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HomeMy WebLinkAboutNC0001376_permit issuance_20100326NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary ' March 26, 2010 Mr. John Lancaster Riverplace, LLC P. 0. Box 31568 Raleigh, NC 27622 Subject: Issuance of Renewal NPDES Permit NPDES Permit NC0001376 Riverplace WWTP Wake County Class 11 Dear Mr. Lancaster: A response was sent to you regarding your questions and comments on the subject draft permit, and on your current activities and anticipated future plans. After further evaluation the Division has approved issuing this renewal for the subject permit with an expiration date of February 28, 2013, corresponding to the next scheduled Neuse River permits renewal date. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). Summary of Changes in Renewal Permit from Existing Permit 1) Effluent Permitted Flow Limit, BOD Limits, Total Suspended Solids (T55) Limits, Ammonia as Nitrogen (NH3 N) Limits, and Total Phosphorus (TP) monitoring were changed. The influent is considered a reduced intermittent domestic wastewater and stormwater source. Therefore: - Permitted flow limit was reduced, reported flow must be total flow over a 24-hour day and no reported flow means no flow event, - NH3-N limits were removed, changed to monitoring only, - BOD and TSS limits were changed to secondary treatment standards, and - TP sampling frequency was reduced to monthly. 2) Effluent Fecal Coliform Limits with weekly monitoring were added. As a domestic treatment system compliance with the Fecal Coliform secondary standard is required. 3) Effluent parameters COD, Total Chromium, Color, Total Copper, Phenols, Sulfides, and Total Zinc were removed. These parameters are not applicable for this domestic discharge at this time. Page 1 of 2 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-64951 Customer Service: 1-877-623-6748 Internet: http:/ / h2o.state.nc.us / An Equal Opportunity 1Affrmative Action Employer NorthCarolina Naturattg 4) Effluent Chronic Toxicity Limit and monitoring was removed. This parameter is not applicable at thi's time. 5) Effluent Total Nitrogen Limits (TNL) and Total Nitrogen Load Allocation Limits (TNLAL) were added. The Neuse River Basin nutrient rules assigned a TNLAL to this discharge in 1997 and was deeded to a third party in 1999 leaving this discharge with a "zero" TNLAL and a "zero" TNL tolerance. This permit was revised to state the applicable TNL and TNLAL limits. Footnotes and special conditions to clarify calculations, minimum reportable level, and the nutrient rule were added. 6) Effluent Nitrite/Nitrate Nitrogen and Total Kje/dahl Nitrogen reporting were added. These parameters are measured to calculate the Total Nitrogen (TN) value. Footnotes were added to define minimum detection and reporting requirements. . 11r 7) Effluent conditional Total Residual Chlorine (TRC) Limit .with 2/weekly monitoring and footnote narrative was added. The applicable conditional TRC water quality standard (WQS) with narrative is stated for compliance. 8) lnstream monitoring was removed. These data are not needed at this time. 9) A Special Condition A. (5.) was added. This condition established the reporting steps with milestones to design, to implement equipment changes, and to eliminate the discharge before the next renewal. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. 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 (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). , Unless such demand is made, this decision shall be final and bipding. Please note. that this permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality or permits required by the Division of Land Resources, the Coastal Area Management Act or any other federal or local governmental permits that may be required. If you have any questions concerning this permit, please contact Ron Berry at telephone number (919) 807-6396. Sincerely, Ik p Coleen H. Sullins Attachments Cc: Raleigh Regional Office/Surface Water Protection Section (email) EPA Region IV/Marshall Hyatt (email) Central Files NPDES Unit Page 2 of 2 NC0001376 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT ► i TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, the Riverplace II, LLC is hereby authorized to discharge wastewater from a facility located at the Riverplace WWTP 9701 Capital Boulevard North of Raleigh Wake County to receiving waters designated as Neuse River in the Neuse River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective May 1, 2010. This permit and authorization to discharge shall expire at midnight on February 28, 2013. Signed this day March 26, 2010. -�f Coleen H.-Sullins, Director f' Division of Water Quality By Authority of the Environmental Management Commission NC0001376 SUPPLEMENT TO PERMIT COVER SHEET All pre vious NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and pro visions included herein. Riverplace II, LLC is hereby authorized to: Continue to operate an existing wastewater treatment facility permitted for 0.002 MGD treated domestic wastewater discharge located north of Raleigh at 970 Capital Boulevard in Wake County, and consisting of: 0 Bar screen 0 Influent flow meter 0 Main influent flow splitter box 0 Two (2) aeration pond A and B 0 One (1) retention pond 0 Secondary flow splitter box 0 One (1) active clarifier A 0 Two (2) inactive clarifiers B and C (requires stormwater dewatering) 0 One (1) inactive polishing pond (requires stormwater dewatering) 0 One (1) inactive alum pond (requires stormwater dewatering) 0 One (1) inactive sludge pond (requires stormwater dewatering) 0 Nine (9) drying beds (used for stormwater dewatering, recycle to retention pond) 0 One (1) dried sludge storage basin 0 Effluent meter 0 Effluent composite sampler 0 Dual submerged discharge line Discharge from said treatment works, through Outfall 001, into the Neuse River, a Class C, NSW water in the Neuse River Basin, at the location specified on the attached map. Riverplace If VA7 TP F ad I Y NCO001316 USGS Quad: D24NE Wake Forest, NC Outfall Facility Latitude: 350 541 30" N 350 54' 47" N Longitude: 780 33, 81, W 780 33' 13" W Stream Class: C, NSW Subbasin: 03-04-02 HUC:03020201 ,Receiving Stream: Neuse River %r,t , 0 i- - NCO001376 Discharge 14 3 I Facility Location Riverplace 11 WWTP NC0001376 Wake County Permit NC0001376 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the effective date of this permit and lasting until expiration, the permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT LIMITS MONITORING REQUIREMENTS Monthly Daily Measurement Sample Sample CHARACTERISTICS Averse Maximum Frequency Type Location Flow 0.002 MGD Continuous Recording Effluent Total Monthly Flow (TMF) Monitor and Report, MG Monthly Calculated Effluent Total Residual Chlorine (TRC) 2 28 µg/L 2/Week Grab Effluent BOD, 5-day, 209 C 30.0 mg/L 45.0 mg/L Weekly Composite Effluent Total Suspended Solids (TSS) 30.0 mg/L 45.0 mg/L Weekly Composite Effluent Fecal Coliform (Geometric mean) 200/100 mL 400/100 mL Weekly Grab Effluent pH Not more than 9.0 S.U. nor Weekly Grab Effluent less than 6.0 S.U. Dissolved Oxygen, mg/L (DO) Not less than 5.0 mg/L, Weekly Grab Effluent daily avers e Temperature, °C Weekly Grab Effluent Total Phosphorus (TP) 2.0 mg/L Monthly 1 Composite Effluent Total Kjeldahl Nitrogen (TKN) 3 Monitor anfi Report, mg/L Monthly Composite Effluent Nitrite/Nitrate Nitrogen (NO -N + NO -N) Monitor and Report, mg/L Monthly Composite Effluent Total Nitrogen (TIN) '3 0.0 mg/L 0.0 mg/L Monthly Calculated Effluent TN = (NO -N + NO -N) + TKN TN Load' "0" Ibs per month 4 Monthly Calculated Effluent "0" Ibs per year 4 Annually Calculated Effluent TN Load = TN x TMF x 8.34 Ammonia as Nitrogen, mg/L Monthly Composite Effluent (NH -N) Footnotes: 1. Total Nitrogen Load is the mass quantity of Total Nitrogen (TN) discharged in a given time period and thus requires Total Monthly Flow (TMF). See A. (2.) for details. 2. Total Residual Chlorine compliance is required for chlorine or chlorine derivative used for disinfection, or if chlorinated water is in the source water. The Division shall consider all effluent TRC values reported below 50 ug/L to be in compliance with the permit. However, the Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 ug/L. 3. All quantities must be measured and reported to a minimum detection level; Nitrite/Nitrate Nitrogen to a minimum of 0.01 mg/L, Total Kjeldahl Nitrogen to a minimum of 0.1 mg/L. 4. This facility has no Total Nitrogen Load allocation and therefore has a "0" Ibs per month and "0" Ibs per year allocation limits. See A. (3.) and A. (4.) for details. "0" Ibs means the calculated Ibs is less than 0.002 Ibs per month and 0.002 Ibs per year. There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit NCO001376 A. (2.) CALCULATION OF TOTAL NITROGEN LOADS a. The Permittee shall calculate monthly and annual TN Loads as follows: Monthly TN Load (pounds/month) = TN x TMF x 8.34 where: TN = the average Total Nitrogen concentration (mg/L) of the composite samples collected during the month TMF =' the Total Monthly'Flow of wastewater discharged during the month ' (MG/month) 8.34 = conversion factor, from (mg/L x MG) to pounds ii. Annual TN Load (pounds/year) = Sum of the 12 Monthly TN Loads for the calendar year b. The Permittee shall report monthly Total Nitrogen results (mg/L and pounds/month) in the discharge monitoring report for that month and shall report each year's annual results (pounds/year) in the December report for that year. A. (3.) ANNUAL LIMITS FOR TOTAL NITROGEN a. Total Nitrogen (TN) allocations and TN Load limits for NPDES dischargers in the Neuse River basin are annual limits and a're applied for the calendar year. b. For any given calendar year, the Permittee shall be in compliance with the annual TN Load limit in this Permit if: i. the Permittee's annual TN Load is less than or equal to said limit, or ii. the Permittee is a Co-Permittee Member of a compliance association. C. The TN Load limit in this Permit (if any) may be modified as the result of allowable changes in the Permittee's TN allocation. i. Allowable changes include those resulting from purchase of TN allocation from the Wetlands Restoration Fund; purchase, sale, trade, or lease of allocation between the Permittee and other dischargers; regionalization; and other transactions approved by the Division. ii. The Permittee may request a modification of the TN Load limit in this Permit to reflect allowable changes in its TN allocation. Upon receipt of timely and proper application, the Division will modify the permit as appropriate and in accordance with state and federal program requirements. iii. Changes in TN limits become effective on January 1 of the year following permit modification. The Division must receive application no later than August 31 for changes proposed for the following calendar year. iv. Application shall be sent to: NCDWQ / NPDES Unit Attn: Neuse River Basin Coordinator 1617 Mail Service Center Raleigh, NC 27699-1617 d. If the Permittee is a member and co-Permittee of an approved compliance association, its TN discharge during that year is governed by that association's group NPDES permit and the TN limits therein. i. The Permittee shall be considered a Co-Permittee Member for any given calendar year in which it is identified as such in Appendix A of the association's group NPDES permit. ii. Association roster(s) and members' TN allocations will be updated annually and in accordance with state and federal program requirements. Permit NC0001376 (Continued from A. (4.) ANNUAL LIMITS FOR TOTAL NITROGEN) ii i. If the Permittee intends to join or leave a compliance association, the Division must be notified of the proposed action in accordance with the procedures defined in the association's NPDES permit. (1) Upon receipt of timely and proper notification, the Division will modify the permit as appropriate and in accordance with state and federal program requirements. , (-2) Membership changes in .a compliance association become effective on January 1 of the year.following modification of the association's permit. e. The TN monitoring and reporting requirements in this Permit remain in effect until expiration of this Permit and are not affected by the Permittee's membership in a compliance association. A. W) TOTAL NITROGEN ALLOCATIONS a. The following table lists the Total Nitrogen (TN) allocation(s) assigned to, acquired by, or transferred to the Permittee in accordance with the Neuse River nutrient management rule (T15A NCAC 02B .0234) and 'the status, of each as of permit issuance. For, compliance purposes, this table does not supercede any TN limit(s) established elsewhere in this permit or in the NPDES permit of a compliance association of which the Permittee is a Co-Permittee Member. ALLOCATION ALLOCATION AMOUNT (1) TYPE SOURCE DATE STATUS Estuary (lb/yr) Discharge (lb/yr) Base Assigned by Rule (T15A NCAC 02B .0234) 12/7/97 28,223.5 56,447 Active Decremental Deeded to LNRA/City of Raleigh (z) 8/4/99 28,223.5 56,447 Deducted TOTAL 0 0 Active rootnote: (1) Transport Factor = 50% (2) Prior to ownership change to Riverplace II, LLC in November 1999. b. Any addition, deletion, or modification of the listed allocation(s) (other than to correct typographical errors) or any change in status of any of the listed allocations shall be considered a major modification of this permit and shall be subject to the public review process afforded such modifications under state and federal rules. Permit NC0001376 A. (5.) IMPLEMENATION PLAN FOR ELIMINATION OF DISCHARGE A discharge elimination implementation plan must be submitted to the Regional Office and NPDES Unit no later than September 30, 2011. This plan must contain but is not limited to: 1) A final engineered -design to divert the current domestic wastewater influent to an acceptable disposal alternative including connection to the regional sewer or other approved non -discharge disposal method. This must include: a) obtaining any additional required permits, ' b) a flow schematic clearly defining the new connection and the disconnect point to the existing treatment facility influent, and c) a timetable with the disposal option operational no later than December 31, 2012, 2) A final engineered -design to terminate flow to NPDES permit NC0001376 outfall as previously agreed including elimination of stormwater discharge. This must include: a) the permanent disconnect and isolation of the existing treatment facility, b) the clean up and/or approved disposal steps for all equipment related items as outlined by the Raleigh Regional Office, pursuant to permit rescission, c) a stormwater control plan to eliminate stormwater discharge, or other approved stormwater alternative, # ` d) a timetable with the completion of items in a) through c) no later than December 31, 2012, e) a narrative on the future dewatering activities that will be required for any remaining impoundments. 3) Date for submittal of NPDES permit NC0001376 application for rescission. Submit a copy of the plan to: Raleigh Regional Office NCDWQ/Surface Water Protection Judy Garrett 1628 Mail Service Center Raleigh, NC 27699-1628 and NCDWQ / NPDES Unit NPDES File File: NC0001367 1617 Mail Service Center Raleigh, NC 27699-1617 If this special condition A. (5.) is not met, the Division may issue a notice of violation and take enforcement action. 4 « DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0001376 Revised: 3/22/10 Facility Information Applicant/Facility Name: Riverplace II WWTP (former Burlington Industries 5.0 MGD WWTP) Applicant Address: P.O. Box 31568; Raleigh, North Carolina 27622 Facility Address: 9701 Capital Boulevard; Raleigh, North Carolina 27857 Permitted Flow Estimated by DWQ 0.002 MGD Type of Waste: Commercial domestic (private) Facility/Permit Status: Class II /Active; Renewal/Modification County: Wake County Miscellaneous Receiving Stream: Neuse River Stream Classification: C, NSW Subbasin: 03-04-02 Index No. 27-(22.5) Drainage Area (mi2): NA 303(d) Listed? No Summer 7Q10 (cfs) NA Regional Office: Raleigh Winter 7Q10 (cfs): NA State Grid / USGS Quad: D24NE Wake Forest, NC 30Q2 (cfs) NA Permit Writer_: Ron Berry Average Flow (cfs): NA Date: 3/22/10 IWC M: NA Other: Nutrient rulet BACKGROUND The original. renewal application had been submitted by Burlington Industries in 1998, a major textile industrial waste treatment discharge with a permitted flow of 5.0 MGD. Prior to expiration and renewal of the permit Riverplace, LLC purchased the Burlington Industries facility which had closed in 1999. The Divisions requested an ownership change notification and a modified renewal application from Riverplace, LLC. Riverplace, LLC indicated a large portion of the physical property that the treatment works occupied was to be reclaimed for future property development. The previous owner Burlington had removed the sludge from the treatment system. One important change was that the previous Burlington Industries NPDES permit TN Load allocation was sold making this a "zero" TN Load point source prior to Riverplace, LLC purchase. Riverplace, LLC renewal application included a narrative on the termination of wastewater discharge to the Neuse River after 2003 and phase -out, reclaimation of the existing treatment works property. Plans called for two of the six ponds to remain operational, one being the polishing pond for stormwater control, neither to discharge to the Neuse River after 2003. Because of expected continuing domestic wastewater, now and in the future, from the existing building Riverplace, LLC had stated that either a permanent connection to the regional sewer line from the Town of Wake Forest or a non -discharge alternative will be installed prior to the end of 2003. A closing statement was made that no development to the property would occur until a firm commitment had been received regarding the provisions for a sanitary sewer. Initially, a renewal draft permit was developed and proposed in November 2002 using BPJ with an estimated 2,000 GPD domestic wastewater influent but was not issued pending connection to regional POTW." In 2006 Judy Garrett, Raleigh Regional Office noted stormwater routinely flowing from the alum pond being discharged and not being monitored. A plug was installed in the alum pond overflow pipe. Any dewatering activity currently required from the alum. pond is conducted by pumping the pond to the drying beds which automatically drain to a sump and are NPDES NC''WO1 70 Patti i of 4 pumped back to.aeration pond#2. A follow up inquiry to Riverplace, LLC in 2007 resulted in a phone narrative that a pumping station and regional sewer connection was being designed. Attempts to further determine the status and timeline for meeting the April 2001 application narratives has been unsuccessful. Currently, EnviroLink a contracted ORC service, is visiting the site, operating dewatering functions, supervising batch discharges of wastewater to the outfall, taking effluent and instream samples, and completing ®MR and logs. It was determined that no toxicity samples had been taken because the discharge events had not occurred in any of the specified months listed in the active oermit. The current owner continues to operate under the existing pre-1999 5.0 MGD permit (1) has not connected to the regional POTW (2) and has not terminated discharge. In addition the permit current TN Load allocation is "zero" but was not amended. CURRENT 5.0 MGD TREATMENT PLANT OPEARTION Domestic wastewater enters through a bar screen to the influent flow flume with meter and totalizer, continues to one of two aeration ponds, then to a large retention pond. Aerators may or may not be in service. Once the water level is above the retention pond outlet pipe the ORC will manually open a value to allow the wastewater to flow to Clarifier A. Once the flow stops (liquid level below outlet pipe) the ORC closes the value to Clarifier A. Clarifier B and C have been disconnected from the process. The wastewater continues from Clarifier A and flows through an effluent flume with meter and totalizer where a composite sample can be taken. The polishing pond, sludge pond, alum pond, Clarifier B and C, and drying beds are dewatered as needed to the retention pond. The effluent flows through a gravity main to a submerged dual discharge in the Neuse River. Various aerators and pumps are operated for preventative maintenance. The influent and effluent meters calibrations are maintained. Instream samples and effluent samples are taken for every discharge event (about twice a year). No addition chemicals treatments such as a chemical disinfectant are added. EFFLUENT DATA REVIEW Since domestic influent was a small intermittent volume, the operation of this large volume treatment facility was a batch process followed by long periods of no discharge. The data below shows actual discharge dates, recorded flow volumes, and parameter measurements, Date Flow BOD Tss pH NH3-N 77V TP MGD (Mg/0 (MCl/1) Is.U.) (Mg/I Imo//1 (mg/I) 3/19/01 0.298 3.3 2.3 7.96 0.02 0.78 4.76 3/22/01 0.128 2.1 3.3 7.99 0.02 1.18 0.50 1/31/02 0.088 2.9 5.3 7.53 0.16 0.04 4/11/02 0.232 3.8 3.8 7.72 0.02 2.72 0.17 10/18/02 0.424 58.0 3.7 45.95 0.78 0.79 0.38 2/27/03 a382 6.7 6.3 7.88 0.43 0.24 2/23/04 a430 6.8 24.0 7.29 0.20 1.68 0.06 11/1/04 0.796 2.7 2.2 6.83 0.54 1.76 0.16 1/13/05 a733 1.0 1.2 7.94 0.60 1.48 0.12 8/30/05 0.167 1.0 1.8 7.98 0.02 1.19 0.09 1/5/06 0.349 1.0 1.3 6.53 0.02 0.88 0.02 7/6/06 0.421 11.0 11.0 7.11 0.07 2.97 0.28 11/22/06 a431 3.4 5.7 7.08 1.34 2.70 0.06 10/10/08 0.476 5.2 15.0 6.89 0.72 1.77 0.13 The values in bold italics would be considered out of compliance with the proposed modified permit. Fact slloo! Pi e 2 c+ 4 COD, Total Chromium, Total Cooper, Total Zinc, Total Phenols, Sulfides . Several required parameters on the prevailing permit were unique to the original industrial effluent. Based on the sample data submitted on the DMR the data was consistent with a system that has no industrial source or residue. Chronic Toxicity and DO No samples were taken since discharge events did not occur in months specified in permit. No data was available for DO. PERMITTING STRATEGY The Division needs resolution by the owner Riverplace, LLC to meet the terms as stated in their 2001 modified renewal application where by (1) the domestic wastewater is collected and discharged to the regional POTW, (2) the discharge to the Neuse River is terminated, and (3) this permit is rescinded. This renewal permit will be issued for 33 months from the effective date to match the next Neuse River renewal cycle. This permit must reflect the standards applicable to this discharge. Therefore, this permit must show compliance with Neuse River Basin nutrient rules. The other required parameters must be applied in accordance with a privately -owned domestic wastewater treatment facility using BPJ. A determined maximum flow (see below) from the existing sanitary facilities and stormwater sources of 2,000 gallon per day will be applied as the permitted flow. Determination of maximum discharge flow: 35 gallons per employee per day = 700 gpd (gpd = gallons per day) Intermittent flow for visitors = 500 gpd Estimates miscellaneous, stormwater = 300 gpd 25% contingency 500 gpd Total: 2,000 gpd Effluent Limitations and Monitoring -Requirements Flow BOD. TSS DO H Total Residual Chlorine Fecal Coliform Total Phosphorus, Total Nitrogen, Total Nitrogen Load All of these limited parameters will be in the renewal permit. Since flow is intermittent the total flow discharged in any physical day (24 hours) must be reported. A new 0.002 MGD permitted flow limit will be applied. For TN and TN Load the compliance value is "zero" which means anytime a discharge occurs and Total Nitrogen is detected the permittee is out of compliance. The permittee will have to submit a monthly calculated TN Load value for each month. If disinfection by chlorination or chlorine derivatives is required then the Total Residual Chlorine limit must be met. Discussed minimum detection limits BAT EPA Method with Reedy Creek Lab, Nitrite/Nitrate Nitrogen is 0.01 mg/L and TKN is 0.1 mg/L. If you assume maximum permitted flow at minimum detection limit then 0.002 MGD x (0.1 mg/L + 0.01 mg/L) x 8.34 = 0.0018 lbs. Add footnote narrative to nitrogen parameters to define minimum requirements. Effluent Monitoring Requirements Ammonia as Nitrogen, Nitrite Nitrate Nitrogen, Total Kieldahl Nitrogen, Temperature All of these parameters must be measured and reported. If not already in the active permit then they will be added to this permit. Ammonia as Nitrogen Limits will be removed from this permit. , COD Total Chromium Total Copper, Total Zinc Total Phenols Sulfides Based on the data there was no evidence that these suspect industrial residuals were present in significant amounts to warrant further monitoring. Therefore, these parameters will be removed from this permit. If future analysis indicates these compounds are present at levels that exceed the prevailing water quality standards then they will be re-evaluated. �('0001376 llq��e 3 uf'4 Chronic Toxicity Based on BPJ this parameter will be removed from this permit. Implementation Plan This new condition must be followed and will be added to this permit. Instream Monitoring Based on BPJ this requirement will be removed from this permit. PROPOSED SCHEDULE FOR PERMIT ISSUANCE Draft Permit to Public Notice: December 30, 2009 Permit Scheduled to Issue: March 2010 Expiration Date: February 28, 2013 NPDES DIVISION CONTACT If you have questions regarding any of the above information or on the attached permit, please conta t Ron B rry at (919) 807-6396 or email ron.berry@ncdenr.gov. li NAME: DATE: REGIONAL OFFICE COMMENTS NAME: DATE: SUPERVISOR: DATE: rjC. S'9,ext. Beverly Eaves Perdue Governor Mr. John Lancaster Riverplace, LLC P. O. Box 31568 Raleigh, NC 27622 Dear Mr. Lancaster: NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director March 10, 2010 Subject: Response to Comments on NPDES Permit NC0001376 Riverplace WWTP Wake County Class II Dee Freeman Secretary Draft Permit The Division has reviewed your February 9, 2010 letter and has the following comments and information. Item 1) One purpose of A.(5.) is to clarify all types of wastewater that must be addressed through the NPDES regulatory process. Under current regulations this includes stormwater. In a large majority of cases stormwater may have its own individual permit. You are correct that in the permit narrative stormwater is specifically not included. Again, we wanted to make you aware that this permit cannot be used as a stormwater discharge. Item 2) You are correct, any discharge will violate the TNLAL since you have no allocation. For details on acquisition, compliance, or mitigation for nutrient requirements as a discharger into the Neuse River see 15A NCAC 028.0234 Neuse River Basin - Nutrient Sensitivity Waters Management Strategy.- Wastewater Discharge Requirements. In your letter you discussed future plans to operate a drinking water treatment facility and potentially continue discharge from this site. Please be aware the Division intentions are to not allow any modification to this NPDES permit, for you to connect to the regional domestic treatment facility with your sanitary waste, for you to decommission the existing treatment system including the proper disposal of any waste residuals, and to have this permit rescinded. Any future discharge activities on this site that are not already part of the draft permit narrative coverage are considered a new discharge, and require you to follow the requirements for applying for a new discharge in this segment of the Neuse River. There is no guarantee a new discharge wil I be allowed. In regards to A. (5.) the narrative and conditions it contains are only applicable to the draft permit. Page 1 of 2 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919.807-64951 Customer Service: 1-877-623-6748 Internet: http:11 h2o.state.nc.us I An Equal Opportunity 1 Affirmative Action Employer Nne orthCarolina Naturally r We have received no other comments from the public on your draft permit. Your renewal permit is scheduled for issuance by the end of March 2010. If you have any additional questions concerning the permit for your facility, please call Ron Berry at (919) 807-6396 or by email at ron.berryPncdenr.gov. Sincerely, . A,, r Ron Berry Eastern NPDES Program Attachments Cc: Raleigh Regional Office/Surface Water Protection Section (email/copy of February letter attached) Central Files (copy of February letter attached) , NPDES Unit (copy of February letter attached) 0 r � r Page 2 of 2 n U n R R p CE LLC P.O. Box 31568, Raleigh, NC 27622 • 4509 Creedmoor Rd., Suite 102 Raleigh, 27612 • (919) 838-8484 Fax (919) 838-8425 February 9, 2010 111A Mr. Ron Berr y ffd North Carolina Division of Water Quality Eastern NPDES Permit Program FEB 1 1 Z010 1617 Mail Service Center Raleigh, North Carolina 27699-1617 RE: NC0001376 Draft Permit Dear Mr. Berry, Thank you for the opportunity to review and comment on Draft Permit NC0001376. Riverplace received the permit on January 6, 2010 anti hoc reviewed the sub; draft per"':t �:^A O`i0 m %i;e following comments. Please feel free to contact us for additional information or clarification. 1. Stormwater requirement Special Condition A. (5) Implementation Plan for Elimination of Discharge. The Supplement To Cover Page in Paragraph 1 authorizes Riverplace to discharge only "treated domestic wastewater' under this permit. However, Condition A. (5.) makes two references to elimination of stormwater. Riverplace does not understand the inclusion of stormwater in this permit and requests clarification or removal from the requirement. 2. Effluent Total Nitrogen Limits (TNL) and Total Nitrogen Load Allocation Limits (TNLAL). Riverplace requests clarification and discussion to the statement made in the cover letter. regarding compliance violations. Riverplace is concerned about the potential for violations resulting from this statement and issuance of this permit. Riverplace fully acknowledges the previous discussions held regarding this permit and facility. Since that time Riverplace and Franklin County have entered into a Memorandum of Understanding and is actively planning the use of this site for the withdrawal and treatment of potable water for delivery to Franklin County. While the Water Treatment Plant design has not been initiated, there is a potential that there could be a need to continue discharge from this site. Riverplace is aware and will comply with NC DENR requirements and to that end has held several meetings with various agencies, including DWR, PWS, SEPA, and DWQ as it continues to make plans for this important project. Riverplace will continue to work closely with NC DENR officials in order to ensure that reaulatory requirements are met. Riverplace is not asking for any modification to the existing permit at this time but mentions this issue here as it potentially may affect the future of this permit and will be included in the Implementation Plan required in Condition A.(5.). Again thank you for the opportunity to provide comment to this permit. If you have any further comments, please feel free to contact either me or Michael Myers with questions or concerns. pne John Lancaster River Place, LLC. Berry, Ron From: Hyatt.Marshall@epamaii.epa.gov Sent: Tuesday, January 05, 2010 11:03 AM To: Berry, Ron Subject: re NC0001376, Riverplace LLC EPA has no comments on this draft permit. 7i t� 1 1:0.3 AM , dr ''je nit. 1 AFFIDAVIT OF PUBLICATION NORTH CAROLINA. Wake County.) Ss. Public Notice North Carolina Environmental Management CommissiorVNPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Notice of Intent to Issue a NPDES'Wastewater Permit The North Carolina Environmental Man- agement Commission proposes to issue a NPDES wastewater discharge permit to the Person(s) listed below. mau comments anaior mtormarion re- quests to DWQ at the above address. Inter- ested persons may visit the DWQ at 512 N. Salisbury Street, Raleigh, NC to review information on file. Additional information on NPDES permits and this notice may be found on our website: www.ncwoterquollfy .o►g, or by ca I I ing (919) 807-6304. Riverplace, LLC requested renewal of Per- mit NC0001376 for Riverplace WWTP in Wake County. This permitted discharge is treated domestic wastewater and storm - water to the Neuse River, Neuse River Basin. N&O: January 2, 2010 Before the undersigned, a Notary Public of Chatham County North Carolina, duly commissioned and authorized to administer oaths, affirmations, etc., personally appeared Debra Peebles, who, being duly sworn or affirmed, according to law, doth depose and say that she is Accounts Receivable Specialist of The News and Observer a corporation organized and doing business under the Laws of the State of North Carolina, and publishing a newspaper known as The News and Observer, in the City of Raleigh , Wake County and State aforesaid, the said newspaper in which such notice, paper, document, or legal advertisement was published was, at the time of each and every such publication, a newspaper meeting all of the requirements and qualifications of Section 1-597 of the General Statutes of North Carolina and was a qualified newspaper within the meaning of Section 1-597 of the General Statutes of North Carolina, and that as such she makes this affidavit; that she is familiar with the books, files and business of said corporation and by reference to the files of said publication the attached advertisement for NCDENR/ DWQ/ POINT SOURCE was inserted in the aforesaid newspaper on dates as follows: 01/02/10 Account Number: 80763040 The above is correctly copied from the books and files of the aforesaid Corporation and publication. Debra Peebles, Accounts Receivable Specialist Wake County, North Carolina Sworn or affirmed to, and subscribed before me, this 04 day of JANUARY , 2010 AD by, Debra Peebles In Testimony Whereof, I have hereunto set my hand and affixed my official seal, the day and year aforesaid. Janet Scroggs, Nota u is My commission expires 14th day of March 2014. RE NC0001376- Riverplace NCDENR Phone: (919) 807-6396 Fax: (919) 807-6495 Office: Archdale Building Room 925N 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: Vinzani, Gil sent: Thursday, December 03, 2009 10:38 AM To: Poupart, Jeff Cc: Berry, Ron; Garrett, Judy; Templeton, Mike Subject: FW: N00001376- Riverplace Jeff: As you know, we have been stymied on this one for quite a while. It had been reassigned to Ron, who was working with Judy at RRO. Gil Gil Vinzani, Engineer Eastern NPDES Program 919-807-6395 E-mail correspondence to and from this address may be subject to the NC Public Records Act From: Templeton, Mike sent: Thursday, December 03, 2009 10:09 AM To: Poupart, Jeff Cc: Vinzani, Gil; Belnick, Tom Subject: FW: N00001376- Riverplace Jeff - It would probably be more appropriate for you to handle this permit question from Marshall. I have only followed Riverplace from a distance since late 2002, when I gave Dave a draft permit to review. It ended up in Gil's lap and he may a better idea about the facility's status. The issue is that Riverplace has zero TN allocation and, although it discharges infrequently, any discharge is an exceedance under the Neuse TMDL and rule. They facility should also have a permit limit of zero, but we've been sitting on the permit since 2003 and the plant is still operating under the old Burlington Industries limits, with no TN limit. The owner assured me in 2002 that they would be connecting to Raleigh or wake Forest in 2003, but the last I heard was that they still discharge once or twice a year (large industrial wwTP, now treating small amounts of domestic waste and whatever stormwater the system collects). The draft permit I gave Dave included a TN limit of zero, effective 1/1/03 per the Neuse rule, but we discussed giving them a brief compliance schedule to allow time to connect or come up with the allocation. The RRO has inspected the facility a few times over the years but, as far as I know, we Page 2 RE NC0001376- Riverplace haven't gotten anywhere with the permit. - Mike T From: Belnick, Tom sent: Wednesday, December 02, 2009 5:16 PM To: Hyatt.Marshall@epamail.epa.gov Cc: Templeton, Mike subject: N00001376- Riverplace Marshall- I'm in training on wed/Thur, but caught your phone message about Riverplace. I don't know much about it- the previous owner (Burlington Industries, textile facility) transferred their TN allocation to Raleigh in 1999. Then in the same year Riverplace bought the site, but still has no TN allocation. No manufacturing in over a decade. I've copied Mike Templeton, who might be able to add some more info as to why permit has been backlogged. Tom Belnick Supervisor, NPDES west Program 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. Page 3 [Fwd: Re: Riverplace LLC] Subject: [Fwd: Re: Riverplace LLC] From: Gil Vinzani <Gi1.Vinzani@ncmail.net> Date: Fri, 21 Nov 2008 07:59:19 -0500 To: ron Berry <Ron.Berry@ncmail.net> Ron: I'll speak with you this afternoon about this one yesterday, that I would like you to pick up. Thanks, Gil Subject: Re: Riverplace LLC From: Mike Templeton <Mike.Templeton@ncmail.net> Date: Fri, 18 Jan 2008 09:04:58 -0500 To: Gil Vinzani <Gil.Vinzani@ncmail.net> CC: Matt Matthews <matt.matthews@ncmail.net>, Susan A It's one of the two I mentioned Wilson <Susan.A.Wilson@ncmail.net> Gil - Did Mike say how they were going to deal with the nitrogen issue? I'll say it again: This facility has no allocation and should have been subject to a TN limit of 0.0 lb/yr as of l/1/03. Five years later, this still don't have a limit. I recommend issuing the permit with the TN limit and a short -as -possible compliance schedule. By not forcing the issue, we are allowing a discharge in violation of the TMDL and giving others the impression that there is an opportunity for continuing, even expanding, the discharge. This one could bite us if we don't do something about it pretty soon. - Mike T Gil Vinzam wrote: As you know, Riverplace is the oldest permit on our backlog. We have heard throughout the years continual excuses on why they can't tie on right away to the Raleigh Neuse Plant. I just spoke with Mike Myers, who is working with Riverplace IV (John Lancaster) to determine what they are going to do. The latest plan is that Franklin Country would utilize the site for the discharge of domestic waste. This would let them avoid having to get an inter basin transfer certificate, since they want to take water out of the Neuse Basin for use within the Tar -Pam. I indicated to Mike that we were disappointed that there was not going to be a tie-in, and that we had been looking forward to getting rid of this one. He is going to work on an Engineering Alternatives Analysis, and send us a letter next week that has more details. Gil Gil Vinzani <Gil.vinzam(r),ncmail.net> Supervisor, Eastern NPDES Program NC Division of Water Quality 12,11]leg .J G 90 of 2 12/12/2008 2:14 PM Re. Riverplace LLC Subject: Re: Riverplace LLC From: Mike Templeton <Mike.Templeton@ncmail.net> Date: Fri, 18 Jan 2008 09:04:58 -0500 To: Gil Vinzani <Gi1.Vinzani@ncmail.net> CC: Matt Matthews <matt.matthews@ncmail.net>, Susan A Wilson <Susan.A.Wilson@ncmail.net> Gil - Did Mike say how they were going to deal with the nitrogen issue? I'll say it again: This facility has no allocation and should have been subject to a TN limit of 0.0 lb/yr as of 1/l/03. Five years later, this still don't have a limit. I recommend issuing the permit with the TN limit and a short -as -possible compliance schedule. By not forcing the issue, we are allowing a discharge in violation of the'TMDL and giving others the impression that there is an opportunity for continuing, even expanding, the discharge. This one could bite us if we don't do something about it pretty soon. - Mike T Gil Vinzani wrote: As you know, Riverplace is the oldest permit on our backlog. We have heard throughout the years continual excuses on why they can't tie on right away to the Raleigh Neuse Plant. I just spoke with Mike Myers, who is working with Riverplace IV (John Lancaster) to determine what they are going to do. The latest plan is that Franklin Country would utilize the site for the discharge of domestic waste. This would let them avoid having to get an inter basin transfer certificate, since they want to take water out of the Neuse Basin for use within the Tar -Pam. I indicated to Mike that we were disappointed that there was not going to be a tie-in, and that we had been looking forward to getting rid of this one. He is going to work on an Engineering Alternatives Analysis, and send us a letter next week that has more details. Gil of 1 11/20/2008 9:53 AM OCT 600 2Z AT6 �� 461,F;A NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Fact Sheet - NPDES Permit FACILITY INFORMATION Facility Name: Permit Flow (MGD): Facility Class: Facility Status: Permit Status: County: Regional Office: USGS Topo Quad: PROPOSED ACTION Riverplace WWTP 0.002 Grade 2 Biological Existing North Carolina Wake Raleigh Riverplace II, LLC Riverplace WWTP NPDES No. NC0001376 RECEIVING STREAM Receiving Streams: Neuse River Subbasin: Index No.: Stream Class: 303(d) Listed: Use Support: Drainage Area (miz): Summer 7Q10 (cfs) Winter 7010 (cfs): 3002 (cfs): Average Flow (cfs): IWC (%): 030402 C-NSW Y PS Riverplace II, LLC, has applied for renewal of NPDES Permit No. NC0001376 for the Riverplace WWTP in Wake County, north of Raleigh. The facility was formerly operated as the Burlington Industries Wake Plant, a textiles mill permitted to discharge 5.0 MGD of treated industrial Wastewater. The facility's current NPDES permit was issued to Burlington Industries on January 25, 1995, and expired January 31, 1999. Burlington Industries ceased operations of the mill in 1996. Riverplace purchased the facility in 1999 and converted it to commercial use. Prior to the sale, Burlington Industries made timely application for renewal of its NPDES permit. Riverplace subsequently submitted a revised application and a change -of -ownership request. Because the original application was submitted at least 180 days prior to permit expiration, the permit was administratively extended and continues to govern discharges from the facility. The Division finds Riverplace's application to be acceptable and has made a tentative determination to reissue the facility's permit with significant modifications, including: • new effluent limitations and monitoring requirements consistent with the nature and scale of the new operation, and • new effluent limitations and monitoring requirements for Total Nitrogen (TN) and Total Phosphorus (TP), consistent with the Neuse River Basin Nutrient Sensitive Waters rules and the approved TN TMDL. FACT SHEET - NPDES PERMIT Riverplace I1, LLC DRAFT NPDES No. NC0001376 PERMITTED FACILITY r The permitted facility was, until 1999, a textile mill owned and operated by Burlington Industries. It was permitted to discharge up to 5.0 MGD of treated process and other wastewaters and was classified as a NPDES "major' facility. Riverplace purchased the facility in 1999 and has converted the former mill for warehouse, retail, and office use. All wastewaters generated in the facility are sanitary wastes from employees (approx. 20) and customers. None of the tenants or wastewaters are industrial in nature. The Division has requested that EPA Region 4 reclassify Riverplace as a NPDES "minor" facility. The sanitary wastewaters are currently treated in the existing 5.0 MGD treatment facility, and discharge is to the Neuse River at Outfall 001. Riverplace has indicated it intends to eliminate its discharge to the river. According to its permit application: "The wastewater treatment plant at the former Wake Mill facility consisted of five f ponds. The applicant plans to phase down over the 2 years to leave only tow ponds operations. The pond currently employed as a polishing pond will be among those retained. The remaining two ponds will be kept permanently for the purpose of managing stormwater, but will not discharge to the Neuse River after 2003. Permits for stormwater management will be obtained as required. The phased -out ponds will [sic] emptied, allowed to dry, mucked out, and closed. Material mucked out of the ponds will [sic] characterized according to applicable solid waste regulations and disposed of accordingly. "Wastewater continues to be contributed to the ponds from the restrooms in the warehouse facility. This flow will continue to 2003, contemporaneous with the phase - down of the ponds. Applicant has received assurances from the Town of Wake Forest that sanitary sewer service will be extended to the property by 2003. If, for whatever reason, sewer is not available by 2003, applicant will temporarily install a nondischarge alternative for wastewater treatment until permanent sanitary sewer becomes available. No development will occur on the property prior to a firm commitment has been received [sic] regarding the provision of sanitary sewer to the property." At the present time, Riverplace has not begun construction to connect to the Wake Forest collection system. It continues to operate the treatment facility (contract operations) and discharges only as needed. However, as noted below, the facility has discharged fewer than ten days since the beginning of 1999 and most of that is the result of rainfall onto the treatment ponds. (The facility actually experienced a net loss of wastewater during the summer of 2002, due to the exceptionally dry �* conditions.) RECEIVING WATERS In order to protect the designated uses of its surface waters, North Carolina has classified each of its stream segments according to the established use(s) and has adopted water quality standards to provide the necessary level of protection for each. Where more than one standard exists (such as for multiple uses), the most stringent standard for a given parameter applies, in order to protect for all designated uses. The receiving waters for the facility is the Neuse River, designated as Class C Nutrient Sensitive Waters (C-NSW). The designated uses of Class C waters are aquatic life propagation and maintenance of biological integrity, wildlife, secondary recreation, and agriculture. No additional uses are associated with the supplemental NSW classification. Water quality standards for Class C waters are specified in T15A NCAC 2B .0211. General requirements for NSW waters are defined in 2B .0223. In December 1997, the state adopted specific requirements to -2- FACT SHEET - NPDES PERMIT Riverplace II, LLC DRAFT NPDES No. NC0001376 address the basin's NSW designation. The point source rule (2B .0234) establishes total nitrogen and total phosphorus limits for many dischargers in the Neuse River Basin, including Burlington Industries. The entire Neuse River Basin has been listed on the state's 303(d) list of impaired waters, due to nutrient impacts from point,.nonpoint, and natural sources on the Neuse River estuary. In 1997 the state adopted as rule a nutrient management strategy to restore water quality in the basin; and in 1999 and 2002, the US EPA approved Total Nitrogen TMDLs for the basin. The 2000 303(d) list again includes the basin but notes that the TMDL has been approved and is being implemented. CURRENT PERMIT AND FACILITY PERFORMANCE Permit Overview The current permit sets limits at Outfall 001 for the former textile mill, including flow, BOD, NH3-N, TSS, COD, chromium, phenols, sulfides, total phosphorus, temperature, pH, and chronic toxicity. In addition, monitoring is required for total nitrogen, copper (total), zinc (total), color, and dissolved oxygen. Instream monitoring is required for pH, temperature, and D.O. Compliance History A review of effluent data indicates that Riverplace discharged on fewer than ten days from January 1999 through July 2002. The main reason for this is that the volume of wastewater treated is minor _...--� compared to the capacity of the treatment plant. If not for rainfall directly onto the plant, the discharge would be even less frequent. Riverplace has monitored most of the parameters in the existing permit, including the industry -specific parameters. It has consistently complied with the (industrial) permit limits for those. BOD values have been less than 5 mg/L, and chromium and copper values have been less than detection levels. The facility passed its last whole effluent toxicity test, conducted in March 1999. PROPOSED EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS The Division has developed effluent limitations, monitoring requirements, and special conditions for the proposed permit based on the following: federal requirements for secondary treatment of municipal wastewater, 40 CFR Part 133; and North Carolina water quality standards, including the Neuse River Basin Nutrient Management Strategy. The current and proposed permit requirements are described below. Effluent Limitations - Outfall 001 Flow Limitations The current permit includes a monthly average flow limit of 5.0 MGD. Riverplace's permit application did not specify a proposed flow rate for the new operation. At 35 gpd per employee, the wastewater . flow for the 20 employees would be 700 gpd. Additional flow is expected from customer use of rest rooms and from stormwater. The new permit includes a limit of 2,000 gpd, or 0.002 MGD, from all sources. -3- FACT SHEET - NPDES PERMIT DRAFT II, LLC NPDES No. NC0001376 Technology -Based Limitations for BOD, TSS, and pH The proposed BOD and TSS limits for sanitary wastes are based on a level of treatment typically required for similar wastes at publicly owned treatment works: 30 mg/L BOD and TSS, pH within the range of 6-9 S.U. Water Quality -Based Limitations Nutrients. In 1997, the Environmental Management Commission adopted as rule the Neuse River Basin Nutrient Sensitive Waters Management Strategy - Wastewater Discharge Requirements (T15A NCAC 2B .0234). The permit includes limits for Total Nitrogen (TN) and Total Phosphorus (TP) as prescribed in the rules. c)�t+ Under the rule, Burlington Industries received a TN allocation. However, prior to the sale of the facility 310 to Riverplace, Burlington Industries deeded its TN allocation to the City of Raleigh for the benefit of a future group compliance association. This leaves the facility with no remaining allocation. Accordingly, the permit specifies a TN limit of zero (0) pounds per year, effective January 1, 2003. In effect, the TN j limit prohibits any discharge of wastewater as of January 1, 2003. Riverplace committed in its j application to eliminating its discharge by 2003, and the permit limit holds the permittee to its commitment. The permit also includes a TP limit of 2.0 mg/L (quarterly average), effective with the permit. Proposed Monitoring Requirements - Outfall 001 State rule 2H .0500 establishes minimum monitoring requirements for discharges to surface waters, based on SIC of the discharging facility. The proposed monitoring frequencies are consistent with the rule. The permit requires continued monitoring for several parameters from the Burlington Industries permit to determine whether they are still found in the treatment plant and are discharged along with the present-day wastewater. The Division proposes quarterly monitoring for these parameters: Chemical Oxygen Demand (COD) Ammonia Nitrogen Total Chromium Total Copper Total Zinc Phenols Sulfides The permit includes a re -opener clause allowing the Division to add effluent limits for these parameters or to increase or decrease the monitoring frequencies depending upon the results of the monitoring. PROPOSED SPECIAL CONDITIONS ac ` Total Nitrogen. The ermit 'nclVdess descril� how Total Nitrogen mass loads are to be s ✓ calculated. ` anda`rd re -opener clauses `�'`" the Division (1) update special conditions pertaining to the group compliance association when those conditions are developed (if necessary) and (2) add other special conditions pertaining to nutrient control requirements if those should be necessary as part of a basin -wide implementatio policy. sic . t�,,. a 'n.res tt • �hV 2� Loo't� �1V�'�T'S,.S.t "'4 �y�'"�� p�.yr � {1.ei'�iv. ��'1" °��vhvc:+��'�,.q 1lw �t'a+'►'1:=d'��, �y �/1f l� � -4- Permit Review Sheet NCDEHR Riverplace II, LLC NORTH GROUNA DEPARTMENT OF Riverplace WWTP ENVIRONMENT IR AND NURAL RESOURCES NPDES No. NC0001376 PERMIT REVIEW Please review the attached draft permit package and provide comments and/or concurrence at least one week before the close of the public comment period (below). If you have any questions on this fact sheet, the draft permit, or other attachments, please contact at (919) 733-5083, extension. PROPOSED SCHEDULE FOR PERMIT ISSUANCE Draft Permit to Public Notice: November 6, 2002 End of Comment Period: December 6, 2002 (approx.) Permit Scheduled for Issuance: December 20, 2002 NPDES Recommendation by: Signature Date REGIONAL OFFICE COMMENTS This space is used by the regional office personnel to identify specific concerns in reference to issuance of the subject permit. Attach additional sheets as needed. Regional Recommendation b Signature Date REVIEWED AND ACCEPTED BY: Regional Supervisor: Signature Date NPDES Unit Supervisor: Si nature Date PERMIT NUMBER: NC0001376 PERIOD ENDING MONTH: 12 - 2002 FACILITY NAME Riverplaco II, LLC - Rivcrplacc II LLC CITY: Wake Forest COUNTY: Wake TCP.,R pass/fell P/F STATRE "lpay Chi Cerioaaphnia 1 - 02 2-02 3-02 4-02 5-02 6-02 7-02 8-02 9-02 10-02 11 - 02 12-02 REGION: Raleigh PERMIT NUMBER: NC0001376 FACILITY NAME Riverplace It, LLC - Riverplave II LLC CITY: Wake Forest COUNTY: Waite OUTFALL. 001 EFFLUENT PERIOD ENDING MONTH: 12 -2001 REGION: Raleigh 00010 o Temperature, Water Deg. Centigrade [00082 1 or, ttrophato, Sept at 7.6 00300 mg/l DO, Oxygen, Dissolved 0031000340 lbs/day Son, 5-Day (20 Deg. C) lba/day COD, Oxygen 0-nd, Chem. (High Level) 00400 u pH 0053deg lbs/dea y Solids, Tots. Suspended 1 -01 390 8.719.8 1,948.9 2-01 390 fi.7t9. c^ t,948.9 3 - 07 14,35 390 2.7 61719. 44 7.96 - 7.99 1,948.9 2.8 4-01 .90 6, 7i9.8 5-019 8.719.E 1,948.9 6.01 _+8 u, 7 1 $ 8 1,948.9 7 - 01 39C 8, 719.8 f,9d8.9 9-01 39; 8.�,9.8 11439 10 - 01 6.7:?'i ti ;.94E.P 11 -01 390 6, ]r9. it l,948.9 12 - D1 39r1 6: 779.E 1.948.9 PERMIT NUMBER: NC0001376 FACILITY NAME River -place IL LLC - Riverplace II LLC CITY: Wake Forest PERIOD ENDING MONTH: 12 - 2001 COUNTY: Wake REGION: Raleigh 00610 00665 00745 '01034 01042 01092 32730 mg/i m9/1 lbs/day lbs/day mq/1 mg/1 1ba/day Nitrogen, Phosphorus, Sulfide, Total Chromic@, Total Capper, Total Zinc, Total las Phenolics, Mmionla Total Total (as PI (as al (as Crl (as Cu) set Total lee N) Recoverable 1 - 01 4 17.9 8.9 8.9 2-01 4 IT9 E.9 8.9 3-01 - 17.9 8.9 8.9 '. 0 2.63 0 0 0 29 0 4 - 01 4 179 .5, 8.9 5-01 .t 3. 8.9 6 - 01 `? 7.9 r,.n, 8.9 7-01 4 1' g 8.9 E.9 8 .01 17.9 8.9 8.9 9 - 01 10-01 - IT9 11-01 r79 8.° d- 12-01 4 17.9 8.9 - PERMIT NUMBER: NC0001376 PERIOD ENDING MONTH: 12 - 2000 FACILITY NAME Riverplace 11, LLC - Riverplace ❑ LLC CITY: Wake Forest COUNTY: Wake TGP3B pass/tail P/F STATRE 7Day Chr Ceri,d.phni- 1 - 00 2.00 3-00 4-00 5-00 6-00 7-00 8-00 9-00 10-00 11 - 00 12-00 REGION: Raleigh PERMIT NUMBER: NC0001376 FACILITY NAME Riverplace 11, LLC - Riverplace II LLC CITY: Wake Forest COUNTY: Wake OUTFALL. OOl EFFLUENT PERIOD ENDING MONTH: 12 - 1999 REGION: Raleigh 0001.0 0D092 0030C 00310 "1" 10110 01131 deq C inq/1 mq/1 Iba/day lbs/day L 1bs/day Tempararere, Color, DO, Oxygen, WD, 5-Day (20 COD, Oxygen pH Solids, Tota. Water Deg. Spaotrophoto, Dissolved Deg. C) Demand, Chem. Suspended Centigrade Wtr Smpl at 7.6 (High Level) 1-99 390 8, 719.a t.948.9 2 - 99 :t90 8. 7 19. 8 1948.9 3 - 99 3x 6,719.8 1,948.9 9 3 69 7.4-7.7 5 4 - 99 s90 6.719.8 1,948.9 5 - 99 6.719.6 1,948.9 6 - 99 t90 6.7i9.6 1,948.9 7.99 390 6, 719.8 1,948.7 8.99 s9 5.719.8 9aa.9 9-99 6, 719.6 1.4489 10 - 99 ,.... .719 a 11-99 9-+98 t, G4r, i 12 - 99 ':'+` 7? d a 4.94ti.9 PERMIT NUMBER: NC0001376 FACILITY NAME Riverplace 11, LLC - Riverplace 11 LLC CITY: Wake Forest COUNTY: Wake PERIOD ENDING MONTH: 12 - 1999 REGION: Raleigh 00610 00665 00745 01031 01042 01092 32730 m9/1 mg/1 lbs/day lba/day mg/1 mg/1 lb./day Nitrogen, Phosphorus, Sulfide, Total Chromium, Total Copper, Total zinc, Total [as Phenolics, Amdonia Total Total (es PI Isa S) (ae Cr) Iss Cu) Sn) Total (as NI Recoverable 1-99 4 2-99 4 17.9 8.9 8,g 3-99 4 17.9 6.9 8.9 0 0 0 0.05 0.05 0.1 0.02 4-99 4 179 8.9 8.9 5 - 99 4 17.9 8.9 8.9 6 - 99 4 17.9 ,..� 8.9 7-99 4 17.9 8 - 99 4 17.9 8.9 B.9 9-99, 10-99 a 17.t) rv.9 39 11-99 179 8.9 89 12-99 17.9 a.9 a,q PERMIT NUMBER: NC0001376 PERIOD ENDING MONTH: 12 - 1999 FACILITY NAME Rivelplace 11, LLC - Rivefplace II LLC CITY: Wake Forest COUNTY: Wake REGION: Raleigh rces�� pass/fail P/F STATRE 10ay Chr Ceriotlaphniz 2-99 3-99 1 4-99 5-99 6-99 7-99 8-99 9-99 10-99 11 - 99 12-99 Riverplace II, LLC - Riverplace WWTP County Wake NC0001376 Region Raleigh Outfall001 Subbasin 03-04-02 Version 1.0 monm uay Year t;omment Parameter Sample UoM Value Modifie Cell Type 3 3 1999 50050 - Flow Recorder mgd .66 DLYVALUE 3 5 1999 50050 - Flow Recorder mgd .14 DLYVALUE 2 10 2000 50050-Flow Recorder mgd .057 DLYVALUE 8 1 2000 50050 - Flow Recorder mgd .774 DLYVALUE 3 19 2001 50050 - Flow Recorder mgd .298 DLYVALUE 3 22 2001 50050 - Flow Recorder mgd .128 DLYVALUE 1 31 2002 50050-Flow Estimate mgd .088 DLYVALUE 4 11 2002 50050 - Flow Recorder mgd .232 DLYVALUE 3 3 1999 00310 - BOD5 Composit Ibs/day 3. DLYVALUE 2 10 2000 00310 - BOD5 Composit mg/L 4.6 DLYVALUE 8 1 2000 00310-BOD5 Composit mg/L LESST DLYVALUE 3 20 2001 00310 - BOD5 Composit mg/L 3.3 DLYVALUE 3 23 2001 00310 - BOD5 Composit mg/L 2.1 DLYVALUE 1 31 2002 00310 - BOD5 Composit mg/L 2.9 DLYVALUE 4 11 2002 00310 - BOD5 Composit mg/L 3.8 DLYVALUE TELEPHONE RECORD Date: 3/13/01 Time: 1200 N ❑ Return Mr./ Mrs. Craig Bromby ® Call to Address ❑ Call from Telephone:-899-3032 FAX: - - Subject: NPDES permit renewal Overdue application NOTES/ SUMMARY Representing: Hunton & Williams Project: Riverplace II (On 1124101, I e-mailed Mr. Bromby to note that I had not yet received permit application and other material that Bill Trent had agreed to submit by Jan 1 — see notes from our Dec 8 meeting. Mr. Bromby responded on 1125, indicating a different understanding from our meeting and asking for a conference call or meeting to clear things up. Today's call was in response to that message.) Mr. Bromby responded differently from his 1/25 e-mail. He recalled that the application was due around Jan 1 and did not question the other information I said was expected with the application. He said he had talked w/ Mr. Trent in late Jan and expressed some confusion as to why we had not received anything yet. He apologized several times for the delay. Mr. Bromby then asked when we needed the application. I replied that it was already overdue; that any discharge would be without a valid permit (last recorded discharge thru 1/31/01 was on Aug 1); that I'm prepared to begin work on the permit — or other action, if needed — within the next couple of weeks. He indicated he will get back to Mr. Trent and will make every effort to get the application and additional information in by the end of next week. Mr. Trent may call me if there is any confusion about what is expected. NEEDED FOLLOW-UP ACTION(S) 1. Submit NPDES application and summary of wastewater management plans for the facility. BY WHOM/WHEN 1. Trent/ Bromby, by Fri, Mar 23 d. �I Signed Mike Templeton NPDES Unit, DWQ, Raleigh MEETING NOTES Who: Bill Trent, Riverplace Craig Bromby, Hunton Et Williams, re r senting Riverplace Mike Templeton, DWQ / NPDES What: Burlington Industries / Riverplace LLC permit transition When: 7 Dec 2000, 1500 - 1645 hrs. Where: Hunton Et Williams offices, downtown Raleigh Why: To clear up questions about Riverplace's plans the Burlington Industries site and about the status of the NPDES permit, and to discuss necessary actions by DWQ and Riverplace Backeround and Riverplace's Plans for the Burlington Industries Site Burlington Industries suspended manufacturing at its Wake textiles plant in November 1996. They had been cutting back production for several years before that and had no process wastes for a while before closing. Riverplace bought the property and plans to develop the plant site for retail and warehouse space. One furniture store has begun business so far. Since the mill ceased operation, the WWTP has received only sanitary wastes. At present, the only water uses are for drinking water and toilets. Seventeen people are employed on the site now, and no more than about 200 could be employed there by 2003. Riverplace does not intend for there to be any sort of non -domestic wastewaters going to the WWTP, now or in the future. The treatment plant is a lagoon system designed for 5 MGD of textile wastewater. The plant is in operation, with EnviroLink as the contract operator, and discharges only occasionally, due to the extremely low flows. Weather conditions (rainy or dry periods) have a considerable effect on the water levels in the lagoons, much more that do the wastewater flows. The water in the lagoons is mostly stormwater. Riverplace will convert the existing textile plant for retail and warehouse space, and plans to manage the rest of the property separately. The site was annexed by Wake Forest on September 14, 2000, and is zoned for heavy industry. Riverplace has petitioned the City to re -zone the building to reflect the intended use. Riverplace intends to connect to Wake Forest's collection system before 2003 and then close the WWTP, empty the lagoons, and restore the site (approx. 37 acres). They expect to sell some or all of this property for others to develop. They have retained an environmental consultant to evaluate the site and determine what is needed to carry out this plan. The Wake Forest sanitary sewer is 4,000 ft. away. When a new development by others (now getting underway) is completed, the connection will be 2,000 ft. away. Riverplace would prefer to wait for the developer to install the first 2,000 ft. but is prepared to install the entire line if necessary to cease discharge by 2003. Estimated cost is $40/ linear foot. None of the waste in the lagoons is from Burlington Industries' operations. The lagoons were emptied before the sale. Questions and Issues Q: What is the permit status? A: Burlington's permit expired in January 1999. Because they submitted an application for renewal in July 1998, their permit was administratively extended. DWQ delayed most permitting activities in the basin while it revised the Nutrient Management Strategy rule and has yet to re -issue the Burlington Industries permit. Burlington sold the facility in the meantime and submitted a name/owner change request. To date, no one has submitted a modified application for the new owner or any explanation of the new owner's plans for the site. Q: Is the Riverplace operation considered to be new or existing? A: For DWQ's purposes, including the Neuse NMS, we are considering the facility to be "existing." The type and quantity of wastewater that Riverplace will generate were already covered under the previous permit to Burlington. Q: Does Riverplace have or need a nitrogen allocation for its operation? A: Riverplace absolutely intends to get out of the wastewater business before 2003 so that it does not have a direct discharge to surface and does not need an allocation. They were aware of the implications of Burlington transferring its entire allocation to Raleigh and made an informed decision to allow it. (Apparently, there is a story to be told about this, but the opportunity has not presented itself yet.) Q: Are there other ways to handle this transition, to speed and/or simplify the termination of their discharge? A: We discussed other options. • One would be to scale down the treatment operation immediately. The WWTP capacity vastly exceeds the current needs, and the unneeded lagoon area only serves to capture more rainfall, which has to be monitored and discharged under the NPDES permit. They could scale down by using only one or two lagoons and closing the others or by bringing in a package treatment plant and closing all four lagoons. Another would be to install a sump and holding tank, collect the sanitary wastewater, and have a contract hauler transport it to the Wake Forest WWTP. In this case, they could proceed to close all four lagoons, end their discharge, and terminate their permit. They would incur costs for the tank and the hauling but would vastly reduce their operating costs (including the contract operator). It is not clear whether the Division would/could approve this approach, because 2H .0205 limits pump -and -haul arrangements to 6 months in most cases. Next Steps We agreed on the following course of action for this permit: Riverplace will submit a revised permit application (Short Form D) by January 1. In the submittal, they will describe their plans for eliminating their surface discharge by 2003, identify key actions, and provide an approximate timetable which will assume the WWTP remains in service during that time. 2. At the same time, Riverplace will begin looking at options for closing the WWTP sooner and will submit their initial findings along with the permit application. 3. 1 will took into the question about the pump -and -haul approach - would this be acceptable under these circumstances? Re: riverplace - npdes r • Subject: Re: riverplace - npdes Date: Wed, 22 Nov 2000 08:49:36 -0500 From: Mike Templeton <mike.templeton @ ncmail.net> To: "Bromby, Craig A." <CBromby@hunton.com> CC: Dave Goodrich <Dave.Goodrich@ncmail.net>, Charles Weaver <Charles.Weaver@ncmail.net> Sorry I didn't get back to you on Tuesday. Have an idea for a new bumper sticker, though - "Meetings Happen." I'm out of the office today, Thursday, and Friday, and will give you a call on Monday, late a.m. or early p.m. For the meantime, here's a little more on the Riverplace matter. First is the NPDES application. The files I have include Burlington Industries' Jul '98 application for renewal and the Nov '99 request for a name change. Since Riverplace is not simply continuing the Burlington textile operation, we need a new application describing the new operation, its wastewater characteristics, and so on. (Form C is on our web site at http://h2o.enr.state.nc.us/NPDES/NPDESweb.htm(; I can get you a hard copy next week, if that works better for you.) You mentioned that some of Burlington's old wastewater is still on site and needs to be disposed of. The application package needs to tell how much water there is, what treatment it's received, what it's characteristics are (the permit parameters, at least), and how it will be managed. It could present a problem if the wastewater is untreated, since Riverplace would need a certified operator to run the treatment plant. Treated or untreated, the discharge still has to comply with the permit, of course. The next issue is the nitrogen allocation. When Burlington deeded its allocation to the City of Raleigh, it left Riverplace with a zero limit for nitrogen, effectively eliminating any possibility of discharge to the river.* There may be some understanding among the three parties as to how this will be handled, but it hasn't been conveyed to the Division. The application package should explain how Riverplace will acquire the nitrogen allocation it needs for its discharge or describe other plans it has to meet the limit by 2003 (connection, etc.). We will need some sort of document which formally memorializes the arrangements. * If all else fails, DWO could assign a portion of the Burlington allocation to Riverplace. We have not had reason to object to the allocation transfer so far and have left it alone. But we are no more bound by this transfer agreement than if Burlington had deeded its BOD allocation to another discharger. (We can always consider such a request from the permittees and, if appropriate, modify both permits to reflect the change. We were not aware of Burlington's intent in this instance until we received a signed copy of the Deed of Gift.) That should give you a clearer idea of what is required for an acceptable application from Riverplace. Let's talk next week and take care of any other questions we have. Hope you have a Happy Thanksgiving. - Mike T "Bromby, Craig A." wrote: This one seems to have slipped through the cracks. Burlington has donated their N allocation from the operation of the former Wake Mill facility, as I understand it. Of course, the facility is no longer being used as a textile mill facility. It is now being used as a warehouse, and may be used for commercial and light industrial (in keeping with the zoning). The wastewater being generated is domestic in nature, but, as you would expect, the flow is significantly reduced, well below 0.5 MGD. When the warehouse facility is completely rented out, over the next permit cycle, I anticipate a maximum of fewer than 1000 employees and visitors per day, which, referring to 15A NCAC 18A .1949 for guidance, would generate a maximum daily flow of 25 gallon per day per person per shift, or 1000 x 25 x 3 = 75,000 gpd or 0.075 MGD maximum flow. In fact, flow would probably not be this high. Ultimately, Riverplace expects that the Town of Wake Forest will extend sewer to the property and the WWTP will simply be phased out. One issue to be aware of is that there was residual wastewater from the Burlington operation that remained in the WWTP at the time of the sale, so there may still be wastes associated with Burlington's operation that would not be expected for just the warehouse use of the property. I am trying to contact the consultants today to get further detail. Do you want to set a time that I can come meet with you and lay out all the information I have? -----Original Message----- 1 of 2 12/7/00 2:38 PM Re: riverplace - npdes From: Mike Templeton [mailto:mike.templeton@ncmail.net] Sent: Thursday, November 16, 2000 9:29 AM To: cbromby@hunton.com Subject: riverplace - npdes Hello, Craig - It's been a while since we talked about the Riverplace case. I am still waiting for your letter re plans for use of the existing WWTP and for discharge, agreements concerning nitrogen allocation, etc. We have considered the expired BI permit to be administratively extended, assuming we had a complete and accurate application for the new permit. Lacking the additional info, the application is incomplete - an awkward position at best for Riverplace II. Please let me know when you will be getting that in to us. - Mike T Mike Templeton NCDENR / DWQ / NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 512 N. Salisbury St. Raleigh, NC 27604 (mailing address) (street address) 919-733-5083 x541 919-733-0719 (fax) mailto:mike.templeton@ncmail.net Mike Templeton NCDENR / DWQ / NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 512 N. Salisbury St. Raleigh, NC 27604 (mailing address) (street address) 919-733-5083 x541 919-733-0719 (fax) mailto:mike.templeton @ ncmail.net 2 of 2 12/7/00 2:38 PM RE: riverplace - npdes Subject: RE: riverplace - npdes Date: Fri, 17 Nov 2000 09:24:04 -0500 From: "Bromby, Craig A." <CBromby@hunton.com> To: 'Mike Templeton' <mike.templeton@ncmail.net> This one seems to have slipped through the cracks. Burlington has donated their N allocation from the operation of the former Wake Mill facility, as I understand it. Of course, the facility is no longer being used as a textile mill facility. It is now being used as a warehouse, and may be used for commercial and light industrial (in keeping with the zoning). The wastewater being generated is domestic in nature, but, as you would expect, the flow is significantly reduced, well below 0.5 MGD. When the warehouse facility is completely rented out, over the next permit cycle, I anticipate a maximum of fewer than 1000 employees and visitors per day, which, referring to 15A NCAC 18A .1949 for guidance, would generate a maximum daily flow of 25 gallon per day per person per shift, or 1000 x 25 x 3 = 75,000 gpd or 0.075 MGD maximum flow. In fact, flow would probably not be this high. Ultimately, Riverplace expects that the Town of Wake Forest will extend sewer to the property and the WWTP will simply be phased out. One issue to be aware of is that there was residual wastewater from the Burlington operation that remained in the WWTP at the time of the sale, so there may still be wastes associated with Burlington's operation that would not be expected for just the warehouse use of the property. I am trying to contact the consultants today to get further detail. Do you want to set a time that I can come meet with you and lay out all the information I have? -----Original Message ----- From: Mike Templeton[mailto:mike.templeton@ncmail.net] Sent: Thursday, November 16, 2000 9:29 AM To: cbromby@hunton.com Subject: riverplace - npdes Hello, Craig - It's been a while since we talked about the Riverplace case. I am still waiting for your letter re plans for use of the existing WWTP and for discharge, agreements concerning nitrogen allocation, etc. We have considered the expired BI permit to be administratively extended, assuming we had a complete and accurate application for the new permit. Lacking the additional info, the application is incomplete - an awkward position at best for Riverplace II. Please let me know when you will be getting that in to us. - Mike T Mike Templeton NCDENR 1 DWO / NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 (mailing address) 512 N. Salisbury St. Raleigh, NC 27604 (street address) 919-733-5083 x541 919-733-0719 (fax) mailto:mike.templeton@ncmail.net 1 of 1 12/7100 2:38 PM