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HomeMy WebLinkAbout2. 2010memo sediment basin�Ji-� �✓ ?,�l int✓M��-� KeH� Belnick, Tom From: Belnick, Tom Sent: Wednesday, October 06, 2010 3:30 PM To: Pickle, Ken; Lawyer, Mike Cc: Bennett, Bradley Subject: RE: Dupont Fayetteville Works NPDES N( NG0003573 al7�010 I've already sent an NPDES no comment reply back to CG&L. The relocation was approved in a permit mod dated 2/26/2008. There was no discussion of a new sediment basin in that mod, just outfall relocation due to the sediment issues within the effluent channel. This permit expires 10/31/2011, and I don't envision reopening the permit before renewal. I can add the sediment basin as a new treatment component at that time, but the permit writer will discuss its purpose with DuPont. I'll put this email in the permit file, as a notice to the next permit writer to discuss any remaining SW issues. Tom Belnick Supervisor, Complex NPDES Permitting Unit NC DENR/Division of Water Quality 1617 Mail Service Center, Raleigh, NC 27699-1617 (919) 807-6390; fax (919) 807-6495 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Pickle, Ken Sent: Wednesday, October 06, 2010 10:50 AM To: Lawyer, Mike Cc: Bennett, Bradley; Belnick, Tom Subject: RE: Dupont Fayetteville Works NPDES No NC0003573 Hi Mike, Further comments: Didn't mean to leave you hanging, just got sidetracked. a) Consider that 12MGD is our current working number for the wastewater discharge flow. You think that's erosive? It has been before. So, I suspect that the sediment basin is there to address the wastewater discharge erosion on a day -in -and -day -out basis. b) The boundary between NPDES and SPU may be unclear in some cases. My perspective is that this entire system is an NPDES system by virtue of all the stormwater being commingled with a wastewater discharge (I don't think it matters that the wastewater discharge is a 'partially treated' discharge during part of the run.) c) Consistent with that perspective, this is not a 'stormwater' basin: it's a wastewater basin, maybe a 'tertiary sedimentation' basin, or whatever lingo is appropriate in the wastewater world. We probably should see if the NPDES guys think this is their basin, or not. This is critical in responding to the question from the guys at CG&L. d) Mike, I agree, if there will be a remnant stormwater-only discharge from the old wooden channel, then the facility will need a stormwater permit for it. As you suggest one path would be just to simply address it with modifications to the existing NPDES wastewater permit. We have some of those permits still in our universe of NPDES permits. But, both SPU and NPDES are trying to move away from combined permits for administrative efficiency reasons. As weird as it might sound, it's easier/quicker/more efficient for the permittee and for the two units, when we issue permits separately, rather than in combo permits. Suggest we get Tom Belnick's input on this point, too. It's possible he may see it differently in this particular case. You may see it differently, too. It's possible that Tom may want to just modify the current NPDES permit by adding stormwater provisions, and address the splitting out of stormwater into two permits at the next scheduled renewal of his NPDES permit. Tom? 1 Ken From: Lawyer, Mike Sent: Friday, October 01, 2010 2:13 PM To: Pickle, Ken; Bennett, Bradley Cc: Patterson, Roberts Henson, Belinda; Rawls, Paul; Ventaloro, Julie Subject: RE: Dupont Fayetteville Works NPDES No. NC0003573 Yes, I neglected to mention this facility's water usage. My understanding is that they withdrawal approximately 12mgd, but only use what they require for processing (not sure how much) and send the rest back to the river via their current outfall. I believe this has been the major cause for the erosion in the effluent channel and subsequent sediment deposition into the riverjust downstream of L&D #3. I would be curious about the wooden channel that serves as their current conveyance of general wastewater and stormwater. If this channel is to remain, then its logical to presume that stormwater from portions of the facility would continue to enter and discharge from it. This may need to be added to their NPDES wastewater permit as a stormwater- only outfall to be monitored in addition to the relocated ww outfall. Mike Michael Lawyer, CPSWQ Environmental Specialist NCDENR-Division of Water Quality Surface Water Protection Section Fayetteville Regional Office Direct: (910) 433-3329 Main: (910) 433-3300 Fax: (910) 486-0707 e-mail:.mike.lawyer(@ncdenr.gov (please note my current e-mail address) *E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Pickle, Ken Sent: Friday, October 01, 2010 1:38 PM To: Lawyer, Mike; Bennett, Bradley Cc: Patterson, Robert; Henson, Belinda; Rawls, Paul; Ventaloro, Julie Subject: RE: Dupont Fayetteville Works NPDES No. NC0003573 Bradley, • Other thoughts: I would suspect that the water usage of this facility is quite large. Aerial photos make it seem I ike their water intake is immediately above the dam and lock, and their discharge is immediately downstream of the dam and lock. Now they're proposing to return the water upstream of the lock and dam, instead of downstream. Who might be concerned about any affect on the dam? The Corps? • NPDES wastewater ATC: Just two additional comments. First: To us this is really nota 'stormwater' basin that they're building, right? It's a settling basin to address the sediment load picked up as the wastewater discharge 2 (augmented by storm flows) erodes the effluent channel, right? The flows are commingled (all now wastewater), and it's being built under a wastewater permit. This all looks ok to me. • Second NPDES wastewater comment: In this case, any measurement of solids at internal outfall #001 masks the sediment load delivered by the erosion of the effluent channel. (As I read the BIMS information, NC0003573 requires TSS measurements at internal outfall #001, but not at outfall #002.) What regulatory requirement is driving this project? A new settling basin and the new 60" and 48" discharge lines have got to be costly. Must be the Corps? • I wonder if our brothers over in NPDES might want to add TSS to #002? • NPDES stormwater? if it's all captured on site and it's all in the wastewater outfall, no comment. (Other unpermitted stormwater outfalls?) • WS -IV CA water supply according to BIMS. • I don't think that we in SPU have any involvement in this project (except via NCG01 at the time of construction ) Ken From: Lawyer, Mike Sent: Friday, October 01, 2010 10:32 AM To: Bennett, Bradley Cc: Patterson, Roberts Pickle, Ken; Henson, Belinda; Rawls, Paul Subject: RE: Dupont Fayetteville Works NPDES No. NC0003573 This facility does not have a separate stormwater permit as their NPDES wastewater permit covers stormwater discharges in addition to wastewater plant effluent and general wastewater from a non -contact cooling tower and a boiler. General wastewater discharges flow into a wooden ditch, which also receives stormwater. Discharges from the facility's WWTP (internal outfall 001) also join the wooden ditch just prior to entering what is currently their effluent channel to the Cape Fear River (outfall 002) and ultimately discharging into the River downstream of Lock and Dam #3. My understanding of the reason they are proposing to reroute their discharge point, which would end up being upstream of L&D #3, is that a large amount of sediment has been deposited over time into the River through the effluent channel due to the amount and velocity of their discharges. As far as their proposal for a stormwater basin, I'm assuming it would be to aid in detention and reduce velocity of discharges. Bladen County is not a Phase II county and the facility is not located within an HQW or ORW watershed. The only possible post -construction requirement might be under the Water Supply rules as that portion of the Cape Fear has been recently reclassified as WS -IV due to the installation of a new intake near the Smithfield Packing facility in Tar Heel. According to revised maps, the WS watershed extends from the new intake upstream into Cumberland County and would cover the DuPont facility located near the Bladen/Cumberland County line. I don't know how much property is owned by DuPont, but if there is any installation of new BUA associated with the outfall rerouting project and it would put them over the 24% density threshold, then an engineered BMP would be required. The reclassification became effective on 1/1/09 and according to a document we have concerning the reclassification, local governments had 270 days after the effective date to develop or modify water supply protection ordinances to meet the state's minimum requirements. Mike Michael Lawyer, CPSWQ 3 Environmental Specialist NCDENR-Division of Water Quality Surface Water Protection Section Fayetteville Regional Office Direct: (910) 433-3329 Main: (910) 433-3300 Fax: (910) 486-0707 e-mail: mil<e.lawyer@ncdenr.gov (please note my current e-mail address) *E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley Sent: Thursday, September 30, 2010 4:08 PM To: Lawyer, Mike Cc: Patterson, Robert; Pickle, Ken Subject: FW: Dupont Fayettevile Works NPDES No. NC0003573 Hey Mike, Take a look at the request from CG&L below. Any thoughts on this one. It doesn't appear that they have an NPDES Stormwater permit currently. I'm not sure if they have the stormwater basin for any other reasons (post -construction permit of some type?). Robert, Ken —let me know if you have any feedback on this one also. Bradley Bennett Stormwater Permitting Unit NC Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 807-6378 Fax: (919) 807-6494 Email: bradley.bennett@ncdenr.gov (New Email Address) Web: http://portal.ncdenr.org/web/wq/ws/su Email correspondence to and from this address maybe subject to the North Carolina Public Records Law and maybe disc%sed to third parties. From: Tsadwa, Steve Sent: Wednesday, September 29, 2010 5:16 PM To: Bennett, Bradley; Belnick, Tom Cc: Henson, Belinda; Allen, Trent Subject: Dupont Fayettevile Works NPDES No. NC0003573 We are reviewing an Authorization to Construct (ATC) application for Dupont at this facility that involves the relocation of Outfall 002. The discharge from NPDES permitted outfall system is conveyed by a new open channel system (about 31000 ft long) to a new storm water management basin and finally discharging through approximately 1,600 If of 48" and '.60" piping to the Cape River. Outfall 002 flows consist of storm water, non -contact cooling water, boiler blowdown condensate, and WWTP effluent from internal Outfall 001. All of this flow is proposed to be routed through the stormwater basin. We want to make sure there are no other applicable permits or reviews (such as stormwater) that are required prior to issue of an ATC. We appreciate all your review comments and feedback. Steve "Tesfu" Y:,adwn, Envir'onmentnl/Chemical Engineer Design Management Uni-i' Construction Gran -s & Loons Section 1633 Mnil ServicE Cen-I-er I�aleigHt, NC 27699-163> 919.715.6230 (phone.) 919.71 5.6229 (Fax) ste:ve, i saclvua�ncdenr.gr�v E-mail corresponcic race to and fr^om this add►^ess may be subjec t to the North Carolina Publie Records Law and may be disclosed to third parties. 5