonsofwaterperminute),aventuri a.

a scrubber (100 gallons of water per minute), a verticle, counter current packed tower wet scrubber (162 gallons por minute), a bagfilter (1696 square feet of fabric filter area) and a HEpA filter (9 filters,1980 square feet total) instclied in series on an existing 1200 pounds per hour capacity, natural gas /No. 2 fuel oil / propane-fired multiple chamberedincinerator(primary

burner, 1.5 million BTU per hour minimum heat input and secondary burner, 2.5 million Blu per hour minimum heat input) burning Type 0 waste and waste oil, b.

primary and secondary dry mat-type filters installed on the incinerator building main exhaust system, c.

a demister and three filter casings with primary and secondary filters installed on a laboratory hood, a centrifuge process, and process operations, d.

a baghouse(178 square feet of filter area) installed on a hydrated lime storage si.o(2500 tons per year maximum throughput),

e, a cyclone (16 inches in diameter) installed on woodworking equipment, f.

two HEPA filter unitt (in parallei) and a gravity spray -hamber scrubber (12.0pallons per minute total liquid injectior, rate) with a demister pad installed in serles on the exhausts of pilot plant process development operations, I

r P;mit No.195R14 page 2 g.

one impingment type wet scrubber (6 gallons por minute minimum water injection rate)withfixed blade mist eliminator (4.9 square feet of area, ID Nos.S-BOO) installed on two steam jacketed wastewater treatment plant sludge (caldtumflaride) dryers, ID Nos. D-500 & D-501, and h.

a packed bed-type wet scrubber (36 gallons per minute distilled water injection rate, ID No. WS-8080) and a HEpA filter unit (ID No. F-8020) installed in series on ventilation hoods and process tank vents at the Uranium Recovery Process Facility (10No.

URPF),

to be constructed and operated in accordance with the completed application received December 13, 1989, and in conformity with the plans, specifications, and other supporting data, all of which are filed with the Department of Environment, Health, & Natural Resources and are incorporated as part of this Permit.

This Permit shall be subject to the following specified conditions and limitations including any

testing, reporting, or monitoring requirements:

A.

SPECIFIC COWIIIONS A W LIMITATIONS 1.

The Permittee shall comply with applicable Environmental Management Connission Regulations, including 15A NCAC 2D.0505,

.0512,.0515,.0516,.0521, and.0535, 2.

Sulfur dioxide emissions from the fuel burning equipsent shall not exceed 2.3 pounds per million BTU heat input.

3.

This Permit may be revoked unless the wet scrubber and HEPA system (Item "h" above) is constructed in accordante with the approved plans, specifications and other supporting data.

If the proposed operational date of August 31, 1990 is not met, then the Permittee must notify in writing the Regional Supervisor of the new operational date.

Existing equipment being replaced is permitted to operate in compliance until the replacement equipment is operational.

I 4.

As required by 15A NCAC 20.0535, when particulate or visible emissions exceed Environmental Management Regulations for more than four hours the Regional Suparvisor, Division of Environmental Management, Wilmington Region,(919)256-4161, shall be notified as promptly as possible but in no case later than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of becoming aware of the occurrence. Such notice shall specify the facility name and location, the nature and cause of the excess emissions, the time when first observed, the expected duration, and the estimated rate of emissions.

This reporting requirement does not allow the operation of the facility in excess of Environmental Management Commission Regulations.

5.

The Permittee must comply with any applicable Federal, State, or local requirements governing the handling, disposal, or incineration cf hazardous wastes, including the Resource Conservation and Recovery Act (RCRA) administered by the Division of Solid Waste Management.

.)

o Permit No. 195R14 page 3 B.

GENERAL COW 1110NS A W LIM 11AT10NS 1.

All reports, test data, monitoring data, notifications, and requests for renewal shall be submitted to the:

Regional Supervisor North Carolina Division of Environmental Management 7225 Wrightsville Avenue Wilmington, North Carolina 28403 2.

Reports on the operation and maintenance of the facility shall be submitted by the Permittee to the Regional Supervisor, Division of Environmental Management at such intervals and in such form and detail as may be required by the Division.

Information required in such reports may include, but is not limited to process weight rates, firing rates, hours of operation, and preventive maintenance schedules.

3.

Any changes in the information submitted in the appilcation regarding facility emissions, or any changes that modify equipment or processes of existing permitted facilities, or any changes in the quantity or quality of materials processed that will result in previously unpermitted, new, or increased emissions must be reported to the Regional Supervisor, Division of Environmentti Management.

If appropriate, modifications to the permit may then be made by the Division of Environmental Management to reflect any necessary changes in the permit conditions, in no case are any new or increased emissions allowed that will cause violation of the emission limitations specified herein.

4.

This permit is subject to revocation or modification by this Division upon a determination that information contained in the application or presented in support thereof is incorrect, conditions under which this Permit was granted have changed, or violations of conditions contained in this Permit have occurred.

The facility shall be properly operated and maintained at all times in such a manner to effect an overall reduction in air pollution.

5.

Under the statutory authority of G.S.143-215.3 (a)(2), no person shall refuse entry or access to any authorized representative of the Division of Environmental Management who requests entry for purposes of inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or interfere with any such representative while in the process of carrying out his official duties.

Refusal of entry may constitute grounds for permit revocation and assessment of civil penalties.

6.

This Permit is nontransferable by the Permittee. Future owners and operators must obtain a new air permit from the Division of Environmental Management,

e 41 2.

P:rmit No.195R14 page 4 7.

This Permit does not relieve the Permittee of the responsibility of complying with all applicable requirements of any federal, State, or Local water quality or land quality control authority.

8.

The Permittee at least ninety (90) days prior to the expiration of this Permit shall request its extension by letter.

The letter should include the permit number, the appropriate renewal fee, description of any modifications, and should be sent to the Regional Supervisor, Division of Environmental Management.

9.

A violation of any term or condition of this Permit shall subject the Permittee to enforcement procedures contained in North Carolina General Statutes 143-215.114, including assessment of civil penalties.

Permit issued this the 21st day of February, 1990.

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT C0 mlSSION k"

George T. Everett, D M ctor 01 vision of Environmental Management By Authority of the Environmental Management Comission Air Permit No. 195R14

,