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Home My WebLink AboutNC0026123_Environmental Assessment_19940427vjc4D 2(� /2 3 DIVISION OF ENVIRONMENTAL MANAGEMENT April 27, 1994 MEMORANDUM TO: Monica Swihart FROM: Jason Doll THROUGH: Carla Sanderson Ruth Swanek SUBJECT: Resubmitted Environmental Assessment Proposed WWTP Expansion City of Asheboro Randolph County The Instream Assessment Unit has reviewed the revised Environmental Assessment from Black & Veatch. The revised EA is significantly improved and has been found to address all of the concerns outlined in our corments on the original document, dated March 14, 1994. The revised EA outlines the facility's current pretreatment demands much better, including efforts undertaken to deal with particular industrial users that have had high mercury levels in the past. The new document still does not outline any future pretreatment needs, but City officials have stated clearly that they have no current plans for recruitment of new industries. The revised document mentions the facility's internment problems in meeting toxicity test limits. The EA states that continued pretreatment attention to mercury, and installation of dechlorination equipment and tertiary filters should bring about improvement in this area. There is not a great deal of detail in the EA regarding the efforts to pass toxicity tests, but communication with the plant operator and the public utilities director have shown that a substantive effort is under way to improve effluent toxicity. The revised EA is most improved in its justification of increased flows and hydraulic needs. It has good support information and explains clearly how the future flow projections were developed. The document also outlines the city's efforts to reduce inflow and infiltration, both present and future. The schedule given for the expansion is more realistic than the one given in the original EA, but it should be noted that the new schedule is very optimistic. It relies on the assumptions that there will be no difficulties in the public notice period and that the city will put the project out to bid before the NPDES permit is final. Thank you for the opportunity to comment on this Environmental Assessment. Please let me know if you need further information or if you have any questions or comments pertaining to this matter. cc: Coleen Sullins Steve Bevington Winston-Salem Regional Office Central Files v DIVISION OF ENVIRONMENTAL MANAGEMENT March 14,1994 MEMORANDUM TO: Monica Swihart THROUGH: Ruth Swanek '� Carla Sanderson FROM: Jason Doll SUBJECT: Environmental Assessment Proposed WWTP Expansions City of Asheboro The Instream Assessment Unit has reviewed the Environmental Assessment for the expansion of the wastewater treatment plant operated by the City of Asheboro. The document was found to be inadequate in several areas. It does not give enough consideration to the alternative of relocating the discharge or address the adverse impacts of the outfall at its current location. The document makes no mention of current industrial users or future growth of such, and it gives no consideration to the resulting waste characteristics caused by present and future industrial use. The document does not address the facility's compliance problems, particularly with regard to effluent toxicity. The metals limits given in the document are incorrect for the current discharge location. The document does not adequately substantiate the plants hydraulic needs, nor does it give consideration to alternative solutions in this area, and the schedule given for achieving improvements to the facility is unrealistic. A discussion of the particular concerns follows. L Effluent Toxicity and Discharge Impacts The facility currently discharges to Hasketts Creek. According to USGS estimates (#0210029550,1987) Hasketts Creek has a 7Q10 = 0.0 for both summer and winter and 30Q2 = 0.2 cfs. During critical flow periods the stream becomes 100% wastewater. The average flow in the creek is 12.0 cfs, so during normal flows the stream will be over 50% wastewater after the plants expansion to 9.0 MGD. The impact of the receiving stream being dominated by waste flow is compounded by intermittent effluent toxicity. Since 1990 the facility has consistently failed one or more chronic toxicity tests annually. A benthic macroinvertebrate study conducted by the Biological Assessment Group in February,1990 found that Hasketts Creek above Asheboro's outfall rated "fair" but most "...taxa either became rare or were completely eliminated below the discharge, indicating severe stress in this portion of Hasketts Creek. The community structure below the Asheboro discharge indicated that toxicity, not organic loading, was the cause of the change in the invertebrate fauna." The assessment of improvements to the facility should address effluent toxicity and outline a mitigation strategy. Given that the low flows in Hasketts Creek are a large factor in the discharge's adverse impacts, a much more thorough consideration should be given to the alternative of relocating the discharge to the Deep River. The current document barely mentions the option. 2. Pretreatment and Industrial Users The EA indicates 70% of the WWTP inflow comes from industrial / commercial users, but makes no mention of what significant industrial users (SIUs) are presently in the pretreatment program or what waste characteristics result from their inputs. Given the facility's problems with intermittent effluent toxicity, the EA should outline current and future pretreatment needs. The only justification given for the expansion is that flows to the plant have been increasing. The EA says the increase to 9.0 MGD is based on calculations derived from the city's growth rates in the 1980's, but gives no description of the nature of that growth (i.e. industrial, commercial, domestic, zoo, etc.). The document should outline any future industrial recruitment plans, in tics, and the associated waste stream characteristics and treatment needs. These areas should also be addressed in terns of secondary impacts. A pretreatment inspection report conducted by the Winston-Salem Regional Office in October 1993 expressed concerns over elevated mercury levels of 1 to 4 ppb coming from the Eveready Battery Plant #2. Review of the facility's discharge monitoring reports has shown detectable levels of mercury consistently each month well above the limit that would be applied to the Hasketts Creek discharge (0.012 ug/1). The NPDES permit currently requires monitoring for mercury, but a limit is scheduled to be phased in on April 1,1996. The EA should outline plans to meet the limit, as well as outline plans to deal with other toxic pollutants of concern, such as arsenic, with which the facility has had problems historically. 3. Metals Limits. The. "probable" metals limits given for the expanded facility in the EA are wrong. The limits are from a speculative done by Instream Assessment in June 1991 which were for a discharge to the Deep River and would by no means apply to Hasketts Creek where there is no dilution during critical flow periods. Because the 7Q10 = 0 the limits at the current discharge location would be equal to the instream water quality standards given in 15A NCAC 2B .0211, and are as follows: Cadmium 2 ug/1 Chromium 50 ug/l Residual Chlorine 17 ug/l Nickel 88 ug/l Lead 25 ug/l Cyanide 5.0 ug/l Mercury 0.012 ug/1 Arsenic 50 ug/1 Fluoride 1.8 mg/1 Essentially, there would be no less stringent limits or monitoring requirements than those already given for the current 6.0 MGD flow. The limits in the EA would apply only if the discharge were relocated to the Deep River. 4. Hydraulic Needs The Environmental Assessment offers projected growth in flow as the justification for plant expansion, but does little to substantiate the projection other than to say it is based on growth rates in Asheboro from the 1980's. The document should go into much greater detail as to how these projections were developed, and should also explain why they are valid when applied to the next 30 years when economic and development trends may have shifted significantly. The document makes no mention of options such as analysis and abatement of inflow and infiltration problems or the ,implementation of a water conservation program to reduce water use and influent volume. These alternatives could prove to be more economical methods to decrease the current hydraulic load, as well as future loads. The increased capacity could eliminate or reduce the magnitude of expansion and the associated adverse impacts and expenses. Such alternatives have been used very successfully in other projects and should be given thorough consideration here. 5. Project Schedule The schedule given in the Environmental Assessment is completely unrealistic, with milestone dates given in parts of the document already past. The project will require a modification to the NPDES permit. An application for the modification cannot be submitted until an initial departmental Finding of No Significant Impact (FONSI) is drafted and sent to the Department of Administration Clearinghouse for review. Once the FONSI is completed and the NPDES permit modification request is made, the projected schedule of issuance is at least 180 days (6 mos.). After the permit is finalized, a request for an authorization to construct (A to C) may be submitted for review and approval. The review period for an A to C is approximately 90 days. By our estimates the project is at about one year, at least, from -having an approved A to C at this point. The EA should be updated to reflect a more current, realistic timeline for completion of the expansion project. 6. Additional Limit Changes In addition, the Environmental Assesment should take into account that studies being conducted currently by the Instream Assesment Unit for the Cape Fear River Basin Management Plan have indicated that the Deep River is experiencincing low dissolved oxygen levels seasonally, often below the 5.0 mg/1 wateVuality standard. Our studies have indicated eutrophication is playing a significant role in the low DO levels. As a result of these documented water quality problems major facilities located in the Deep River drainage are likely to receive nutrient limits as per the basinwide plan. The City of Asheboro may wish to begin planning to meet these potential requirements and should address such plans in the EA document. Thank you for the opportunity to comment on this Environmental Assesment. Please let me know if you need further information or if you have any questions or comments pertaining to this matter. cc: Coleen Sullins Steve Bevington Winston-Salem Regional Office Central Files WHOLE EFFLUENT TOXICITY TESTING OISELF-MONITORING SUMMARY] Tuc,Fcbl5,1994 VACILI'IY REOVIREMIUI17 YrAR JAN Min MAR APR M JI PGE ARCADIAN CORI4)RAIION PERM CIIR LIMA.6% 90 - - - - - - -- -- - - - - N(7gXX13727=1 ftin:.N1092 rnvPwnry: Q PIP A JAN APR JN. OCT N.ComP:Single 91 - - - - - - - - - - - - Comny:NliWHANOVIiR Re& :WIRO 5,IbI,.iu:CI'I:I7 92 -- -- - PASS - - PASS - - LATE PASS - I'H:0.28 Sgeel.l 93 PASS - -- PASS -- -- PASS - - PASS - - 7QIQ,.27.2 IWC(%): 1.6 ° W PASS AR('IIP.R DANII'3ti MIDLAND (Y)l001 MiRM: 24HR AC MONK LC50(FmD OR MYS1D) g0 FAIL( FAIU FAILmy 61.2f bl - PASSI - - PASSI - - NC0027065/001 13,in:8/IN3 Fmgnney:Q OCI'IAN APR 1IIL NnnComP: 91 m PASSI PASSI m -- - >501 ._ _. NOND •- - Counly:nRUNSWICK Region: WIRO Suhhasin: CPF17 92 M 79.21 -- 33.01 - - >1001 - - >1001 - - PF:,1,502 SM(ial 93 >tm - - >1001 - - Am - -- >SD.01 - - 7QIMODA1. IW('(%): n.03 oomr: B4 ARIXNE HOSIERY MIJ. 1HiRM CIIR LIM: 8.0% 90 m m FAIL m m FAIL m m FAIL m m m NV"7927A81I netamlif1/89 FmPmwy: Q 1'n' A MAR JIINSITIIEC NImCmmP: 91 m FAIL PASS PASS - m - -_ FAIL m m FAIL Couni, 111IRKli Reµm,.: ARO Suldvsin: (I1132 92 m m PASS - -- PASS --- - PASS -- - FAIL - I'F: O.W75 SPr•Inl 93 FAIL Nl FAIL.PASS -- -- H --- --- PASS --- - PASS 7010:0.13 IWC(%1:8.19 Hither. W ASHEBORO WWII' Pl;RM CIIR I.IM:W% Y 90 - FAIL PASS - - PASS -- - PASS - - FAIL N(IM261!3AN11 Ilegim9/1293 Fu sen,y:Q PA' A MAR IIINSIiI OF.17 Nm0,a.,:SINGI.I( .91 PASS -_ FAIL PASS - PASS --- - PASS - - PASS Ciunly:RANDOLP11 Regiml:WSRO SYbhusln:011n9 92 - - PASS - - FAIL PASS - PASS - - PASS IT 6a S"W SO _- -- PASS - - PASS ._ - PASS - - nl 7QIQ 0.00 IWCI'J4: MN) unler 94 JeAZL ASIROLINECORK MO(MAH OR AI'MONO FPIS m - '-- 63.2 -- -" -'- -- -' - -' W=146W. 1 Begin:5/ISM9 1i,,ency: 5 OW0- Pnnnly:G1IIl,lY)RU Ih•, WSIIO Snldwrin( ITT2 02 •- --- -- -- -- - -- - - - - 19;. 51r. U1 03 ... ... --. _. ... ... ... .--- 1111,1 II IYI 1\1'1'1'S1 11YI IY1 x4, 1Is AIK'IPERM CIIR I.IM"AI% 80 ._ ... ... ... --. ... .-. _- --- --. -- - N( WROH5,1/(KI 6•Bin:IPIN2 Imryenry: Q PA! A MAR ION SET DEC NuoCom,Single 91 -- -- --- -- -- -- --- -- -- --- - V,Iu.1y:1A)RSY'lll Regi.m:WSRO Snhhnsin:YAD(M 92 -- - - -- - -- - - - - H IT IL1010 Fm,gm W - --- H - --- H --- -- H H 7QIO: 0.05 IWC(%):90.32 Ihder: 94 AORORA W WIP TERM AC I.IM:NO AC (FMID) Q P/F B0 N('002I5310101 Segin:2/INI 1'mlwsuy: Q I'? A MAR IIIN SEP DRC NuuCnmP: 91 Cnunly:nlUlR'DR'1' Reginn:WARO Subhosin:TAR07 92 1-11:0.12 % rdnl JOC:.WA)0-9/IN4 NO TOX RI:Q 03 7QI0t 0.0 IW('(%):100.0 Oh r. 94 0AKINSVILLIi\\WW PERM CIIR LIM: 3. 1% - 90 PASS --- - m PASS - PASS - - PASS -- - NOI12."61MI negin:7/I/89 Imlwclry: Q P71; A JAN APR IIIL OCT NnnComP: 91 PASS - - bl M PASS PASS - - PASS - - Caunty:Mf10110.1. Regilm:ARO Subbadn: FRB06 92 PASS - - FAIL PASS - PASS - - PASS - - PF:0.075 5"1.1 0 FAIL PASS - PASS - - PASS - - PASS - - 7QI0:3.6 IWCI%0.12 dole': 94 IIANDAG. INC. PERM: 2411R AL' IJM 9117h (FOID) 90 c30' 66.1' 33.3' 253- >100X >100% m NONE. 42.5- 56.42- 12.43- 11.4' NCfX111121N00t Orgin:9/IN3 F.,o,ua'Y: Q Pn' 611-:131 MAY AIIGNOV NanCu.p:SINGIJi et 12.2- 16.3• 23.8' 17.3- 10.87' NONE. 64.42- 74.52- NONE. >100. 4.69' 10.51' ('nnm,011ANVII J J! Re9imI: RR(Suhlmsim:TAR01 92 7.054- 2.67• >100. >I00' 40.61- >100' 28.72• 70.71- 22.53' 12.94- 10.51' >100• I'F: VAR Sm601 93 12.07- 85.58' M 20.31. 17.88• 72.01- >100' >100' PASSISIG FAILI PASSI -- 7QI6:0.(XI IW('f%1: 101m Onh: W IIA.M: I'I:JtM('1 lR LIb1:21%. PO -- -- - -- -- - - - - -' LATE bl NOXH 01-11AXII Ile,mAWI0111 lia•lwlxy: Q P/I' A 1'1-11 MAY AIIG NOV N.... I „P: 01 PASS TABS _. ._ PASS - -_ PASS -. ... 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