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HomeMy WebLinkAboutNCS000151_Meeting Notes for Draft Permit Discussion_20201110Arauco Moncure is required to have an individual industrial NPDES stormwater permit. NCDEQ's Division of Energy, Mineral, and Land Resources (DEMLR) may require any owner/operator to apply for and obtain an individual permit. [15A NCAC 02H .0127(i)-(j)]. Cases where an individual permit may be required include, but are not limited to, the following: a) The discharger is a significant contributor of pollutants; b) Conditions at the permitted site change, altering the constituents and/or characteristics of the discharge such that the discharge no longer qualifies for a general permit; c) The discharge violates the terms or conditions of this general permit; d) A change has occurred in the availability of demonstrated technology or practices for the control or abatement of pollutants applicable to the point source; e) Effluent limitations are promulgated for the point sources covered by this general permit; f) A water quality management plan containing requirements applicable to such point sources is approved after the issuance of this general permit; g) The Director determines at his or her own discretion that an individual permit is required. The general industrial NPDES stormwater permit for lumber & wood products (NCG21) requires semi-annual sampling of COD and TSS, with the same benchmarks as the draft permit for Arauco Moncure (NCS000151): Table 1 Analytical Monitoring Requirements Parameter Code Discharge Characteristics [hits Measurement Frequency) Sample Type2 Sample Location3 00340 Chemical Oxygen Demand in,,/L semi-annual GI-CIII SDO L0530 'rotai Suspended Solids nig/L semi-annual Grab SDO 46529 1 Total Rainfall4 hiclic semi-annual Rain gauge - Footnotes: 1 Measurement Frequency: Twice per year (unless other provisions of this permit prompt monthly sampling) during a measurable storm event, until either another permit is issued far this facility or until this permit is revoked or rescinded. See Table 2 for schedule of monitoring periods through the end of this permitting cycle. I the facility is monitoring monthly because of Tier Two or Three response actions under the previous General Permit, the facility should continue a monthly monitoring and reporting schedule. 2 Grab samples shall be collected within the first 30 minutes of discharge. 3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless representative outfall status (ROS) has been granted. A copy of the DEMLR letter granting RGS shall be kept on site. 4 For each sampled measurable storm event, the total precipitation musk be recorded. An on -site rain gauge reading must be recorded. Where isolated sites are unmanned for extended periods of time, a local rain gauge reading may be substituted for an on -site reading. Table 3 Benchmark Values for Analytical Monitoring Requirements Discharge Characteristics Benchmark Value Chemical Oxygen Demand COD 120 m L Total Suspended Solids (TSS) 100 m L Total Suspended Solids H W ORW Trout (Tr), and PNA waters 50 m L Oil & Grease monitoring for outfalls with onsite equipment and vehicle maintenance (>55 gal/month oil) are also the same for the NCG21 general permit and Arauco Moncure's permit. The NCG21 permit for lumber & wood products also notes the following: Any other point source discharge to surface waters of the state is prohibited unless it is an allowable non-stormwater discharge or is covered by another permit, authorization, or approval. Discharge of leachate From accumulations of small -sized woody materials is = considered an allowable non-stormwater discharge and may be more appropriately covered under General Permit NCG240000 Compost facilities. The discharges allowed by this General permit shall not cause or contribute to violations of Water Quality Standards. Discharges allowed by this permit must meet applicable wetland standards as outlined in 15A [CAC 2B.0230 and .021 and water quality certification requirements as outlined in 15A NCAC 2H .0500. The requirements for the NCG24 permit for Compost Facilities include quarterly analytical monitoring for the following: Table 1 Analvtical MonitorinLy Reouirements For Stormwater Discharees Parameter Code Discharge Characteristics Units Measurement Frequency' Sample Type2 Sample Location3 S30 Total suspended solids (TSS) mg/L Quarterly Grah SDO 340 Chemical Oxygen Demand (COD) mg/L Quarterly Grab SDO 31615 Fecal eoliform colonies/100 mL Quarterly Gi,ah SDO 600 Total nitrogen mg/L Quarterly Grab I SDO 66-S Total phosphorus mg/L Quarterly Grab SDO 1119 Copper, Total Recoverable mg/L Quarterly Grab SDO 1051 Lead, Total Recoverable mg/L Quarterly Grab SIX) 1094 Zinc, Total Recoverable Ing/L Quarterly Grab SDO 400 pH standard units Quarterly Grab 5L][] 46529 Total rainfall I inches Quarterly -- -- y�� �• : .. _ _ �t- �'' �, 1 . � .__ �.. Below is a description of the proposed parameters and benchmarks for the NCS000151 draft permit: Parameter Discharge Measurement Benchmark Benchmark Rationale Reasoning for Parameter Code Characteristics Frequency Chemical Oxygen BPJ, Generally found at levels 4 x Standard for lumber & wood products industry 00340 Demand (COD) semi-annual 120 mg/L (BODS) in domestic wastewaters. BPJ, Based on Secondary An indicator of waste organic matter in stormwater. Treatment Regulation (40 CFR This parameter shows how active bacteria are in CO310 Biological Oxygen semi-annual 30 mg/L 133.03). breaking down organic matter in water. BOD is Demand (BOD) applicable due to the large amounts of wood material stored uncovered onsite, and in stormwater conveyances/basins, per inspections. CO530 Total Suspended Solids semi-annual 100 mg/L National Urban Runoff Program Standard for lumber & wood products industry (TSS) (NURP) study from 1983. BPJ, based on approximate A measure of nitrogen bound up in organic material. equivalency to secondary This parameter is applicable for the same reason as 00625 Total Kjeldahl Nitrogen semi-annual 20 mg/L treatment of wastewater Total Nitrogen (below), and because there are large (expressed in mg/I of N). amounts of organic material (wood) stored uncovered onsite. FAV derived from EPA's Leachate from wood chip piles has been found to ECOTOX Database (Feb 2005, J. contain phenols and other toxic components (Rex, et al. Wynn). * Note — 0.3 mg/L may 2016; Hedmark & Scholz, 2008). The lignin in wood is - Phenol semi-annual 4.5 mg/L exhibit an organoleptic effect. made up of phenols. Additionally, phenols are a common byproduct of organic decomposition. Because organics commonly volatilize from stormwater, the presence of phenols in any amount above the detection limit is a cause for concern. TKN + Nitrate + Nitrite This site discharges to Shaddox Creek, which is a class Benchmarks (Expressed in mg/I WS-IV stream. Immediately downstream, Shaddox of N). Creek converges with the Haw River, which in turn immediately converges with the Haw and Deep Rivers, CO600 Nitrogen, Total semi-annual 30 mg/L becoming the Cape Fear River. At that point, the Cape Fear River is impaired for Chlorophyll a. This impairment means that algal blooms are frequent. Nutrient monitoring was added due to this impairment, as nutrients promote the growth of algae CO655 Total Phosphorus semi-annual 2 mg/L BPJ, based on wastewater See above permit limits for NSW waters. Parameter Discharge Measurement Benchmark Benchmark Rationale Reasoning for Parameter Code Characteristics Frequency Water Quality Standard This parameter is included because pH values are 00400 pH semi-annual 6-9 critical to interpreting monitoring data for other parameters. 46529 Total Rainfa114 semi-annual - Consistent across all NPDES individual industrial stormwater permits Targets petroleum -based Consistent across all NPDES individual industrial Non -Polar Oil & Grease hydrocarbons with silica gel stormwater permits by EPA Method 1664 treatment step and hexane 00552 (SGT-HEM) semi-annual 15 mg/L extraction. Value based on for outfalls with vehicle/ review of other states' equipment maintenance maximum daily benchmark activities' concentrations. Equal to one half x [O&G benchmark. New Motor Oil Usage Consistent across all NPDES individual industrial for outfalls with vehicle/ semi-annual -- stormwater permits equipment maintenance activities' Additionally, Arauco Moncure has not shown any significant improvements in meeting their benchmarks through site modifications, best management practices (BMPs), or other means. See below for a summary of results provided by the facility: Sampling Data Summary - NOTE: DMRs without measurable rainfall event were not included Outfall 006 (north outfall) Sampling Date Rainfall BODS COD O/G Phenol Total P TKN Total N TSS pH Benchmarks 30 120 4.5 2 20 30 100 6-9 11/7/2015 0.7 NA 360 NA 0.05 0.9 56 58 160 7.4 9/2/2016 1.1 22 210 NA 0.03 0.3 57 57 9 8.5 12/18/2016 0.4 71 1100 NA 0.03 4.7 110 110 520 8.0 1/20/2017 0.15 690 2800 1 NA 0.32 4.3 1 750 750 140 8.3 3/27/2017 0.1 35 270 NA 0.03 0.4 38 38 NA NA 6/30/2017 1.50 21 170 NA 0.03 0.2 9 9 52 9.1 8/23/2017 0.4 63 500 NA 0.03 0.4 69 70 NA NA 1/11/2018 1 0.2 1 19 96 NA 0.03 1 0.7 15 15 1 40 7.7 12/14/2018 0.8 42 67 NA 0.34 0.1 10 11 10 6.7 4/8/2019 0.7 56 280 NA <0.034 0.3 45 45 150 7.4 Outfall 004 (south outfall) Sampling Date Rainfall BOD5 COD O/G Phenol Total P TKN Total N TSS pH Benchmarks 30 120 4.5 2 20 30 100 6-9 11/7/2015 0.7 NA 120 4.2 0.04 0.7 5 6 69 7.0 9/2/2016 1.1 >70 270 18.3 0.09 0.3 21 22 100 7.4 12/18/2016 0.4 3 32 2.4 0.03 0.1 3 4 13 8.3 1/20/2017 0.2 120 930 11.5 0.10 1.5 3 63 450 7.4 3/27/2017 0.1 18 220 5.6 0.13 0.2 34 35 19 7.4 6/30/2017 1.5 95 500 2.4 0.03 0.3 22 23 350 9.3 8/23/2017 0.4 110 620 15.5 0.03 0.5 33 35 280 6.8 1/11/2018 0.2 >200 390 67.7 0.07 0.7 41 42 85 8.0 12/14/2018 0.8 6 170 2.6 0.04 0.2 33 34 110 7.4 4/8/2019 0.7 24 150 <1.50 0.03 0.2 9 10 31 8.1 The Division applauds Arauco Moncure for implementing the site improvements detailed in their comments on the draft permit on October 23, 2020. However, there is a lack of data consistently showing that these improvements have resulted in improved stormwater quality. When the analytical monitoring results show consistent improvement, the facility may apply for a permit modification to change the parameters in the permit. Furthermore, Arauco Moncure is reminded of the Tier Two response requirements in their current permit. If the sampling results exceed a benchmark value for any outfall on more than four occasions, the permittee shall notify the Regional Office Supervisor in writing within 30 days of receipt of the fourth analytical results. Simply submitting DMRs noting the exceedance for that sampling period does not satisfy this requirement. Failure to notify the Regional Office Supervisor as described constitutes a permit violation and may be subject to enforcement. References: Hedmark, A., and Scholz, M. (2008). Review of environmental effects and treatment of runoff from storage and handling of wood. Bioresource Technology, 99(14), S997-6009. https://doi.org/10.1016/m.biortech.2007.12.042. Rex, J., Dube, S., Krauskopf, P., & Berch, S. (2016). Investigating Potential Toxicity of Leachate from Wood Chip Piles Generated by Roadside Biomass Operations. Forests, 7(2), 40. https://doi.org/10.3390/f7O2OO4O.