NC0032719_SOC (Application)_20151130 (2)

Strickland, Bev
From:
Howard, Kevin B
Sent:
Monday, November 30, 2015 2:34 PM
To:
Tankard, Robert
Cc:
Watson, Mickey
Subject:
SOC Application
Attachments:
20151130132944.tif
Robert,
I have attached the SOC application we sent in last week.
Kevin Howard
County Manager
252-482-8431 ext. 3
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.

CHOWAN COUNTY, NORTH CAROLINA
P.O. Box 1030
Edenton, NC 27932
[phone]
[phone] fax
November 25, 2015
North Carolina Division of Water Resources
Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: SOC Application
To Whom It May Concern:
Please find the 1 original and 2 copies of Chowan County's SOC Application for our Water Treatment
Plant.
If you need additional information please let us know.
Sincerely,
Kevin oward
County Manager

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
APPLICATION FOR A SPECIAL ORDER BY CONSENT (SOC)
I. PERMIT RELATED INFORMATION:
1. Applicant (corporation, individual, or other): Chowan County, NC
2. Print or Type Owner's or Signing Official's Name and Title: Kevin Howard, County Manager
3. Facility Name (as shown on Permit): Valhalla Water Treatment Plant
4. Owner Phone: [phone] (or) 252-232-8208
5. Owner Email: [e-mail]
4. Application Date: 11/25/15
5. NPDES Permit No. (if applicable): NC 0032719
6. Name of the specific wastewater treatment facility (if different from 7.3. above):
Same as Above
II. PRE -APPLICATION MEETING:
Prior to submitting this completed application form, applicants must meet with the appropriate
regional office staff to discuss whether or not an SOC is appropriate for this situation. Please
note the date this meeting occurred and who represented the permittee:
Representative: Kevin Howard Date: 1/27/2015.
I11. ADDITIONAL FLOW OR FLOW REALLOCATION:
In accordance with NCGS 143-215.67(b), only facilities owned by a unit of government may
request additional flow.
Additional flow may be allowed under an SOC only in specific circumstances. These
circumstances may include eliminating discharges that are not compliant with an NPDES or
Non -discharge permit, These circumstances do not include failure to perform proper
maintenance of treatment systems, collection systems or disposal systems. When requesting
additional flow, the facility must include its justification and supporting documentation.
If the requested additional flow is non -domestic, the facility must be able to demonstrate the
ability to effectively treat the waste and dispose of residuals. The applicant must provide a
detailed analysis of the constituents in the proposed non -domestic wastewater.

The total domestic additional flow requested: _n/a gallons per day.
The total non -domestic additional flow requested: _n/a gallons per day.
The total additional flow (sum of the above): _n/a gallons per day.
Please attach a detailed description or project listing of the proposed allocation for additional
flow, with an explanation of how flow quantities were estimated. Further, any additional flow
requested must be justified by a complete analysis, by the permittee, that additional flow will not
adversely impact wastewater collection/treatment facilities or surface waters.
IV. NECESSITY NARRATIVE:
Please attach a narrative providing a detailed explanation of the circumstances regarding the
necessity of the proposed SOC. Include the following issues:
• Existing and/or unavoidable future violations(s) of permit conditions or limits(s),
Our WTP uses rock salt to regenerate the ion exchange resin in our softeners which is discharged
into an unlined retention/settling pond and from this discharges into an unnamed tributary to
Pollock Swamp. The brine discharge water from the softeners has seeped into the groundwater to
the point we are in violation of 2L standards. Ground water samples taken on 7/10/2015 indicate
that chloride levels are at 3350 mg/L. If iron and manganese in the groundwater in excess of 2L
standards is determined to be caused by plant operations, the SOC implementation phase will
include actions to correct this problem.
The existing treatment process and any process modifications that have been made to
date to ensure optimum performance of existing facilities,
At this time we have notified our customer of our intent to discontinue our water softening process
until an alternate means to soften the water can be put in place. Beginning on December 1, 2015 we
will increase the plants hardness levels from 100 parts hardness to 150 parts. On January 1, 2016 it
will be increased from 150 to 200 parts, on February 1, 2016 from 200 to 250 parts and on March 1,
2016 we will discontinue all softening processes.
• Collection system rehabilitation work completed or scheduled (including dates),
n/a
• Coordination with industrial users regarding their discharges or pretreatment facilities.
Identify any non -compliant significant industrial users and measure(s) proposed or
already taken to bring the pretreatment facilities back into compliance. If any industrial
facilities are currently under consent agreements, please attach these agreements,
n/a
• Date and outcome of last Industrial Waste Survey,
n/a

• Whether or not the facility is acting as a regional facility receiving wastewater from other
municipalities having independent pretreatment programs.
n/a
V. CERTIFICATION:
The applicant must submit a report prepared by an independent professional with expertise in
wastewater treatment. This report must address the following:
• An evaluation of existing treatment units, operational procedures and recommendations
as to how the efficiencies of these facilities can be maximized. The person in charge of
such evaluation must sign this document.
• A certification that these facilities could not be operated in a manner that would achieve
compliance with final permit limits. The person making such determination must sign
this certification,
• The effluent limits that the facility could be expected to meet if operated at their
maximum efficiency during the term of the requested SOC (be sure to consider interim
construction phases).
• Any other actions taken to correct problems prior to requesting the SOC.
Letter is attached
VI. PREDICTED COMPLIANCE SCHEDULE:
The applicant must submit a detailed listing of activities along with time frames that are
necessary to bring the facility into compliance. This schedule should include milestone dates for
beginning construction ending construction and achieving final compliance at a minimum In
determining the milestone dates, the following should be considered:
• Time for submitting plans, specifications and appropriate engineering reports to DWR for
review and approval.
• Occurrence of major construction activities that are likely to affect facility performance
(units out of service, diversion of flows, etc.) to include a plan of action to minimize
impacts to surface waters.
• Infiltration/Inflow work, if necessary.
• Industrial users achieving compliance with their pretreatment permits if applicable.
• Toxicity Reduction Evaluations (TRE), if necessary.
• By December 31, 2015:
Chowan County is presently having an Initial Site Assessment (ISA) performed by Groundwater
Management Associates (GMA); it is anticipated that this ISA will be completed and a report
submitted to Department of Environmental Quality (DEQ) by December 31, 2015. The purpose of
the ISA is to identify all potential receptors (e.g., drinking water wells, surface water features, etc.)
and significant exposure pathways, conducting a monitoring event of existing compliance boundary
monitoring wells to ascertain the levels of iron, manganese and chloride in the aquifer(s) in the

vicinity of the Valhalla Water Plant, establishing groundwater flow direction in the Surficial
Aquifer, and preparation of a work plan for the future Comprehensive Site Assessment.
• December 1, 2015:
The water softeners in the plant will be adjusted to increase the water hardness to about
150 parts per million; this is higher than the plant has traditionally produced.
• January 1, 2016:
The water softeners in the plant will be adjusted to increase the water hardness to about
200 parts per million.
• February 1, 2016:
The water softeners in the plant will be adjusted to increase the water hardness to about
250 parts per million.
• March 1, 2016:
All softening of the water by the ion exchange method at the Valhalla water plant will be
discontinued.
• January 1, 2016 through December 31, 2016:
A Comprehensive Site Assessment (CSA) will be performed to determine the horizontal and
vertical extent of the subject groundwater contamination. This CSA will entail drilling a
number of temporary wells to sample the groundwater at different depths and then
constructing a series of permanent monitoring wells to enable periodic monitoring of the
groundwater quality during the later phases of the SOC. Because there are more than 37
parcels within a 2000' radius of the Valhalla WTP settling pond, and because the county
will need to obtain written permission to access any of these properties to drill temporary or
permanent monitoring wells, we feel that 12 months may be required to complete this
phase.
• January 1, 2017 through December 31, 2017:
A Corrective Action Plan (CAP) will be performed during this phase of the SOC. This CAP
will evaluate different methods of correcting the groundwater contamination (including
natural attenuation) and will contain preliminary sketch designs of any engineered solutions
evaluated. Preliminary cost estimates of the various alternatives proposed will be prepared,
and a recommendation of the selected alternative will be made. The CAP will be presented
to DEQ for review and approval, and the proposed 12 months for this phase includes 60
days for this DEQ review and approval.
11

• January 1, 2018:
ILnplementation of the approved remediation method from the CAP will begin. This phase
of the SOC will continue until the groundwater that has been determined to have been
affected by the Valhalla WTP has returned to compliance with 2L standards.
VII. FUNDING SOURCES IDENTIFICATION:
The applicant must list the sources of funds utilized to complete the work needed to bring the
facility into compliance. Possible funding sources include but are not limited to loan
commitments, bonds, letters of credit, block grants and cash reserves. The applicant must show
that the funds are available, or can be secured in time to meet the schedule outlined as part of this
application.
If funding is not available at the beginning of the SOC process, the permittee must submit a copy
of all funding applications to ensure that all efforts are being made to secure such funds.
Note: A copy of the application should be sufficient to demonstrate timeliness unless regional
office has reason to request all information associated with securing funding.
Due to the fact that the total scope of the work is not known at this time, Chowan County will
utilize Fund balance and reserves to cover cost that are incurred through the Corrective Action
Plan phase of the project. As soon as the scope of the work is determined Chowan County will seek
to obtain additional funds for the project through construction grants from all state sources,
availability of existing federal agency sources (i.e. USDA), installment purchase loans from
conventional lenders as approved by the local Government Commission and general obligation t
bonds to supplement water fund revenues.
THE DIVISION OF WATER RESOURCES WILL NOT ACCEPT THIS APPLICATION
PACKAGE UNLESS ALL OF THE APPLICABLE ITEMS ARE INCLUDED WITH THE
SUBMITTAL.
Required Items:
a. One original and two copies of the completed and appropriately executed application
form, along with all required attachments.
• If the SOC is for a City / Town, the person signing the SOC must be a ranking
elected official or other duly authorized employee.
• If the SOC is for a Corporation / Company / Industry / Other, the person signing
the SOC must be a principal executive officer of at least the level of vice-
president, or his duly authorized representative.
• If the SOC is for a School District, the person signing the SOC must be the
Superintendent of Schools or other duly authorized employee.
Note: Reference to signatory requirements in SOCs may be found in the North
Carolina Administrative Code [T15A NCAC 2H .1206(a)(3)].

b. The non-refundable Special Order by Consent (SOC) processing fee of $400.00. A
check must be made payable to The Department of Environment and Natural
Resources.
c. An evaluation report prepared by an independent consultant with expertise in
wastewater. (in triplicate)
APPLICANT'S CERTIFICATION:
(NO MODIFICA,(TII�O.NTO THIS CERTIFICATION IS ACCEPTABLE)
I> "/;� o ,/ J r'� , attest this application for a Special Order by
Consent (SOC) has been reviewed by me and is accurate and complete to the best of my
knowledge. I understand if all required parts of this application are not completed and if all
required supporting information and attachments are not included, this application package may
be returned as incomplete. (Please be advised that the return of this application does not prevent
DWR from collecting all outstanding penalties upon request). Furthermore, I attest by my
signature that I fully understand that an upfront penalty, which may satisfy as a full
settlement of outstanding violations, maybe imposed. {Note: Reference to upfront penalties
in Special Orders by Consent may be found in the North Carolina Administrative Code [T15A
NCAC 2H .1206(c)(3)1.1
Signing Official
Name of Signing
THE COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO
COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS, SHOULD BE SENT
TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER RESOURCES
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
IF THIS APPLICATION IS FOR A NON -DISCHARGE SYSTEM, THEN SEND TO:
NORTH CAROLINA DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1636

DIEHL & PHILLIPS, P.A.
CONSULTING ENGINEERS
1500 Piney Plains Rd., Suite 200
Cary, Now-th Carolina 27518
Telephone (9I9) 467-9972 — Fax [phone]
WILLIAM C. DIEHL, P.E.
JOHN F. PHIL.LIPS, P.E.
ALAN R. KEITH, P.E.
This document is being prepared for the County of Chowan Valhalla WTP NPDES Permit
#NC0032719 as supporting information for their Application for a Special Order by Consent for
the referenced facility.
CERTIFICATION
• An evaluation of existing treatment units, operational procedures and recommendations
as to how the effectiveness of these facilities can be maximized.
The Valhalla WTP has 6-11' diameter filters and 4-7' diameter softeners. The filters are
backwashed every other day, and the softeners regenerate automatically based on the volume of
water they have treated; the softeners generally regenerate once or twice per day depending on
the amount of water the plant has produced that day. At the present time, the groundwater in the
vicinity of the plant exceeds 2L Groundwater Standards for iron, manganese and chlorides. It is
believed the iron, manganese and chlorides are entering the groundwater from the unlined
settling pond on the Valhalla plant site that is used for solids settling. Iron and manganese are
backwashed out of the filters; chlorides are associated with softener regeneration. The filter
backwash schedule cannot be extended and still produce drinking water that is in compliance
with state standards. However, there is no state standard for water hardness, so the softeners can
be shut off. Raw water hardness is about 300 parts per million (ppm); presently the plant softens
that water to about 100 ppm. The plan is to increase finished water hardness in steps to allow
customers to get accustomed to the harder water. On December 1, 2015, the plant will be
adjusted to produce water at 150 ppm; on January 1, 2016, the plant will be adjusted to 200 ppm.
On February 1, 2016, the plant will be adjusted to 250 ppm, and finally on March 1, 2016, the
softeners will be fully shut off and the chloride discharge into the settling pond will cease.
A certification that these facilities could not be operated in a manner that would achieve
compliance with final permit limits.
At the present time it is not known if the iron and manganese concentration in the groundwater is
due to plant operations or is a naturally occurring background level; during the SOC this
question will be answered by analyzing samples from monitoring wells. As described above, the
chloride discharge attributable to softener regeneration into the unlined pond will cease in total
by March 1, 2016. If it is determined that the iron and manganese in the groundwater is being
affected by the filter backwash operations, it is not possible for the plant to be operated without
discharging iron and manganese from the filter backwash water and still produce water that
meets state standards.

• The effluent limits the facility could be expected to meet if operated at their maximum
efficiency during the term of the SOC.
The purpose of this proposed SOC is to return the groundwater that is determined to have been
affected by plant operations to 2L standards. As such, the chlorides discharge into the unlined
pond will cease as described herein. If iron and manganese in the groundwater in excess of 2L
standards is determined to be caused by plant operations, the SOC implementation phase will
include actions to correct this problem.
• Any other actions taken to correct problems prior to requesting the SOC.
At the present time a site assessment is being performed to determine how many (if any) adjacent
properties rely on private wells for potable water supply; this report will be presented to DEQ by
December 31, 2015. A schedule for reducing the chlorides in the plant discharge, as described
above, has been made, and will begin December 1, 2015.
11/z7