NC0024911_2022 Annual Report for Ammonia Compliance_20221222

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December 22, 2022
Metropolitan Sewerage District
OF BUNCOMBE COUNTY, NORTH CAROLINA
NCDEQ/Water Quality
NPDES Complex Permitting
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Dear Sir/Madam:
NCDEQ/Water Quality
Asheville Regional Office
2090 US 70 Highway
Swannanoa, NC 28778-8211
Metropolitan Sewerage District (MSD) of Buncombe County was issued a NPDES discharge permit
(#NC0024911), effective October 1, 2018. Section A (8) of the NPDES Permit requires submission of an
annual report stating optimization/construction progress for compliance with the NPDES ammonia
schedule. By December 31, 2022, MSD is to continue High Rate Primary Treatment (HRPT) system
performance testing and begin Biological Treatment Consultant selection. This letter provides a status
update of the HRPT project and identifies way in which MSD will incorporate operational strategies,
optimization procedures and sampling protocols to attain the October 31, 2030, ammonia limits
deadline.
Shook Construction is the General Contractor for the new HRPT Project. The HRPT
Project Notice to Proceed was issued December 5, 2018, and construction began
January 7, 2019. The HRPT original substantial completion date was October 28, 2020.
The project experienced significant delays attributable to all of the following: inclement
weather days, delays due to the fire on November 10, 2020, and associated lead times
of replacement equipment, COVID-19 pandemic, labor and supply chain shortages
issues, and contractor efficiency and workmanship. As a result, the revised contractual
substantial completion date was February 2022 (HRPT process online) with final
completion December 2022.
Introduction of wastewater into the HRPT began Thursday, December 09, 2021. The
optimization of HRPT treatment train #2 was completed Friday, December 10, 2021.
Grab samples were collected from HRPT influent and HRPT clarifier effluent. The
optimization of HRPT treatment train #1 began Monday, December 13, 2021, with grab
samples collected the same as HRPT train #2. All samples were delivered to Pace
Laboratories for analysis.
The acceptance testing for HRPT train #2 began the week of January 3`d, 2022. During
acceptance testing 24-hour composite samples were collected and delivered to Pace
Laboratories for analysis. From November 8tn-181h another round of testing was
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performed by the vendor. As of this date an acceptable test run, within the parameters
of the pilot study, has not been achieved. We have experienced unsustainable levels of
sand loss and chemical usage. Veolia will conduct another test from in January 2023.
• MSD will begin HRPT performance testing at conclusion of acceptable results of the
HRPT acceptance testing. Influent and effluent HRPT samples will be collected as
outlined in the NPDES ammonia schedule. Data will be compiled and analyzed to
achieve maximum efficiency of the overall wastewater treatment process.
• MSD will continue NPDES influent and effluent compliance sampling as per the Permit
and will incorporate additional sampling in the ammonia schedule in preparation of
future reports. A new sampling point will be established beginning as soon as feasible at
the effluent of the HRPT process located north of the headworks removal systems, prior
to entering Rotating Biological Contractor (RBC) Basin number one (1).
• On 10/28/2022 MSD issued a Request for Qualifications (RFQ) for the purpose of
studying the current solids handling and disposal practices, and recommendations for
the future. In the next few weeks MSD will also be issuing a RFQ for the Biological
Treatment Consultant to determine a new treatment process to replace the RBCs
currently in use. Both studies will consider the new ammonia limits as well as other
future potential parameter limits.
• The COVID 19 pandemic has continued to have long lasting impacts and has disrupted
many of the normal operations. Unfortunately, this has occurred during the course of
the HRPT construction project. Due to the pandemic, MSD is experiencing supply chain
disruptions, workforce shortages and economic impacts like many utilities across the
nation. MSD remains committed to the established ammonia compliance deadline of
October 1, 2030 and will continue to comply with the reporting schedule as outlined in
the NPDES Permit. However, MSD is making notice of a general force majeure for all
projects regarding operation, maintenance and pre -established deadlines in all issued
State and Federal Permits. Due to the pandemic and the effects listed above, MSD is
struggling to deliver existing projects on time and may experience similar impacts on
projects in the coming months and years. The impacts on current and future projects
are unforeseen and immeasurable, and no prediction can be made for how projects will
be impacted in the coming years. On 6/10/2022 MSD submitted an application for
NPDES permit renewal. In this application, we have requested an extension to the
10/01/2030 deadline for ammonia compliance due to the factors listed above.
If there are questions or concerns regarding this report, please do not hesitate to contact Bart Farmer,
Water Reclamation Facility ORC, at [e-mail] or 828-225-8224.
Sincerely,
L_
Thomas E. Hartye, PE
General Manager
MSD of Buncombe County